ILLINOIS POLLUTION CONTROL BOARD

May

19,

1988

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Petitioner,

v.

)

 PCB 88—15

MID—CITY LITHOGRAPHERS,

 INC.,

a foreign corporation,

Respondent.

OPINION AND ORDER OF THE BOARD (by J. Marlin):

This matter comes before the Board on

 a January 14,

1988

Complaint filed by Illinois Environmental Protection Agency

(Agency) against Mid—City Lithographers,

 Inc.

 (Mid—City).

The

Complaint alleges

 three counts

 of violations

 against Mid—City

concerning

 the operation

 of its Lake Forest facility.

Count

I

 of the Complaint alleges

 that from April

24,

 1986 to

November 21,

 1986, Mid—City violated Section

 9(b)

 of the Illinois

Environmental Protection Act

 (Act)

 as well as

 35 Ill.

 Adm.

 Code

201.141 and 201.143 by causing or allowing the operation of seven

sheet—fed offset printing presses without Agency operating

permits.

Count

 II alleges

 that

 from April

14,

 1986 until the date of

the filing of this Complaint, Mid—City violated Section 9(b)

of

the Act as well as 35

 Ill.

 Adm.

 Code 201.141 and 201.143 by

 causing

 or allowing the operation of three film laminators and

one paper

 top coater without Agency operating permits.

Finally, Count

 III alleges

 that from January

1,

 1985 until

the date of the filing of the Complaint,

 Mid—City violated

Section

 9(a)

 of the Act as well

as

 35 Ill. Mm.

 Code 215.204(c)

and 201.141

 by using,

 in its coating operations,

 adhesives and

coatings containing volatile organic material

 (VOM)

 in excess of

2.9 pounds

 of VOM per gallon.

A hearing

 in this matter was held on April

12,

1988

 in Lake

Forest.

 No members

of

 the public were present.

At

hearing,

the

parties introduced

 a Stipulation and Proposal

 for Settlement

(Settlement) which was admitted by the Hearing Officer as Joint

Exhibit No.

1.

 The Settlement

 is attached and adequately

addresses the facts

 in this matter.

 Accordingly,

 this Opinion

will not contain

 the customary discussion of the issues.

The Board

 notes

 that the Settlement states:

 “Mid—City

neither admits nor denies the violations...as alleged by the

89—255

2

Agency.”

 However, according

 to the Agency, Mid—City has now

procured

 the proper permits

and

 is now operating an afterburner

in order

 to achieve compliance.

 (fl.

 5—6).

Further,

 the Board

 notes

 that the settlement was apparently

signed prior

 to the Agency’s filing

 of its Complaint.

Notwithstanding this curiosity,

 the Board will accept the

Settlement

 as proposed.

In evaluating

 this enforcement action and proposed

settlement agreement,

 the Board has taken

 into consideration all

the facts

 and circumstances

 in light of

 the specific criteria

delineated

 in Section

 33(c)

of

 the Act and finds

 the Stipulation

and Proposal

 for Settlement acceptable under

 35 Ill. Mm.

 Code

103.180.

 Accordingly,

 the Board orders Mid—City

 to comply with

the Order

 set forth herein.

This Opinion constitutes

 the Boar~3’s findings of fact and

conclusions of law

 in this matter.

ORDER

It

 is the Order of

 the Illinois Pollution

Control

B~ar~

that:

1)

 The Board hereby accepts

 the stipulation and Proposal

for Settlement executed by Mid—City Lithographers,

 Inc.

(Mid—City)

 and the Illinois Environmental

 Protection

Agency and which was filed with

 the Board

 on. April 12,

1988.

 The Stipulation and Proposal for Settlement

is

attached hereto.

2)

 Mid—City shall,

 by certified check

or

money

order

payable

 to the State

 of Illinois and designated

for

deposit

 into the Environmental Protection Trust Fund,

pay the sum of

 $10,000

 (ten thousand dollars).

 This sum

shall

 be paid within

 30 days from the date

of

 this

Order.

 The payment shall

 be sent by first class mail

to:

Illinois Environmental Protection Agency

Fiscal Services Division

2200 Churchill Road

P.O. Box

19276

Springfield,

62794—9276

3)

 The terms

 and conditions of the attached Stipulation and

Proposal

 for Settlement are incorporated

 into and made

a

part

 of this Order.

IT

IS

 SO ORDERED.

J.T. Meyer dissented.

8~—256

3

I,

 Dorothy

M.

 Gunn,

 Clerk of the Illinois Pollution Control

Board, hereby certify

 that the above Opinion and Order was

adopted on the

 day of

_________________,

 1988,

by

 a vote

of

Dorothy

M.

 unn, Clerk

Illinois Pollution Control Board

89—257

BEFORE

THE

ILLINOIS

POLLUTION

CONI

~1~1

 BOARD

APR

 I 21988

ILLINOIS

ENVIRONMENTAL

)

PROTECTION

AGENCY,

)

PO1LUT~C~

CONTROL

BOARD

)

Complainant,

)

v.

)

 PCB 8&-/5’

)

MID-CITY LITHOGRAPHERS,

 INC.,

)

a foreign corporation

)

Respondent.

STIPULATION AND PROPOSAL FOR SETTLEMENT

Complainant,

 Illinois Environmental Protection Agency,

 by its

attorney,

 Neil

F.

 Hartigari, Attorney General of

 the State of

Illinois,

 and Respondent, Mid—City Lithographers,

 Inc.,

 by its

attorneys,

 Jenner & Block,

 submit this Stipulation and Proposal

for

Settlement.

 The parties agree that the statement

 of facts contained

herein represents

 a fair summary of the evidence and testimony that

would

 be introduced by the parties

if

 a full hearing were held.

The

parties

 further stipulate that this statement of facts

 is made and

agreed upon for purposes of settlement only and that neither the

fact that

 a party has entered into this Stipulation,

 nor any of

the

facts stipulated

 herein,

 shall be introduced into evidence

 in this

or any other proceeding except to enforce the terms hereof by the

parties

 to this agreement.

 This agreement shall

 be null and void

unless the Illinois Pollution Control Board

 (“Board”)

 approves and

disposes of this matter on the terms

 of the settlement

 set forth

herein.

~j~J~4

89-258

~

—2—

I.

JURISDICTION

The Board has jurisdiction of the subject matter herein and

of

the parties consenting hereto pursuant

 to the Illinois Environmental

Protection Act

 (Ill. Rev. Stat.

ch.

111

1/2,

 pars.

1001

(1985).

II.

AUTHORIZATION

The undersigned representatives

 for each party certify that they

are fully authorized by the party whom they represent to enter

 into

the terms and conditions of this Stipulation and Proposal for

Settlement and to legally bind them to

it.

III.

APPLICABILITY

This Stipulation and Proposal for Settlement (‘~Settlement”)

shall apply to and be binding upon the Complainant and Respondent,

as well as the successors

 and assignees

 of each and any officer,

director,

 agent, employee or servant of Respondent.

 The Respondent

shall not raise

as

 a defense to any enforcement action taken

pursuant

 to this Settlement the failure of any of its

 agents,

servants or employees

 to take such action as shall be required to

comply with the provisions of

 this Settlement.

89—259

—3—

‘V.

UNCONTESTED

 FACTS

A.

 Complainant,

 Illinois Environmental Protection Agency

(hereinafter “Agency” or “IEPA”),

is

 an administrative agency

established

 in the executive branch of the State government by

Section

4

 of the Illinois Environmental Protection Act (hereinafter

“the Act”)

 (Ill. Rev.

 Stat.

ch.

ill

 1/2,

 par.

 1001 et

 (1985),

and charged,

 inter

 alia,

 with the duty of enforcing the Act,

pursuant

 to Title VIII thereof and recovering civil penalties

pursuant

 to Title XII thereof.

B.

 Respondent, Mid-City Lithographers,

 Inc.

 (“Mid—City”)

is

a

foreign

 corporation duly authorized

 to conduct business

 in the State

of Illinois.

C.

At

 all times pertinent hereto Mid—City has engaged in the

printing

 and laminating

 of children’s text books

at

 a plant located

at 13825 West Laurel Drive

 in Lake Forest, Lake County,

 Illinois

(the “Lake Forest plant”).

D.

 Located

 at the Lake Forest plant are seven sheetfed offset color

printing presses, three film laminators

 arid one top paper coater.

Three of

 the seven sheetfed color printing presses are six-color

presses.

 The remaining four are four—color presses.

E.

 On April

14,

 1986, Agency inspector Jeanne Kukla

 (nee Damlos)

conducted an inspection of the Mid-City Lake Forest plant.

 At the

time of

 this inspection Mid—City did not possess any Agency permits

to operate its printing presses, laminators

 and coater.

89—260

—4—

Consequently,

 on April

22,

 1986 the Agency sent Mid-City

a

Compliance Inquiry Letter

 (CIL)

 alleging

 an apparent violation of

the Act and 35

 Iii. Adm. Code 201.144

 arising from Mid-City’s

operation of

 its presses,

 laminators and coater

 in the absence of

an

operating permit.

F.

 On May

6,

 1986,

 Mr. Thomas

C.

 Koonz,

 the General Manager

of

Mid—City’s Finishing Division,

 sent

 a letter to Ms.

 Kukla advising

her that Mid—City was

 in the process of completing

 its permit

applications

 and would mail them to the Agency by May 23,

 1986.

G.

 On May 22,

 1986,

 representatives of Mid-City and the Agency met

to discuss Mid-City’s status with respect

 to compliance with state

environmental

 laws.

 At this meeting the Agency learned for the

first time that volatile organic material

 (VOM)

 emissions

attributable to the use of solvent—based coatings

 in Mid-City’s

coating operations

 (encompassing the use of the

 laminators

 and the

top paper coater) allegedly exceeded the allowable VOM emission of

2.9

 lb VOM/gal under 35

 Ill.

 Adrn. Code 215.204(c).

 Three

solvent-based coatings used in

 1985 contained VON in the amount of

3.27,

 5.1 and 5.94 lb VOM/gal.

 However,

 because Mid—City had begun

using adhesives which were 90

 water-based and replaced

a

non-compliant coating with

 a coating containing

2.7

 lb yaM/gal in

January of 1986,

 it was Mid—City’s position that compliance could be

demonstrated under the Board’s internal offset rule (35

 Ill. Adm.

Code 215.207).

 It was agreed that Mid—City would have until August

15,

1986

 to demonstrate compliance under

 the internal offset rule

and submit the necessary permit applications

 to the Agency’s

Springfield office.

89—261

—5—

H.

 On August

6,

 1986,

 representatives of Mid-City and the Agency

again met

 to discuss Mid—City’s compliance efforts.

 At this meeting

the Agency briefly reviewed Mid—City’s proposed permit

applications.

 In addition,

 the procedures

 for demonstrating

compliance under the internal offset rule were discussed.

I.

 On October

7,

 1986, Agency and Mid-City representatives met

for

the third time.

 Upon reviewing Mid-City’s calculations of daily

actual and allowable VOM emission rates from April

—

 August

of

 1986,

~çthe

 Agency

 aliegedthat compliance under

 the internal offset rule

could not be demonstrated.

 Consequently,

 on October

17,

 1986,

the

Agency sent Mid-City a Pre-enforcement Conference Letter

 (PECL)

alleging apparent violations

 of the Act,

35

 Ill.

 Adm. Code

215.204(c)

 and 35

 Ill. Adm. Code 201.144 associated with the

operation of its laminators and coater.

 No violation of the Board’s

operating permit requirement arising from the unpermitted operation

of Mid-City’s seven offset printing presses was alleged

 in the PECL,

however, because Mid-City had submitted an operating permit

application for this equipment to the Agency on October

14,

 1986.

The October

17,

 1986 PECL contained the notice required by Section

31(d)

 of the Act

 (Ill.

 Rev.

 Stat.

ch.

 111—1/2,

 par.

 l031d).

J.

 The Pre—enforcement Conference was held on November

5,

 1986.

At

this conference Mid-City representatives stated that Mid-City

intended

 to achieve compliance with 35

 Ill, Adm, Code Part 215 by

installing

 a catalytic afterburner

 to control VOM emissions from its

coating operations.

89—262

—6—

K.

 On November

21,

 1986,

 the Agency issued Mid-City

a

 five-year

operating permit for its

 seven sheetfed offset printing presses

 (No.

86100037)

L.

 On December 22,

 1986,

 the Agency received

 a permit application

from Mid—City to construct

 a VOC incineration system at

 its Lake

Forest plant.

 On December

30,

 1986,

 the Agency notified Mid-City in

writing that its permit application was

 incomplete.

 Mid—City

reapplied for

 a construction permit for its VOM incineration system

on or about January

8,

 1987.

 On February

3,

 1987,

 the Agency issued

to Mid—City

 a construction permit

for

 a VON incineration system.

V.

CONTESTED FACTS

A.

 The Agency contends that Mid-City’s operation of

 its Lake Forest

plant has resulted

 in the following violations

 of Section

9

 of the

Act (Ill.

 Rev.

 Stat.

ch.

 111—1/2,

 par.

1009

 1985)

 and the Board’s

Air Pollution Control regulations

(35

 Ill. Adm. Code Subtitle B,

Chapter

I)

 as alleged in Counts

 I—Ill of the Agency’s complaint:

1.

 Section 9(b)

 of the Act,

35

 Ill.

Adrn.

 Code 201.141 and 35

Ill.

 Adm. Code 201.143

—

 Operation of seven sheet offset

color printing presses without an operating permit from at

least April

14,

1986

 to November

21,

 1986.

89—263

—7—

2.

 Section 9(b)

 of the Act,

35

 Ill, Adm. Code 201.141 and

35

Ill. Adm. Code 201.143

—

 Operation of three film laminators

and one top paper coater without

 an operating permit from

at

 least April 14,

 1986 to the date of filing of

the

complaint.

3.

 Section 9(a)

of

 the Act,

35

 Ill. Adm. Code 201.141 and 35

Ill.

 Adm. Code 215.204(c)

—

 Emission of VON from coating

operations

 in excess of the allowable VON emission of 2.9

lb VON/gal since at

 least January

1,

 1985 to the date of

filing

 of the complaint,

B.

 Respondent neither admits nor denies the allegations

 of Counts

I

—

III

 as summarized above.

VI.

SECTION 33(C) FACTORS

(Ill.

 Rev.

 Stat,

 1985,

ch.

 111—1/2,

 par.

 1033ct1985)

Section 33(c)

 of the Illinois Environmental Protection Act

provides:

In making

 its orders

 and determinations,

 the Board shall take

into consideration all the facts

 and circumstances bearing upon

the reasonableness of the emissions, discharges, or deposits

involved including, but not

 lirnited.to:

89—264

—8—

1.

 the character and degree of injury to,

or

 interference with

the protection of the health, general welfare and physical

property of the people;

2.

 the social and economic value of the pollution source;

3.

 the suitability or unsuitability of

 the pollution source

to

the area

 in which

it

 is located,

 including the question of

priority of

 location

 in the area involved; and

4.

 the technical practicability and economic reasonableness of

reducing or eliminating the emissions,

 discharges or

deposits resulting from such pollution source.

In response

 to each of

 these factors the parties state

as

follows:

A.

 Mid—City’s coating operations emit hydrocarbons which contribute

to

 the formation of atmospheric ozone.

 Ozone

is

 a pollutant which

has well—established adverse effects on property,

 plant

 and animal

life.

 The most recent Illinois Annual Air Quality Report,

 prepared

by the Agency, contains the following statements on the potentially

adverse health and welfare effects of ozone:

Injury to vegetation is one of the earliest manifestations

of

photochemical

 air pollution,

 and sensitive plants are useful

biological

 indicators of this type of pollution.

 The visible

symptoms of photochemical oxidant produced injury to plants may

be classified

as:

(1)

 acute

 injury, identified by cell collapse

with subsequent development of necrotic patterns;

(2)

chronic

injury,

 identified by necrotic patterns or with other pigmented

patterns;

and

 (3) physiological effects,

 identified by growth

alterations, reduced yields,

 and changes in the quality of plant

products.

 The acute symptoms are generally characteristic of

a

specific photochemical oxidant;

 though chronic injury patterns

89—265

—9—

are not.

 Ozone injury to

 leaves

 is identified

as

 a strippling

or flecking.

 Adverse effects on sensitive vegetation have been

observed from exposure

 to photochemical oxidant concentrations

of

 about. 100 ug/m3

 (0.05 ppm) for

 4 hours.

Adverse effects on materials (rubber products and fabrics) from

exposure to photochemical oxidants have not been precisely

quantified,

 but have been observed

 at the levels presently

occurring in many urban atmospheres.

Ozone accelerates the aging

 of many materials,

 resulting

in

rubber cracking, dye fading,

 and paint erosion.

 These effects

are linearly related

 to the total dose of ozone and can occur

at

very low levels,

 given long duration exposures.

Ozone

is

 a pulmonary irritant that affects the respiratory

mucous membranes,

 other

 lung tissues and respiratory functions.

Clinical and epiderniological studies have demonstrated that

ozone impairs

 the normal mechanical function of the

 lung,

causing alterations

 in respiration;

 the most characteristic of

which are shallow,

 rapid breathing and

 a decrease in pulmonary

compliance.

 Exposure to ozone results

 in clinical symptoms such

as chest tightness,

 coughing, and wheezing.

 Alterations

in

airway resistance can occur,

 especially to those with

respiratory diseases

 (asthma,

 bronchitis,

 emphysema).

 These

effects may occur

 in sensitive individuals,

 as well as

in

healthy exercising persons,

 at short—term ozone concentrations

between 0.15 and 0.25 ppm.

Ozone exposure increases the sensitivity of the lung to

bronchoconstrictive agents such

 as histamine,

 acetycholine,

and

allergens,

 as well as increasing the individual’s susceptibility

to bacterial infection.

 Simultaneous exposure to ozone and

SO2 can produce larger changes

 in pulmonary function than

exposure to either pollutant

 alone.

B.

 The Mid—City Lake Forest plant

is

 located in Libertyville

Township, Lake County,

 Illinois.

 Lake County

 is designated by the

United States Environmental Protection Agency as non-attainment for

ozone.

C.

 The Agency alleges that in the absence of VON control equipment,

actual VOM emissions

 from Mid-City’s coating operations exceed the

allowable emission rate of

 11.2 tons VON/year by 35.2 tons VON/year.

89—26(~

—

D.

 The parties agree

 that Mid-City’s printing of children’s text

books

 at its Lake Forest plant

 is of considerable social

and

economic benefit.

E.

 The Lake Forest plant

 is located in an industrial park west of

the city of Lake Forest.

 The finishing division (encompassing the

coating operations)

 has been located

 at the Lake Forest plant

for

nearly six years.

 The printing division (encompassing the presses)

moved to the Lake Forest plant from Northfield

 in late

 1985.

 There

are no residences nearby the facility.

F.

 The parties believe that it

 is technologically feasible and

economically reasonable to control VON emissions from Mid-City’s

coating operations with a catalytic afterburner.

 Construction and

operation of

 a system satisfying the VON capture and control

requirements

of

35

 Ill. Adm. Code 215,205 will bring Mid—City’s

operations into compliance with the VON emission limits of

35

 Ill.

Adm. Code Part 215, Subpart

F.

VII.

PROPOSAL FOR SETTLEMENT

As

 a result of settlement negotiations between the parties

and

the

actions

taken

Respondent,

the

parties

believe

that

the

public

interest and the environment will be best served by resolution of

this enforcement

 action under the terms and conditions provided

herein.

 This proposal for settlement will be effective upon the

approval of the Board.

 All statements contained herein are agreed

to for purposes of settling this action only and shall be null and

void and of no effect

 if the Board does not approve this proposal

for settlement in its entirety.

89—267

—

VIII.

TERMS

SETTLEMENT

Mid—City and IEPA have agreed

 to the following Terms

of

Settlement.

 These terms

 shall be

 in full

settlement

the

action

filed herein by the Agency and

Mid-City’s

liability

for

all

violations alleged by IEPA

 in its Complaint.

A.

 Mid—City neither admits nor

denies

the

violations

Section

of the Act,

35

 Ill. Mm.

 Code 201.143,

 201.141 and 215.204(c)

as

alleged by the Agency

 in the Complaint filed

 in this action.

B.

 The Respondent agrees to

 abide by all applicable provisions

of

the Illinois Environmental Protection Act and Rules and Regulations

of the Illinois Pollution Control

 Board arising from the operation

of its plant located at 13825 West Laurel Drive,

 Lake Forest,

Illinois.

C.

 The Respondent agrees

 to abide by all terms and conditions of

the permit

 issued by the Agency to Respondent on February 3,

 1987 to

construct

 a VOC Incineration System at its plant located

 at 13825

West Laurel Drive, Lake Forest,

 Illinois.

 Said permit

 (No.

86120051)

 is attached hereto

 as Exhibit A and its terms are

incorporated by reference

 as though fully set out herein.

89—268

—

12

—

D.

 The Agency agrees

 to issue an operating permit to Respondent

for

its paper coating operations (including the operation of three

 film

laminators, one top paper coater and VOC Incineration System)

following

 the receipt

 and review of an operating permit application

proving that the conditions of the VOC Incineration System

construction permit have been satisfied and that the operation of

Respondent’s paper coating operations will not cause

 a violation of

the Illinois Environmental Act or Illinois Pollution Control

 Board

Rules and Regulations,

 in accordance with Section 39(a)

 of the Act

(Ill.

 Rev. Stat.

ch.

 111—1/2,

 par.

 1039Ea).

E.

 Mid-City may operate its VOC Incineration System pending the

results

 of the stack test performed

 in accordance with the terms of

the VOC Incineration System construction permit

 (No.

86120051)(Exhibit A).

 If the stack test results

 fail

to

satisfactorily demonstrate that Mid—City’s VOC Incineration System

meets the requirements of

35

 Ill.

 Adm. Code 215.205(a),

 then

Mid—City will so arrange its production schedule

so

as

 to use only

compliant coatings in its paper coating operations, until such time

as such

 a satisfactory demonstration is made.

F.

 The parties enter

 into this Stipulation and Proposal for

Settlement and Mid—City agrees

 to pay the amount

 specified

 in this

paragraph in order

 to avoid

 the substantial costs and inconvenience

and uncertainties of

 litigation.

 In order to

 resolve this dispute

and as

 a condition of settlement,

 the Respondent agrees

 to pay

$10,000 into the Environmental Protection Trust Fund within 30 days

from the date the Board adopts

 a final order approving,

 accepting

89—269

—

13

—

and incorporating this Stipulation and Proposal

 for Settlement.

Payment shall be made by certified check or money order

 arid shall be

sent by first class mail

to:

Illinois Environmental Protection Agency

Fiscal Services Division

2200 Churchill Road

P.O.

 Box 19276

Springfield, Illinois

 62794—9276

The parties

 agree that said payment aids

 in enforcement of the Act

due to the length of

 time and number of

 alleged violations and the

substantial

 efforts undertaken by the Agency to obtain Respondent’s

compliance with the Act and

 the Board’s regulations.

G.

 The Agency,

 provided the various provisions of

 this settlement

agreement are complied with,

 agrees that

 it shall not pursue its

claims against Respondent for violations of the Act or Pollution

Control Board Rules governing Air Pollution Control,

 as stated in

the Complaint.

IX.

COMPLIANCE WITH OTHER LAWS AND REGULATIONS

A.

 This Settlement Agreement in no way affects Respondent’s

responsibility to comply with any federal,

 state or local

regulations, including but not limited to,

 the Act and the Illinois

Pollution Control Board Air Pollution Control Regulations

 at the its

plant located at 13825 West Laurel Drive, Lake Forest,

 Illinois.

89—270

—

14

—

B.

 This Settlement Agreement resolves and disposes

 of all past

and

existing violations,

 which could have been alleged based on facts

known to Complainant at

 the time of

 filing the Complaint.

 However,

nothing

 in this Settlement Agreement shall

 be construed as

 a waiver

by Complainant of the right

 to redress future violations or obtain

penalties with respect thereto.

WHEREFORE, Complainant and Respondent jointly request

 that

the

Board

adopt

and

the

foregoing

Stipulation

and

Proposal

for

Settlement

written.

FOR COMPLAINANT:

 FOR RESPONDENT:

ILLINOIS

ENVIRONMENTAL

MID-CITY

LITHOGRAPHERS,

INC.

PROTECTION AGENCY

/~eph/.S~,E~

anager,

 Enforcement Programs

Dated:

______________

 Dated:

~

7/

ATTORNEY GENERAL OF THE

•

STATE

ILLINOIS

l!i~

~-11...Neil F..JHartigan

Dated:_____________

076913

89—271

kr—

rPK’-•’-’~’~.

Illinois Environmental

Protection Agency

2200 Churchill Boa1Spk~ttZit

62706

7/782-2113

CC?ISItUCTIO#

PErMIT

PER!IITTEE

19d

Cfty

Lithographers

Attention:

 Theras C.

ltoonz

13825 West Laurel

~rive

Lake Forest, Illinois

 60C’~5

Application flo.:

36120051

 1.!).

 flc’.:

097030AAU

nmstcanrs

cesignatlon:

Pf1LCOH1tCL

Date

 ReceIved:

Janucry

 2, l&87

Subject:

Y~C

Incineration

Systat

Rate

Issued:

February

lCP7

Location:

13825

West

Laurel

Drive,

Lake

Forest

Permit

hereby

granted

the

above—designated

Pennittee

CONSTRUCT

emission

source(s)

and/or air

pollution

control

equipment

consisting

one

catalytic

afterburner

as

described

the

above—referenced

application.

This

Permit is

subject

standard

conditions

attached

hereto

and

the

following

special condition(s):

1.

a.

 Within 30 days of completion of construction of the catalytic

afterburner

described

the

above

referecced

permit application,

the

organic

r.aterial

concentrations

the

effluent

stretm

the

afterburner

shall

neasured

approved

testing

service.

These

tests

shall

conducted,

documented,

and

reported

accordance

with

35 Ill.

Mn.

Cods

215.202,

and

Ill.

Akt.

Code

Part

 283.

The test

procedures

shall

~‘edesigned

verify

both

destruction

vcn

across

the

afterburner

and

overall

control

YOTI

the

capture

system

and

afterburner

as

req’ii

red

35 Ill.

Ad~i.Code

21 E.20C(a).

Prior

conducting

such

test,

the

Agency

 shall to

consulted

verify

that

the

intencted

test

rathod

apprnved

and

appropriate

for

usein

testing

this

equipment

show

ccnpi

lance

wIth

this

rule.

This

test

shall

conducted

during

circumstncos

which

are

representative of

naxirauls

emissIons,

and

equipment

data

and

material

usage

during

the

test

shall

 recorded.

RECE!VED

MAY

WOOD

OFFsCE

MAR 09

1987

EPA/OAPC

STATE ci

ILLINOIS

89—272

 ‘4

Illinois Environmental

Protection Agency

2200

Churchill Bad, Sprlngfl.ld,

IL $2706

Paget

2a.

Prior

to

cerryin~out

these

tests,

t’e

Pro-Test

Proce?ures

3C Ill.

Act’.

Code

282,

Subport

shall

ccn~loted.

particular,

the

Agency’s

regional

office

and

the

Agency’s

Source

Emission

Test Specialist

shall

notified

ninirun

of

thirty

(30)

clays

prior

the

expected

date of

tkese

tests

a~dfurther notIfied a

minImum

five

(5)

tiorting

days

prior to

the

test of

the exact

date, tte

an’

piece

these

tests,

enable

the

Agency

ul tuoss

t!;ese

tests.

Illinois

Envi

romnental

Protection

Agency

Division

Air

Pollution

Control

—

Regional

Office

The

Intercontinental

Center

1701

Fl rst

Averue

Mayiccod,

Illinois

60153

Ill inots

Envirorcental

Protection

Agency

Atto:

Source

Emission

Test SpecIalist

Division

Air

PollutIon

Control

IntercontInental

Center

1701

First

Avenue

rayuood,

Illinois

60153

Three

(3)

copies

the

FInal

Report(s)

for

 these

tests,

fri

accordance

with

35 III.

Ada.

Code

283,

Subparts

and

shall

submitted

the

Agency

within

days

after

the

test

results are

compiled and finalized,

prior

to or

accompanyIng

the

operating

permit

applicatIon.

SatIsfactory

completion

these

 tests

and

compliance

with

the

limitations

this

permit

 shall be a

prerequisite

the

issuance

of

 an operating permit.

copy

of ttc

Siszary

Results,

General

Infottation,

and

Conclusions,

contained

the

Final

Report,

shall

also

 submitted

to the

Source

Einisslcn Test SpecialIst.

Terry A.

SwoltzerCh.E.

P.anagor,

Permit Section

Division of Air Pollution Control

TM:CR14:

ds:41

G411/30—31

~gm

‘fain

cc: ~gIon1

89—273