REC~VED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CLERK’S
OFFICE
OASIS INDUSTRIES, iNC.
)
APR
062004
)
STATE OF ILLINOIS
Petitioner,
)
PCB #
04-116
PollutIon Control Board
v.
)
(PermitAppeal-Air)
ILLiNOIS ENVIRONMENTAL
)
(90
dayextension)
PROTECTION AGENCY
)
)
Respondent.
)
NOTICE OF
FILING
To:
Ms.
Maureen
Wozniak
Dmston of
Legal
Counsel
Illinois Environmental
Protection
Agency
1021 N.
Grand
Ave.
P.O.
19276
Springfield,
IL
62794-9276
PLEASE
TAKE
NOTICE
that I have
today filed
with
the Office ofthe Clerk ofthe
Pollution
Control
Board the
originalandnine copies
ofthe PETITION FOR
REVIEW
OF
CAAPP PERMIT,
FILiNG
FEE, and
APPEARANCE OF
HEIDI
E. HANSON, a copy
ofwhich ishereby served upon you.
Respectililly submitted,
Heidi E.
Hanson
Dated- Aprll2, 2004
Heidi E.
Hanson
H. E.
Hanson, Esq.
P.C.
4721
FranklinAve, Suite
1500
Western
Springs, IL
60558-1720
(708) 784-0624
This filing is
submitted
on
recycled paper.
RECE~VED
CLERK’S OFFICE
CERTiFICATE
OF SERVICE
APR 062004
I, the undersigned, certifythat
I have served the
attached PETITION FOR ~
~
OF
CAAPP
PERMIT,
FILING FEE,
and
APPEARANCE
OF
HEIDI
E. HANSON,
by U.
S.
Mail
return receipt requested
before 4:30 April 2,
2004, upon
the following
persons:
Filing Fee, original and
nine copies
ofPetition and Appearance
to:
Clerk, IllinoisPollution Control Board
100
W. Randolph
Street
State of
Illinois
Center
Suite
11-500
Chicago, Illinois 60601
one copy of
Petition and Appearance to
Ms.
Maureen Wozniak
Division
ofLegal
Counsel
IllinoisEnvironmental Protection Agency
1021
NGrandAve.
P.O. 19276
Springfield,
IL
62794-9276
Dated:
April 2, 2004
Heidi E. Hanson
H. E.
Hanson, Esq.
P.C.
4721
Franklin Aye,
Suite 1500
Western
Springs, IL 60558-1720
(708) 784-0624
This
filing
is submitted onrecycled
paper.
REcEWED
CLERK’S OFFICE
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
APR 062004
•
STATE OF ILLINOIS
OASIS
INDUSTRIES INC.
)
Pollution Control Board
)
•
Petitioner,
)
PCB #04-116
v.
)
(Permit Appeal
-
Air)
)
ILLiNOIS ENVIRONMENTAL
)
PROTECTION AGENCY
)
)
Respondent.
)
APPEARANCE OF UEIDI E. HANSON
I hereby
file
my
appearance in this proceeding
on
behalf
of
Petitioner, Oasis
Industries Inc.
Respectfully submitted.
on behalfof
OasisIndustries, Inc.
Dated:
April2, 2004
Heidi E. Hanson
H. E.
Hanson, Esq.
P.C.
4721
Franklin
Aye,
Suite
1500
Western Springs, IL
60558-1720
(708) 784-0624
~IECE~VEb
BEFORE THE
ILLINOIS
POLLUTION
CONTROL
BOARD
•
CLER1c’~
OFFICE
OASIS INDUSTRIES iNC.
)
APR
(36
2004
•
)
STATE
OF
ILLINOIS
Petitioner,
)
PCB #
04-116
Pollution Control Board
v.
)
(PerrnitAppeal-Air)
)
ILLINOIS
ENVIRONMENTAL
)
PROTECTION AGENCY
)
)
Respondent.
•
)
PETITION FOR REVIEW
OF CMPP
PERMIT
NOW COMES the Petitioner, OASIS INDUSTRIES iNC., by and through its
attorney HeidiE. Hanson, H. E. HansonEsq. P.C. and pursuant to Section 40.2 ofthe
Illinois Environmental Protection Act (415 ILCS 5/40.2) and
35 In
Adm. Code
105
Subpart C, andthe Board’s Order ofJanuary 22, 2004, petitionsthe Illinois Pollution
ControlBoard
fur
review oftheNovember 26, 2003 Clean Air Act Permit Program
(“CAAPP”) permit#99090059 issued to Oasis Industries, Inc., and fwiher petitions
fur
a
stay ofcertain conditions
of
that permit.
In support thereofPetitionerstates as follows;
Description ofthe CAAJ’P Source
OasisIndustries, Inc. (“Oasis”) is located in an industrial park in Aurora, Illinois
in
Kane County.
It manufactures bathtubs, whirlpools, tub shower units and showerbasins.
Oasis applied for aCAAPP permit on December
4, 1995.
A preliminarydraftof
the CAAPP permit was sentto Oasis
on
June 3,1997 andwas under review when, hi July
of
1997,
it
moved its entire operation from Batavia, also
in
Kane County,to its current
location in Aurora.
Oasis followed the Illinois Environmental Protection Agency’s
instructions
regarding
transfer
of
the CAAPP permit applicationand applying for acurrent
construction andoperating permit at the new facility.
Oasis made numerous comments
on
the CAAPP application
while it was pending.
The
processthat was moved involved tbermoforming an acrylic sheet into a
product,
for
example
a bathtub, then using
fiberglass
as a reinibrcing material,
Benzoyl
Peroxide (SPO) as a
catalyst and styrene as apolynierizing agent.
A state operating
permit issued July
25,
1997
(#97070058),
allowed it
to emit 15.7 tons peryear (“tpy”)of
volatile organic
material
(“VOM”) from
two fiberglass
resin spray
lay-up booths and one
gelcoat
spray lay-up
boothat its Aurora location.
The CAAPP permit refursto
these
originalbooths as
Line #1.
A second permit,
#98020084,
issuedAugust
31, 1998,
allowed Oasis
to
construct
and
operate
four more
booths
andto emit an additional 8.8 tpy VOM.
The second permit
was for a
new
process which involvedapplying gelcoat to a mold then
adding additional
layers
ofgelcoat for strength.
The CAAPP permit
refers to the newbooths asLine #2.
A
detailed
description of
the
process is given in Section 7.1,
pages
18
and
19 of
the attached CAAPP permit.
IEPA has proposed to issue a
permit
(#02090027) for
another spray
booth.
When
that permit is
granted, Oasis will
be permittedto
emit
a total of40.5 tons ofVOM.
Request and
Justification
for
Review
The
“Date Received” listed on page
1 ofthe permit
is
incorrect.
The IEPA
received the permit application
fur
this operation on December 4,1995.
The “Responsible Official” (Mr. Dale Graham) listed
on
page
1 ofthe permit and
in section 1.3, page
4,
isincorrect.
The IEPAwas infonned at aNovember 22,
2003
meeting that Mr. Dale Grahamhad left the company.
The Responsible Official should be
Mr. William Jahnke.
The
reference in
condition 3.2.2,.page 8,
to
“266.110” should be to
“212.321(c)”
to
claii1~thisrequirement.
Condition 3.2.3,
page 8,
states
that
35
IAC 218.301 “..requires that organic
materialemissions not exceed 8.0 lbs per
hour or do
not quatil~r
as photochemically
reactive material...”
This section misstatesBoard rule
35
JAC 218.301,
in that the permit
section, as drafted, couldbe read asrequiring that Oasis’ organic emissions not be
photoebemically reactive, whereasthe Boardrule only states that ifemissions are not
phototchemically reactive they may be exempted from the
8.0
lbs per hour limit, unless
they constitute an odor nuisance.
Rule 2 18.301 is
correctly
described in condition
7.1.3(b), page
19 ofthe
CAAPP permit.
Condition
4.0,
page
9,
listsincorrect start up dates
for
emission units
1,2
and
3.
These emission units were constructed in Batavia
in
1995 andmoved
to Aurora
in 1997.
Condition 5.1.1, page
10,
states that
the
source is a major source
ofVOM.
This is
incorrect asthe permititselfrestricts operations
to
less than
25
tpy
ofVOM.
See
condition 7.1.6.
Condition
5.2.5, page 11, incorrectly
indicates that
40
CFR
Part
63
Subpart
WWWW was not
yet
filial on the date ofissuance ofthe permit.
It should be
revised
to
reflect
the fact that
40 CFR
Part
63 Subpart WWWW
was adopted
onApril21,2003.
68
Fed. Reg. 19402,
April
21,2003.
2
Condition 5.2.7,
page 12, should be deleted because it is
not
applicable
to Oasis,
and 40 CFRPart 64 should be listed under permit section
5.3
as aNon-Applicable
Regulation.
There are no emission units that are
subject to 40
CFR Part 64, Compliance
Assurance Monitoring (“CAMrule”).
Oasisuses work practices and low VOM emitting
materials to comply with applicable VOM limits.
The only control equipment that it uses
is for particulate control
None ofOasis’ units have precontrol device emissions that equal
or exceed major sourcethresholds for particulate matter, asa result the CAMrule isnot
applicableto Oasis.
40 CFR 64.2(a)(2) and
(3).
Inaddition, condition 5.2.7 also
incorrectly states that the CAAPP permit was notdeemed complete before April
20,1998.
Pursuant to 415
1TLCS
5/39.5(5)(f)
Oasis’ CAAPP
application was
deemed completeprior
to that date.
Condition
5.5.1,
page
13, restricts
particulate matter
to 0.60
tpy.
Oasis had
requested alimit of0.88 tpyand therewas no justification for denyingthat request.
Condition
5.6.2(b),
page
14, requires that monthly HAP emissions be calculated
“asafraction
of
VOM emissions according to vaporweight percentage”.
This calculation
procedure reflects Roalt’s lawand it is not applicable for the type ofemission sources at
Oasis.
Roalt’s law assumes that the amount ofVOM emitted is roughlyproportionalto
the amount ofVOC in liquid.
it is
appropriate for situations where the VOM isbeing
used asa solvent.
In Oasis’ case theVOM is part
of
thechemical reactionbecause it is
being used as apolymerizing agent and therefore Roalt’s law
(the procedure
given
in
Condition
5.6.2)
will yield inaccurate results.
HAP emissions shouldbe calculatedas
described in
Condition 7.1.12 using the
appropriate
UEF and
source
specific
emissioli
factors.
Condition 5.9.1(a), page
15, also uses
Roalt’s law and is objected to for
the
reasons set
forth inreference to
Condition
5.6.2, above.
In condition
7.1.3(d), page 20, the word “which”
should be added after
“process
emission unit”
to
reflect the language and intent
of
the rule
from
which
it
was derived,
35
IAC
212.321(a).
Condition 7.1.4
should include
the provision on nonapplicability ofNew
Source
Reviewthatwas included in
the
December 2,2002 draft permitas draft condition
7.1.4(a).
The permit
by
its terms (condition
7.1.6)
limits
VOM to
below major source
levels, therefore
New
Source Reviewdoes not apply.
Condition 7.1.6, page 23,
limits
VOM emissions from Lines
1
and 2.
The only
part
ofthis condition that
Oasis asks the Boardto review are the specific monthlyand
annual emission limitations
for
each line.
Oasis
does
not
object to the
combined limits,
although as noted it has apending permit
application for another boothwhich will
increase
total emissions
from
the plant
to
above
24.5
tpy,
By limiting the two
lines
to the
specific
amounts, the JEPA is
deciding what type
ofproduct can be
produced,
It is
forcing Oasis
to produce more acrylic
bathtubs than gelcoat bathtubs.
There is no environmental
3
justification
for this and
the individual line limitations
are
notnecessary
to complywiththe
Illinois
Environmental
Protection Act
In condition 7.1 .9(e)(i), page 28, “on”
should
be
“or” inorder to
claril!y this
requirement.
Condition 7.1.12(a),
page
31,
sets
out specific emission factors and then provides
that the permittee
may
use other
emission factors ifthey
are approved bythe IEPA.
In
September of2003,
Oasis
providedthe IEPA with a test
report
from
the CARL laboratory
at Purdue
University
for emissions
tests
doneonOasis’ resin.
Their
tests
determined that
8.545
of
the
VOMinthe resin is
emitted during
application and
curing
(8.699
ofthe
styrene is emitted and
5.771
ofthe
vinyl
toluene.
The permit does not
explain
whether
the emission factor developed as a result ofthe
CARL report is deemed
approved for
purposes ofdetermining compliance under
the
permit, therefore itis unclear how
compliance
with the
resin
emissions limits is
to be determined.
Condition
7.1.12(c),
page
31,
requiresthat
the
monthly materialusage be
computedbythe
15th
day
of
each
month.
However, 7.1. 10(aXiv) does
not require that an
exceedence be
reported until
30 days
afterthe exceedence.
There is nojustification
for
requiring the computations to be done 15 days
before the
report date.
Condition 7.1.12
should be changed to be consistent with 7.1 .10(a)(iv) and to allow the full period oftime
(up to 30 days) to completethe computations.
Condition 7.1.13, page
32,
seeks to limit the permit shield
in section8.1
stating
that
“the permittee is not shielded
from possible enforcement actions initiated
by either USEPA or the Illinois EPA involving the abovenamed emissions
units or activities.
In addition, compliance with
this permit does not serve
as proof
of
compliance for those emissions units or activities.”
The section does not specil~r
what emissions units oractivities arecovered, leading
to
thepossible implication thatthe condition covers-all permitted units
or
activities and
therefore there is no permit shield
for
any unit oractivity.
The permit shield limitation as
drafted
is
too broad, arguably goes beyond the points at issue in theviolation notice, fails
to
comply with
415
ILCS5/39.5(7).(j), and inappropriatelyprejudges the outcome of
contested alleged violations.
It
should be noted that Oasis
does not agree
with
the
Illinois
EPA
thatpast
New
Source Review violations
occurred,
or
that ifthey didoccur
theywould have any
implications for thispermit.
It is not appropriate to
attempt
to
address
such
alleged
violations though thedrafting
ofa permit.
Oasis should be granted a permit shield
that
covers all emission units and activities excepting only as provided in
415
ILCS
5139.5(7Xj)(ivXb) and further excepting
that compliance withthe
CAAPP
permit will not
be deemed
to
be compliance with
New Source
Review and ERMs if, and
to
the extent
of,
any violations
ofthose programs
that
predated the issuance ofthis permit in
the
event
that
4
Board ordersOasis to provideoflacts for such program as aremedy for the alleged
violations..
Petitioner reserves theright to review thepermit record and verii~r
that all
materials sent to the IEPA and which should appear in
the
record do in fact appear in the
record, including butnot limited to filed comments, notes ofmeetings and telephone
conversations, anddocuments relatingto the operation that was moved from Batavia.
For the above reft~renced
reasons, the contested CAAPP permitconditions are not
necessary to accomplishthe purposes
ofthe
Actor Board regulations, are arbitrary and
unnecessary, are beyond the Agency’s authority and! or render certain permit sections
ambiguous or internally inconsistent
WHEREFORE, Petitionerrequests that the Board remandthis permit
to
the IEPA and
order that
it
make the changes described above.
FURTHERMORE, pursuant
to 35
IAC
105.304(b) Petitioner asksthat
the Board stay the
effectiveness of
permit
conditions 3.2.3,
5.2.7,
5.6.2(b), 5.9.1(a) and 7.1.12(c)
each
of
which impose requirements
not found in previous permits
and
not supported
by the Act or
theBoard’s regulations.
Such
stayis necessary
inorder to avert irreparable harm to
Petitioner.
Such stay will not harm the public or
the
environment.
Respectfully
submitted.
Dated:
April2, 2004
onbehalfof
OasisIndustries, Inc.
Heidi E.
Hanson
H. E.
Hanson. Esq.
P.C.
4721
Franklin Aye, Suite 1500
Western
Springs,
IL 60558-1720
(708)
784-0624
5
217/782—2113
TITLE V
-
CLEAN AIR ACT PERMIT PROGRAM
(CAAPP) PERMIT
and
TITLE
I PERMIT’
PERMITTEE
Oasis Industries, Inc.
Attn:
Dale Graham,
Vice President of Manufacturing
1600 Mountain Street
Aurora,
Illinois
60505
Application No.:
99090059
I.D. No.:
089407AAL
Applicant’s Designation:
Date Received:
September
22, 1999
Operation of:
Polyester Resin Product Manufacturing
Date Issued:
November 26, 2003
Expiration Date2:
November 26,
2008
Source Location:
1600 Mountain Street, Aurora, Kane County
Responsible Official:
Dale Graham, Vice President of Manufacturing
This permit is hereby granted to the above—designated Permittee to OPERATE a
polyester resin product manufacturing facility, pursuant to the above
referenced permit application.
This permit is subject to the conditions
contained herein.
If you have any questions concerning this permit, please contact Jonathan
Sperry at 217/782—2113.
Donald E. Sutton,
P.E.
Manager, Permit Section
Division of Air Pollution Control
DES:JS:psj
cc:
Illinois EPA,
FOS,
Region
1
This permit may contain terms and conditions which address the applicability, and
compliance if determined applicable,
of Title
I of the
CAA
and regulations promulgated
thereunder,
including 40 CFR 52.21
—
federal PSD and 35
IAC Part 203
—
Major Stationary
Sources construction and Modification.
Any such terms and conditions are identified
within this permit.
Except as provided in Condition 8.7 of this permit.
TABLE OF CONTENTS
PAGE
1.0
SOURCE IDENTIFICATION
4
1.1
Source
1.2
Owner/Parent Company
1.3
Operator
1.4
General Source Description
2.0
LIST OF ABBREVIATIONS/ACRONYMS USED IN THIS PERMIT
5
3.0
INSIGNIFICANT ACTIVITIES
7
3.1
Identification of Insignificant Activities
3.2
Compliance with Applicable Requirements
3.3
Addition of Insignificant Activities
4.0
SIGNIFICANT EMISSION UNITS AT THIS SOURCE
9
5.0
OVERALL SOURCE CONDITIONS
10
5.1
Source Description
5.2
Applicable Regulations
5.3
Non—Applicability of Regulations of Concern
5.4
Source-Wide Operational and Production Limits and Work
Practices
5.5
Source-Wide Emission Limitations
5.6
General Recordkeeping Requirements
5.7
General Reporting Requirements
5.8
General Operational Flexibility/Anticipated Operating
Scenarios
5.9
General Compliance Procedures
6.0
EMISSIONS REDUCTION MARKET SYSTEM
(ERMS)
16
6.1
Description of ERNS
6.2
Applicability
6.3
Recordkeeping and Reporting
7.0
UNIT SPECIFIC CONDITIONS
18
7.1
Polyester Resin Product Manufacturing
8.0
GENERAL PERMIT CONDITIONS
34
8.1
Permit Shield
8.2
Applicability of Title IV Requirements
8.3
Emissions Trading Programs
8.4
Operational Flexibility/Anticipated Operating Scenarios
8.5
Testing Procedures
8.6
Reporting Requirements
8.7
Obligation to Comply with Title I Requirements
2
PAGE
9.0
STANDARD PERMIT CONDITIONS
39
9.1
Effect of Permit
9.2
General Obligations of Permittee
9.3
Obligation to Allow Illinois EPA Surveillance
9.4
Obligation to Comply with Other Requirements
9.5
Liability
9.6
Recordkeeping
9.7
Annual Emissions Report
9.8
Requirements for Compliance Certification
9.9
Certification
9.10
Defense to Enforcement Actions
9.11
Permanent Shutdown
9.12
Reopening and Reissuing Permit for Cause
9.13
Severability Clause
9.14
Permit Expiration and Renewal
10.0
ATTACHMENTS
10.1
Attachment
1
—
Example Certification by a Responsible
1—1
Official
10.2
Attachment
2
—
Particulate Matter Emissions from Process
2-1
Emission Units
10.3
Attachment
3
—
Emissions from Polyester Resin Product
3-1
Fabrication Processes
10.4
Attachment
4
—
Guidance on Revising This Permit
4—1
10.5
Attachment
5
—
Form l99—CAAPP, Application For
5—1
Construction Permit
(For CAAPP Sources Only)
10.6
Attachment
6
—
Guidance on Renewing This Permit
6-1
3
1.0
SOURCE IDENTIFICATION
1.1
Source
Oasis Industries,
Inc.
1600 Mountain Street
Aurora,
Illinois
60505
630/898—3500
I.D. No.:
089407AAL
Standard Industrial Classification:
3088,
Plastics Plumbing
Fixtures
1.2
Owner/Parent Company
NAPCOR
1600 Mountain Street
Aurora,
Illinois
60505
1.3
Operator
Oasis
Industries,
Inc.
1600 Mountain Street
Aurora,
Illinois
60505
Dale Graham, Vice President of Manufacturing
630/898—3500
1.4
General Source Description
Oasis
Industries,
Inc. is located at 1600 Mountain Street in
Aurora,
Illinois.
The source manufactures polyester resin
plastic products,
for example,
fiberglass bathtubs.
Polyester
styrene resins and fiberglass reinforcements are the two major
components of the products.
The source uses spray booths to mold
polyester resins and other raw materials into the desired
product.
4
2.0
LIST OF ABBREVIATIONS/ACRONYMS USED IN THIS PERMIT
ACMA
Alternative Compliance Market Account
Act
Illinois Environmental Protection Act
415
ILCS 5/1 et seq.
AP—42
Compilation of Air Pollutant Emission Factors, Volume
1,
Stationary Point and Other Sources
(and Supplements A
through F), USEPA,
Office of Air Quality Planning and
Standards, Research Triangle Park, NC
27711
ATU
Allotment Trading Unit
Etu
British thermal unit
CAR
Clean Air Act
42
U.S.C. Section 7401 et seq.
CAAPP
Clean Air Act Permit Program
CAM
Compliance Assurance Monitoring
CFA
Composite Fabricators Association
CFR
Code of Federal Regulations
cm
centimeter
Dept.
Department
ERMS
Emissions Reduction Market System
°F
degrees Fahrenheit
ft
feet
ft’
cubic foot
gal
gallon
HAP
Hazardous Air Pollutant
hr
hour
I.D. No.
Identification Number of Source,
assigned by Illinois EPA
IAC
Illinois Administrative Code
ILCS
Illinois Compiled Statutes
Illinois EPA
Illinois Environmental Protection Agency
kg
kilogram
kW
kilowatts
lb
pound
m
meter
Mg
megagram
mm
minute
MMA
methyl methacrylate
mmBtu
Million British thermal units
mo
month
MW
megawatt
N/A
Not applicable
NESHAP
National Emission Standards for Hazardous Air Pollutants
NNMA
National Marine Manufacturers Association
NO~
Nitrogen Oxides
NSPS
New Source Performance Standards
NVS
non—vapor suppressed
PM
Particulate Matter
PM,0
Particulate matter with an aerodynamic diameter less than or
equal to a nominal 10 microns as measured by applicable test
or monitoring methods
ppm
parts per million
PSD
Prevention of Significant Deterioration
psi
pounds per square inch
5
PVC
polyvinyl chloride
RMP
Risk Management Plan
SCAQMD
South Coast Air Quality Management District
SIP
State Implementation Plan
SO2
Sulfur Dioxide
Tl
Title
I
—
identifies Title
I conditions that have been
carried over from an existing permit
T1N
Title
I New
—
identifies Title
I conditions that are being
established in this permit
T1R
Title
I Revised
—
identifies Title
I conditions that have
been carried over from an existing permit and subsequently
revised in this permit
UEF
United Emission Factors
USEPA
United States Environmental Protection Agency
VOM
Volatile Organic Material
VS
vapor suppressant
VSR
vapor suppressed resin
yr.
year
6
3.0
INSIGNIFICANT ACTIVITIES
3.1
Identification of Insignificant Activities
The following activities at the source constitute insignificant
activities as specified in 35 IAC 201.210:
3.1.1
Activities determined by the Illinois EPA to be
insignificant activities, pursuant to 35 IAC 201.210 (a) (1)
and 201.211,
as follows:
Repair Booth
(EV-4)
Bath Shield Spray Booth
(EV—5)
Resin/Filler Mix Tank
(EV-7)
Tubset Resin/Filler Five Gallon Mixer
(EV—8)
Equipment Room Exhaust Fan
(EV-9)
Resin Storage Vent Fan
(EV-10)
Resin/Filler Mix Tank
(EV-15)
Roof Vents
3.1.2
Activities that are insignificant activities based upon
maximum emissions,
pursuant tO 35 IAC 201.210 (a)
(2) or
(a) (3), as follows:
Grinding Booth
(EV-6)
3.1.3
Activities that are insignificant activities based upon
their type or character, pursuant to 35 IAC 201.210 (a) (4)
through
(18), as follows:
Direct combustion units designed and used for comfort
heating purposes and fuel combustion emission units
as follows:
(A) Units with a rated heat input
capacity of less than 2.5 rnmBtu/hr that fire only
natural gas, propane,
or liquefied petroleum gas;
(B)
Units with a rated heat input capacity of less than
1.0 mmBtu/hr that fire only oil or oil in combination
with only natural gas, propane, or liquefied
petroleum gas;
and
(C)
Units with a rated heat input
capacity of less than 200,000 Btu/hr which never burn
refuse,
or treated or chemically contaminated wood
35
IAC 201.210 (a) (4)
3.1.4
Activities that are considered insignificant activities
pursuant to 35 IAC 201.210(b).
3.2
Compliance with Applicable Requirements
Insignificant activities are subject to applicable requirements
notwithstanding status as insignificant activities.
In
particular,
in addition to regulations of general applicability,
such as 35 IAC 212.301 and 212.123
(Condition 5.2.2),
the
Permittee shall comply with the following requirements, as
applicable:
7
3.2.1
For each cold cleaning degreaser,
the Permittee shall
comply with the applicable equipment and operating
requirements of 35 IAC 215.182,
218.182,
or 219.182.
3.2.2
For each particulate matter process emission unit, the
Permittee shall comply with the applicable particulate
matter emission limit of 35 IAC 212.321 or 212.322.
For
example, the particulate matter emissions from a process
emission unit shall not exceed 0.55 pounds per hour if the
emission unit’s process weight rate is 100 pounds per hour
or less, pursuant to 35 IAC 266.110.
3.2.3
For each organic material emission unit that uses organic
material, e.g., a mixer or printing line,
the Permittee
shall comply with the applicable VOM emission limit of 35
IAC 215.301, 218.301,
or 219.301, which requires that
organic material emissions not exceed 8.0 pounds per hour
or do not qualify as photochemically reactive material as
defined in 35 IAC 211.4690.
3.3
Addition of Insignificant Activities
3.3.1
The Permittee is not required to notify the Illinois EPA
of additional insignificant activities present at the
source of a type that is identified in Condition 3.1,
until the renewal application for this permit is
submitted, pursuant to 35 IAC 201.212(a).
3.3.2
The Permittee must notify the Illinois EPA of any proposed
addition of a new insignificant activity of a type
addressed by 35 IAC 201.210(a)
and 201.211 other than
those identified in Condition 3.1, pursuant to Section
39.5(12) (b) of the Act.
3.3.3
The Permittee is not required to notify the Illinois EPA
of additional insignificant activities present at the
source of a type identified in 35 IAC 201.210(b).
8
4.0
SIGNIFICANT EMISSION UNITS AT THIS SOURCE
Emission
Unit
Description
Date
Constructed
Emission Control
Equipment
EV—1
Fiberglass Spray—Up Chop
Station_#1
1997
Filter
EV-2
Fiberglass Spray—Up Chop
Station #2
1997
.
Filter
EV—3
Fiberglass Spray—Up Chop
Station_#3
1997
Filter
EV-11
Gelcoat Spray Booth
1998
Filter
EV—12
Skin Coat Spray Booth
1998
Filter
EV—13
Final Coat Fiberglass
Spray-Up Booth #13
1998
•
Filter
EV-14
Final Coat Fiberglass
Spray—Up_Booth_#14
1998
Filter
9
5.0
OVERALL SOURCE CONDITIONS
5.1
Source Description
5.1.1
This permi.t is issued based on the source requiring a
CAAPP permit as a major source of VOM and
HAP
emissions.
5.2
Applicable Regulations
5.2.1
Specific emission units at this source are subject to
particular regulations as set forth in Section 7
(Unit—
Specific Conditions) of this permit.
5.2.2
In addition,
emission units at this source are subject to
the following regulations of general applicability:
a.
No person shall cause or allow the emission of
fugitive particulate matter from any process,
including any material handling or storage activity,
that is visible by an observer looking generally
overhead at a point beyond the property line of the
source unless the wind speed is greater than 40.2
kilometers per hour
(25 miles per hour),
pursuant to
35 IAC 212.301 and 212.314.
Compliance with this requirement is considered to be
assured by the inherent nature of operations at this
source, as demonstrated by historical operation.
b.
No person shall cause or allow the emission of smoke
or other particulate matter, with an opacity greater
than 30 percent, into the atmosphere from any
emission unit other than those emission units subject
to the requirements of 35 IAC 212.122,
pursuant to 35
IAC 212.123(a),
except as allowed by 35 IAC
212.123(b)
and 212.124.
5.2.3
Ozone Depleting Substances
The Permittee shall comply with the standards for
recycling and emissions reduction of ozone depleting
substances pursuant to 40 CFR Part 82, Subpart F, except
as provided for motor vehicle air conditioners in Subpart
B of 40 CFR Part 82:
a.
Persons opening appliances
for maintenance, service,
repair, or disposal must comply with the required
practices pursuant to 40 CFR 82.156.
b.
Equipment used during the maintenance, service,
repair, or disposal of appliances must comply with
the standards for recycling and recovery equipment
pursuant to 40 CFR 82.158.
10
c.
Persons performing maintenance, service, repair, or
disposal of appliances must be certified by an
approved technician certification program pursuant to
40 CFR 82.161.
5.2.4
Risk Management Plan
Should this stationary source, as defined in 40 CFR
Section 68.3, become subject
to. the Accidental Release
Prevention regulations in 40
CFR
Part 68, then the owner
or operator shall submit
40
CFR 68.215 (a)
(2) (i)
and
(ii):
a.
A compliance schedule for meeting the requirements of
40 CFR Part 68 by the date provided in 40 CFR
68.10 (a); or
b.
A certification statement that the source is in
compliance with all requirements of 40 CFR Part 68,
including the registration and submission of the Risk
Management Plan
(RMP),
as part of the annual
compliance certification required by 40 CFR Part 70
or 71.
5.2.5
a.
Should this stationary source become subject to a
regulation under 40 CFR Parts
60,
61,
or 63,
or 35
IAC after the date issued of this permit, then the
owner or operator shall, in accordance with the
applicable regulation(s), comply with the applicable
requirements by the date(s) specified and shall
certify compliance with the applicable requirements
of such regulation(s)
as part of the annual
compliance certification, as required by 40 CFR Part
70 or 71.
b.
No later than upon the submittal for renewal of this
permit, the owner or operator shall
submit, as part
of an application, the necessary information to
address either the non-applicability of, or
demonstrate compliance with all applicable
requirements of any potentially applicable regulation
which was promulgated after the date issued of this
permit.
c.
This stationary source will be subject to 40 CFR Part
63,
Subpart
WWWW,
Reinforced Plastic Composites
Production,
when such rule becomes final and
effective.
The Permittee shall comply with the
applicable requirements of such regulation by the
date(s) specified in such regulation and shall
certify compliance with the applicable requirements
of such regulation as part of the annual compliance
certification required by 40 CFR Part 70 or 71
11
beginning in the year that compliance is required
under a final and effective rule.
5.2.6
Episode Action Plan
a.
If the source is required to have an episode action
plan pursuant to 35 IAC 244.142,
the Permittee shall
maintain at the source and have on file with the
Illinois EPA a written episode action plan
(plan)
for
reducing the levels of emissions during yellow
alerts,
red alerts,
and emergencies, consistent with
safe operating procedures.
The plan shall contain
the information specified in 35 IAC 244.144.
b.
The Permittee shall immediately implement the
appropriate steps described in this plan should an
air pollution alert or emergency be declared.
c.
If a change occurs at the source which requires a
revision of the plan
(e.g., operational change,
change in the source contact person),
a copy of the
revised plan shall be submitted to the Illinois EPA
for review within 30 days of the change.
Such plans
shall be further revised if disapproved by the
Illinois EPA.
d.
For sources required to have a plan pursuant to 35
IAC 244.142,
a copy of the original plan and any
subsequent revisions shall be sent to:
i.
Illinois EPA,
Compliance Section; and
ii.
For sources located in Cook County and outside
of the city of Chicago:
Cook County
Department of Environmental Control; or
iii.
For sources located within the city of
Chicago:
Chicago Department of Environmental
Control.
5.2.7
CAM
Plan
This stationary source has a pollutant—specific emissions
unit that is subject to 40 CFR Part
64, Compliance
Assurance Monitoring
(CAM)
for Major Stationary Sources.
As a result of this application either not having been
submitted or deemed complete by April 20,
1998, the source
is required to comply with the requirements of 40 CFR Part
64 for large pollutant—specific emissions units in the
initial application and CAAPP permit.
The source must
submit
a CAN plan for all other affected pollutant-
specific emissions units upon application for renewal of
the initial CAAPP permit,
or upon a significant
modification to the CARPP permit for the construction or
12
modification of a large pollutant—specific emissions unit
which has the potential post-control device emissions of
the applicable regulated air pollutant that equals or
exceeds major source threshold levels.
5.3
Non-Applicability of Regulations of Concern
None
5.4
Source—Wide Operational and Production Limits and Work Practices
In addition to the source—wide requirements in the Standard
Permit Conditions in Section 9, the Permittee shall fulfill the
following source—wide operational and production limitations
and/or work practice requirements:
None
5.5
Source—Wide Emission Limitations
5.5.1
Permitted Emissions for Fees
The annual emissions from the source,
not considering
insignificant activities as addressed by Section 3.0 of
this permit, shall not exceed the following limitations.
The overall source emissions shall be determined by adding
emissions from all emission units.
Compliance with these
limits shall be determined on a calendar year basis.
These limitations
(Condition 5.5.1) are set for the
purpose of establishing fees and are not federally
enforceable.
Permitted Emissions of Regulated Pollutants
Pollutant
Tons/Year
Volatile Organic Material
(VOM)
24.50
Sulfur Dioxide
(SO2)
———
Particulate Matter
(PM)
0.60
Nitrogen Oxides
(NOw)
HAP,
not included in VOM or PM
--
Total
25.10
5.5.2
Emissions of Hazardous Air Pollutants
Source—wide emission limitations for HAP5 as listed in
Section 112(b)
of the CAR are not set.
This source is
considered to be a major source of HAP5.
5.5.3
Other Source-Wide Emission Limitations
Other source—wide emission limitations are not set for
this source pursuant to either the federal rules for
Prevention of Significant Deterioration
(PSD),
40 CFR
52.21,
Illinois EPA rules
for Major Stationary Sources
13
Construction and Modification,
35 IAC Part 203, or Section
502 (b) (10)
of the CAR.
However, there may be unit
specific emission limitations set forth in Section 7 of
this permit pursuant to these rules.
5.6
General Recordkeeping Requirements
5.6.1
Emission Records
The Permittee shall maintain records of the following
items for the source to demonstrate compliance with
Condition 5.5.1, pursuant to Section 39.5(7) (b)
of the
Act:
Total annual emissions on a calendar year basis for
the emission units covered by Section
7
(Unit
Specific Conditions)
of this permit.
5.6.2
Records for VOM and HAP Emissions
The Permittee shall maintain records of the following
items for the source to quantify annual VOM and HAP
emissions, so as to demonstrate compliance with the annual
emission limits in Condition 5.5:
a.
Aggregate monthly VOM emissions from emission units
included in Section 7 of this permit; and
b.
Aggregate monthly HAP emissions from emission units
included in Section 7 of this permit, calculated as a
fraction of VOM emissions according to vapor weight
percent.
5.6.3
~ecords
for Operating Scenarios
N/A
5.6.4
Retention and Availability of Records
a.
All records and logs required by this permit shall be
retained for at least five years from the date of
entry
(unless a longer retention period is specified
by the particular recordkeeping provision herein),
shall be kept at a location at the source that is
readily accessible to the Illinois EPA or TJSEPA,
and
shall be made available for inspection and copying by
the Illinois EPA or USEPA upon request.
b.
The Permittee shall retrieve and print,
on paper
during normal source office hours, any records
retained in an electronic format
(e.g., computer)
in
response to an Illinois EPA or USEPA request for
records during the course of a source inspection.
14
5.7
General Reporting Requirements
5.7.1
General Source—Wide Reporting Requirements
The Permittee shall promptly notify the Illinois EPA,
Compliance Section,
of deviations of the source with the
permit requirements as follows, pursuant to Section
39.5(7) (f) (ii) of the Act.
Reports shall describe the
probable cause of such deviations, and any corrective
actions oi~preventive measures taken.
5.7.2
Annual Emissions Report
The annual emissions report. required pursuant to Condition
9.7 shall contain emissions information for
the previous
calendar year.
5.7.3
Annual Reporting of
HAP
Emissions
The Permittee shall submit an annual report to the
Illinois EPA, Compliance Section, on HAP emissions from
the source.
This may be included in the annual emissions
report required pursuant to Condition 9.7.
5.8
General Operational Flexibility/Anticipated Operating Scenarios
N/A
5.9
General Compliance Procedures
5.9.1
General Procedures for Calculating Emissions
Compliance with the source—wide emission limits specified
in Condition 5.5 shall be based on the recordkeeping and
reporting requirements of Conditions
5.6 and 5.7,
and
compliance procedures in Section 7
(Unit Specific
Conditions) of this permit.
a.
For the purpose of estimating HAP emissions from
equipment at the source,
the vapor weight percent of
each HAP for each organic liquid times the VOM
emissions contributed by that organic liquid is
acceptable.
5.9.2
Compliance Plan/Schedule of Compliance
To achieve compliance with applicable limitations of this
permit,
the Permittee shall follow a schedule of
compliance consistent with the compliance plan required by
Section 39,5(5) (d)
of the Act.
Such compliance plan shall
describe how each emission unit will comply with all
applicable requirements
.‘
The schedule of compliance as
required by Section 39.5(7) (p) (iii) of the Act is in
Condition 7.1.13 of this permit.
15
6.0
EMISSIONS REDUCTION MARKET SYSTEM
(ERNS)
6.1
Description of ERMS
The ERMS is a “cap and trade” market system for major stationary
sources located in the Chicago ozone nonattainment area.
It is
designed to reduce VOM emissions from stationary sources to
contribute to reasonable further progress toward attainment,
as
required by Section 182(c)
of the CAR.
The ERNS addresses VOM emissions during a seasonal allotment
period from May
1 through September 30.
Participating sources
must hold “allotment trading units”
(ATUs)
for their actual
seasonal VOM emissions.
Each year participating sources are
issued ATTJs based on allotments set in the sources’
CAAPP
permits.
These allotments are established from historical VON
emissions or “baseline emissions” lowered to provide the
emissions reductions from stationary sources required for
reasonable further progress.
By December 31 of each year,
the end of the reconciliation period
following the seasonal allotment period, each source should have
sufficient ATUs in its transaction account to cover its actual
VOM emissions during the preceding season.
A transaction
account’s balance as of December 31 will include any valid ATU
transfer agreements entered into as of December 31 of the given
year, provided such agreements are promptly submitted to the
Illinois EPA for entry into the transaction account database.
The Illinois EPA will then retire ATU5 in sources’
transaction
accounts in amounts equivalent to their seasonal emissions.
When
a source does not appear to have sufficient ATU5 in its
transaction account,
the Illinois EPA will issue
a notice to the
source to begin the process for Emissions Excursion Compensation.
In addition to receiving ATUs pursuant to their allotments,
participating sources may also obtain ATU5 from the market,
including ATU5 bought from other participating sources and
general participants in the ERMS that hold ATU5
(35 IAC 205.630)
andATU5 issued by the Illinois EPA as a consequence of VON
emissions reductions from an Emissions Reduction Generator or an
Intersector Transaction
(35 IAC 205.500 and 35 IAC 205.510).
During the reconciliation period,
sources may also buy ATU5 from
a secondary reserve of ATUs managed by the Illinois EPA, the
“Alternative Compliance Market Account”
(ACMA)
(35 IAC 205.710).
Sources may also transfer or sell the ATU5 that they hold to
other sources or participants
(35 IAC 205.630).
6.2
Applicability
This permit is issued based on this source’s status under the
Emissions Reduction Market System
(ERMS),
35 IAC Part 205, being
resolved as part of an ongoing enforcement inquiry.
(See also
Condition 7.1.13)
16
6.3
Recordkeeping and Reporting
a.
The Permittee shall maintain the following records to
allow the confirmation of actual VON emissions during the
seasonal allotment period:
i.
Records of operating data and other information for
each individual emission unit or group of related
emission units at the source,
as specified in
Sections
5 and
7 of this permit,
as appropriate, to
determine actual VON emissions during the seasonal
allotment period;
ii.
Records of the VOM emissions,
in tons, during the
seasonal allotment period, with supporting
calculations,
for each individual emission unit or
group of related emission units
at the source,
determined in accordance with the procedures
specified in Sections
5 and
7 of this permit; and
iii.
Total VON emissions from the source, in tons,
during
each seasonal allotment period, which shall be
compiled by November .30 of each year.
17
7.0
UNIT SPECIFIC CONDITIONS
7.1
Polyester Resin Product Manufacturing
7.1.1
Description
Oasis Industries,
Inc., manufactures plastic plumbing
fixtures.
The manufacturing process is comprised of
fiberglass/resin spray lay—up booths with particulate
matter filter systems, a gelcoat spray lay—up booth with
particulate matter filter system,
a grinding booth with a
cartridge filter collection
system,
a curing oven,
and
associated cleanup operations.
The resin materials used in this industry are generally
referred to as thermosetting resins.
The thermosetting
polyester resins used are complex polymers resulting from
the cross—linking reaction of a liquid unsaturated resin
with a vinyl type monomer, most commonly styrene or a
styrene/methyl methacrylate
(MMA) blend used for some gel
coats.
Acrylic Process
(Line
1)
A thermoform acrylic sheet is clamped into a holding frame
and heated to 320—350 °Fand then vacuum formed into the
shape of a bathtub.
After the sheet
(shell) has cooled
enough to retain its shape, the shell is placed onto a
holding fixture and is ready for its coat of polyester
resin.
The final layers of fiberglass/resin/filler are sprayed
onto the acrylic shell and hand rolled down against the
shell.
After two—hour cure time for the final coat,
the
fiberglass re—enforced acrylic shell is removed from its
holding fixture and a pre-made leveling base is bonded to
the bottom of the tub.
After
a thirty minute cure time,
the tub is moved into the grinding booth and the tub deck
is ground to a finished deck height to accommodate
standard installation methods as applied in new house
construction.
The next work station is a buffing/polishing area where
any scratches or defects that may have occurred at one of
the previous work stations are fixed.
At a drilling
station,
the proper whirlpool jet hole configuration is
drilled through the side wall of the bathtub and hydro
jets are installed on the tub.
Then the pump and piping
to the hydro jets are installed by cutting rigid PVC pipe
to proper length and heating to bend into the shape
necessary.
The last step before crating the whirlpool
bathtub for shipment is to water test each tub and final
inspect the appearance of the finished product.
18
Miratec or Gel Coat Process
(Line
2)
The Miratec or Gel coat process differs from the Acrylic
process in how the outer shell is made.
In the Miratec
process a gel coat is sprayed onto a form.
The gel coat
is allowed to cure before the
skin and final coats are
sprayed on.
The grinding and buffing/polishing process to
finish the bath fixture is essentially the same as for the
Acrylic process and uses the same work stations.
7.1.2
List of Emission Units and Air Pollution Control Equipment
Emission
Unit
Description
Emission Control
Equipment
EV—1
Fiberglass Spray—Up
Chop_Station_#1
Filter
EV-2
Fiberglass Spray-Up
Chop Station #2
Filter
EV-3
Fiberglass Spray—Up
Chop_Station_#3
Filter
EV—ll
Gelcoat Spray Booth
Filter
EV—12
Skin Coat Spray Booth
Filter
EV—13
Final Coat Fiberglass
Spray-Up Booth #13
Filter
EV—l4
Final Coat Fiberglass
Spray-Up Booth #14
Filter
7.1.3
Applicability Provisions and Applicable Regulations
a.
The “affected polyester resin product manufacturing
processes” for the purpose of these unit—specific
conditions, are processes for manufacturing polyester
resin plastic products, as described in Conditions
7.1.1 and 7.1.2.
Emission Units EV-1,
EV-2,
and EV—3
constitute Line 1 and emission Units EV-11, EV-l2,
EV—13,
and EV-14 constitute Line 2.
b.
The affected polyester resin product manufacturing
processes are subject to 35 IAC Section 218.301,
which provides that no person shall cause or allow
the discharge of more than 3.6 kg/hr
(8 lb/hr)
of
organic material into the atmosphere from any
emission unit, except as provided in 35 IAC 218.302
and with the following exception:
if no odor nuisance
exists the limitation shall apply only to
photochemically reactive material.
c.
The affected polyester resin product manufacturing
processes are subject to 35 IAC 218 Subpart CC:
Polyester Resin Manufacturing Process.
The
requirements of 35 IAC 218 Subpart CC shall apply to
a source’s polyester resin products manufacturing
process emission units and associated handling of
materials,
cleanup activity, and formulation activity
35
IAC 218.660 (a) (2).
19
d.
The affected polyester resin product manufacturing
processes are subject to 35 IAC 212.321,
which
provides
that:
No person shall cause or allow the emission of
particulate matter into the atmosphere in any one
hour period from any new process emission unit,
either alone or in combination with the emission of
particulate matter from all other similar process
emission units for which construction or modification
commenced on or after April 14,
1972,
at a source or
premises, exceeds the allowable emission rates
specified in subsection
(c)
of 35 IAC 212.321
(See
also Attachment
2)
35
IAC 212.321(a).
7.1.4
Non—Applicability of Regulations of Concern
a.
This permit is issued based on the affected polyester
resin product manufacturing processes not being
subject to 35 IAC 218.204, because the affected
polyester resin product manufacturing processes does
apply coating to a substrate included in this
regulation.
b.
This permit is issued based on the affected polyester
resin product manufacturing processes not being
subject to 35 IAC 218 Subpart PP: Miscellaneous
Fabricated Product Manufacturing Process, because the
requirements of 35 IAC Subpart PP shall not apply to
a source’s miscellaneous formulation manufacturing
process emission units which are included within the
category specified by 35 IAC 218 Subpart CC
35
IAC
218.920(b) (2).
c.
The affected polyester resin product manufacturing
processes are not subject to 40 CFR
63,
Subparts U
and JJJ: National Emission Standards for Hazardous
Air Pollutants: Group
I and IV Polymers and Resins,
because the manufacture of polyester products is not
included in these regulations.
7.1.5
Operational And Production Limits
And
Work Practices
a.
Every owner or operator of an affected polyester
resin product manufacturing process shall comply with
any of the following operating requirements below:
i.
Use polyester resin material with a monomer
content as follows:
A.
For polyester resin materials used for
products requiring corrosion resistant or
fire retardant materials,
a monomer
content of no more than 48
by weight as
applied
35
IAC 218.666(a) (1) (A) (i)
~
20
B.
For polyester resin materials for
products requiring a tensile strength of
10,000 psi or more,
including tooling
resins,
a monomer content of no more than
48
by weight as applied
35
IAC
218.666(a) (1) (A) (ii);
C.
For clear gel coat,
a monomer content of
no more than 50
by weight as applied
35
IAC 218.666(a) (1)
(A) (iii);
D.
For other pigmented gel coats,
a monomer
content of no more than 45
by weight as
applied
35
IAC 218.666 (a)
(1) (A) (iv);
or
E.
For all other polyester resin materials,
a monomer content of no more than 35
by
weight as applied
35
IAC
218.666 (a) (1) (A) (v)
ii.
Use any materials or processes that are
demonstrated to the satisfaction of the
Illinois EPA to achieve VON emission levels
equivalent to any of the above. This
alternative must be approved by the Illinois
EPA and the USEPA in a federally enforceable
permit or as a SIP revision
35
IAC
218.666(a) (1) (D).
b.
For spraying operations, in addition to the
requirements specified in Condition 7.1.5(a),
use
only high—volume low pressure
(HVLP), airless,
air—
assisted airless,
or electrostatic spray equipment,
except for touch—up and repair using a hand—held,
air—atomized spray gun which has a container for
polyester resin material as part of the gun
35
IAC
218.666(a) (2).
c.
Any owner or operator of an affected polyester resin
product manufacturing process shall use closed
containers for all polyester resin materials,
cleaning materials which contain VON (including waste
cleaning materials),
and other materials that contain
VON (including waste resin materials)
in such
a
manner as to effectively control VON emissions to the
atmosphere and in accordance with the practices
described in the certification pursuant to 35 IAC
218.672(b)
(2) (A)
35
IAC 218.666(b):
21
d.
Any
owner or operator of an affected polyester resin
product manufacturing process which formulates
polyester resin material at the source shall comply
with the following operating requirements:
i.
A cover
shall be in place on any tank,
vat,
or
vessel with a capacity greater than 7.5 liters
(2 gallons),
including a container in which
polyester resin materials are delivered to the
source, while polyester resin materials are
being formulated.
The cover shall:
A.
Completely cover the tank,
vat,
or vessel
opening except for an opening no larger
than necessary to allow for safe
clearance for a mixer shaft
35
IAC
218.666(c) (1) (A);
B.
Extend at least 1.27 cm
(0.5 inch) beyond
the outer rim of the opening or be
attached to the rim
35
IAC
218.666(c) (1) (B);
C.
Remain closed except when adding or
removing material or when sampling or
inspection procedures require access
35
IAC 218.666(c)
(1) (C);
and
D.
Be maintained in good condition such
that, when in place,
the cover maintains
contact with the rim of the opening for
at least 90
of the circumference of the
rim
35
IAC 218.666(c)
(1) (D).
ii.
Carry out emissions shall be minimized when a
mixer used for formulation of polyester resin
material is being removed from a tank,
vat,
or
vessel containing polyester resin material by
allowing the material retained on the mixer
blades to drain back into the tank,
vat,
or
vessel before the mixer is completely removed
from the tank,
vat, or vessel
35
IAC
218.666(c) (2).
e.
Any owner or operator of affected polyester resin
product manufacturing processes which as a group use
more than
4 gallons per day of cleaning materials
which contain more than 200 grams of VOM per liter
(1.7 pound per gallon)
shall use
a solvent recovery
system for such materials.
Solvent recovery may be
done at the source or by using an off—site commercial
solvent recovery service.
The waste residue from a
solvent recovery system located at the source shall
not contain more than 20
VON by weight
35
IAC
218.666(d)
.
22
f.
The Permittee shall operate, maintain,
and replace
the filters and bag house in a manner that assures
compliance with the conditions of this section.
An
adequate inventory of spare filters shall be
maintained.
7.1.6
Emission Limitations
In addition to Condition 5.2.2 and the source wide
emission limitations in Condition
5.5,
the affected
polyester resin product manufacturing processes are
subject to the following:
a.
Emissions from the affected polyester resin product
manufacturing processes shall not exceed the
following limits:
VOM Emissions
Emission Unit
(Ton/Mo)
(Ton/Yr)
Line 1
1.31
15.70
Line 2
0.74
8.80
Totals
2.05
24.50
These limits are based on emission factors, material
usage,
and resin VOM content information provided in
the construction permit applications for each line.
Compliance with annual limits shall be determined on
a monthly basis from the
sum
of the data for the
current month plus the preceding 11 months
(running
12 month total)
T1R.
The above limitations contain revisions to previously
issued Permits 97070058 and 98020084.
The source has
requested that the Illinois EPA establish conditions
in this permit that allow various refinements from
the conditions of the aforementioned permits.
Specifically,
the separate emission limits for Line 2
activities were combined into a single emission
limit,
with no change in the total amount of the
limitation.
As part of this revision, the associated
operating limitations in the aforementioned permits
were not transferred into this CAAPP permit.
(See
also Condition 7.1.13)
T1R.
7.1.7
Testing Requirements
a.
Testing Methods
i.
The VON content of fresh cleaning materials
shall be determined from supplier data or by
sampling and analysis using USEPA Reference
Method 24
35
IAC 218.668(a) (1).
23
ii.
The VOM content of waste residue from a
solvent recovery system shall be determined by
sampling and analysis using USEPA Reference
Method 24
35
IAC 218.668 (a) (2).
iii.
The monomer content of polyester resin
materials shall be determined:
A.
From supplier data and operating data
35
IAC 218.668 (a) (3) (A);
B.
By sampling and analysis by the methods
set forth in SCAQMD Method 312-91
35
IAC 218.668 (a) (3) (B);
or
C.
By site—specific sampling and analysis
methods approved by the Illinois EPA and
USEPA in a federally enforceable permit
35
IAC 218.668 (a) (3) (C).
iv.
The weight loss from a vapor suppressed
polyester resin material per square meter of
exposed surface area shall be determined:
A.
From supplier data and operating data
35
IAC 218.668 (a) (5) (A);
B.
By sampling and analysis by the methods
set forth in SCAQMD Method 309-91
35
IAC 218.668 (a) (5) (B);
or
C.
By site—specific sampling and analysis
methods approved by the Illinois EPA and
USEPA in a federally enforceable permit
35
IAC 218.668 (a) (5) (C).
v.
In the event of a difference between data
obtained by sampling and analysis and other
data,
the data from sampling and analysis
shall govern
35
IAC 218.668(a) (6).
b.
When in the opinion of the Illinois EPA it is
necessary to conduct sampling and analysis to
demonstrate compliance with 35 IAC 218.668, the owner
or operator of a polyester resin products
manufacturing process subject to the i-equirements of
35 IAC 218 Subpart CC,
shall at his own expense,
conduct such sampling and analysis in accordance with
the applicable test methods and procedures specified
in 35 IAC 218.668(a)
(see also Condition 7.1.7(a)).
The Illinois EPA’s decision to invoke this subsection
maybe based on such factors including, but not
limited to,
a change in operation of the polyester
resin products manufacturing process,
or a reasonable
24
belief that a previous test resulted in erroneous
data
35
IAC 218.668(b).
c.
Nothing in Condition 7.1.7
shall limit the authority
of USEPA pursuant to the Clean Air Act,
as amended,
to require sampling and analysis
35
IAC
218.688(c).
7.1.8
Monitoring Requirements
a.
The Permittee shall perform scheduled inspections to
confirm the proper use of closed containers; covers
on vats, vessels,
and tanks;
and proper drainage of
mixers, as required by Conditions 7.1.5(c)
and
(d).
b.
The Permittee shall visually inspect the filters and
bag house to check for air flow drop on a regular
basis in order to ensure proper operation of the
filters and the need for replacement.
7.1.9
Recordkeeping Requirements
In addition to the records required by Condition 5.6,
the
Permittee shall maintain records of the following items
for the affected polyester resin product manufacturing
processes to demonstrate compliance with Conditions 5.5.1
and 7.1.5 through 7.1.7, pursuant to Section 39.5(7) (b)
of
the Act:
a.
The owner or operator of an affected polyester resin
product manufacturing process shall collect and
record the following information to maintain a
complete record of all polyester resin materials
which are used by such polyester resin products
manufacturing process:
i.
The name and identification number of each
polyester resin material used in the process
35
IAC 218.672 (a)
(2) (A);
ii.
The particular operating requirement with
which each polyester resin material will
comply,
the actual monomer content of the
material
(percent by weight) and other
relevant data to show compliance with the
operating requirement,
including:
A.
For each polyester resin material which
is classified as a material used for
products requiring corrosion resistant or
fire retardant materials,
a material used
for products requiring tensile strength
of 10,000 psi or more, or a clear gel
coat,
justification for such
classification if the material is applied
to comply with the monomer content
limitation of Condition 7.1.5(a)
(i) (A),
25
(B), or
(C), respectively
35
IAC
218.672 (a) (2) (B) (i);
B.
For each polyester resin material which
is approved by the Illinois EPA and the
USEPA in a federally enforceable permit
or as a SIP revision so as to comply with
Condition 7.1.5(a) (ii),
information
showing the VON emission level which is
achieved and the VOM emissions which
would result from compliance with
Condition 7.1.5(a) (i)
35
IAC
218.672 (a) (2) (B) (iv).
iii.
A description of the testing which was
performed, in accordance with Condition 7.1.7,
to determine the monomer content of polyester
resin materials and the information in 35 IAC
218.672 (a) (1) (C) (ii),
(iii)
and
(iv)
and
(a) (1) (D), including data, calculations,
and
descriptions and results of the sampling and
analysis that the owner. or operator has relied
upon to show compliance with Condition
7.1.5(a)(i)
35
IAC 218.672(a) (2) (C).
iv.
The processes and applications for which each
polyester resin material may be used in
compliance with applicable operating
requirements,
including:
A.
For each polyester resin material which
is classified as a material used for
products requiring corrosion resistant or
fire retardant material or a material
used for products requiring tensile
strength of 10,000 psi or more which is
applied to comply with the monomer
content limitation of Condition
7.1.5(a)
(i) (A)
or
(B), respectively,
the
required products or circumstances
for
the materials’ use
35
IAC
218.672
(a)
(2)
(D)
(i)
B.
For each polyester resin material which
is approved by the Illinois EPA and
approved by the USEPA as a SIP revision
so as to comply with Condition
7.1.5(a) (ii),
the required process
operating conditions or product
specifications
35
IAC
218.672 (a) (2)
(D) (iv).
v.
For each polyester resin material which is
applied in a spraying operation,
the type of
spray equipment with which the material will
26
be applied so as to comply with Condition
7.1.5(b)
35
IAC 218.672(a) (2) (E).
b.
The owner or operator of an affected polyester resin
product manufacturing process shall collect and
record all of the following information each day for
each process and maintain the information at the
source.
i.
The name,
identification number and amount of
each polyester resin material applied on each
process
35
IAC 218.672 (a) (3) (A);
and
ii.
The specific data identified pursuant to
Condition 7.1.9(a) (iv) to confirm that the
polyester resin material was applied in such a
manner that it complied with the applicable
operating requirement
35
IAC
218.672 (a) (3) (B).
c.
The owner or operator of an affected polyester resin
product manufacturing process shall collect and
record all the following information and maintain the
information at the source:
i.
The date, time and duration of scheduled
inspections performed to confirm the proper
use of closed containers to control VON
emissions, and any instances of improper use
of closed containers, with descriptions of
actual practice and corrective action taken,
if any
35
IAC 218.672(b) (2) (A);
ii.
Information on a daily basis confirming the
proper use of a recovery system if one is
required or is used,
including operation of a
recovery system at the source to produce a
waste residue that is 20
or less VON by
weight and information identifying any
observation of noncompliance
35
IAC
218.672(b) (2) (B);
and
iii.
Information on a daily basis on the use of
cleaning materials which contain more than 200
grams of VOM per liter
(1.7 pound per gallon)
if a recovery system is not required or is not
used.
This information shall include the
name, identification number, amount used and
VON content of each such cleaning material
35
IAC 218.672(b) (2) (C).
d.
The owner or operator of an affected polyester resin
product manufacturing process that formulates
polyester resin material at the source shall collect
27
and record all the following information and maintain
the information at the source:
i.
The date,
time,
and duration of scheduled
inspections to confirm the proper use and
maintenance of covers on vats, vessels, and
tanks and proper drainage of mixers and any
instance of improper use, with description of
actual practice and corrective action
taken,
if any
35
IAC 218.672(c)
(2) (A);
and
ii.
A maintenance log for covers on vats,
vessels,
and tanks, detailing all routine and non—
routine maintenance performed and initial use
of new covers, including dates of such
activities
35
IAC 218.672(c) (2) (B).
e.
The Permittee shall also keep the following records
at the source.
i.
Name or identification number and monomer
content
(e.g., percent by weight of styrene)
of each polyester resin mixture and vapor—
suppressed on nonvapor—suppressed resin or gel
coat;
ii.
VOM content
(weight percent)
of any solvent
and VOM-containing material used in the plant;
iii.
Usage of solvents, raw polyester styrene resin
or other hybrid resins,
and other VON-
containing materials (lb/month and lb/year);
iv.
Maximum process weight rate of materials used
in the process
(lb/hr);
V.
Amount of cleanup solvent sent off site for
disposal,
if credit for emissions reduction is
counted (lb/month and lb/year);
vi.
The operating schedule of the affected
polyester resin product manufacturing
processes;
vii.
VON emissions of the affected polyester resin
product
manufacturing
processes
(ton/month
and
ton/year); and
viii.
Results of filter inspections and dates of
replacements made.
7.1.10
Reporting Requirements
a.
The Permittee shall promptly notify the Illinois EPA,
Compliance Section,
of deviations of the affected
28
polyester resin product manufacturing processes with
the permit requirements as follows, pursuant to
Section 39.5(7) (f) (ii)
of the Act.
Reports shall
describe the probable cause of such deviations,
and
any corrective actions or preventive measures taken.
The owner or operator of an affected polyester resin
product manufacturing process shall notify the
Illinois
EPA:
i.
Of any violation of the operating requirements
of 35 IAC 218 Subpart CC by sending a copy of
such record to the Illinois EPA within 30 days
following the occurrence of the violation
35
IAC 218.672 (a) (4) (A);
ii.
Of a violation of the requirements of 35 IAC
218 Subpart CC with respect to handling
practices and solvent recovery for cleaning
materials by sending a copy of all such
records to the Illinois EPA within 30 days
following the calendar quarter in which such
violation occurred
35
IAC 218.672(b)
(3) (A);
and
iii.
Of a violation of the requirements of 35 IAC
Subpart CC with respect to formulation of
polyester resin material by sending a copy of
all such records to the Illinois EPA within
30
days following the calendar quarter in which
such violation occurred
35
IAC
218.672(c) (3) (A).
iv.
If there is an exceedance of the requirements
of Condition 7.1.5 or 7.1.6 as determined by
the records required by this permit, the
Permittee shall submit a report to the
Illinois EPA’s Compliance Section in
Springfield,
IL, within 30 days after the
exceedance.
The report shall include the
emissions released in accordance with the
recordkeeping requirements,
a copy of the
relevant
records,
and a description of the
exceedance or violation and efforts to reduce
emissions and future occurrences.
b.
The owner or operator of an affected polyester resin
product manufacturing process shall notify the
Illinois EPA:
i.
At least 30 calendar days before changing the
method of compliance with the 35 IAC 218
Subpart CC from one operating requirement
among Condition 7.1.5(a) (i) to another
29
operating requirement,
of compliance with all
requirements of 35 IAC 218.672 (a) (1).
Upon
changing the method of compliance from one
operating requirement to another,
the owner or
operator shall comply with all applicable
requirements
35
IAC 218.672(a)
(4) (B);
ii.
Within 30 calendar days of changing the
handling
practices
for
polyester
resin
materials,
cleaning
materials
and
waste
materials or changing source practice with
respect to a solvent recovery system for
cleaning materials, describing the change
35
IAC 218.672(b) (3) (B);
and
iii.
Within 30 calendar days of changing the
handling practices for formulation of
polyester resin materials, describing the
change
35
IAC 218.672(c)
(3) (B).
c.
At least
30 calendar days before changing the method
of compliance for an affected polyester resin product
manufacturing
operation, including the applicable
emission factors and calculation methods indicated in
Condition 7.1.12,
the Permittee shall certify to the
Illinois EPA that the polyester resin plastic product
manufacturing operation will be in compliance with
the applicable limitation of Condition 7.1.6
consistent with the requirements of the compliance
certification reports of Condition 9.8.
7.1.11
Operational Flexibility/Anticipated Operating Scenarios
The Permittee is authorized to make the following physical
or operational change with respect to the affected
polyester resin product manufacturing process without
prior notification to the Illinois EPA or revision of this
permit.
This condition does not affect the Permittee’s
obligation to properly obtain a construction permit in a
timely manner for any activity constituting construction
or modification of the source, as defined in 35 IAC
201.102:
a.
Usage of various resin,
gel coat,
or solvent
materials without exceeding monomer content
(
by
weight),
operational limits, and VON emission limits
in Conditions 5.5.1, 7.1.5, and 7.1.6 and provided
that the materials are tested in accordance with the
conditions of this section.
b.
The Permittee is authorized to relocate emission
units and parts of emission units to any location
within the permitted source.
Notwithstanding
Condition 9.11, the Permittee may temporarily remove
emission units or parts of emission units from the
permitted source for purposes of maintenance,
repair,
30
and testing without voiding the permit for the
operation or activity.
7.1.12
Compliance Procedures
Compliance with the limitations of this Section shall be
determined by the recordkeeping requirements in Condition
7.1.9 and the emission calculation methodology described
below:
a.
Emissions of VON from monomer contained in resin
and/or gel coat:
Monomer Emission
(lb)
=
Material usage
(ton)
*
E
UEF
(lb/ton)
Where:
~
UEF
=
The sum of all Unified Emission Factors
for all monomers present in the material.
The Unified Emission Factors
(UEF), listed in Attachment
3,
are from “Technical Discussion of the Unified
Emission Factors for Open Molding of Composites”
(CFA,
April 1999)
.
Emissions shall be based on the actual
monomer content and application method of the material.
Monomer content includes the monomer content as supplied
plus any extra monomer added by the operator, but before
the addition of other additives such as powders and
fillers.
The Permittee may use other emission factors
or data from source—specific testing if approved by the
Illinois EPA.
b.
Emissions from solvent usage
(e.g., cleaning
materials):
VON Emissions
(lb)
=
Solvent Usage
(gal)
*
Solvent
Density
(lb/gal)
-
Solvent
Sent Off Site for Disposal
(lb)
c.
Compliance with the annual usage and VON limitations
in Conditions 7.1.5 and 7.1.6 shall be determined as
follows:
Compute the weight of each material
(e.g.,
raw resin or gelcoat)
used each month by the 15th of
the following month.
By the 15th of each month, add
the monthly material usage used for the 12 previous
months to obtain the annual usage of each material.
Annual emissions shall be determined as the sum of
the products of monthly emission rates for each resin
and gelcoat,
as determined above,
and the hours of
operation over a consecutive 12 month period.
For
purposes of calculating emission, the Permittee may
use the procedures above for any portion of the 12
31
month period that occurred prior to the issuance of
this
permit.
d.
Compliance with the VON emission limit in Condition
7.1.3(b)
shall be determined by the maximum process
weight rate
(lb/hr)
of VON-containing materials and
the emission determination methods of 7.1.12(a)
and
(b).
e.
Compliance with the operational and control
requirements Condition 7.1.3(c) and 7.1.5 shall be
determined
by
the
recordkeeping
and
reporting
requirements in Conditions 7.1.9 and 7.1.10.
f.
Compliance with the PM emission limits in Condition
7.1.3(d)
is assured and achieved by the proper
operation and maintenance of the filters and bag
house as required by Conditions 7.1.5 and 7.1.8 and
the work—practices inherent in the operation of an
affected polyester resin product manufacturing
process.
7.1.13
Compliance Plan/Schedule of Compliance
a.
The Permittee was sent Violation Notice A-2002—00343
by the Illinois EPA for,
among other things,
allegedly failing to comply with the limits in
Permits 97070058 and 98020084, and the applicable
provisions of 35 IAC Part 203, Major Stationary
Sources Construction and Modification,
and 35 lAO
Part 205, Emissions Reduction Market System (ERMS),
for the affected polyester resin product
manufacturing processes.
As these applicable
requirements are not included in this permit and
cannot be included until the alleged violations are
resolved, the permit shield in Condition 8.1 does not
apply and the Permittee is not shielded from possible
enforcement actions initiated by either USEPA or the
Illinois EPA involving the above named emission units
or activities.
In addition,
compliance with this
permit does not serve as proof of compliance for
these emission units or activities.
b.
The Permittee shall comply with the following
schedule of compliance to address compliance with the
alleged violations of 35 IAC Parts 203:
I
Milestone
Timing
I
32
Milestone
Timing
Submit a proposal and
schedule for achieving
compliance with New
Source Review
No later than any schedule
established pursuant to
resolution of the pending
enforcement action
pertaining to the alleged
violations
Achieve full compliance
with the requirements of
New Source Review
following issuance of the
requisite permit(s)
No later than any schedule
established pursuant to
resolution of the pending
enforcement action
pertaining to the alleged
violations
c.
The Permittee shall continue to pursue
its status as
a participating
source
under
the
ERMS
with
an
allocation
of
Allotment
Trading Units
(ATU5).
The
Permittee shall promptly supply any information
requested by the Illinois EPA to support processing
of its ERMS application filed on January 21,
2003,
until and unless an appropriate request for revision
to this permit
is submitted that would result in the
source no longer being subject to requirements to
hold and retire ATUs for its seasonal VON emissions,
pursuant to 35 IAC Part 205.
d.
Submittal of Progress Reports
A Progress Report shall be submitted every six
months, beginning six months from the date of
issuance of this permit and ending upon the
achievement of compliance. The Progress Report shall
contain at least the following:
i.
The required timeframe for achieving the
milestone or action, and actual dates when
such milestone or action is achieved.
ii.
An explanation of why any required timeframe
was not met, and any preventive or corrective
measures adopted.
e.
The Permittee shall, if needed,
apply for revision of
this permit to address the resolution of any such
outstanding issue
(e.g.,
include a new compliance
schedule, identify appropriate applicable
requirements, establish new requirements)
33
8.0
GENERAL PERMIT CONDITIONS
8.1
Permit Shield
Pursuant to Section 39.5(7)
(j)
of the Act,
the Permittee has
requested and has been granted a permit shield.
This permit
shield provides that compliance with the conditions of this
permit shall be deemed compliance with applicable requirements
which were applicable as of the date the proposed permit for this
source was issued, provided that either the applicable
requirements are specifically identified within this permit, or
the Illinois EPA, in acting on this permit application,
has
determined that other requirements specifically identified are
not applicable to this source and this determination
(or
a
concise summary thereof)
is included in this permit.
This permit shield does not extend to applicable requirements
which are promulgated after December
11,
2002
(the date of
issuance of the draft permit) unless this permit has been
modified to reflect such new requirements.
8.2
Applicability of Title IV Requirements
(Acid Deposition Control)
This source is not an affected source under Title IV of the CAR
and is not subject to requirements pursuant to Title IV of the
CAR.
8.3
Emissions Trading Programs
No permit revision
shall be required for increases in emissions
allowed under any USEPA approved economic incentives, marketable
permits, emissions trading,
and other similar programs or
processes for changes that are provided for elsewhere in this
permit and that are authorized by the applicable requirement
Section
39.5(7) (o) (vii) of the Act.
8.4
Operational Flexibility/Anticipated Operating Scenarios
8.4.1
Changes Specifically Addressed by Permit
Physical or operational changes specifically addressed by
the Conditions of this permit that have been identified as
not requiring Illinois EPA notification may be implemented
without prior notice to the Illinois EPA.
8.4.2
Changes Requiring Prior Notification
The Permittee is authorized to make physical or
operational changes that contravene express permit terms
without applying for or obtaining an amendment to this
permit, provided that
Section
39.5(12) (a) (i)
of the
Act:
a.
The changes do not violate applicable requirements;
34
b.
The changes do not contravene federally enforceable
permit terms or conditions that are monitoring
(including test methods), recordkeeping,
reporting,
or compliance certification requirements;
c.
The changes do not constitute
a modification under
Title
I
of
the
CAR;
d.
Emissions will not exceed the emissions allowed under
this permit following implementation of the physical
or operational change;
and
e.
The Permittee provides written notice to the Illinois
EPA, Division of Air Pollution Control,
Permit
Section,
at least
7 days before commencement of the
change.
This notice shall:
i.
Describe the physical or operational change;
ii.
Identify the schedule for implementing the
physical or operational change;
iii.
Provide a statement of whether or not any New
Source Performance Standard
(NSPS)
is
applicable to the physical or operational
change and the reason why the NSPS does or
does not apply;
iv.
Provide emission calculations which
demonstrate that the physical or operational
change will not result in a modification; and
v.
Provide a certification that the physical or
operational change will not result in
emissions greater than authorized under the
Conditions of this permit.
8.5
Testing Procedures
Tests conducted to measure composition of materials, efficiency
of pollution control devices,
emissions from process or control
equipment, or other parameters shall be conducted using standard
test methods.
Documentation of the test date,
conditions,
methodologies,
calculations, and test results shall be retained
pursuant to the recordkeeping procedures of this permit.
Reports
of any tests conducted as required by this permit or as the
result of a request by the Illinois EPA shall be submitted as
specified in Condition 8.6.
35
8.6
Reporting Requirements
8.6.1
Monitoring Reports
If monitoring is required by any applicable requirements
or
conditions
of
this
permit,
a
report
summarizing
the
required
monitoring
results,
as
specified
in
the
conditions of this permit,
shall be submitted to the Air
Compliance Section of. the Illinois EPA every six months as
follows
Section
39.5(7) (f)
of the Act:
Monitoring Period
Report Due Date
January
—
June
September 1
July
-
December
March
1
All instances of deviations from permit requirements must
be clearly identified in such reports.
All such reports
shall be certified in accordance with Condition 9.9.
8.6.2
Test Notifications
Unless otherwise specified elsewhere in this permit,
a
written test plan for any test required by this permit
shall be submitted to the Illinois EPA for review at least
60 days prior to the testing pursuant to Section
39.5(7) (a) of the Act.
The notification shall include at
a
minimum:
a.
The name and identification of the affected unit(s);
b.
The person(s) who will be performing sampling and
analysis and their experience with similar tests;
c.
The specific conditions under which testing will be
performed,
including a discussion of why these
conditions will be representative of maximum
emissions and the means by which the operating
parameters for the source and any control equipment
will be determined;
d.
The specific determination of emissions and operation
which are intended to be made,
including sampling and
monitoring locations;
e.
The test method(s)
which will be used,
with the
specific analysis method, if the method can be used
with different analysis methods;
f.
Any minor changes in standard methodology proposed to
accommodate the specific circumstances of testing,
with justification; and
36
g.
Any
proposed use of an alternative test method, with
detailed justification.
8.6.3
Test Reports
Unless otherwise specified elsewhere in this permit, the
results of any test required by this permit shall be
submitted to the Illinois EPA within
60 days of completion
of the testing.
The test report shall include at a
minimum
Section
39.5(7) (e)
(i)
of the Act:
a.
The name and identification of the affected unit(s);
b.
The date and time of the sampling or measurements;
c.
The date any analyses were performed;
d.
The name of the company that performed the tests
and/or analyses;
e.
The test and analytical methodologies used;
f.
The results of the tests including raw data,
and/or
analyses including sample calculations;
g.
The operating conditions at the time of the sampling
or measurements;
and
h.
The name of any relevant observers present including
the testing company’s representatives,
any Illinois
EPA or USEPA representatives, and the representatives
of the source.
8.6.4
Reporting Addresses
a.
The following addresses should be utilized for the
submittal of reports, notifications,
and renewals:
i.
Illinois EPA
-
Air Compliance Section
Illinois Environmental Protection Agency
Bureau of Air
Compliance Section
(NC 40)
P.O.
Box 19276
Springfield, Illinois
62794—9276
ii.
Illinois EPA
—
Air Regional Field Office
Illinois Environmental Protection Agency
Division of Air Pollution Control
9511 West Harrison
Des Plaines,
Illinois
60016
37
iii.
Illinois EPA
—
Air Permit Section
Illinois Environmental Protection Agency
Division of Air Pollution Control
Permit Section
(MC
11)
P.O.. Box 19506
Springfield, Illinois
62794—9506
iv.
USEPA Region 5
-
Air Branch
USEPA
(AE
-
17J)
Air
& Radiation Division
77 West Jackson Boulevard
Chicago,
Illinois
60604
b.
Unless otherwise specified in the particular
provision of this permit, reports shall be sent to
the Illinois EPA
-
Air Compliance Section with a copy
sent to the Illinois EPA
—
Air Regional Field Office.
8.7
Obligation to Comply with Title I Requirements
Any term,
condition,
or requirement identified in this permit by
T1,
T1R, or TiN is established or revised pursuant to 35 IAC Part
203 or 40 CFR 52.21
(“Title I provisions”) and incorporated into
this permit pursuant to both Section 39.5 and Title
I provisions.
Notwithstanding the expiration date on the first page of this
permit,
the Title
I conditions remain in effect pursuant to Title
I provisions until the Illinois EPA deletes or revises them in
accordance with Title
I procedures.
38
9.0
STANDARD
PERMIT
CONDITIONS
9.1
Effect of Permit
9.1.1
The issuance of this permit does not release the Permittee
from compliance with State and Federal regulations which
are part of the Illinois State Implementation Plan,
as
well as with other applicable statutes and regulations of
the United States or the State of Illinois or applicable
ordinances, except as specifically stated in this permit
and as allowed by law and rule
Section
39.5(7)
(j)
(iv) of
the Act.
9.1.2
In particular,
this permit does not alter or affect the
following:
a.
The provisions of Section 303
(emergency powers)
of
the CAR, including USEPA’s authority under that
Section;
b.
The liability of an owner or operator of a source for
any violation of applicable requirements prior to or
at the time of permit issuance;
c.
The applicable requirements of the acid rain program
consistent with Section 408(a)
of the CAR; and
d.
The ability of USEPA to obtain information from a
source pursuant to Section 114
(inspections,
monitoring, and entry) of the CAR.
9.1.3
Notwithstanding the conditions of this permit specifying
compliance practices for applicable requirements, any
person
(including the Permittee)
may also use other
credible evidence to establish compliance
or. noncompliance
with applicable requirements.
9.2
General Obligations of Permittee
9.2.1
Duty to Comply
The Permittee must comply with all terms and conditions of
this permit.
Any
permit noncompliance constitutes a
violation of the CAR and the Act, and is grounds for any
or all of the following:
enforcement action, permit
termination, revocation and reissuance, modification, or
denial of a permit renewal application
Section
39.5(7) (o) (i)
of the Act.
The Permittee shall meet applicable requirements that
become effective during the permit term in a timely manner
unless an alternate schedule
for compliance with the
applicable requirement is established.
39
9.2.2
Duty to Maintain Equipment
The Permittee shall maintain all equipment covered under
this permit in such a manner that the performance or
operation of such equipment shall not cause
a violation of
applicable requirements.
9.2.3
Duty to Cease Operation
No person shall
cause, threaten or allow the continued
operation of any emission unit during malfunction or
breakdown of the emission unit or related air pollution
control equipment if such operation would cause a
violation of an applicable emission standard, regulatory
requirement, ambient air quality standard or permit
limitation unless such malfunction or breakdown is allowed
by a permit condition
Section
39.5(6) (c)
of the Act.
9.2.4
Disposal Operations
The source shall be operated in such a manner that the
disposal of air contaminants collected by the equipment
operations,
or activities shall not cause
a violation of
the Act or regulations promulgated thereunder.
9.2.5
Duty to Pay Fees
The Permittee must pay fees to the Illinois EPA consistent
with the fee schedule approved pursuant to Section
39.5(18)
of the Act, and submit any information relevant
thereto
Section
39.5(7) (o) (vi)
of the Act.
The check
should be payable to “Treasurer, State of Illinois” and
sent to:
Fiscal Services Section,
Illinois Environmental
Protection Agency, P.O. Box 19276, Springfield, Illinois
62794—9276.
9.3
Obligation to Allow Illinois EPA Surveillance
Upon presentation of proper credentials and other documents, the
Permittee shall allow the Illinois EPA, or an authorized
representative to perform the following
Section
39.5(7) (a) and
(p) (ii)
of the Act and 415 ILCS 5/4:
a.
Enter upon the Permittee’s premises where an actual or
potential emission unit is located; where any regulated
equipment,
operation, or activity is located or where
records must be kept under the conditions of this permit;
b.
Have access to and copy,
at reasonable times, any records
that must be kept under the conditions of this permit;
c.
Inspect during hours of operation any sources,
equipment
(including monitoring and air pollution control
40
equipment), practices, or operations regulated or required
under
this
permit;
d.
Sample or monitor any substances or parameters at any
location:
i.
At reasonable times,
for the purposes of assuring
permit compliance;
or
ii.
As otherwise authorized by the CAR, or the Act.
e.
Obtain and remove samples of any discharge or emission of
pollutants authorized by this permit; and
f.
Enter and utilize any photogrhphic, recording,
testing,
monitoring,
or other equipment for the purposes of
preserving,
testing,
monitoring,
or
recording
any
activity,
discharge or emission
at
the
source
authorized
by
this
permit.
9.4
Obligation
to
Comply
with
Other
Requirements
The issuance of this permit does not release the Permittee from
applicable State and Federal laws and regulations,
and applicable
local ordinances addressing subjects other than air.pollution
control.
9.5
Liability
9.5.1
Title
This permit shall not be considered as in any manner
affecting the title of the premises upon which the
permitted source is located.
9.5.2
Liability of Permittee
This permit does not release the Permittee from any
liability for damage to person or property caused by or
resulting from the construction, maintenance, or operation
of the sources.
9.5.3
Structural Stability
This permit does not take into consideration or attest to
the structural stability of any unit or part of the
source.
9.5.4
Illinois EPA Liability
This permit in no manner implies or suggests that the
Illinois EPA
(or its officers,
agents or employees)
assumes any liability,
directly or indirectly,
for any
41
loss due to damage,
installation, maintenance, or
operation of the source.
9.5.5
Property Rights
This permit does not convey any property rights of any
sort,
or any exclusive privilege
Section
39.5(7) (o) (iv)
of the Act
9.6
Recordkeeping
9.6.1
Control Equipment Maintenance Records
A maintenance record shall be kept on the premises for
each item of air pollution control equipment.
As a
minimum, this record shall show the dates of performance
and nature of preventative maintenance activities.
9.6.2
Records of Changes in Operation
A record shall be kept describing changes made at the
source that result in emissions of a regulated air
pollutant subject to an applicable requirement, but not
otherwise regulated under this permit, and the emissions
resulting from those changes
section
39.5(12)
(b) (iv)
of
the Act.
9.6.3
Retention of Records
a.
Records of all monitoring data and support
information
shall be retained for a period of at
least
5 years from the date of the monitoring sample,
measurement, report,
or application.
Support
information includes all calibration and maintenance
records,
original strip—chart recordings for
continuous monitoring instrumentation,
and copies of
all reports required by this permit
Section
39.5(7) (e) (ii) of the Act.
b.
Other records required by this permit shall be
retained for a period of at least
5 years from the
date of entry unless a longer period is specified by
a particular permit provision.
9.7
Annual Emissions Report
The Permittee shall submit an annual emissions report to the
Illinois EPA,
Compl.iance Section no later than May
1 of the
following year,
as required by 35 IAC Part
254.
9.8
Requirements for Compliance Certification
Pursuant to Section 39.5(7) (p)
(v)
of the Act,
the Permittee shall
submit annual compliance certifications.
The compliance
42
certifications shall be submitted no later than Nay
1 or more
frequently as specified in the applicable requirements or by
permit condition.
The compliance certifications shall be
submitted to the
Air
Compliance Section,
Air Regional Field
Office,
and USEPA Region
5
—
Air Branch.
The addresses for the
submittal of the compliance certifications are provided in
Condition 8.6.4 of this permit.
a.
The certification shall include the identification of each
term or condition of this permit that is the basis of the
certification;
the compliance
status; whether compliance
was continuous or intermittent; the method(s) used for
determining the compliance status of the source, both
currently and over the reporting period consistent with
the conditions of this permit.
b.
All compliance certifications shall be submitted to USEPA
Region
5 in Chicago as well as to the Illinois EPA.
c.
All compliance reports required to be submitted shall
include a certification in accordance with Condition 9.9.
9.9
Certification
Any document
(including reports)
required to be submitted by this
permit shall contain a certification by a responsible official of
the Permittee that meets the requirements of Section 39.5(5)
of
the Act
Section
39.5 (7) (p)
(i)
of the Act.
An example
Certification by a Responsible Official is included as an
attachment to this permit.
9.10
Defense to Enforcement Actions
9.10.1
Need to Halt or Reduce Activity Not
a Defense
It shall not be
a defense for the Permittee in an
enforcement action that it would have been necessary to
halt or reduce the permitted activity in order to maintain
compliance with the conditions of this permit
Section
39.5(7) (o) (ii) of the Act.
9.10.2
Emergency Provision
a.
An emergency shall be an affirmative defense to an
action brought for noncompliance with the technology—
based emission limitations under this permit if the
following conditions are met through properly signed,
contemporaneous operating logs,
or other relevant
evidence:
i.
An emergency occurred as provided in Section
39.5(7) (k) of the Act and
the
Permittee
can
identify the cause(s)
of the emergency.
43
Normally, an act of God such as lightning or
flood is considered an emergency;
ii.
The permitted source was at the time being
properly
operated;
iii.
The
Permittee
submitted
notice
of
the
emergency
to
the
Illinois
EPA
within
two
working days of the time when emission
limitations were exceeded due to the
emergency.
This notice must contain a
detailed description of the emergency,
any
steps taken to mitigate emissions,
and
corrective actions taken; and
iv.
During the period of the emergency the
Permittee took all reasonable steps to
minimize levels of emissions that exceeded the
emission limitations,
standards, or
regulations in this permit.
b.
This provision is in addition to any emergency or
upset provision contained in any applicable
requirement.
This provision does not relieve a
Permittee of any reporting obligations under existing
federal or state laws or regulations.
9.11
Permanent Shutdown
This permit only covers emission units and control equipment
while physically present at the indicated source location(s)
Unless this permit specifically provides for equipment
relocation, this permit is void for the operation or activity of
any item of equipment on the date it is removed from the
permitted location(s)
or permanently shut down.
This permit
expires if all equipment is removed from the permitted
location(s), notwithstanding the expiration date specified on
this permit.
9.12
Reopening and Reissuing Permit for Cause
9.12.1
Permit Actions
This permit may be modified,
reopened, and reissued,
for
cause pursuant to Section 39.5(15) of the Act.
The filing
of a request by the Permittee for a permit modification,
revocation,
and reissuance,
or of a notification of
planned changes or anticipated noncompliance does not stay
any permit condition
Section
39.5(7) (o) (iii)
of the
Act.
44
9.12.2
Reopening and Revision
This permit must be reopened and revised if any of the
following occur
Section
39.5(15) (a)
of the Act:
a.
Additional requirements become applicable to the
equipment
covered
by
this
permit
and
three
or
more
years
remain
before
expiration
of
this
permit;
b.
Additional
requirements
become
applicable
to
an
affected source for acid deposition under the acid
rain program;
c.
The Illinois EPA or USEPA determines that this permit
contains a material mistake or inaccurate statement
when establishing the emission standards or
limitations, or other terms or conditions of this
permit;
and
d.
The Illinois EPA or USEPA determines that this permit
must be revised to ensure compliance with the
applicable requirements of the Act.
9.12.3
Inaccurate Application
The Illinois EPA has issued this permit based upon the
information submitted by the Permittee in the permit
application.
Any misinformation,
false statement or
misrepresentation in the application shall be grounds for
revocation under Section 39.5(15)
(b)
of the Act.
9.12.4
Duty to Provide Information
The Permittee shall furnish to the Illinois EPA, within
a
reasonable time specified by the Illinois EPA any
information that the Illinois EPA may request in writing
to determine whether cause exists for modifying,
revoking
and reissuing, or terminating this permit,
or to determine
compliance with this permit.
Upon request, the Permittee
shall also furnish to the Illinois EPA copies of records
required to be kept by this permit, or for information
claimed to be confidential,
the Permittee may furnish such
records directly to USEPA along with a claim of
confidentiality
Section
39.5(7) (o) (v)
of the Act.
9.13
Severability Clause
The provisions of this permit are severable, and should any one
or more be determined to be illegal or unenforceable,
the
validity of the other provisions shall not be affected.
The
rights and obligations of the Permittee shall be construed and
enforced as if this permit did not contain the particular
provisions held to be invalid and the applicable requirements
45
underlying these provisions shall remain in force
Section
39.5(7) (i)
of the Act.
9.14
Permit Expiration and Renewal
The right to operate terminates on the expiration date unless the
Permittee has submitted a timely and complete renewal
application. For a renewal to be timely it must be submitted no
later than 9 and no sooner than 12 months prior to expiration.
The equipment may continue to operate during the renewal period
until final action is taken by the Illinois EPA, in accordance
with the original permit conditions
Section
39.5(5) (1),
(n),
and
(o)
of the Act.
46
1b~i
(DIDtJW
10.0
ATTACHMENTS
10.1
Attachment
1
-
Example Certification by a Responsible Offièiàl
I certify under penalty of law
that
this document and
all
attachments were prepared
under
my
direction or supervision in
accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted.
flased on my inquiry of the person or persons directly responsthis
for gathering the information1
the information submitted is,
to
the best of my knowledge and belief, tne, accurate,
and
complete.
I am aware that there are significant penalties for
submitting false information,
including the possibility of
tine
and imprisonment for knowing violations.
Signature
Name:
Official Title;
Telephone No.;
bate Signed:
LI
~
t
U~S15INDLJ5
PAGE
02/14
1-1
jZfj.Ofa5J
su:4b
ibitJi(blbtlb
UA515
1NDIJ5
PAGE
03/14
10.2,
Attachment
2
-
Particulate Matter Emissions from Process Emission
Units
Z0.2-3.
Section
212.321
-
Process Emission. Units For Which
Construction
or Modification Commenced On or After
April
14,
1972.
a.
Except as further provided in 3S IAC Part 212, no
person shall cause or allow the emission of
particulate matter into the atmosphere in any one
hour
period
from
any
new
process
emission
unit which,
either alone or in combination with the emission of
particulate matter from all other similar process
emission units for which conetnetion or modification
commenced on or after April
14,
1972,
at a source or
premises, exc~edsthe allowable emission rates
specified in subsection
Cc)
of this Section.
b.
Interpolated and extrapolated values of the data in
subsection
(c)
of this Section Shall be determined by
-
using the equation;
where;
-
P
=
Process weight rate;
and
E
Allowable emission rate;
and,
i.
Up to process weight
rates of
408 Mg/hr
(450
Ton/hr);
Metric
English
P
Mg/hr
Ton/hr
E
kg/hr
lbs/hr
A
1.214
2.54
5
0.534
0.534
ii.
For process weight rate greater than or equal
to 405 Mg/hr (450 Tonfhr):
Metric
English
Mg/hr
Ton/hr
kg/hr
lbs/hr
A
1L42
24.8
5
0.16
0.16
C.
Limits
for
Process
Emission
units
For
Which
Construction
of
Modification
Commenced
On
or
After
April
14,1972
E
=
A(S)8
P
E
.~
e
.1.
,.
—
2-1
JD;qb
Ui-’~5I5INDU5
PAGE
S4/14
Metric
English
P
E
P
E
Mg/hr
kg/hr
Ton/hr
lbs/hr
0.05
0.25
0.05
0.55
0.1
0.29
0.10
0.77
0.2
04~
0.20
1.10
0.3
0.84
0.30
1.35
0.4
0.74
0.4.0
1.58
0.5
0.84
0.50
1.75
0.7
1.00
0.75
2.40
0.9
1.15
1.00
~.GO
1.8
1.66
2.00
3.70
2.7
2.1
3.00
4.60
3.6
2.4
4.00
5.35
4.5
2.7
5.00
6.00
9.0
3.9
~,0.00
6.70
13.0
4.8
15.00
10.80
16.0
5.7
20.00
12.50
23.0
6.5
2.00
14.00
27.0
7.1
30.00
15?0
32.0
7.7
35.00
17.00
36.0
~.2
40.00
18.20
41.0
8.8
45.00
19.20
45.0
9.3
50.00
20.60
90.0
13.1
100.00
29.50
140.0
17.0
150.00
37.00
180.0
19.4
200,00
43.00
230.0
22.0
250.00
48.50
270.0
24.0
300.00
53.00
320.0
26.0
350.00
58,00
360.0
28.0
400.00
.
62.00
408.0
30.1
450.00
66.00
454.0
30.4
500.00
61.00
Where;
=
Process ~eig~i1rate
tn Mg/hr or Ton/hr,
arid
E
=
Allowable emission
rate
in
kg/hr
or
lbs/hr.
ib~J
(~Lb~
-
2-2
10.3
Attachment 3
-
Emissions
from
Polyester
Resin Product Fabrication Processes
These tables are the United Emission Factors
CUEF)
from ‘~TechnicalDiscussion of
-the Unified
Emission Factors
for Open Molding of
Compoeites~’
(CFA, April
1999).
If there are any
updates to this
document,
the updated factors may be
used.
Table
1
-
8missicn Rate
in Pounds of Monomer Emitted per -Ton of Resin or
c3e.coat
Processed
Styrene
Content
()t
33
I
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
--~
49
.~
SO.
.
~ppl±catioo
Method
.~131
-
::~!-
jj-
~jj~
j~
~
106
123
129
140
152
163
169
174
.-
111.
126
140
154
168
183
197
211
225
240
254
268
283
297
311
325
340. 35~
-
.
86
97
108
119
130
141
152
163
174
185
196
207
218
229
240
251
262
273~
:
7iIanual2~
Mechanical
Atomized~”
Mechanical
~.tomized
Controlled
Spray3”
Mechanical
Non-
~tomized3’5
Filament
71
74
122
127
77
133
80
138
83
144
86
149
89
155
93
160
96
166
99
171
102
105
177
182
108
188
111
193
115
199
118
204
121
210
i24~
.
-.
215-
--
79
83
86
90
93
97
100
104
ioa
iii.
115
118
122
125
129
133
136’
140.
Gelcoat
294
315
336
356
377
398
418
439
460
481
501
522
543
564
584
605
626
646
~3e1coat
Controlled
Spray
215
230
245
260
275
290
305
321
336
351
366
381
396
411
427
442
457
472
‘
MNA
Content
1
2
3
4
5
6
7
8
9
tO
ii
12
13
14
is
16
17
18
Application
Method
‘
-
.
-
Celcoat
is
30
45
60
75
90
105
120
135
150
165
180
195
210
225
240
225
.a~
.:~
3-1
-
;
I
I..
--
~
:.~-~I
-1
~
‘-.
N
~-.
:~
cs
a.
C.!;
C,.
Cl
I-.
Cl
C
:51
ci:
I-
ci:
I.-
z
C
ci:
-u
m
-
~-,::~
-
-
-:
..,
For styrene contents less than 33
or
greater
than
50
and
for
t4MA
contents
greater
-
than
18-,
refer to Table
2.
For Vapor Suppressed ResJ.nIVSR), multiply the
CJEF from
the
table
above
by
~1
-
(0.5
-
*
specific
VSR
reduction factor))
to obtain the
correct
emission
factor.
The
VSR
reduction
factor
is
based
on
testing
of
the
specific
resin/suppressant
formulation.
For
VSRJ,
nrnltiply
the
UEF
from
the
table
above
by
(1
-
(0.45
*
specific
.VSR
reduction
factor))
to obtain the correct
emission
factor.
The
‘ISR
reduction
factor
is baaed on
testing of the specific resin/suppressant formulation,
For processes
using
covered
curing
after
roll-out,
multiply
the
UEF from the table
above
by
0.8
to obtain the correct emission factor.
For Processes
using
covered-
curing without roll-out, multipiy the
TJEP
from
the
table- above by
0.5
to obtain the
correct emission factor.
-
For processes using
covered
curing after roll-out,
multiply
the
UEF front
the table
above by 0.85 to
obtain
the correct emission factor.
For Processes using covered
curing without toll-out,
multiply
the
UEF
front the table above by 0.55 to obtain the
correct emission factor.
-
3—2
I.-
Cs
‘p
a
C
I-
(I:
I-
C
ci:
Table
2
-
Rnii.ssion
Rate Equation
Variables1
~c
-
-
Application ~1ethod
Manual
-
Monomer
~
Styrene
-
fi
0.126
0
Styrene
1.
0.169
0
P1~
1
8a
0.286
C2
-
0:.aS29~-.’~
Mechanical Atomized
1-
0.714
0r18
-
0.18
-
-
-0~O165.-:1
-.
U.
0298’~
00298
Mechanical Atomized Controlled Spray
Styrene
2.
0.13
0
0.77 0.714
Mechanical
Non-Atomized
Styrene
1
0.107
0
1
0.151
Filament Application
Filament
~pplication
with
VSR
Styrene
Styrene
l~
1
0.184
0.12
0
0
1
0.65
0~2746
0.2746
-
Gelcoat
Application
Styrene
1
0.445
0
1
1.03646
0.195
-
Gelcoat
Controlled
Spray
~pplication
styrene
1.
0.325
0
0.73
1.03646
0.195
~elcoat
Application
Methyl Methacrylate
i.
0.75
0
1
0.75
0
These
variables
and
the
equation- below shall be used
for
monomer
conterits above or below the
values included in Table 1.
Variables A~,
~,
and C~are used for monomer contents less than 33.
Variables A2,
83,
and
c,
are used with monomer contents greater
than
or equal to 33.
TJEF
=
A
*
(5
*
Monomer
Content
-
C)
*
2000
r~here
Monomer Content is in weight percent
e.g..
for a monomer content of 40,
use 0.40)
3-3
:-~-~-
c
-
-
-
~—~-
-
~:~W-j
-n
-
-
u~i~-1
-
—.1
-
-
----~:
i-~
