BEFORE THE
ILLINOIS POLLUTION CONTROL BOARD
CLERK’S
OF~r~
OF THE STATE OF ILLINOIS
~4AR
2
4
20D5
STATE OF ILIJNOJS
IN THE MATTER OF:
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Pollution Control
Board
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PETITION OF SCA TISSUE NORTH AMERICA,
)
AS 2005-04
L.L.C., FOR AN ADJUSTED STANDARD FROM
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(Adjusted Standard-Air)
35
ILL. ADM. CODE 2 18.301
AND 218.302(C).
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NOTICE
To:
DorothyGunn, Clerk
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois
60601
Brad Halloran
John J. Privitera
Hearing Officer
McNamee, Lochner, Titus & Williams, P.C.
James R. Thompson Center
75
State Street
Suite 11-500
P.O. Box
459
Chicago, Illinois
60601
Albany, New York
12201-0459
PLEASE TAKE NOTICE that I have today filed with the Office ofthe Clerk of
the Illinois Pollution Control Board an original (1) and ten (10) copies ofan
APPEARANCE and
RECOMMENDATION
ofthe Respondent, Illinois
Environmental Protection Agency, a copy ofwhich is herewith served upon the assigned
Hearing Officer and the attorney for the Petitioner, SCA Tissue North America, L.L.C.
Respectfully submitted by
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
Robb H. Layman
Assistant Counsel
Division of Legal Counsel
Illinois Environmental Protection Agency
1021
North Grand Avenue East
P.O. Box
19276
Springfield, Illinois 62794-9276
(217) 524-9137
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REC~V~D
BEFORE THE ILLINOIS POLLUTION CONTROL
BOAR1~~
OFFICE
OF THE STATE OF ILLINOIS
24 2O~5
STATE OF
ILUNOIS
IN THE MATTER OF:
.
)
Pollution
Control Board
)
PETITION OF SCA TISSUENORTH AMERICA,
)
AS 2005-04
L.L.C., FOR AN ADJUSTED STANDARD FROM
)
(Adjusted Standard-Air)
35 ILL. ADM. CODE 2 18.301 AND 2 18.302(C).
)
APPEARANCE
NOW COMES Robb Layman, Assistant Counsel, and
enters his appearance on
behalfofthe Respondent, ILLINOIS ENViRONMENTAL PROTECTION AGENCY, in
the above-captioned matter.
Respectfully submitted by,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
Robb H. Layman
Assistant Counsel
Division ofLegal Counsel
March 21,2005
Illinois Environmental Protection Agency
1021
North Grand Avenue East
P.O. Box
19276
Springfield, Illinois 62794-9276
(217) 524-9137
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARD
CLERK’~O~P
OF THE STATE OF ILLINOIS
*
~4AR242UQ5
IN TREMATTER OF:
)
•
STATE OF ILLII\JOIS
)
Pollution Control Board
PETiTION OF SCA TISSUE NORTH AMERICA, L.L.C.
)
AS 2005-04
FOR AN ADJUSTED STANDARD FROM
)
(Adjusted Standard-Air)
35 ILL. ADM. CODE 218.301
AND 2 18.302(C)
)
RECOMMENDATION
The ILLINOIS ENVIRONMENTAL PROTECTION AGENCY (“Illinois EPA”) hereby
submits its Recommendation in the above-captioned matter in accordance with thePollution
Control Board’s (“Board”) procedural requirements of35 Ill. Adm. Code 104.4 16.
The Illinois
EPA supports the Petition for Adjusted Standard (hereinafter “Petition”) sought by SCA TISSUE
NORTH AMERICA, L.L.C., (“SCA Tissue”), in this proceeding and recommends that the Board
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GRANT the Petition subject to the terms and conditions contained herein.
In support ofthis
Recommendation, the Illinois EPA states as follows:
BACKGROUND
SCA Tissue filed its Petition forAdjusted Standard (hereinafter“Petition”) with the
Board on February 4,2005, pursuant to Section 28.1 ofthe Illinois Environmental Protection Act
(“Act”), 415 ILCS
5/28.1,
and the Board’s regulations promulgated at 35
111. Adm. Code
104.402.
The Board accepted the Petition forhearing in an order dated March 3, 2005, and, further,
granted the Petitioner’s Motion for incorporation ofthe record ofa prior docket.
In its order, the
Board also observed that the Illinois EPA’s recommendation must be filed within 45 days of
receipt ofthe petition, as required by Section
104.4 16(a) ofthe Board’sprocedural regulations at
1
Title 35 ofthe Illinois Administrative Code.
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The Illinois EPA was served a copy ofthe Petition on February 8, 2005.
The illinois
EPA’s filing ofthe recommendation is therefore due
on Friday, March
25,
2005.
REQUESTED RELIEF
The Petition requests that the Board grant SCA Tissue an adjusted standard from 35 ill.
Adm. Code 218.301
and 2 18.302(c) as applied to the emissions ofvolatile organic material
(“VOM”) from SCA Tissue’s tissue manufacturing facility, located in Alsip, Illinois.
Section 218.301 ofTitle 35-ofthe Illinois Administrative Code, entitled “Use of Organic
Material,” establishes a blanket emission limit of8 pounds per hour (“lbs/hr”) for emission
sources engaged in activities emitting VOM emissions in the Chicago metropolitan area.
The
regulation provides:
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“No person shall cause or allow the discharge ofmore than 3.6 kg/hr (8 lbs/hr) oforganic
material into the atmosphere from any emission unit, except as provided in Sections
218.302,
2 18.303, 218.304 and the following exception: Ifno odornuisance exists the
limitation ofthis Subpart shall apply only to photochemically reactive material.”
Emissions in excess ofthe 8 lbs/hour limit are permissible under the Board’s Part 218 regulations
only ifthe VOM emissions are controlled by the methods specified in its companion provision of
35 Ill. Adm. Code 2 18.302.
Section 218.302 ofTitle 35 ofthe illinois Administrative Code, entitled “Alternative
Standard,” provides:
“Emissions oforganic material in excess ofthose permittedby Section 218.301 ofthis
Part are allowable if such emissions are controlledby one ofthe following methods:
a)
Flame, thermal or catalytic incineration so as either to reduce such
•
emissions to 10 ppm equivalent methane (molecularweight 16) or less, or
to convert 85 percent ofthe hydrocarbons to carbon dioxide and water; or,
2
b)
A vapor recovery system which adsorbs and/or condenses- at least 85
percent ofthe total uncontrolled organic material that would otherwise be
emitted to the atmosphere; or,
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c)
Anyother airpollution control equipment approved by the Agency and
approved by the USEPA as a SIP revision capable ofreducing by
85
percent or more the uncontrolled organic material that would be otherwise
emitted to the atmosphere.
The provision essentially identifies the type of control options that are available to a source in
complying with the 8 lbs/hr limit established in Section 218.301.
The issue surroundingthe tissue manufacturing facility’s compliance with the
8 lbs/hr
limit arose in the context ofa formal enforcement action originally filed in June 2002 against
SCA Tissue and
its predecessors (i.e., XCTC,
Limited Partnership, Wisconsin Tissue Mills, Inc.
and Georgia Pacific).
The lawsuit principally addressed the facility’s historical violations ofthe
Board’s New Source Review regulations for non-attainment areas and the emission control
requirements governing “other emission units” under Subpart TT ofPart 218.
During the course ofsettlement discussions, information necessary to obtain a Title I
construction permit and a proposed demonstration ofthe Lowest Achievable Emission Reduction
(“LAER”) forthe stationary source was exchanged between SCA Tissue,
its consultants and the
Illinois EPA.
As part ofthe review ofthe aforesaid information, itwas revealed that the paper
machine operations were emitting VOM emissions at a rate greater than the
8
lbs/hr limit
prescribed by Section
2 18.301.
As more fully explained in SCA Tissue’s Petition, the paper
machine operations require the use ofcleaning solvents to effectively remove “stickies” from the
wire webs ofthe machines.
See,
Petition at page 6.
These deposits become attached to the
wire web and felt rolls ofthe tissue machines, causingholes to develop in the tissue sheets. The
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periodic application ofthe cleaning solvents is necessary to control the damage from the build-up
of stickies and is the source ofVOM emissions that exceed the
8 lbs/hr rule.
Id..
In the initial
stages ofthis investigation,
SCA Tissue
suggested that certain emission
reductions achieved at the facility through various process changes constituted “other air
pollution control equipment” under Section 218.302(c).
Based on the company’s estimation,
those process changes reduced historical VOM emissions
even beyond the eighty-five percent
emissions control requirements established in the subsection.
See2
Petition at pages 8-9.
The
illinois EPA, however, ultimately disagreedwith SCA Tissue’s interpretation ofSection
2 18.302(c).
The Illinois EPA reasoned that the express language ofthe provision, as well as
surrounding text ofthe Part 218 regulations, did not support a construction that encompassed the
process changes undertaken by SCA Tissue.
Following subsequent discussions about the nature ofthe rule and its applicability to the
tissue manufacturing facility, SCA Tissue presented evidence to the Illinois EPA indicating that
prior process-related changes had substantially reduced VOM emissions and that additional
controls were not economically feasible.
Thereafter, the illinois EPA encouraged SCA Tissue to
pursue adjusted standard relief before the Board.
To the Illinois EPA’s knowledge, no other
paperrecycling manufacturers in Illinois
are affected by Subpart G’s requirements in the same or
similar manner as SCA Tissue.
The Petition filed by SCA Tissue seeks an adjusted standard ofone ofthe control options
set forth in Section 218.302 so as to allow the company to comply with the 8 lbs/hr limit.
SCA
Tissue requests that the alternative standard primarily consist ofthe company’s past and
continuing implementation ofprocess controls that have been implemented to satisfy a LAER
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demonstration and achieve compliance with Subpart TT ofPart 218.
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DESCRIPTION
OFTHE
FACILITY
Thetissue manufacturing facilityowned by SCA Tissue is located at 13101
South Pulaski
Road in Alsip, Cook County, illinois.
SCA Tissue produces
approximately 200 tons oftissue
and toweling products from recycled wastepaper in a day.
See,
Petition at page 3.
A full and
accurate description ofthe tissue manufacturing facility, including the papermachine operations
and associated cleaning processes that are the subject ofthis regulatory proceeding, is
set forth in
SCA Tissue’s Petition at pages 2 through 6.
The illinois EPA is satisfied that the Petition
adequatelyidentifies the nature ofthe emissions-related activity that
is the subject of adjusted
standardrelief in this proceeding.
STANDARD OF REVIEW
Section
28.1 ofthe Act states that the Board may grant individual adjusted standards
from
rules ofgeneral applicability whenever the Board determines that an applicant canjustify an
adjustment.
In the absence ofa level ofjustification specified by the Board in the rule itself, as is
the case in this instance, criteria set forth in Section 28.1(c) ofthe Act guide the Board in
evaluating requests for adjusted standards.
See,
415 ILCS
5/28.1(c)(2002).
Section 28.1(c) states that the Board may grantindividual adjusted standards whenever
the Board determines that:
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(1)
Factors relating to that petitioner are substantially and sufficiently different
from the factors relied uponby theBoard in adopting the general regulations
applicable to that petitioner;
(2)
The existence ofthose factorsjustifies an adjusted standard;
(3)
The requested
standard will not result in
environmental or health
effects
5
substantiallyand sufficientlymore adversethan the effects consideredby the
Board in adopting the rule ofgeneral applicability; and
(4)
The adjusted standard is consistent with any applicable federal law.
See,
415
ILCS
5/28.1(c)(2002).
In
addition, the Board’s procedural regulations impose various content requirements for
petitions, some ofwhich dovetail with the statutory requirements ofSection 28.1.
Section
104.406 ofTitle 35 ofthe Board’s procedural regulations require a petition foradjusted standard
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to contain the following:
a)
A statement describing the standard- from which an adjusted standard is sought.
This must include the Illinois Administrative Code citation to the regulation of
general
applicability imposing the standard as well as the effective date ofthat
regulation;
b)
A statement that indicates whether the regulation ofgeneral applicability was
promulgated to implement, in whole or in part, the requirements ofthe CWA (33
USC
1251
et
seq.), Safe Drinking Water Act (42 USC 300(f) et seq.),
Comprehensive Environmental Response, Compensation and Liability Act (42
USC 9601
et seq.), CAA (42 USC 7401 et seq.), or the State programs concerning
RCRA, UIC, orNPDES
415
ILCS
5/28.1;
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c)
The level ofjustification as well as other information or requirements necessary
for an adjusted standard as specified by the regulation ofgeneral applicability or a
statement that the regulation ofgeneral applicability doesnot specify a level of
justification or other requirements 415
ILCS
5/28.1
(See Section
104.426);
d)
A description ofthe nature ofthe petitioner’s activity that is the subject ofthe
proposed adjusted standard.
The description must include the location of, and
area affected by, the petitioner’s activity.
This description must also include the
number ofpersons employed by the petitioner’s
facility at issue, age ofthat
facility, relevant pollution control equipment already in use, and the qualitative
and quantitativedescription ofthe nature ofemissions, discharges orreleases
currently generated by the petitioner’s activity;
e)
A description ofthe efforts that would be necessary if the petitionerwas to
comply with the regulation ofgeneral applicability.
All compliance alternatives,
with the corresponding costs for each alternative, must be discussed.
The
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discussion ofcosts must include the overall capital costs as well as the annualized
capital and operating costs;
f)
A narrative description ofthe proposed adjusted standard as well as proposed
language for a Board order that would impose the standard.
Efforts necessaryto
achieve this proposed standard and the corresponding costs must also be
presented;
g)
The quantitative and qualitative description ofthe impact ofthe petitioner’s
activity on the environment if the petitioner were to comply with the regulation of
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general applicability as compared to the quantitative and qualitative impact on the
environment ifthe petitioner were to comply only with the proposed adjusted
standard.
To the extent
applicable, cross-media impacts must be discussed.
Also,
the petitioner must compare the qualitative and quantitative nature ofemissions,
discharges or releases that would be expected from compliance with the regulation
of general applicability as opposed to that which would be expected from
compliance with theproposed adjusted standard;
h)
A statement which explains how the petitioner seeks to justify, pursuant to the
applicable level ofjustification, the proposed adjusted standard;
i)
A statement with
supporting reasons that the Board may grant the proposed
adjusted standard consistent with federal law.
The petitioner must
also inform the
Board ofall procedural requirements applicable to theBoard’s decision on the
petition that are imposed by federal law and not requiredby this
Subpart.
Relevant regulatory and statutory authorities must be cited;
j)
A statement requesting or waiving a hearing on the petition (pursuant to Section
104.422(a)(4) ofthis Part a hearing will be held
on all petitions for adjusted
standards filed pursuant to 35 Iii.
Adm. Code 212.126 (CAA));
k)
The petitionmust cite to supporting documents or legal authorities whenever they
are used as a basis for the petitioner’s proof.
Relevant portions ofthe documents
and legal authorities other than Board decisions, State regulations, statutes, and
reported cases must be appended to the petition;
I)
Any additional information which may be required in the regulation ofgeneral
applicability.
See,
35111.
Adm. Code 104.406.
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NATURE OF STANDARD
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FOR WHICH RELIEF IS SOUGHT
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As correctly noted by SCA Tissue in its Petition, the Subpart G regulation evolved from
an earlier version ofemission controls on the use oforganic material, as found at 35 ill.
Adm.
Code 215.301
and, prior to that, Rule 205(f) ofChapter2: AirPollution, promulgated by the
Board in 1971.
Sections 218.301
and 218.302 were promulgated in 1991
as part ofthe creation
ofthe Part 218 regulations.
See,
In the Matter of: RACT Deficiencies in the Chicago Area:
Amendments to 35
111. Adm. Code part 215 and the Addition ofPart 218, R91-7 (July
25,
1991).
The Part 218 regulations addressed deficiencies identified by the United States’ Environmental
Protection Agency (“USEPA”) with respect to the Illinois’ State Implementation Plan and
provided forthe imposition ofReasonably Available Control Technology (“RACT”) among
certain sources ofVOM emissions
located in the Chicago metropolitan area.
The regulations
were intended to implement requirements under the federal Clean AirAct.
Section 218.301 ofthe Subpart G regulations establishes a general emissions limitation
with which all sources engaged in the use oforganic material and located in the ozone non-
attainment area ofmetropolitan Chicago must comply unless
such sources are subject to another
rule that specifically excludes the applicability ofSection 218.301.
As noted above, Section
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218.302 provides three principle compliance options that sources-may undertake-as-an alternative-
to the 8 lbs/hour limit.
Notably, the list ofcompliance alternatives is
limited to certain types of
airpollution control equipment.
The first and second options identify control requirements for
flame, thermal or catalytic incineration devices and vapor recoverysystems respectively.
See,
35 Ill. Adm.
Code 2 18.302(a) and (b).
The third option authorized under the Board’s regulation
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is for“any other” control equipment that achieves an eighty-five percent reduction in
uncontrolled VOM emissions.
See,
35 ill. Adm.
Code 218.302(c).
The illinois EPA has traditionally interpreted the catch-all category ofemissions controls
under Section 218.302(c) as foreclosing the use ofprocess-related emission units or
modifications for achieving the requisite eighty-fivepercent emissions reduction.
As the Illinois
EPA explained in a letter to SCA Tissue in April 2004,
see,
Petitioner’s Exhibit C,
Section
218.302(c) employs the term “air pollution control equipment,” which is specifically defined
under the Board’s Part 211
regulations as “any equipment or apparatus ofa type intended to
eliminate, prevent, reduce or control the emission ofair contaminants to the atmosphere”.
See,
35 Ill. Adm. Code 211.410.
By defining the term according to
its “intended” use orpurpose, the
Board’s definition denotes a class ofcontrol technologies whose function is the control of
emissions.
This class ofequipment is distinct from process equipment, the latter ofwhich may
offer some incidental emission controls but generally do not require permitting under 35 ill.
Adm. Code Part 201.
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It is also noteworthythat the terminology employed by the Board in Section
2 18.302
plainly refers to conventional types ofcontrol equipment.
See,
Petitioner’s Exhibit C.
This
approach is consistent with other Part 218 provisions wherein the Board has expressly identified
the primary method ofcontrol in terms ofemission capture and control equipment.
See,
35
Ill.
Adm. Code 218.207; 35111. Adm. Code 218.926(a), 218.946(a), 218.966(a) and 218.986(a).
The Board’s choice oflanguage in each ofthe aforementioned provisions is contrasted with other
regulatory provisions that appearto support a broader, more inclusive approach.
For example,
several provisions allow subject sources to achieve emission reduction requirements-through-an
9
“equivalent alternative control plan” that is
approved by both the Illinois EPA and USEPA.
(i.e.,
35 Ill. Adm. Code 218.966(b); 35 Ill.
Adm. Code 218.782(b); 35 ill. Adm. Code 218.926(c); 35
ill. Adm. Code 2 18.946(b); and 35 Ill. Adm. Code 218.986(c)).
This alternative approach to
compliance can be broadly depicted as a type ofplan or strategywhose principle focus is on
“equivalency,” rather than the nature ofthe controls.
In the illinois EPA’s view,
a literal construction of Section 2 18.302(c) does not favor
treating process equipment as conventional “airpollution control equipment?’
For this reason,
the Illinois EPA was compelled to reject SCA Tissue’s argument that its past process-related
modifications resulting in significant emission reductions constituted air pollution control
equipment under Section 218.302(c).
The Illinois EPA is cognizant that various process
modifications and source reduction techniques can achievesignificant emission reductions for
stationary sources ofair pollution in the absence ofconventional controls.
While such “pollution
prevention” opportunities should be encouraged, they cannot be read into the existing provisions
ofSection 218.302 in the absence ofregulatory amendment.
COMPLIANCE ALTERNATIVES
In its Petition, SCA Tissue has outlined a variety ofmeasures that the company and its
predecessors have undertaken since the early
1 990s to reduce VOM emissions
from the tissue
manufacturing operations.
The focal point ofthe facility’s attention has been the papermachine
operations, where cleaning solvents must be applied to remove “stickies” from the tissue
machine formingwire webs.
The stickies, which are created from the recycling of glue-
containing magazines and wastepaper, have historically represented a “significant” constraint on
SCA Tissue’s manufacturing operations,
see,
Petition at page 6,
thus becoming the subject of
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several process and equipment modifications to both improve operating efficiency and reduce
overall solvent usage.
SCA Tissue’s predecessors initially modified the process ofun-metered solvent spraying
with new equipment featuring a controlled spraydesign,
a soak cycle and water-based power
wash.
See,
Petition at page 12.
At approximately the same time, that company also
implemented a change in the design ofthe detacifier and wire polymer application equipment,
resulting in further reductions of VOM emissions
for each cleaning cycle run during the
operation.
See,
Petition at pages 12-13; Petition’s Attachment E.
In the late
1 990s, another of
SCA Tissue’s predecessors redesigned some
screening components in the manufacturing process
at locations prior to the introduction ofpulp to the papermachine wires, therebyproducing a
more effective removal ofstickies and contributing to a reduction in the required frequency of
solvent cleanings.
See,
Petition at page 13.
Spray nozzles for the paper machine operations
were also modified so as to reduce the quantity of solvent spent
during each cleaning cycle.
Id..
As described in its Petition, the various process and equipment modifications
implemented by SCA Tissue and its predecessors resulted in a significant reduction in VOM
emissions since the early
1 990s.
Emission calculations prepared by SCA Tissue indicate a nearly
ninety-threepercent reduction in VOM emissions since 1990 that are attributable to the process
and equipment changes.
See,
Petition at pages 13-14; Petition’s Exhibit F and G.
The source reduction measures adopted by SCA Tissue and its predecessors, together
with the substitution ofthe release oil used in the process, were an important consideration in the
illinois EPA’s evaluation ofthe Lowest Achievable EmissionRate (“LAER”) for the facility.
In
the absence ofthose measures and the resulting precipitous reduction in VOM emissions
from
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the facility, it is
likely that add-on controls would have been required as LAER.
Instead, cost
estimates for potential add-on control technologies,
as shown in the LAER evaluation, support
the conclusion that add-on controls would be economically unreasonable.
See
generally,
Petition at pages 14-15; Exhibit B, Appendix E.
In addition, SCA Tissue documented
qualitative concerns with add-on control devices in that theywould potentially generate greater
amounts ofnitrogen oxide and carbon monoxide emissions than the reductions achieved in VOM
emissions.
See,
Exhibit B, page 3; pages 27-28.
The Illinois EPA ultimately concurred with the findings ofthe LAER report that are
attached to SCA Tissue’s Petition.
A Title I Federally Enforceable Permit (“Title I permit”) was
issued to SCA Tissue on August 4, 2004, which expressly recognized that the facilitywill meet
LAER.
See,
Respondent’s Exhibit A, Special Condition 4a (i) and (ii).
Among other things,
the Title I permit restricted cleanup materials and the release agent to an emissions limit ofless
than or equal to fifty percent by weight VOM.
Exhibit
A, Special Condition 2.1.6 (b) and (c).
In this instance, the Illinois EPA accepts SCA Tissue’s findings from the LAER report for
purposes ofdemonstrating the possible compliance alternatives available to the company, as
well as the estimated costs related thereto, forcomplying with Subpart G.
Each ofthe
alternatives identified by SCA Tissue are economically unreasonable given the estimated cost-
per-ton reduction in VOM emissions from the various emissions sources-at the manufacturing
facility.
It should be noted that SCA Tissue has also investigatedpossible raw material
substitutions forthe cleaning solvents and possible control options available to sources subject to
the National Emissions Standards for Hazardous AirPollutants (“NESHAPs”).
The illinois EPA
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accepts SCA Tissue’s assertion concerning the absence, to date, ofcleaning solvent alternatives
that either comply with the 8 lbs/hour limitation orthat are non-photochemically reactive.
See,
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Petition atpage
16; Petition’s Exhibit H.
As shown in the Proposed Adjusted Standard section
below, the Illinois EPA nonetheless recommends that SCA Tissue continue to investigate
potential cleaning solvent alternatives.
The Illinois EPA also
accepts SCA Tissue’s assessment
that little information relatingto Maximum Achievable Control Technology ifi source category is
helpful or relevant in identifying available controls for the solvent cleaning operations.
JUSTIFICATION
FOR ADJUSTED
STANDARD
Upon review ofSCA Tissue’sPetition, the Illinois EPA finds that the requested adjusted
standard is fullyjustified and supported by the relevant criteria by which the Board evaluates this
form ofrequested regulatory relief.
As discussed below, the Illinois EPA agrees with SCA
Tissue’s analysis concerning justification, including the existence offactors relating to SCA
Tissue that are substantially and significantly different from the factors relied upon by the Board
in adopting Subpart G, the absence ofenvironmental impact and -consistencywith federal law.
A.
Substantial
and Significant Differences
Several factors make SCA Tissue’s present situation substantially and significantly
different from the considerations given by the Board to the Section
2 18.302(c).
SCA Tissue’s
use ofrecycledpaper in tissue manufacturing, which in itself is an environmental goal worth
promoting, creates a serious impediment to the production process.
The creation of”stickies”
necessitates a cleaning operation to prevent degradation to the manufactured-product.
In SCA
Tissue’s experience, solvent cleaning operations are the most effective means ofaccomplishing
this task.
Unfortunately, the size ofthewire webs that must be cleaned with the solvents are
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sufficiently large enough as to require the application ofmore than 8 lbs/hour ofsolvent during
each cleaning event.
See,
Petition at page 22.
No solvent substitutes have been identified by
SCA Tissue to date.
While the existence ofenvironmental obstacles in any given manufacturing process may
not be particularly~unusual,
SCA Tissue’s situation is more unique because ofthe significant
progress made by the company in recent years
to reduce historical VOM emissions, much of
which was accomplished through process modifications and materials substitutions-relating to
the cleaning solvent operations.
Those efforts in reducing emissions admittedly did not directly
relateto Subpart G’s requirements but, rather, focused on SCA Tissue’s attempts to obtain LAER
forthe facility and to achieve a minimum eighty-one percent overall control efficiency forthose
emission units covered by the Board’s Part 218, Subpart TT regulations.
However, neither SCA
Tissue nor the illinois EPA were aware ofthe company’s noncompliance with Subpart G until
late in the stages ofthe Title V/Clean Air Act Permit Program permit review.
Even if the issue
ofnoncompliance had been known, it is highly improbable that SCA Tissue’s path towards
compliance with Subpart G would have differed at all from those measures that were undertaken
to address non-attainment areaNew Source Review and Subpart TT.
The principle dilemma precluding SCA Tissue’s adherence to Subpart G’s requirements
is the narrowly-drawn language found in the catch-all provision of Section
2 18.302(c).
As
previously mentioned, the precise wording ofthe provision appears to limit a source’s ability to
employ potential source reduction techniques, including process modifications similar to those
undertaken by SCA Tissue, in achieving an eighty-five percent reduction in VOM emissions
from the use oforganic materials.
Because SCA Tissue’s various process and equipment
14
modifications
do not technically constitute a type of“airpollution control equipment,” the
companywas confronted with only two options: installing add-on controls under circumstances
that would ordinarily be economicallyunrealistic or, alternatively, seeking regulatoryrelief.
SCA Tissue asserts, and the Illinois EPA does not dispute, that the Board’s Subpart G
regulations could not have possibly anticipated the advances made in pollution prevention
technologies since the early 1970s, when the original Rule 205(f) was promulgated, or even ten
or more years ago, when SCA Tissue’s predecessors began investigating improvements to its
spraysolvent operations.
Indeed, the concept ofpollution prevention and its evolving
application to the field ofair pollution control is a fairly recent development and could not have
been envisioned by the Board when the basic framework ofRule 205 was promulgated over
thirty years ago.
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SCA Tissue also notes that the principle underpinnings ofthe original Rule 205, and by
extension, the current Subpart G requirements, was to ensure that sources emitting organic
materials did not violate federal National Air Quality Standards for ozone or cause an odor
nuisance.
See,
Petition at page 21.
The Board has generallyaccepted this proposition in
similar situations.
See,
In the Matter of: Petition ofCrownline Boats, Inc., for an Adjusted
Standard from 35 Ill. Adm.
Code 2 15.301, AS 04-01 (July 22, 2002).
Based on the proposed
means ofcompliance which will be achieved by adherence to LAER and the underlying ninety-
threepercent reduction in historical VOM emissions brought about from process-related changes,
the proposed adjusted standard will not impair compliance with applicable ozone standards orthe
prohibition ofodor nuisances.
15
B.
Environmental Impact
SCA Tissue contends that its proposed adjusted standard would not cause any adverse
impact on the environment orpublic health.
The illinois EPA does not dispute SCA Tissue’s
assertion.
Given the nature ofthe solvent cleaning operations and the fact that SCA Tissue has
already reduced VOM emissions beyond the level ofemissions control required by Section
218.302(c), the Illinois EPA does not foresee any adverse impacts associated with SCA Tissue’s
proposed adjusted standard.
C.
Consistency with Federal Law
The Board may grant the proposed adjusted standard consistent with federal law under
Section
110 ofthe Clean Air Act, 42 U.S.C. Section 7410, which grants individual States
authority to promulgate a plan, subject to USEPA approval, for the implementation,
maintenance,
and enforcement ofair quality standards.
States also possess authority to revise
such implementation plans, subject to USEPA approval.
By following its adjusted standard
procedures with respect to the Board’s federally authorized and approved air emission
regulations, the Board is exercising the authority granted to
States through the federal Clean Air
Act.
In the event that the adjusted standard requested by SCA Tissue is adopted by the Board,
the illinois EPA will submit, pursuant to its own legal authority, the adjusted standard to USEPA
as a SIP revision.
PROPOSED ADJUSTED STANDARD
SCA Tissue
has requested an Adjusted Standard from the Board’s air pollution control
requirements from 35
ill. Adm. Code Section 218.301
and 218.302(c).
SCA Tissue
referenced
Section 218.301
in its Petition presumablybecause the provision reflects the underlying emission
•
16
limit of8 lbs/hour.
Themain focus ofSCA Tissue’s Petition is Section
2 18.302(c).
See,
Petition
at pages
18-19.
As stated therein,
SCA Tissue seeks an adjustment to the provision so
as to allow the company to maintain the ninety-three percent reduction in VOM emissions
achieved with previous process and equipment modifications, thereby satisfying the eighty-five
percent control requirements that are otherwise subject to sources employing any other pollution
control equipment.
The Illinois EPA recommends that the Board GRANT SCA Tissue’s request for
regulatory relief and, further, requests that the Board allow SCA Tissue to maintain and operate
its solvent cleaning operations in the manner set forth in the Petition so long as the company
complies with the following conditions:
a.
SCA Tissue shall continue to investigate alternatives to the use of existing
cleaning solvents, including possible substitutions that have a lower VOM content or that are
non-photochemicallyreactive.
Where practicable, SCA Tissue shall substitute currently-used
cleaning solvents with available substitutes as long as -such substitution. doesnot result in a net
increase in VOM emissions.
SCA Tissue shall agree to conduct any emissions testing as may be
requested by the Illinois EPA in this regard.
A written report shall be prepared that summarizes
any testing ofpotential substitute(s) in cleaning solvents, as well as any actual substitution(s),
that were implemented by SCA Tissue on an annual basis.
The report shall be prepared by SCA
Tissue and
submitted to the Illinois EPA’s Bureau ofAir, Compliance and Enforcement Section,
to the attention ofMs. Julie Armitage.
b.
The reliefgranted in this proceeding shall be limited to the emission activities at
SCA Tissue’s Alsip,
illinois facility as ofthe date ofthis filing.
17
-
-
:
-
c.
SCA Tissue shall otherwise operate its Alsip, Illinois manufacturing facility in full
compliance with the Clean AirAct,• its Title V/CleanAir Act Permit Program permit, the illinois.
Environmental Protection Act and the Board’s applicable air pollution regulations.
HEARING
SCA Tissue has requested a hearingbefore the Pollution Control Board.
The Illinois
EPA concurs with SCA Tissue’s proposal for a hearing.
WHEREFORE, the illinois EPA recommends that SCA Tissue’s Petition for Adjusted
Standard be GRANTED, and an order be entered adopting the adjusted standard with the
specific language presented in this Recommendation.
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
By:
*‘
Robb H. Layman~.”
Assistant Counsel
Division ofLegal Counsel
1020 North Grand Avenue East
P.O.
Box 19276
--
Springfield, illinois 62794-9276
(217)782-5544
(217)782-9807 Facsimile
18
217/782-2113
TITLE
I
FEDERALLY
ENFORCEABLE
PERMIT
PERMITTEE
SCA Tissue North America
Attn:
Ki
C.
Harmon
13101 South Pulaski Road
Alsip,
Illinois
60803
Application No.:
02020043
.
I.D. No.:
O31003ADF
-
Applicant’s Designation: TISSUE
Date Received: February
11,
2002
Subject:
Paper Recycling
Date Issued: August
4,
2004
Location:
13101 South Pulaski Road,
Alsip
Permit is hereby granted to the above-designated Permittee to OPERATE
emission source(s)
and/or air pollution control equipment consisting of a
plant that processes direct entry wastepaper, virgin pulp,
and de-inked
market pulp
(fiber)
into tissue paper as described in the above-referenced
application.
This Permit
is subject to standard conditions attached hereto
and the following special condition(s):
-
Findings
1.
SCA Tissue North America
(SCA Tissue)
has applied for a permit for its
paper recycling plant in Alsip, which it purchased in 2001.
This
permit would address requirements of
35 IAC Part 203
for a major
source,
including control of volatile organic material emissions to the
Lowest Achievable Emission Rate
(LAER).
This permit would be issued in
conjunction with the settlement of the related enforcement action.
2.
The area in which the source is located is designated as nonattainment
for ozone.
3.
This permit addresses the plant as a major new source subject to
35
IAC,
Part 203
(Major Stationary Sources Construction and Modification
(MSSCAM))
because the plant’s actual VOM emissions were in excess of
100 tons/year,
when it was initially constructed and began operation in
1988.
4a.
i.
After reviewing
all materials submitted by SCA Tissue,
the
Illinois EPA has determined that the plant will meet the Lowest
Achievable Emission Rate
(LAER).
ii.
Conditions 2.1.6(b),
(c),
and 2.2.6 of this permit represent the
Lowest Achievable Emissions Rate
(LAER),
pursuant to 35 IAC
203.301,
for emissions of VOM.
As these conditions constitute a
determination of LAER,
these requirements remain in effect
pursuant to 35 IAC 203.601 until the Illinois EPA deletes or
revises these requirements in accordance with applicable
procedures of 35 IAC Part 203.
—
~
A
Page
2
b.
This permit relies upon the majority of the plant’s VOM emission units
complying with “Other Emission Units”
35
IAC Part 218,
Subpart TT,
by
means of the alternative standard of 35
IAC 218.986(c)
rather than
control on subject emission units in accordance with 35 IAC 218.986(a).
C.
As related to 35 IAC 218.301, operation of certain emission units
is
otherwise provided for by the terms and conditions of the Consent Order
entered in Case No.
03-CH-09501
(Cook County Circuit Court), State of
Illinois v. XCTC,
Wisconsin Tissue,
Georgia-Pacific Tissue and SCA
Tissue.
5a.
The permitted VOM emissions of this plant,
as established by this
permit are 75 tons/year.
As
a consequence, SCA Tissue must provide
emission offsets in the amount of
75 tons to fulfill the offset
-
requirements of 35
IAC 203.302,
as they existed when the plant was
constructed.
-
However,
this permit does not address the requirement to provide
emission offsets under 35
IAC 203.302 for operation of the plant prior
to issuance of this permit.
The requirement for emissions offsets for
prior operation of the plant and the means by which such obligation
is
satisfied is being addressed in a separate legal proceeding to resolve
a pending enforcement
case.-~
-
r~I~~1~’
vlh
~3.t))n~i:Lic~
b.
SCA Tissue has identified other major sources in Illinois that it owns
or
operates or that are under common control with SCA Tissue and
confirmed that such sources are in compliance with applicable emission
standards under the Clean Air Act,
as required by 35 IAC 203.305.
c.
The Illinois EPA has considered alternatives for the plant and
determined that the benefits of this plant, which has operated for over
a decade,
outweigh its environmental and social costs, as required by
35
IAC 203.306.
6.
For purposes of 35
IAC 218, Subpart TT,
this permit establishes
an
“alternative control plan”
as provided by 35 IAC 218.986(c),
35
IAC
218.991(c)
and 35
IAC 218.108(b)
for almost all operations conducted at
this source.
The Illinois EPA is authorized to establish alternative
control plans in a federally enforceable permit.
The alternative
control plan is found in Condition 2.1.3(c)
and other related
recordkeeping and reporting requirements in conditions of this permit
that address VOM emissions from the affected units.
7.
A copy of the application,
the Illinois EPA’s project summary and a
draft of this permit were forwarded to a location in the vicinity of
-
the plant,
and the public was given notice and opportunity to examine
this material,
to submit comments,
and to request and participate in a
public hearing on this matter.
-
1.0
PLANT-WIDE CONDITIONS
VOM emissions from this plant shall not exceed 75.0 tons per year.
Page3
•
-
2.0
UNIT SPECIFIC CONDITIONS
2.1
Emission Units 01-02:
Tissue Paper Mill
(Chemical Addition Activities)
2.1.1
Description
There are two principal process areas at the plant.
In the Pulping Process Area,
fiber is received from the
warehouse, blended with water,
and pulped to separate the
paper fibers.
Dirt, paper fillers,
and ink are washed
from the fiber in
a series of vessels with the aid of
chemical surfactants and polymers.
The fiber is also
bleached using a non-chlorine based process.
The prepared
fiber
is partially dewatered and stored in a large vessel,
commonly called a high density chest.
In this area,
-
process water is filtered for reuse,
and excess water is
treated before being sent to the local municipal
wastewater treatment plant.
The cleaned fiber is pumped from the high density chest to
stock preparation in thePaperMachine~Process Area.
The
fiber receives further physical preparation and additives to
impart desirable physical properties to the fibers.
The
prepared fiber
is then pumped to the wet end of the paper
machine where the fiber is spread out on a bed of wire.
The
wire
is periodically cleaned with a solvent
as needed to
inhibit and remove accumulation of “stickies” on the wire
that result in “holes” in the paper product.
The pulp
drains and forms into a wet mat that is pressed and dried to
form the tissue paper.
The tissue paper winds onto massive
spoo1s.
From the spools the paper is trimmed into rolls for
shipping to converting plants.
VOM is generated during
processing by the volatilization of organic materials in the
paper.
VOM emissions are further generated during paper
drying
(i.e.,
in the Yankee Dryer)
and during treatment of
wastewater.
2.1.2
List of Emission Units and Pollution Control Equipment
Emission
Unit
-
Description
Emission
Control
Equipment
01
-
~
Pulping Process Area
(Including Fiber
Storage Building,
Displector, High Density
Pulper, Thickeners with Cyclones,
Cloudy
Water Tanks,
Clarifiers,
Double Wire Press,
High Density Storage Towers, Flotation
Cells, Screw Press,
and Medium Consistency
-
Standpipe)
None
-
Emission
Unit
.
Description
Emission
Control
Equipment
02
~
Paper Machine Process Area
(Including Disk
Filter,
Clarifier,
Paper Machine, Headbox,
Vacuum Pump/Blower Systems,
Fan Pump Silo,
and_Clean-Up_Spray)
None
.
2.1.3
Applicability Provisions and Applicable Regulations
a.
The “affected units” for the purpose of these unit-
specific conditions are the operations described in
Condition 2.1.1,
including the specific emission
units listed in Condition 2.1.2.
b.
The application of release agent applied at the
Yankee Dryer,
as well as Yankee adhesive shall meet
the requirements of 35 IAC 218.204(c)
for paper
coating,
requiring that the VOM content of the
coating not exceed 2.3 lb VOM/gal of coating as
applied,
minus water and exempt compounds.
--
-
c’.
Except as provided in Condition 2.1.3(b)
above,
the
affected units are subject to
35 IAC 218,
Subpart TT:
Other Emission Units,
because the maximum theoretical
emissions
from applicable emission units were in the
past greater than 100 tons per year.
Compliance
shall be met based on compliance with a limit of 73.9
tons of VOM per year considering VOM emissions from
affected units.
The alternative control plan
requirements are
set forth in 35
IAC 218.986(c).
Note:
This alternative control plan requires an
equivalent 81
reduction in VOM emissions generated at
the source during its first representative year of
operation in 1990.
The emission limit of 73.9 tons of
VOM per year was demonstrated to be equivalent to
greater than 81
reduction in VOM emissions when
measured in the appropriate units for paper production
of lb VOM per
ADT
(Air-Dried Ton of finished paper).
d.
i.
Each affected unit
is subject to 35
IAC
218.301:
Use
of Organic Material, which
provides that no person shall cause or allow
the discharge of more than 3.6 kg/hr
(8
lbs/hr)
of organic material into the
atmosphere from any emission unit,
except as
provided by Board rule
(e.g.,
35 IAC 218.302,
218.303 or 218.304) and the following
-
exception:
If no odor nuisance exists this
limitation shall apply only to photochemically
reactive material.
For this purpose,
the
Page 4
a..
...
..—...
—.
~
•••••
..•l...••••...
••~~
-•
.•
....
I.
PageS
definition of photochemically reactive
material at 35 IAC 211.4690 is applicable.
ii.
Notwithstanding the above requirement,
the
Permittee’s compliance with 35 IAC 218.301
is
fully addressed by terms and conditions of the
Consent Order entered in Case No.
03-CH-09501
(Cook County Circuit Court),
State of Illinois
v.
XCTC,
Wisconsin Tissue, Georgia-Pacific
Tissue and SCA Tissue.
2.1.4
Non-Applicability of Regulations of Concern
None
-
2.1.5
Control Requirements and Operational Limits
For
the solvent system used for cleaning the paper
machine,
the Permittee shall perform routine inspections
of the affected units in order to identify and repair
leaks of VOM from components,
as defined by 35
IAC
211.1350.
For this purpose,
a component means a valve,
pump,
flange or similar fitting or device~that is intended
to operate without leaks
(such as the system used for
delivering cleaning solvent to the paper machine),
and
does not include open tanks, drying systems, or material
transfer in which process materials are normally exposed
to the atmosphere.
Any
leaks from components subject to
the control requirements of
35 IAC 218,
Subpart TT shall
be subject to the following control measures:
Repair any component from which a leak of volatile
organic liquid
(VOL)
can be observed.
The repair
shall be completed as
soon as practicable but no
later than
15 days after the leak is
found, unless
the leaking component cannot be repaired until the
next process unit shutdown,
in which case the leaking
component must be repaired before the unit
is
restarted
35
IAC 218.986(e) (1)
2.1.6
Emission Limitations
a.
the VOM emissions from affected units shall not
exceed 73.9 tons/year,
total.
Compliance with this
limit shall be determined as
the sum of
(i)
readily
quantified VOM emissions,
i.e., VOM emissions
attributable to specific VOM containing process
materials used on an affected unit,
and
(ii)
other
VOM emissions.
For this purpose, the “readily
quantifiable VOM emissions”
attributable to specific
raw materials
shall be determined by material
balance, based on actual usage and the VOM of the
a-..
~.-
~-1-.~
Page6
-
material
as
provided
by
the
supplier
or
as
determined
by
representative
testing
in
accordance
with
Condition
2.1.7.
“Other
VOM
emissions”
shall
be
presumed
to
contribute
0.97
pounds
of
VOM
per
ton
of
air
dried
finished
paper,
this
factor
developed
from
emission
test
data
cited
in
the
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement
(NCASI)
Technical
Bulletin
739
Table
5-20,
Mill
DD
and
NCASI
Technical
Bulletin
740
Tables
5-41
and
5-42
Mill
HH.
b.
The
VOM
content
of
the
following
materials
used
on
the
affected
units
shall
not
exceed:
Material
Emission
Limitation
Cleanup
50
by
weight
VOM
Defoamer
1
by
weight
VOM
Release
Agent
50
by
weight
VOM
C.
The
VOM
emissions
attributable to use of the
following
materials
on
the
affected
units
shall
not
exceed
5.0
tons/year-,
total:
-
~U~-
..
~
O.k
~)i
kk~-~
i.
Displector
ii.
Cationic
Press
Polymers
iii.
Anionic
Polymers
iv.
Surfactants
for
Boilouts
v.
Wire
Polymer
vi.
Pulp
Detactifier
vii.
Absorbency
Aid
viii.
Retention
Aid
ix.
Color
Control
Dyes
x.
Wet
Strength
Resin
Note:
Conditions
2.1.6(b)
and
(c)
represent
the
Lowest
Achievable
Emission
Rate
(LAER)
for
emissions
of
VOM
from
the
paper
machine
process
and
fiber
process,
pursuant
to
35
IAC
203.301.
Page
7
2 .1.7
Testing
Requirements
-
a.
Upon
request
by
the
Illinois
EPA,
the
VOM
content
of
VOM-containing
materials
shall
be
determined
according
to
USEPA
Reference
Methods
24
and
24A
of
40
CFR
Part
60,
Appendix
A
and
the
procedures
of
35
IAC
218.105
35
IAC
218.211(a).
b.
Upon
request
by
the
Illinois
EPA,
the
Permittee
of
a
VOM
emission
unit
subject
to
the
requirements
of
35
IAC
218,
Subpart
TT
shall,
at
his
own
expense,
conduct
such
tests
in
accordance
with
the
applicable
test
methods
and
procedures
specified
in
35
IAC
218.105
35
IAC
218.988(a).
Nothing
in
this
condition
shall
limit
the
authority
of
the
USEPA
to
require
testing
35
IAC
218.988(b).
2.1.8
Monitoring
Requirements
None
2.1.9
Recordkeeping
Requirements
a.
The
Permittee
shall
record
the
following
for
leaks
detected
by
the
inspection
program
required
by
Condition
2.1.5:
-
For
any
leak
which
cannot
be
readily
repaired
within
-
one
hour
after
detection,
the
following
records,
as
set
forth
below
in
this
subsection,
shall
be
kept.
These
records
shall
be
maintained
by
the
owner
or
operator
for
a
minimum
of
two
years
after
the
date
on
which
they
are
made,
or
such
longer
period
as
may
be
specified
by
this
permit.
Copies
of
the
records
shall
be
made
available
to
the
Illinois
EPA
or
USEPA
upon
verbal
or
written
request.
-
i.
The
name
and
identification
of
the
leaking
-
component
35
IAC
218.986(e)
(2) (A);
ii.
The
date
and
time
the
leak
is
detected
35
IAC
218.986(e)
(2)
(B);
iii.
The
action
taken
to
repair
the
leak
35
IAC
218.986(e)
(2) (C);
and
iv.
The
date
and
time
the
leak
is
repaired
35
IAC
218.986(e)
(2)
(D)
.
-
b.
The
Permittee
shall
keep.the
following
records
of
operation
of
affected
units:
Page
8
i.
Production
of
finished
paper
(tons/month
and
ton/year
of
air-dried
finished
product);
ii.
Identification
of
each
VOM-containing
material
used,
with
type
of
material,
maximum
VOM
content
(weight
percent),
overall
density
(lb/gal)
and
source
of
data
for
VOM
content,
i.e.,
supplier
data
or
testing
in
accordance
with
Condition
2.1.7(a);
and
iii.
Quantities
of
each
VOM-containing
material
used
(lb/month
and
ton/year).
c.
The
Permittee
shall
keep
the
following
records
related
to
emissions
from
affected
units:
i.
The
annual
VOM
emissions
from
each
emission
unit which
is not subject to the requirements
of
35
IAC
218,
Subpart
TT;
ii.
The
aggregate
monthly
and
annual
VOM
emissions
from
the
affected
units
based
on
the
material
--
-
--usage and production,
with supporting
calculations;
and
iii.
Calculation of the lb/ADT value over the past
12 months.
-
d.
The Permittee shall maintain records of the testing
required by Condition 2.1.7, which include the
following:
i.
The date,
place and time of sampling or
measurements;
-
ii.
-
Identification of material tested;
iii.
The operating conditions as existing
at the
time of sampling or measurement;
iv.
The date(s) analyses were performed;
v.
The company or entity that performed the
analyses;
vi.
The analytical techniques or methods used;
and
vii.
The results- of such analyses.
-
•
-
----
-
-a-
-
-• -
-
-
Page
9
2.1.10
Reporting
Requirements
The
Permittee
shall
promptly
notify
the
Illinois
EPA
of
deviations
of
the
affected
units
with
the
permit
requirements
as
follows.
35
IAC
218.211(c)
and
-
218.991(c)
a.
Reports
shall
describe
the
probable
cause
of
such
deviations,
and
any
corrective
actions
or
preventive
measures
taken.
-
b.
Reports
shall
include
a
copy
of
all
relevant
records.
c.
Reports
shall
be
sent
to
the
Illinois
EPA
within
30
days
following
the
occurrence
of
the
deviation
35
IAC
218.991
(a)
(3) (A).
2.2
Emission
Unit
03:
Heaters
(Paper
Machine
Yankee
Dryer)
2.2.1
Description
-
Large heaters provide heat used for the final step in
-‘
-
-,
drying the tissue paper in paper machine.
2.2.2
List of Emission Units and Pollution Control Equipment
Emission
Unit
Description
Emission Control
Equipment
03
Two
Natural
Gas-Fired
Heaters
(Total
Capacity:
44
Million_Btu/Hr)
None
2.2.3
Applicability
Provisions
and
Applicable
Regulations
a.
The
“affected
heaters”
for
the
purpose
of
these
unit-
specific
conditions,
are
the
heaters
listed
in
Condition
2.2.2,
used
for
drying
finished
paper.
b.
The
affected
heaters
are
subject
to
35
IAC
216.121
which provides that no person shall cause or allow
the
emissions
of
carbon
monoxide
(CO)
into
the
atmosphere from any fuel combustion emission source
with
actual
heat
input
greater
than
2.9
MW
(10
mmBtu/hr)
to
exceed
200
ppm,
corrected
to
50
percent
excess
air.
2.2.4
Non-Applicability
of
Regulations
of
Concern
None
Page
10
2.2.5
Operating
and
Control
Requirements
a.
The
firing
rate
of
the
affected
heaters
shall
not
exceed
44
mmBtu/hr,
total.
b.
The
affected
heaters
shall
only
be
fired
with
natural
gas.
-
c.
The
Permittee
shall
maintainand
operate
the
burners
in
the
heaters
in
accordance
with
good
combustion
practices.
2.2.6
Emission Limitations
Emissions from the affected heaters shall not exceed the
following limits:
NO~Emissions
CO Emissions
VOM Emissions
(T/Yr)
(T/Yr)
(T/Yr)
19.30
16.2
1.06
2.2.7
Testing Requirements
-
---
‘-~‘~
‘i..-:
~-
~
“m~-
~
None
2.2.8
Monitoring Requirements
None
-
2.2.9
Recordkeeping
Requirements
The
Permittee
shall
maintain
records
of
the
following
items for the affected heaters to demonstrate compliance
with Conditions 2.2.5 and 2.2.6:
Consumption
of natural gas by the affected heaters
(in million cubic feet per month and per year)
2.2.10
Reporting Requirements
The Permittee shall promptly notify the Illinois EPA,
Compliance Section of deviations of an affected heater
with the permit requirements as follows.
Reports shall
describe the probable cause of such deviations,
and any
corrective actions or preventive measures taken:
a.
Reports shall describe the probable cause of such
deviations, and any corrective actions or preventive
measures taken.
b.
Reports, shall include a copy of all relevant records.
Page
11
-
c.
Reports
shall
be
sent
to
the
Illinois
EPA
within
30
days
following
the
occurrence
of
the
deviation
35
IAC
218.991
(a)
(3)
(A).
2.2.11
Operational Flexibility/Anticipated Operating Scenarios
N/A
2.2.12
Compliance
Procedures
For
the
affected
heaters,
compliance
with
the
emission
limits
of
this
permit
shall
be
based
on
the
recordkeeping
requirements
in
Condition
2.2.9
and
appropriate
emission
factors.
If
the
heaters
are
properly
operated,
the
following
factors
may
be
used:
Emission Factor
Pollutant
(lb/million
ft3)
CO
-
84
NO~
100
--
__~_~_P1YI.
-
ii’--’~~~~
7.6~
~
--~-~~‘.
502
0.6
-
VOM
5.5
These are the emission factors for uncontrolled natural
gas
combustion
in
small
boilers
(
100
mmBtu/hr),
Tables
1.4-1
and
1.4-2,
AP-42,
Volume
I,
Supplement
D,
March,
1998.
-
3.0
Emission
Offsets
3.1
The
Permittee
shall
provide
75
tons
of
VOM
emissions
reduction
credits
generated
by
itself
and
by
other
sources
in
the
Chicago
ozone
nonattainment
area
such
that
the
total
is
equal
to
the
VOM
emissions
allowed
for
the
plant,
i.e.,
75
tons/year
of
VOM.
3.2
These
emission
reduction
credits
shall
be
acquired
from
other
sources
as
further
provided
by
agreement
between
the
Permittee
and
the
State
of
Illinois
regarding
past
noncompliance
with
35
IAC
Part
203.
The
Permittee
shall
provide
the
Illinois
EPA
with
documentation,
as
follows,
demonstrating
that
it
has
obtained
the
requisite
amount
of
VOM
emission
offsets
as
specified
above.
a.
Reliance
upon
emission
reduction
credits
from
such
-
source(s),
i.e.,
supplier(s),
must
be
approved
by
the
Illinois
EPA
subject
to
the
following:
-
i.
The
supplier
of
emission
reduction
credits
must
be
located
in
Illinois
in
the
Chicago
ozone
nonattaininent
area;
a
.
....
.
.
..
.
.
.
.
..
..
II..
...
.
.
..
.
......
.
.
~
.
.
.
.
.
.....
.
.
.
Page
12
ii.
Any
proposal
to
supply
emission
reduction
credits
must
be
accompanied by detailed documentation to
support
the
amount
and
creditability
of
the
emission
reduction
credit;
iii.
This
permit
must
be
amended
by
the
Illinois
EPA
to
identify
the
supplier
of
emission
reduction
credits
pursuant
to
a
-request
from
the
Permittee
for
such
a
permit
amendment
if
the
Illinois
EPA
approves
the
use
of
emission
reduction
credits
from
the
supplier,
and
iv.
The
supplier
of
emission
reduction
credits
must
be
subject
to
appropriate
measures
given
the
nature
of
the
underlying
emission
reduction
to
make
the
emission
reduction
permanent
and
federally
enforceable.
b.
If
the
Permittee
obtains
emission
offsets
directly
from
the
supplier
without
the
involvement
of
the
Illinois
EPA,
the
following
additional
requirements
shall
also
be
satisfied:
i.
The
-supplier
of
offsets
must?submi;Ya
lettez~orotberi
document
signed
by
a
responsible
official
or
other
authorized
agent
certifying
that
a
transfer
of
emission
reduction
credit
from
its
source
has
been
made
to
the
Permittee
in
the
requisite
amount
to
provide
offsets
for
the
wastepaper
processing
operation.
ii.
The
Permittee
must
submit
a
letter
or
other
document
signed
by
a
corporate
officer
or
other
authorized
agent
certifying
that
a
transfer
of
emission
reduction
credits
has
been
received
from
such
other
source
to
provide
offsets
for
the
fiber
processing
operation.
In
this
letter,
the
Permittee
must
also
acknowledge
that
it
may
subsequently
transfer
these
offsets
to
another
party
or
return
them
to
the
supplier
only
if
the
allowable
emissions
of
the
tissue
paper
manufacturing
operation
are
correspondingly
reduced
by
an
appropriate
limitation
in a federally enforceable permit,
as the Permittee
is otherwise under a legal obligation to maintain
thee offsets pursuant to 35 IAC 203.602.
3.3
If this required document with respect to emission offsets is
‘not
provided within 90 days of the issuance of this permit,
the
permit shall cease to be effective until such time as such
documentation is provided to and approved by the Illinois EPA.
Condition
3 represents the actions identified in conjunction with the
fiber processing operation to ensure that
it
is accompanied by emission
•
‘-
‘a’
-
-
-
-
-
Page
13
offsets
and
does
not
interfere
with
reasonable
further
progress
for
VOM.
Note:
Emission
offsets
are
being
required
for
this
project
because
USEPA
has
not
approved
provisions
of
the
ERMS
that
would
allow
compliance
with
the
ERMS
to
satisfy
the
offset
requirements
for
a
major
modification in 35 IAC Part 203.
If you have any questions on this,
please call Bob Smet at 217/782-2113.
Donald E. Sutton,
P.E.
Manager,
Permit Section
Division of Air Pollution Control
DES :RPS :jar
cc:
Region 1
-
•
‘a
CERTIFICATE OF SERVICE
Ihereby certify that on th~~day’~i~rch,
2005,1 did send, by First Class
Mail, with postage thereon fully paid and deposited into the possession ofthe United
States Postal
Service, one (1) original and ten (10) copies ofthe following instruments
entitled APPEARANCE and
RECOMMENDATION to:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
-
-
100 WestRandolph Street
Suite 11-500
Chicago, Illinois
60601
and a true and correct copy ofthe same foregoing instruments by First Class Mail with
postage thereon fully paid and deposited into the possession ofthe United States Postal
Service, to:
Brad Halloran
John J. Privitera
Hearing Officer
McNamee, Lochner, Titus & Williams, P.C.
James R. Thompson Center
75 State Street
-
-
Suite 11-500
P.O. Box
459
Chicago, Illinois
60601
Albany, New York
1220 1-0459
•
________
By:
Robb H. Layman
Assistant Counsel
-
Division of Legal Counsel
-
This filing
is submitted on recycledpaper.
