RE CE ~JV ED

CLERK’S 0FACE

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

OF THE STATE OF ILLiNOIS

JUN 1 6 20C4

STATE OF ILLINOIS

VILLAGE OF ROBB1NS and ALLIED

)

Pollution Control Board

WASTE TRANSPORTATION, INC.,

)

)

Petitioners,

)

)

vs.

)

Case No. PCB No. 04-48

)

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

)

Respondent.

)

PETITIONERS’ MOTION TO SUPPLEMENT

RECORD

NOW COME the Petitioners, VILLAGE OF ROBB1NS, ILLINOIS, and ALLIED

WASTE TRANSPORTATION, iNC., by and through undersigned counsel ofrecord, and hereby

respectfully request that this Board grant Petitioners’ Motion to Supplement Record:

1.

It has come to the attention of Petitioners that certain materials that should be

included in the administrative record are absent from the record.

2.

Most notably, the administrative record is devoid of permits granted by the

Illinois Environmental Protection Agency to the Village ofRobbins, Robbins Resource Recovery

Partners, L.P. and Forster Wheeler Illinois, Inc. as the owners and operator of the pollution

control facility located in Robbins, Illinois.

3.

These permits are directly relevant to the issues presented in this case, namely the

type of facility approved and permitted in the Village of Robbins and the types of activities

approved and permitted to take place at the facility.

4.

In fact, pursuant to section 39(c) of the Illinois Environmental Protection Act, 415

ILCS

5/39(c),

these permits provide direct and clear proof that the facility was approved by the

7041 1324v1 820753

---

local siting authority and, thereafter, the Illinois Environmental Protection Agency granted

permits for the development and construction of the facility.

5.

Clearly, these permits were erroneously overlooked in the creation of the record,

as they are directly relevant to the issues presented in this case.

WHEREFORE, the Petitioners, VILLAGE OF ROBBINS and ALLIED WASTE

TRANSPORTATION, INC. request this Honorable Board grant its Motion to Supplement

Record to include the various permits, attached hereto.

Dated: June 15, 2004

Respectfully Submitted,

VILLAGE OF ROBBINS and ALLIED WASTE

TRANSPORTATION, INC., Petitioners

HINSHAW AND

100 Park Avenue

P.O. Box 1389

Rockford, IL 61105-1389

815-490-4900

By

Helsten

One of Attorneys

This document utilized 100

recycled paper products

---

AFFIDAVIT

OF SERVICE

The undersigned, pursuant to the provisions of Section 1-109 of the illinois Code of Civil

Procedure, hereby under penalty ofperjury under the laws ofthe United States ofAmerica, certifies that

on June 15, 2004

,

a copy ofthe foregoing was served upon:

Dorothy M. Gunn, Clerk

illinois Pollution Control Board

James R. Thompson Center

100 West Randolph Street

Suite 11-500

Chicago, IL 60601

John J.Kim

Renee Cipnano

Special Assistant Attorney General

Division of Legal Counsel

1021 N. Grand Avenue, East

Springfield, IL 62794-9276

Mr. Brad Halloran

Hearing Officer

Illinois Pollution Control Board

100 West Randolph, 11th Floor

Chicago, illinois 60601

Mr. William Mansker

Village ofRobbins

3327 W. 137th Street

Robbins, IL 60472

Steve Smith

Allied Waste Transportation, hic.

13701 South Kostner

Crestwood, IL 60445

By depositing a copy thereof, enclosed in an envelope in the United States Mail at Chicago, illinois,

proper postage prepaid, before the hour of5:00 P.M., addressed as above.

HINSHAW & CULBERTSON LLP

100 Park Avenue

P.O. Box 1369

Rockford,IL 61101

(815) 490-4900

This document utilized 100 recycled paper

70411389v1 820753

---

•

ENVIRONMENTAL PROTECTION AGENCY

Mazy A. Gade, Director

2200 Churchill Road, Springfield, IL 62794-9276

217/524-3300

CERTIFIED MAIL

J

2

1997

~

~

une

S

P’ 344 345 760

OWNER

-

Práperty

OWNER

-

Facility

Village ofRobbins

Robbins Resource Recovery Partners, L.P.

3327

W. 137th Street

Pertyville Corporate Park

Robbins, Illinois 60472

Clinton, New Jersey 08809-4000

OPERATOR

Foster WheelerIllinois, Inc.

13400 South Kedzie Avenue

Robbins, I11inoi~60472

Re: 0312700001 --CookCounty

•

Robbins Resource Recovery

Permit

No.

1990-068-DE

Permit

No. 1997-072-OP

Log No. 1997-072 (1994-300, 1989-189)

State Permit File

Gentlemen:

Permit is hereby granted to Village ofRobbins as property owner, Robbins Resource Recovery

Partners, L.P. as owner ofthe facility, and Foster Wheelerillinois, Inc. as the operator, to operate

a 16 acre solid waste management site to manage waste for introduction into a waste-to-energy

facilityall in the Village ofRobbins, Cook County, illinois. In addition,this permit allows the

developmentand operation ofa porta~1eshredder. All plans, specifications, application and

supporting documents as submitted and approved shall constitute part ofthis permit and are

identified on the records ofthe illinois Environmental Protection Agency, Division of Land

Pollution Control by the permit number(s) and log ‘number(s) designated

in

the heading above.

The permitis issued subjectto the standard conditions attached hereto.and incorporated herein by

reference, and further subjectto the followingspecial conditions:

1.

This permit allows for the operation ofthe units listed below.

Unit Designation’

Apnroximate Size

Proposed Use

i~

3000 ton capacity

storage ofwaste

prior to processing

RRRP 015873

a.

•

Tipping area

Printed

on

Reescled

PaDer

---

Page2

S

S

.

ç

b.

Portableshredder

.5

tons per hour.

to shred bulky

waste

c.

Processing Lines (2)

80 to 100 tons per hour

i.

primarytrommel

.

screening ofwaste

ii.

shredder

‘

shreds wastes over

5

inches in size

iii. magnets

(5)

to remove ferrous

•

material

•

iv.

secondaryirommel

.

separation ofwaste

•

into sizes

v.

air classifier

removal ofinert

material

vi. eddy current

to remove

separator

aluminum cans

vii. picking station

to rethove

unacceptable

material forwaste

removal

and

S

.

recovery

of

•

recyclable

I’

.

materials

viii. glass and compost

to separate

organic

recovery

system

,

material from the

glass material

d.

Circulating fluidized

600 ton per day

(ave.)

bed boiler trains (2)

i.

combustion chamber

waste to energy

ii.

cyclone

to remove

entrained material

RRRP ~i587~

---

Page4

S

4

c.

Not

withstanding

the above, the

Perinittee

mayaccept

waste

for additional periods

•

during extended curtailed facility

operations caused by unusual circumstances

only as

approved in

writing

by the

Illinois

EPA.

3.

This

facility shall not accept special waste (i.e.,

hazardous

waste, potentially

infectious

medical

waste,

pollution controlwaste or

indusirial

process waste). Special waste does not

include uncontaminated corrugated cardboard, wooden crates

and pellets,

plastics (both

packaging

and

rigidmaterials), officewaste

(primarily

paper

and

plastic)

and

cafeteria

• waste.

4.

Special wastes (incinerator ash) generated at the site sent for

disposal,

storage,

incineration

or further treatment elsewhere shall be

transported

to thereceiving facility utilizing the

Illinois EPA’s supplemental permit system

and

manifest system. The receivin~tes

manifest ifrequired maybe

used

in place ofan Illinois manifest.

5.

A copy of

all

records

and reports

required by

this

permit

shall

be

maintained

in thefacilities

operating record. The operating record shall be made available by the

illinois

EPA upon

request.

All

information shall be maintained in the reconi for a period ofat

least

three

years

beyond the date ofthe report.

6.

The following information

shall

be included in the operating record

and

recorded daily:

a. ‘the amount

of

waste

delivered,

S

b.

the

amount

of

RDF

produced (as calculated),

c.

the

amount

of

waste

rejected,

d.

the

amount

of

unacceptable

waste removed.

e.

the amount

of

materials

recovered (e.g., Fe, Al,

glass),

S

f.

the

amount

of

bottom and

fly

ash

removed,

S

g.

where the above

materialswere taken

to,

and

h.

the date

and time any

event

results

in the

bypassing

ofthe air pollution equipment,

•i.

an inspection certification. The operator shall, certify,

daily that

all incomingrailroad

ties were visually inspected.

.

7.

On an annual basis, the Permitteeshall

familiarize local emergency response units with the.

contingency plan

and

document the date, time

and

contents of

meetings

held to comply

with

these requirements.

8.

This

permit is subjectto review

and

modification by theillinois EPA as deemed necessary

S

to

fulfill the

intent

and

purpose ofthe

Environmental

Protection Act

and all

applicable

S

environmental rules

and regu1ation~

.

.

S

9.

The Permittee shall

notify

the illinois EPA of

any

changes from the information submitted

to the illinois EPA in

its

application for a development

and

operating permit for

this

site

~po~58l6

---

S

Page3

iii. a superheater

to

raise steam

temperature above

S

saturation’

iv.

economizers

preheat boiler

S

S

feedwater

S

v.

urea injection

to control NO~

emissions

e.

Spray

dryer absorber

size to handleapproximately

to remove acid

S

‘

•

baghouse system (2)

85,500 SCFM

each

-

gase~~l

S

,•

particulate

f.

•

Ash

storage silos (2)

storage of

ashprior

S

to disposal

g.

Ash conditioner

mixes

water

with

ash

to

control dust

S

h.

RDF storage building

3000 ton capacity

storage of

RDF

prior to

burriiñk

i.

pumps, piping, controls,

•

loading

and

unloading

areas

and appurtenances’

S

2.

The

Permitteemay

accept

waste

at the facility during

periods

of

curtailed

under the following conditions:

a.

During the first 14 days of

curtailed

operations

waste

may be accepted normally;

b.

After fourteen days:

S

i.

if one incinerator is in service, no more than 1120 tons per

day (nominal)

of

waste

may

be

accepted

unless the excess

amount

can be processed or

stored

on site; an•

ii.

ifboth

incineratorsare

o,t~of

service,

no waste maybe accepted

until

one

incinerator is placed back’ih service.

S

RRRP 015875

---

Page

5

Any modifications to the facilities shall be the subject ofan application or supplement

permit submitted

to the Illinois EPA for those changes.

10. The incinerator

ash

destined for disposal

shall

be

disposed

Of only in a properly permitted

landfill.

11.

All

ofthe ash meets

the definition

ofan

industrial processwaste and thc-fly~

ash

portion

is

also considered a pollution control waste. The Permittee shall establish a reliable method of

determining the

amount

offly ash sent for disposal.

12. The Permittee shall submit a quarterlyreport tothe Solid Waste Management Section,

Division of

Land

Pollution Control which

summarizes

the

amount

of

industrial process

waste

and

pollution control waste for purposes ofthesolid waste

fee systel

portion

which is a pollution conti~olwaste will be exempt

from

fees.

13.

The.

Permittee

shall collect a weekly

grab

sample ofthe incinerator ash. The results from

the analysis shall be made a

part of

the

operating record.

The weekly samples shall be

composited quarterly

and analyzed

for the characteristics ofa hazardous waste by TCLP as

described in

35

111. Adm. Code 72 1.124 for the parameters; arsenic,

barium, cadmium,

chromium, lead, mercury, selenium

and

14. The following conditions are included pursuant to Section 22.16b(b):

a.

The incinerator

must

be designedtoprovide continuous monitoring while in operation,

with direct transmission

ofthe

resultant

data to the Agency, until theAgency

determines the. best available control technology for monitoring the data. The Agency

shall establish the testmethods,

procedures and

averaging periods, as

certified

by the

form and.frequency

ofrepOrt

containing results ofthe monitoring. Compliance and

enforcement shall be

based~,n

suchreports.

Copies ofthe

results

of

suchmonitoring

shall be maintained

on file at the facility

concerned

for one year,

and copies shall be

made

available for

inspection and copying

by

interested

members ofthe

public

during

business

hours.

S

Also, please refer

to

operating pemiit

8812055

issued

bythe

Illinois

EPA’s

Bureau

of

Air.

b.

The

facility

shall

comply

with

the emission limits adopted by the Agencyunder

subsection (c).

Also,

please refer to operatin~eimit8812055 issued by the Illinois EPA’s

Bureau

of

Air.

S

RRRP 015877

---

Page 6

c.

The operator ofthe facility

shall take reasonable measures

to

ensure that

waste

accepted for incineration complies

with

all legal

requirements

for

incineration.

The

•

incinerator operator shall establish

contractual

requirements or other notification

and

S

inspection procedures sufficient to

assure

compliancewith

this

subsection

(b)(3)

which

may include, but not be

limited

to,

routine inspections

of

waste, lists

ofacceptable

and

unacceptablewaste

provided tO

haulers and notification

to the Agencywhen the facility

operator reject

and

sends loads away. The notification shall contain at least the

name

o~the

hauler and

the site from where the load

was

hauled.

Also, please refer to Special Condition Nos.

15,

16

and

21 herein.

S

d.

The operator may not accept for incineration

anywaste

generated or collected in a

municipality

that

has not implemented a recycling plan or is

party

to an ii~temented

county plan, consistent with State goals and

objectives. Such

plans shall include

provisions for collecth1g~recycling or diverting from landfills

and

municipal

incinerators

landscape

waste, household

hazardous waste and

batteries. Such

provisions

may be

performed

at

the site

ofthe new

municipal incinerator.

15.

Waste

wasteNo.

18categories,

and

19, herein.one

of

5

which will be

incineratedon Site

and

the other sent off-site. The Permittee shall not

accept•wa,sta

wbi~h...

-

55

does not comply

with

thewaste screening/analysis plan in the approvedapplication Section

5

9.4

and

Special Condition #3 herein. The procedures

shall

be

modified

to include screening

for

all

unacceptable or prohibited waste

and

comply

with

the

following conditions:

a.

Upon unloading, the Permittee shall

inspect

each incoming

load

of

waste

to determine

if theload contains waste which

this

facility is not permitted to receive in accordance

with

theprocedures in’the approvedpermit

application

Log 1989-189;

•

5

b.

The Permittee

shall

inspect

all

wastes prior to placement

into

the incinerator feed

system to remove

waste

which is unacceptable for incineration. If unacceptable waste

S

is discovered,

it

shall

be diverted from the incinerator feed

and transported

to a

unit

which

is properly

permitted

to receive the waste.

c.

The

Permittee shall notify

the Illinois EPA in

writing

within48 hours ofrejection ofa

load of

unacceptable waste

as described in the

facilities waste inspection/analysis plan.

The notification

shall

include atleast the nameofthehauler

and site

from where the

load

was

hauled.

d.•

The

Permittee shall visually

inspect wastes which

are

processed to become

part

ofthe

5

refuse derived fuel (RDF)

system to remove wastes identified as prohibited

waste in the

WasteManagement Practice Plan. Such wastes shall include but not be limited to:

S

RRRP

015878

---

1

Page7

S

1.

explosives or

ammunitions,

2.

combustible liquids or

gas

containers, bottles or cylinders or cans,

3.

batteries ofany type including dry cell, wet cell, motor vehicle or marine,

4.

special

wastes (i.e.,

industrial

process waste, hazardous waste, pollution control

•

waste or potentially infectious waste),

5.

radioactive wastes,

6.

asbestos wastes,

S

7.

waste regulated by the Toxic Substance

Conirol

Act,

8.

landscape waste,

9.

household hazardous waste,

10. railroad ties treated

with

a material other than creosote,

11. telephone poles,

and

S

12. tires.

S

~

S

e.

The Permifteeshall provide a list of

wastes

which are

inacceptable

for receipt at

this

facility

and

list ofexamples ofacceptable

waste

to each

hauler

beforethe hauler

collects waste for

transport

to

this

facility.

S

16. The Permittee shall visually inspect used creosote-treated wood to verify

that

thewood is

•weathered and contains

no surface deposits or stains. Unweathered wood, or wood which

contains surface staining or deposits, is subject to the requirements of35 III. Adxn. Code

722.111

(by

testing) to verify the wood is not characteristically hazardous.

.

S

17. Waste generated in Illinois Municipalities

and

Illinois counties outside ofHamilton County,

•

Illinois as of

June 2,

1997

are

deemed to have complied

with

the

requirements

in

Special

S

Condition 14(d) and

no further documentation is

required.

Provisions for collecting,

recycling or diverting from landfills

and municipal incinerators landscape

waste, household

hazardous

waste and

batteries

m~y

be

performed

at this site

may

be used to comply

with

these requirements.

•“

S

18. Prior to receipt of

waste

from out-of-state or Hancock County, Illinois,

the Permittee

shall

obtain a certification from thehauler that the waste was

generated

or

collected in a

municipalitythat has

provisions for collecting, recycling or diverting household

hazardous

waste from landfills and

municipal incinerators.

19. The facility shall perform routine housekeepingas

outlined

in

Section

9.3.2 oftheapproved

application Log #1989-189, to control litter. Routine housekeeping measures at a minimum

shall

include:

S

S

a.

inspection and maintenance

ofthe equipment in accordance

with

the

manufacturers

recommendations;

RRRP 015879

---

Page8

S

b.

periodic sweeping

and

cleaning oftipping floor,

RDF residue loading area, and

bottom

and

fly

ash loading area,

S

c.

dailyjanitorial

cleaning of

administrative

office, sanitary

and

employee facilities,

and

control room;

S

d.. periodic sweeping and cleaning

of

floors

in

RDF

production

area and

boiler building;

e.

periodic

cleaning

of

turbine

generatorroom;

f.

daily

inspection

and cleanup ofyard

areafrom spillage, litter, and

other foreign

materials;

S

g.

weekly

cleaning and

inspection ofmaintenance

areas

for orderhnes

and safety

•

compliance

with industrial standards;

S

h.

weekly inspection and

cleaning of

drainage

basins, oil-waterseparators, sumps, etc.

1.

weekly

fire

and safety inspections.

The time

and results date

of

each inspection shall

be

maintained

in theoperating record.

20. The facility shall be

maintained and

operated to prevent

nuisance odors and litter outside-the

building by drawing air

from

inside

the

waste

receiving,

RDF

processing

and RDF

storage

buildings for combustion air in the

combustors

(orventing

air through

the

combustors

when

they are not

operational) and

othernecessary

measures. Any

liter present outside ofthe

building shall be collecteddaily.

21. The load

checking program shall consist

of, at a

minimum,

the following components:

1)

Random inspections

S

S

A. An

inspector

designated by

the facility shall examine

at

least threerandom loads

ofsolid waste delivered tothe

landfill

on a

random day each

week.

The drivers

randomlyselected

by the

inspector shall

be directed to

dischargetheir loads

ata

separate, designated locationwithin the

facility.

The

facility shall

conducta

detailed inspection ofthe discharged

material

for

any regulatCd hazardous

or

other

unacceptable wastesthat

may be

present Cameras

or other

devices may

be

‘used

to recordthe visible contents of solid

waste shipments. Where such devices

are

employed,

theiruse

~iouldbe designated on a sign posted

near

the

entrance

of

the

facility.

I

S

S

S

RRRP 015880

---

Page9

B.

If

regulated hazardous

wastes or other

unacceptable wastesare suspected,

the

facility

shall communicate with

the

generator, hauler

or other

party responsible

for shipping the

waste

to the facility to

determine

the

identity

ofthe

waste.

2)

Recording inspection results

Information and observations derived

from each

random inspection shall

be recorded

in

writing and retained

at the facility for at

least threeyears.

The

recorded information

shall

include, at a minimum the date

and time

ofthe

inspection;

the names ofthe

hauling finn and

the

driver of

the vehicle; the vehicle licenseplate

number, the source

ofthe waste, as stated by the

driver,

and observations

made

by the

inspectorduring

the

detailedinspection.

The

written

record

shall

be

signed

by both the

inspector-and

the

driver.

•

S•~

The

“security wastes” are excluded from the random inspection program.

22. The

permittee shall transport the compostablewaste stream to a properlypermitted

facility.

The

only facilities in flhinois which may receive this waste stream forcomposting are mixed

municipal waste composting facilities.

-

lIthe compostable stream

includes landscape waste

that is not separated atthe

point

ofgeneration

and collected and processed

separatelyfrom

therest

ofthe

municipal waste stream,

it is subject to thedisposal

prohibitions in Section

22.22(c) oftheEnvironmental Protection Act.

-

23.

The Permittee(s)

shall

notify the illinois EPA’s Bureau

of

Land in writing

of

its intent to

•

close at

least

45

days prior to thedate

closure

is

expected

to begin.

Along with this

notification,

the

Permittee(s) shall submit

the

procedure and

the

sampling and analysis

plan

to be used in

demonstrating

the

area

has been

properly decontm’ninated.

-

This plan shall be

approved by the

Illinois

EPA’s Bureau of

Land in writing

prior

to being implemented.

S

24. The operator

shall notify

theIllinois EPA within 30 days

after receiving

the final volume of

waste.

S

•

S

25. The

operator shall initiateimplementation

ofthe closure plan within 30

daysafter

the site

receives

its final

volume ofwaste.

-

26. The operator shall

not

file any application to modify

the

closure plan less than 180 days

priorto

receipt ofthe final

volume of

waste.

S

27. Upon completion of

closure

activities, the operator will

notify

the illinois

EPA that the

site

has been closed

in accordance with~he

approved closure plan utilizing the illinois EPA’s

-

“Affidavit for Certification of

Coth~1ètion

ofClosure of

Non-Hazardous

RRRP

01588

---

PagelO

S

•

27. Upon completion ofclosure activities, the

operator will notify

theIllinois EPA

that

the site

-

has

been closed in

accordance with

the approved

closure

plan

utilizing

the Illinois EPA’s

“Affidavit

for Certification of Completion of

Closure

of

Non-Hazardous Waste

Facilities.”

28, The

Permittee

is prohibited from placing white goods in the shredder

unless

the white goods

components have been removed.

S

29. The Permittee may only

bum waste that

has been processed into

RDF

on site except for

those wastes identifiedas “security waste” in the letter

dated

April 24 from Ross Hardees

that are managed in compliance

with

the following conditions:

a.

The constituents in security waste

must

be readily identified by visual inspection

notwithstanding

any

shredding or

size

reduction

performed

off-site;

:

For

this purpose, a municipal

waste shall be considerea a security

Waste

ifit is a

-

municipal waste and if its origin

or

circumstances

effectively exclude the presence of

undesirable components, such as household batteries; precluderecycling ofthe

•

S

material; and

generally

assure that

the

waste

is ofa specific character or

nature, as

certified by the generatorofthe

waste and verified

by thePerinittee: Examples of

security

wastes include garbage from

international airline flights,

which

must

be

incinerated

pursuant

to US Department of

Agriculture

Rules, and

bank

or

medical

records,, which

must

be destroyedto

maintain

client/patient privacy;

.

,~

b.

The Permittee shall implement

practices

for handling ofsecurity waste at the facility

that reasonably provide for identification

and removal ofany

prohibited materials in

the waste. At a minimum, theseprocedures

shall

include continuous oversight ofeach

shipment of security

waste

at the facility by designated facility

personnel until

-

unloading

is complete

and

the

waste

is mixed

with

other

waste

or

RDF; and

c.

The Permittee

shall maintain

records for each source

and type

ofsecurity waste

•

accepted by thefacility

and

confirm that such

waste

is properly considered

security

waste and

define the specificpractices establishedfor

handling

such

waste

atthe

facility,

accompanied by reasonable supporting documentation

and explanation.

The

Perniittee shall

also

maintain records for each shipment of

security waste

that is

S

received at the facility that include the date,time, waste source

hauler, type and amount

of

waste

for the shipment and that document implementation ofthe specified

handling

procedures by the facility, including thenames

and

personnel ofsupervising the

handling

of theshipment.

S

SRRRPOISBS2

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Page11

-

S

-

Within

35

days

after

the date of

mailing

ofthe Illinois EPAs final decision, the applicant may

petition for a hearing before the Illinois Pollution Control Board to contestthe decision ofthe

Illinois EPA, however,

the 35-day

period

for

petitioning

for a

hearing

may be extended for a

period of

time

not to exceed 90 days by

written

notice

provided

to the Board

from

the applicant

and

the Illinois EPA within the 35-day

initial appeal period.

Sincerely,

-S

Edwin C. Bakowski, P.E.

Manager, Permit

Section

Bureau ofLand

-

S

ECB~~S:bjh\973012S.WPD

S

•

RRRP 015883

---

STANDARD CONDITIONS FOR CONSTRUCTION/DEVELOPMENT PERIIITS

ISSUED BY THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

July 1, 1979

The Illinois Environmental Protection Act (Illinois Revised Statutes,

Chapter 111—1/2. Section 1039) grants the Environmental Protection Agency

authority to impose conditions on permits which it issues.

These standard conditions shall apply to all permits which the Agency

issues for construction or development projects which require permits

under the Divisions of Water Pollution Control, Air Pollution Control,

Public Water Supplies, and Land and Noise Pollution Control. Special

conditions may also be imposed by the separate divisions in addition

to these standard conditions.

1. Unless this perrnit.has been extended or it has been voided by a

newely issued permit, this permit will expire two years after date

of issuance unless construction or development on this project has

started on or prior to that date.

~

2. The construction or development of facilities covered by th1s~~it

S

S

shall be done in. compliance with applicable provisions of Federal

laws and regulations, the Illinois Environmental Protection Act,

and Rules and Regulations adopted by the Illinos Pollution Control

-

Board.

5

3. There shall be no deviations from the approved plans and specifi—

S

cations unless a written request for modification of the project,

along with plans and specifications as required, shall hays, been

submitted to the Agency and a supplemental written permit issued.

)

4. The permittee shall allow any agent duly authorized by the Ageñcy~

upon the presentation of credentials:

a. to enter at reasonable times the permittee’s premises

where actual or potential effluent, emission or noise

sources are located or where any activity is to be con-

ducted pursuant toth~spermit.

b. to have access to and copy at reasonable times any

records required to be kept under the terms and con-

S

diticrns of this permit.

S

-

S

c. to inspect at reasonable times, including during

any hours of operation of equipment constructed or

S

operated under this permit, such equipment or monitoring

S

methodology or equipment required to be kept, used, operated,

calibrated and maintained under this permit.

~ o158~tr

Printed on

Recyc’ed

Paper

---

d. to obtain and remove at reasonable times samples of any

discharge or emission of pollutants.

e. to enter at reasonable times and utilize any photographic,

recording, testing, monitoring or other equipment for the

purpose of preserving, testing, monitoring, or recording

any activity, discharge, or emission authorized by this

permit.

5. The issuance of this permit:

a. shall not be considered as in arty manner affecting the title

of the premises upon which the permitted facilities are to

be located;

b. does not release the perinittee from any liability for

damage to person or property caused by or resulting from

the construction, maintenance, or operation of the proposed

facilities;

c. does not release the permittee from compliance with oth~a~

applicable statutes and regulations of the United States,

of the State of Illinois, or with applic~blelocal laws,

ordinances and regulations;

d. does not take into consideration or attest to the structural

stability of any units or parts of the project;

e. in no manner implies or suggests that the Agency (or its

officers, agents or employees) assumes any liability, directly

or indirectly, for any loss due to damage, installation,

maintenance, or operation of the proposed equipment or

• -

facility.

5

6. Unless a joint construction/operation permit has been issued, a

permit for operating shall be obtained from the Agency before the

facility or equipment covered by this permit is placed into

S

operation.

S

7. These standard conditions shall prevail unless modified by special

conditions.

S

8. The Agency may file a compliant with the Board for modification,

suspension-or revocation of a permit:

S

a. upon discovery that the permit application contained

misrepresentations, misinformation or false statements

or that all relevant facts were not disclosed; or

b. upon finding that any standard or special conditions have

been violated; or

c. upon any violation o?the Environmental Protection Act or

any Rule or Regulation effective thereunder as a res~ult

of the construction or development authorized by this permit.

MLK:dh/.7

S

RRRP 015885

---

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 North Grand Avenue East, P.O. Box 19276, Springfield, Illinois 62794-9276

Mary A. Gade, Director

17/524-3300

CERTIFIED

MAIL

April 6, 1998

P 344 291 368

S

P 344 291 369

P344291370

OWNER

-

Property

OWNER

-

Facility

Village ofRobbins

S

Robbins Resource Recovery Partners,

L.P.

3327 W. 137th Street

Perryville Corporate Park

Robbins,

Illinois 60472

Clinton, New Jersey 08809-4000

OPERATOR

S

Foster Wheeler illinois,

Inc.

13400 South Kedzie Avenue

Robbins, illinois 60472

Re: 0312700001 —Cook County

S

Robbins Resource Recovery

PennitNo.

1990-068-DE

Permit No.

1997-072-OP

S

S

Supplemental Permit 1998-030-DE

Log No. 1998-038, 1998-030, (1997-072, 1994-300, 1989-189)

State Permit File

Gentlemen:

-

S

S

S

This supplemental permit is hereby granted to Village ofRóbbins as property owner,Robbins

Resource Recovery Partners,

L.P. as

owner ofthe facility, and Foster Wheeler illinois, Inc. as

the

operatorto modifythe operation ofthe solid waste management site by (1) installinga portable

conveyor to convey security and railroad wastes directly onto the shredder processing line and (2)

reducing the role ofthe stripper coolers

to a back-up role by installing

two discharge hoppers

(chutes) which are

cooled by noozies and water

sprays. The site consists ofa 16 acre site in the

Village ofRobbins, Cook County, illinois.

All plans,

specifications, application

and

supporting

documents as submitted and approved shall

constitute part

of

this permit and are identified on the records ofthe illinois Environmental

Protection Agency, Division ofLand

Pollution

Control by the permit number(s) and

log

number(s) designated in the heading above.

~

•• •~ -

S

The permit is issued subject to the standard conditions attached hereto and incorporatedherein by

reference, and further

subject to

the following special conditions:

51~ This permit allows for the operation ofthe units

listed below.

---

Page 2

Unit Desiwiation

Approximate Size

S

Proposed Use

a. Tipping area

3000 ton capacity

storage

of

waste

S

prior

to processing

b.

Portable shredder

5

tons per hour.

to shred bulky

waste

c.

Processing Lines (2)

80 to 100 tons per hour

i.

primarytrommel

screening ofwaste

ii.

shredder

-

shreds wastes over

5

inches in size

iii. magnets

(5)

to remove ferrous

material

iv. secondary.trommel

S

separation ofwaste

into sizes

v.

air classifier

removal ofinert

material

vi. eddy

current

to remove

5

separator

aluminum cans

vii. picking station

to remove

S

unacceptable

S

material

for

waste

S

removal and

S

recovery of

recyclable

S

materials

viii. glass and compost

to separate organic

recovery system

material from the

S

glass

material

d.

Circulating fluidized

600 ton per

day

(ave.)

bed boilertrains (2)

e~.

---

Page3

S

i.

combustion chamber

waste to energy

ii.

cyclone

to remove

S

S

entrained material

iii. a superheater

to raise steam

5

temperature

above

S

saturation

iv.

economizers

preheat boiler

S

v.

urea injection

to control NO~

5

5

5

emissions

e.

Spray dryer absorber

size to handle approximately

to remove acid

baghouse system (2)

85,500 SCFM each

gases and

S

particulate

S

f.

Ash storage

silos ~2)

storage of ash prior

S

to

disposal

g. Ash conditioner~

mixes water

with

S

ash

to control dust

h.

RDF

storage

building

3000 ton capacity

storage ofRDF

prior

to

burning

i.

All corresponding sumps,

S

pumps,

piping, ôontrols,

loading

and

unloading

areas and appurtenances

5

2.

The Permittee

may accept

waste

at the facility

during

periods of

curtailed facility operations

under the following conditions:

a.

During

the first 14 days of

curtailed operations waste may be accepted normally;

b.

After fourteen days:

S

---

Page 4

i.

if one incinerator is in service, no more than 1120 tons per day (nominal) ofwaste

may be accepted unless the excess amount can be processed or stored on site; and

ii.

if both incinerators

are

out of

service, no waste

may

be accepted until one

incinerator is placed back in service.

c.

Not withstanding the above, the Permittee may accept waste for additional periods

during extended curtailed facility operations caused by unusual circumstances only as

approved in

writing

by the illinois EPA.

3.

This facility shall not accept special waste (i.e., hazardous waste, potentially infectious

medical waste, pollution control waste or industrial process waste). Special waste does not

include uncontaminated corrugated cardboard, wooden cratesand pallets, plastics (both

packaging and rigid

materials),

office waste (primarily

paper

and

plastic)

and cafeteria

waste~

S

S

4.

Special wastes (incinerator ash)

generated at

the site sent for disposal, storage, incineration

or further treatment elsewhere shall be

transported

to the receivmg facility utilizing the

illinois EPA’s supplemerital permit

system and manifest system. The receiving state’s

manifest if required may be used in place ofan Illinois manifest.

5.

A copy ofall records

and reports required by this

permit shall be maintained in the facility’s

operating record. The operating record shall be made available by the illinois EPA upon

request. All information shall be maintaitied in the record for a period ofat least three years

beyond the date ofthe report

6.

The following information.shall be included in the Soperatrng record and recorded daily:

a.

the amount ofwaste delivered,

b.

the amount ofRDF produced (as calculated),

c.

the amount

of

waste rejected,

d.

the amount ofunacceptable waste removed,

S

e.

the amount ofmaterialsrecovered (e.g., Fe, Al, glass),

f.

the

amount

ofbottom and fly

ash removed,

g.

where the above materials were

taken

to,

and

h.

-

the date

and time any

event results in the bypassing ofthe air pollution equipment,

i.

an inspection certification. The operator shall certify daily that

all

incoming railroad

-

ties were visually inspected.

7.

On an annual basis,

the Permittee shall familiarize local emergency response units with

the

contingency plan and document the date, time

and contents ofmeetings held to comply with

these requirements.

---

Page

5

8.

This permit is subject to review and

modification by the illinois EPA as deemed necessary

to fulfill the intent

and purpose

ofthe

Environmental

Protection Act

and

all applicable

environmental rules

and

regulations.

S

9.

The Permittee shall notify the Illinois

EPA ofany changes from the information submitted

to the illinois EPA in its application for a development and operating permit forthis site.

Any modifications to the facilities shall be the subject ofan application orsupplement

permit submitted tothe Ill

moisS

EPA for those changes.

10. The incitierator

ash destined for disposal shall be disposed ofonly in a properly permitted

landfill.

S

11. All of the

ash meets

the definition ofan

industrial

process waste

and

the fly ash

portion

is

also

considered a pollution control

waste.

The

Permittee

shall establish a reliable method of

determining the amount of fly ash sent for disposal.

12. The Permittee shall submit a. quarterly report to the Solid

Waste Management Section,

Division ofLand Pollution Control which summarizes

the

amount ofindustrial process

waste and

pollution control

waste

for purposes ofthe solid waste fee system. The portion

which is a pollution control waste will be exempt. from fees.

S

13. The Permittee shall collect a weekly

grab sample

ofthe incinerator

ash.

The results from

the analysis shall be made a

part

ofthe operating record. The

weekly samples shall be

cömposited quarterlyand analyzed for the characteristics of a hazardouswasteby TCLP

as

described in 35111. Adm. Code 721.124 forthe parameters; arsenic, barium,cadmium,

chromium,

lead,

mercury,

selenium and silver.

14. The following conditions are

included

pursuant to Section 22.16b(b):

S

a. The incinerator

must

be designed to provide

continuous monitoring while in operation,

with

direct transmission of the resultant data

to the illinois EPA, until the illinois EPA

S

determines the best available control technology formonitoring the data. The Illinois

EPA shall establish the test methods, procedures and

averaging periods, as certified by

the form and

frequency ofreport containing

results

ofthe monitoring. Compliance and

enforcement shall be based on such reports. Copies

Ofthe results ofsuch monitoring

shall be maintained on file at the facilityconcerned for one year, and copies shall be

made

available for inspection

and copying by interested members ofthe public during

businesshours.

~.

5

Also, please refer to operating permit 8812055 issued by the Illinois EPA’s Bureau of

Air.

---

Page 6

b.

The facility shall comply with the emission limits adopted by the Illinois EPA under

subsection (c).

S

Also, please refer to operating permit 8812055 issued by the Illinois EPA’s Bureau of

Air.

c.

The operator of the facility shall takereasonable measures to ensure that waste

accepted for incineration complies with all legal requirements for incineration. The

incinerator operator shall establish contractual requirements

or other notification

and

inspection procedures sufficient to

assure

compliance with

this

subsection

S(b)(3)

which

may include, but not be limited to, routine inspections ofwaste, lists ofacceptable and

unacceptable waste

provided to haulers and notification to the Agency when the

facility operator reject

and

sends loads away. The notification

shall

contain at least the

name ofthe hauler and the

site from where the load

was hauled.

Also, please refer to Special Condition Nos.

15,

16

and

21 herein.

d. The operator may not accept for incineration any

waste generated or collected in a

municipalitythathas

not implemented a recycling plan or is

party

to an implemented

county plan, consistent

with State goals and objectives. Such

plans shall include

-

provisions for collecting, recyclingor diverting from landfills

and municipal

incinerators landscape waste, household hazardous waste and batteries.

Such

provisions may be performed at the site ofthe new municipal incinerator.

Also, please refer to Special Condition No. 18 and 19, herein.

15.

Waste may be received forsegregation into waste categories, one ofwhich will be

incinerated on site and the other sent off-site. The Permittee shall

not accept

waste which

does not comply with the waste screening/analysis plan in the approved application Section

9.4

and

Special Condition #3 herein. The procedures shall be modified to include screening

for all unacceptable or prohibitedwaste and

comply with the following conditions:

a.

Upon unloading, the Permittee shall inspect each incoming load ofwaste to determine

if the load contains waste which this

facility 15 not

permitted

to receive in accordance

with

the procedures

in the approved permit application Log 1989-189.

b. The Permittee shall inspect

all

wastes prior to

placement into the incinerator feed

system

to

remove waste which is unacceptable

for incineration. Ifunacceptable waste

is discovered, it shall be diverted from the

incinerator

feed

and transported

to a

unit

which is properly permitted to receive the waste.

c. The Permittee shall

notify the illinois

EPA in writing within

48 hours of rejection of a

load ofunacceptable waste as described in the facilities waste inspection/analysis plan.

---

Page 7

The notification shall include at least

the

name ofthe hauler and site from where

the

-

load was hauled.

S

d. The

Permittee shall visually

inspect wastes which

are processed to become part ofthe

refuse derived fuel (RDF) system to remove

wastes identified as prohibited waste in

the Waste Management Practice Plan. Such wastes shall include but not be limited to:

1.

explosives or ammunitions,

2.

-

combustibleliquids or

gas containers, bottles or cylinders or cans,

3.

batteries ofany type including dry cell, wet cell, motor vehicle or marine,

4.

special wastes (i.e., industrial process waste, hazardous waste, pollution control

waste

orpotentially infectious waste),

5.

radioactive wastes,

6.

asbestos wastes,

7.

waste regulated by the Toxic Substance Control Act,

8.

landscape waste,

9.

household hazardous waste,

10. railroad ties treated with a material other than

creosote,

11. telephone poles,

and

12. tires.

S

e.

The Permittee shall provide a list ofwastes which are unacceptable for receipt at this

facility

and list ofexamples ofacceptable waste to each hauler before the hauler

-

collects waste fortransport to this facility.

16. The Permittee shall visually inspect used creosote-treated woodto verify

that the wood ~5

weathered and contains no surface deposits orstains. Unweathered wood, or wood which

contains

surface staining or deposits, is subject to the requirements of35111. Adm. Code

722.111

(by testing) to verify

the wood is not characteristicallyhazardous.

17.

Waste generated in Illinois municipalities and

illinois counties outside ofHamilton County,

illinois as ofJune 2, 1997 are deemed to have complied with the requirements in. Special

Condition 14(d) and no further documentation is required. Provisions for collecting,

recycling or diverting from landfills and municipal incinerators landscape waste, household

hazardous waste and batteries may be performed at this site may be used to comply with

these requirements.

18. Prior to receipt ofwaste from out-of-state orHamilton County, illinois, the Permittee shall

obtain a certification from the hauler that the waste was generated or

collected in a

municipality thathas provisions for collecting, recycling or diverting household hazardous

waste from landfills and municipal incinerators.

---

Page8

S

19. The facility shall perform routine housekeeping as outlined in Section 9.3.2 ofthe approved

application Log #1989-189, to control litter. Routine housekeeping measures at a minimum

shall include:

a.

inspection and maintenance ofthe equipment in accordance with the manufacturer’s

recommendations;

b.

periodic sweeping and cleaning oftipping floor, RDF

residue loading

area,

and bottom

and

fly

ash loading area;

c.

dailyjanitorial cleaning of

administrative

office,

sanitary and employee facilities, and

control room;

d. periodic sweeping and cleaning -of floors in

RDF production area and boiler building;

e.

periodic cleaning ofturbine generator room;

f.

daily inspection and cleanup ofyard area from spillage, litter, and other foreign

materials;

g.

weekly cleaning and inspection ofmaintenance areas for orderliness and safety

compliance with industrial standards;

h.

weekly inspection and cleaning ofdrainage basins, oil-water separators, SUmpS, etc.

i.

weekly fire and safety inspections.

The time and results date ofeach inspection shall be maintained

lfl

the operating record.

20. The facility shall be maintained and operated to prevent nuisance odors and litter outside the

building by drawing air from inside the waste receiving, RDF processing and RDF storage

buildings for combustion air in the combustors (or venting air through the combustors when

they are not operational) and other necessary measures. Any litter present outside ofthe

building shall be collected daily.

21. The load checking program shall consist

of,

at a minimum, the following components:

1)

Random inspections

S

A. An inspector designated by the facility shall examine at least three random loads

ofsolid waste delivered to the landfill on a random day each week. The drivers

randomly selected by the inspector shall be directed to discharge their loads at a

---

Page 9

S

separate, designated location within the facility. The facility shall conduct a

detailed inspection of

the discharged material forany regulated hazardous or

other unacceptable wastes that may be present.

Cameras or other devices may be

S

used to record the visible contents of solid

waste shipments. Where such devices

are employed, theiruse should be designated on a sign posted near the entrance

of

the facility.

S

B. Ifregulated hazardous wastes or other unacceptable wastes are suspected, the

facility shall communicate with the generator, hauler or other party responsible

for shipping the waste to the facility to determine the identity ofthe waste.

2)

Recording inspection results

-

Information and observations derivedfrom each random inspection shall be recorded

in

writing

and retained at the facilityforat least three years. The recorded information

shall include, at a minimum the date and

time of

the inspection; the names ofthe

hauling firm and the driver ofthô vehicle; the vehicle license plate number; the source

ofthe waste, as stated by the driver; and

observations made

by.the inspector during

the

detailed inspection. The written record shall be signed by both the inspectorand the

driver.

S

S

The

“security wastes” are

excluded from the random inspection program.

22. The permittee shall

transport

the compostable waste stream to a properly permitted facility.

The only facilities in.Illinois which mayreceive this waste stream for composting are mixed

municipal waste composting facilitiea. Ifthe compostable stream includes landscape waste

that is not separated at the point ofgeneration and collected and processed separately from

the rest ofthe municipal waste stream, it is subjectto the disposal prohibitions in Section

22.22(c) ofthi~EnvironmentalProtection Act.

23. The Permittee(s) shall notify the illinois EPA’s Bureau ofLand in writing ofits intent to

close at least 45days prior to the date closure is expectedto begin. Along with this

notification, the Permittee(s) shall submit the procedure and the sampling and analysis plan

to be used in demonstrating the area has beenproperly decontaminated. This plan shall be

approved by the Illinois EPA’s Bureau ofLand in writing prior to being implemented.

24 The operator shall notify the Illinois EPA within 30 days after receiving the final volume of

waste.

25. The operator shall initiate implementation ofthe closure plan within 30 days afterthe site

receives its final volume ofwaste.

---

Page 10

26. The operator shall not file any

application to modify the closure plan less

than

180 days

prior to receipt ofthe final volume ofwaste.

S

27. Upon completion ofclosure activities, the operator will notify the illinois EPA that the

site

has been closed in accordance with the approved closure plan utilizing the illinois EPA’s

“Affidavit

for Certification of Completion of Closure of Non-Hazardous Waste Facilities.”

28. The Permittee is prohibited from placing white goods in the shredder unless

the white goods

components

have been removed.

S

29. The

Permittee may only bum

waste that has been processed into

RDF on site except for

those wastes identified as

“security waste”. A security waste is defined as municipal waste

where the

origin or circumstances effectively exclude the presence ofundesirable

components, such as household batteries; preclude recycling ofthe material; and generally

assure that the waste is ofa specific character ornature, as certified by the generator ofthe

waste and verified by the Permittee. Examples of securitywastes include garbage from

international

airline flights, which must be incinerated pursuant to US Department of

Agriculture Rules, and bank ormedical records, which must be destroyed to maintain

client/patient privacy. Security wastes must be managed in compliance with

the following

conditions:

S

a.

The constituents in security waste must be readily identified by visual inspection

notwithstanding any shredding or size reduction performed off-site;

b.

The Perinittee shall implement practices for handling ofsecuritywaste at the facility

that reasonãbi~’provide for identification and removal of any prohibited materials in

the waste. At a minimum, these procedures shall include continuous oversight ofeach

shipment of securitywaste at the facility by designated facility personnel until

unloading is complete and the waste is mixed with other waste or RDF; and

c.

The Permittee shall maintain records for each source and type ofsecurity waste

accepted by the facilityand confirm that suchwaste is properly considered security

waite and define the specific practices established forhandling such wasteatthe

facility, accompanied by reasonable supporting documentation and explanation. The

Permittee shall also maintain records for each shipment ofsecurity waste that is

received at the facility that include the date, time, waste source, hauler, typeand

amount ofwaste forthe shipment and that document implementation ofthe specified

handling procedures by the facility, including the names and personnel ofsupervising

the handling ofthe shipment

30. Only “security waste” as defmed in condition no. 29 and railroad ties may be placed into the

portable conveyor device.

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Page 11

31. The modifications: 1) to use

a portable conveyor to convey

security and railroad wastes

directly onto the shredder processing line, and (2) reduce the role ofthe strippercoolers to a

back-up role as approved in Supplemental Permit l998-030-DE are authorized for

construction and development only. The applicant must notify the Illinois EPA in writing

that development has been completed in accordance with the supplemental permit and

submit an application for.an operating permit before a pre-operation

inspection can

be

conducted or

an operating permit cánbe issued shall not be implemented until an operating

permit is approved.

-

Within 35 days afterthe date ofmailing ofthe illinois EPA’s final decision, the applicant may

petition for a

hearing before the illinois Pollution Control Board to contest the;decision ofthe

illinois

EPA, however, the 35-day period for

petitioning for a hearing may be extended for a

period oftime not to exceed 90 days by written

notice provided to the Board

from the applicant

and

the illinois EPA

within the 35-day initial appeal period.

S

F

Sincerely,

S

S~~’

~

Edwin C. Bakowski, P.E.

Manager, Permit Section

Bureau ofLand

ECB:MAS :bjh197301 2S.WPD

-~

bcc: Bureau File

Maywood Region

DLC-Kyle Davis

Ted Dragovich

Mark Schollenberger

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ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

217/524-3300

1021

Worth Grand Avenue East, P.O. Box 19276, Springfield. Illinois

62794-9276

Mary A. Gade, Director

June~3,1998

OWNER

-

Property

Village ofRobbins

3327 W. 137th Street

Robbins, illinois 60472

OPERATOR

Foster Wheeler Illinois, Inc.

13400 South Kedzie Avenue

Robbins, Illinois 60472

CERTIFIED MAIL

P

344 291 483

P 344

291 484

P 344 291 485

OWNER

-

Facility

Robbins Resource Recovery Partners, L.P.

Perryville Corporate Park

Clinton, New Jersey 08809-4000

Re: 0312700001

—

Cook

County

Robbins Resource Recovery

Permit No. 1990-068-DE

Permit

No. 1997-072-OP

Supplemental Permit l998-078-DE

Log

No. 1998-038, 1998-030, (1997-072, 1994-300, 1989-1 89)

State Permit File

Gentlemen:

This supplemental permit

is hereby granted to Village of Robbins as

property

owner, Robbins

Resource Recovery Partners, L.P. as

owner of the facility,

and

Foster

Wheeler illinois, Inc. as the

operator

to modify the operation ofthe

solid waste management site by

retrofitting two conveyors

with a head pulley magnet. The site consists ofa 16 acre site in the Village ofRobbins,

Cook

County, illinois.

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All pians,

specifications, application and supporting

documents as submitted and

approved shall

constitute

part

of

this

permit

and are

identified on the records of the illinois

Environmental

Protection Agency, Division ofLand Pollution Control by the permit number(s) and

log

number(s) designated in the heading above.

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The permit is issued subject to the standard conditions attached hereto and incorporated herein by

reference, and further

subject

to the following special conditions:

1.

This

permit allows

for the operation ofthe units listed below.

Jut~-

STER

~LUN

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.

.

3,.,~j.,.

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Page 2

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Unit Designation

Approximate Size

Proposed Use

a.

Tipping area

3000 ton capacity

storage ofwaste

prior to processing

b.

Portable shredder

5

tons per hour.

to shred bulky

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waste

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C.

Processing Lines (2)

80 to 100 tons per hour

i. primary trommel

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screening of waste

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~

shredder

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shredswastes over

5

inches in size

iii. magnets (7)

to remove

ferrous

material

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iv. secondary trommel

separationinto

sizes

ofwaste

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v. air

classifier

removal ofinert

material

vi. eddy

current

to remove

separator

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aluminum cans

vii.

picking station

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to remove

unacceptable

material for waste

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removal

and

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recoveryof

recyclable

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materials

viii. glass and

compost

to

separate organió

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recovery system

material from the

glass material

d. Circulating fluidized

600

ton per day (ave.)

-

5

bed boiler trains (2)

5

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Page3

5

5

i.

combustion chamber

waste to energy

ii.

cyclone

to remove

entrained material

iii. ~superheater

5to

raise steam

temperature above

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saturation

iv. economizers

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preheat

boiler

feedwater

v.

urea injection

to control NO~

emissions

e. Spray dryer absorber

size to handle approximately

to remove acid

baghouse system (2)

85,500 SCFM each

gases and

particulate

f.

Ash storage silos (2)

storage ofash prior

to disposal

5

g.

Ash conditioner

mixes water with

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ash

to control dust

Sh.

RDF storage building

3000 ton capacity

storage ofRDF

prior

to

burning

i.

All corresponding sumps,

pumps,piping, controls,

loading

and unloading

areas and appurtenances

2.

The Permittee may accept waste at the facility during periods ofcurtailed facility operations

under

the following conditions:

a.

During

the first 14 days of

curtailed operations waste

may be accepted normally;

b.

After fourteen days:

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Page4

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i.

if one incinerator is in service,no more than 1120 tons per day (nominal) ofwaste

may be accepted unless the excess amount can be processed or stored on site; and

ii. if both incinerators

are

out of service, no waste may be accepted

until

one

incinerator is placed back in service.

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c. Not withstanding the above, the Permittee may accept waste

for additional periods

during

extended

curtailed facility operations

caused by unusual circumstances only as

approved in

writing by

the Illinois EPA.

3.

This

facility shall not accept special waste (i.e., hazardous waste, potentially infectious

medical waste, pollution control waste or industrial

process waste). Special waste does not

include uncontaminated corrugated cardboard, wooden crates and pallets, plastics (both

packaging and rigid materials), office waste ~rimarily paper and plastic) and cafeteria

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waste.

4.

Special wastes (incinerator ash) generated at the site sent for dispOsal, storage, incineration

.

orillinoisfurtherEPA’s

treatment

supplementalelsewherepermitshall systembe

transportedand

manifestto

the

system.receivingThefacilityreceivingutilizingstate’sthe

manifest if required may be used in place ofan Illinois manifest.

5.

A copy ofall

records

and

reports required by

this permit

shall be

maintained in the facility’s

operating record. The operating

record shall be

made available by the Illinois EPA upon

request. All

information shall be maintained in the record for a period of

at least three years

beyond the date ofthe report.

6.

The following information shall be included in the operating record and recorded daily:

a.

the amount

of

waste

delivered,

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b. the amount ofRDF

produced (as calculated),

c.

the amount ofwaste rejected,

d.

the amount ofunacceptable waste removed,

e.

the amount ofmaterials recovered (e.g., Fe, Al, glass),

f.

the amount ofbottom and fly ash removed,

g.

where the above materials were taken to, and

h.

the date arid time any event results in the bypassing ofthe air pollution equipment,

i.

an inspection certification. The operator shall certify daily that all incoming railroad

ties were visually inspected. -

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• 7.

On an annual basis, the Permittee shall familiarize local emergency response units with the

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thesecontingencyrequirements.plan and document

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the date, time and

S contents ofmeetings held to complywith

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Page

5

8.

This permit is subject to review and modification by the Illinois EPA as deemed necessary

to fulfill the intent and purpose ofthe Environmental Protection Act and all applicable

environmental rules and regulations.

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9.

The Pennittee shall notify the Illinois EPA ofany cl~angesfrom the information submitted

to the illinois EPA in its application for a development and operating permit forthis site.

Any modifications to the facilities shall be the subject ofan application or supplement

permit submitted to the Illinois EPA forthose changes.

10. The incinerator ash destined for disposal shall be disposed ofonly in a properly permitted

landfill.

11. All

of

the ash meets the definition ofan industrial process waste and

the fly

ash portion

is

also considered a pollution control waste. The Permittee shall establish a reliable method of

determining the amount offly ash sent for disposal.

12. The Permittee shall submit a quarterly report to the Solid Waste Management Section,

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Division ofLand Pollution Control which summarizes the amount

of

industrial process

which

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waste andis apollutionpollution controlcontrol-wastewaste forwillpurposesbe exemptof thefromsolidfees.waste fee system. The portion

13.

The

Permittee

shall

collecta weekly grab sample

of the

incinerator ash. The results from

the analysis shall be made a part

of the operating record. The

weekly samples shall be

composited quarterly

and analyzed for the characteristics ofa hazardous waste by TCLP as

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described in 35 Ill. Adm.

Code 721.124 for the parameters; arsenic,

barium, cadmium,

chromium,

lead, mercury,

selenium and silver.

14. The followi~igconditions are included pursuant to Section 22.16b(b):

a.

The incinerator must be designed to provide continuous monitoring while in operation,

with direct transmissionofthe resultant data to the Illinois EPA, until the illinois EPA

determines the best available, controltechnology formonitoring the data. The illinois

EPA shall establish the test methods, procedures and averaging periods, as certified by

the form and frequency ofreport containing results ofthe monitoring. Compliance and

enforcement shall be based on such reports. Copies ofthe results of such monitoring

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shall be maintained on file at the facility concerned for one year, and copies shall be

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made available for inspection and copying by interestedmembers ofthe public during

business hours.

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Also, please refer to operating permit 8812055 issued by the Illinois EPA’s Bureau of

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~Air.

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Page 6

b.

The facility shall comply with the emission limits adopted by the illinois EPA under

subsection (c).

Also, please refer to operating permit 8812055 issued by the Illinois EPA’s Bureau of

Air.

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c.

The operator ofthe facility shall take reasonable measures to ensure that waste

accepted for incineration complies with all legal requirements forincineration. The

incinerator operator shall establish contractual requirements or other notification and

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inspection procedures sufficient to assure compliance with this subsection (b)(3) which

may include, but not be limited to, routine inspections ofwaste, lists ofacceptable and

unacceptable waste provided to haulers and notification to the Agency when the

facility operator reject and sends loads away. The notification shall contain at least the

name of the hauler and the site from where the load was

hauled.

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Also, please refer to Special Condition Nos.

15,

16

and 21 herein.

d.

The operator may not accept for incineration any waste generated or collected in a

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countymunicipalityplan, consistentthat

has notwithimplementedState

goalsaandrecyclingobjectives.plan

orSuchis partyplanstoshallan implementedinclude

provisions for collecting, recycling ordiverting from landfills and municipal

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incinerators landscape waste, household hazardous waste and batteries. Such

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provisions may be performed at the site ofthe new municipal incinerator.

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Also,

please refer to Special Condition No. 18 and

19, herein.

15. Waste may be received for segregation into waste categories, one ofwhich will be

incinerated on site and the other sent off-site. The Permittee shall not accept waste which

does not comply with the waste screening/analysis plan in the approved application Section

9.4 and Special Condition #3 herein. The procedures shall be modified to include screening

for all unacceptable or prohibited waste and comply with the following conditions:

a.

Upon unloading, the Permittee shall inspect each incoming load ofwaste to determine

ifthe load contains waste which this facility is not permitted to receive in accordance

with the procedures in the approved permit application Log 1989-189.

b.

The Permittee shall inspect all wastes prior to placement into the incinerator feed

system to remove waste which is unacceptable for incineration. Ifunacceptable waste

is discovered, it shall be diverted from the incinerator feed and transported to a unit

which is properlypermitted to receive the waste.

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c.

The Permittee shall notify the Illinois EPA in writing within 48 hours ofrejection ofa

load ofunacôeptable waste as described in the facilities waste inspection/analysis plan.

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Page7

The notification shall include at least the name ofthe hauler and site from where the

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load was hauled.

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d.

The Permittee shall visually inspect wastes which are processed to become part ofthe

refuse derivedfuel (RDF) system to remove wastes identified as prohibited waste in

the Waste Management Practice Plan. Such wastes shall include but not be limited to:

•

1.

explosives or ammunitions,

2.

combustible liquids or gas containers, bottles or cylinders or cans,

3.

batteries ofany type including dry cell, wet cell, motor vehicle or marine,

4.

special wastes (i.e., industrial process waste, hazardous waste, pollution control

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waste or potentially infectious waste),

5.

radioactive wastes,

6.

asbestos wastes,

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7.

waste regulated by the Toxic Substance Control Act,

8.

landscape waste,

9.

household hazardous waste,

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10. railroad ties treated with a material other than creosote,

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11.12. telephonetires.

poles, and

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e.

The Permittee shall provide a list ofwastes which are unacceptable for receipt at this

facility and list ofexamples ofacceptable waste to each hauler before the hauler

collects waste for transport to this facility.

16. The Permittee shall visually inspect used creosote-treated wood to

verify

that the wood is

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weathered and contains no surface deposits or stains. Unweathered wood, or wood which

contains surface staining or deposits, is subject to the requirements of35 111. Adm. Code

722.111 (by testing) to verify the wood is not characteristically hazardous.

17. Waste generated in illinois municipalities and Illinois counties outside of Hamilton County,

illinois as ofJune 2, 1997 are deemed to have complied with the requirements in Special

•

Condition 14(d) and no further documentation is required. Provisions for collecting,

recycling or diverting from landfills and municipal incinerators.landscape waste, household

hazardous waste and batteries may be performed at this site may be used to comply with

these requirements.

18. Prior to receipt of

waste

from out-of-state or Hamilton County, illinois, the Permittee shall

obtain a certification from the haulerthat the waste was generated or collected in a

municipality that has provisions for collecting, recycling or diverting household hazardous

waste from landfills and municipal incinerators.

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Page 8

19. The facility shall perform routine housekeeping as outlined in Section 9.3.2 ofthe approved

application Log #1989-189, to control litter. Routine housekeeping measures at a minimum

shall include:

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a.

inspection and maintenance ofthe equipment in accordance with

the

manufacturer’s

recommendations;

b.

periodic sweeping and cleaning oftipping floor, RDF

residue loading

area, and bottom

and fly ash loading area;

c.

dailyjanitorial cleaning ofadministrative office, sanitary and employee facilities, and

control room;

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d.

periodic sweeping and cleaning offloors in RDF production area and boiler building;

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e.

periodic cleaning ofturbine generator room;

f.

daily inspection and cleanup ofyard area from spillage, litter, and other foreign

materials;

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g.

weekly cleaning and inspection ofmaintenance areas for orderliness and safety

compliance with industrial standards;

h.

weekly inspection and cleaning ofdrainage basins, oil-water separators, sumps, etc.

i.

weekly fire and safety inspections.

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The time and results date of each inspection shall be maintained in the operating record.

20. The facility shall be maintained and operated to preventnuisance odors and litter outside the

building by drawing air from inside the waste receiving, RDF processing and RDF storage

buildings for combustion air in the combustors (or venting air through the combustors when

they are not operational) and other necessary measures. Any litter present outside ofthe

building shall be collected daily.

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21. The load checking program, shall consist of, at a minimum, the following components:

1)

Random inspections

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A. An

inspector designated by the facility

shall examine at least three random loads

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randomlyofsolid wasteselecteddeliveredby thetoinspectorthe landfillshallonbea randomdirecteddayto dischargeeach week.theirTheloadsdriversat a

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Page 9

separate, designated location within the facility. The facility shall conduct a

detailed inspection of the discharged

material for any regulated hazardous

or

other unacceptable wastes that may be present. Cameras or other devicesmay be

usedto record the visible contents ofsolid waste shipments. Where such devices

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are employed, their use should be designated on a sign posted near the entrance of

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the facility.

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B. Ifregulated hazardous wastes or other unacceptable wastes are suspected,

the

facility shall communicate with the generator, hauler or other party responsible

for shipping the waste to the facility to determine the identity ofthe waste.

2) Recording inspection results

Information and observations derived from each random inspection shall be recorded

in writing and retained at the facility for at leastthree years. The recorded information

shall include, at a minimum the date and time ofthe inspection; the names ofthe

hauling firm and the driver ofthe vehicle; the vehicle license plate number; the source

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ofthe waste, as stated by the driver; and observations made by the inspectorduring the

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detailed inspection. The written record shall be signed by both the inspector and the

driver.

The “security wastes” are excluded from the random inspection program.

22. The permittee shall transportthe compostable waste stream to a properly permitted facility.

The only facilities in illinois which may receive this waste stream for composting are mixed

municipal waste composting facilities. Ifthe compostable stream includes landscape waste

that is not separated at the point of generation and collected and processed separately from

the rest ofthe municipal waste stream, it is subjectto the disposal prohibitions in Section

22.22(c) ofthe Environmental Protection Act.

23. The Permittee(s) shall

notify

the illinois EPA’s Bureau ofLand in writing ofits intent to

close at least 45 days prior to the date closure is expected to begin. Along with this

notification, the Permittee(s) shall submitthe procedure and the sampling and analysis plan

to be used in demonstratingthe areahas been properly decontaminated. This plan shall be

approved by the illinois EPA’s Bureau ofLand in writing prior to being implemented.

24. The operatorshall notify the illinois EPA within 30 days after receiving the final volume of

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waste.

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25. The operator shall initiate implementation ofthe closure plan within 30 days afterthe site

receives its final volume ofwaste.

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Page 10

26. The operator shall not file any application to modify the closure plan less than

180

days

prior

to receipt~ofthe final volume ofwaste.

27. Upon completion ofclosure activities, the operator will notify the illinois EPA that the site

has been

closed in accordance

with the approved closure plan utilizing the illinois EPA’s

“Affidavit for Certification ofCompletion ofClosure ofNon-Hazardous Waste Facilities.”

28. The Permittee is prohibited from placing white goods in the shredder unless the white goods

components have been removed.

29. The Permittee may only bum waste that has been processed into RDF on site except for

those wastes identified as “security waste”. A security waste is defined as municipal waste

where the origin or circumstances effectively exclude the presence ofundesirable

components, such as household batteries; preclude recycling ofthe material; and generally

assure that the waste is of a specific character or nature, as certified by the generator ofthe

waste and verified by the Permittee. Examples ofsecurity wastes include garbage from

international airline flights, which must be incinerated pursuant to US Department of

Agriculture Rules, and bank ormedical records, which must be destroyed to maintain

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conditions:client/patient privacy. Security wastesmust be managed in compliance with the following

a.

The constituents in security waste must be readily identifiedby visual inspection

notwithstanding any shredding or size reduction performed off-site;

b.

The Permittee shall implement practices for handling ofsecurity waste at the facility

that reasonably provide for identification and removal ofany prohibited materials in

the waste. At a minimum, these procedures shall include continuous oversight ofeach

shipment ofsecurity waste at the facility by designated facility personnel until

unloading is complete and the waste is mixed with other waste or RDF; and

c.

The Permittee

shall

maintain records for each source and type

of

security waste

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accepted by the facility and confirmthat such waste is properlyconsidered security

waste and define

the

specific practices established for handling such waste at the

facility, accompanied by reasonable supporting documentation and

explanation. The

Permittee shall also maintain records for each shipment ofsecuritywaste that

is

received at the facility that include the date, time, waste source, hauler, type and

amount ofwaste

for the shipment

and

that document

implementation

ofthe

specified

handling procedures by the facility, including the names and personnel ofsupervising

the handling ofthe shipment

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30. portableOnly “security

convcyor

waste”device.as defmed in condition no. 29 and

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railroad ties may be placed into the

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Page 11

31. The modifications: 1) to use a portable conveyor to convey security and railroad wastes

directly onto the shredder processing line, and (2) reduce the role ofthe stripper coolers to a

back-up role as approved in Supplemental Permit 1998-030-DE are authorized for

construction and development only. The applicant must notify the illinois EPA in writing

that development has been completed in accordance with the supplemental permit and

submit an

application for

an operating permit before a pre-operation inspection can

be

conducted or an operating permit can be issued. The modifications shall not be

implemented until an operating permit is approved.

32.

The modification, to retrofit

the

two

existing conveyors (CR-354A and B) with a head

pulley

magnet,

is authorized for construction and development only. The applicant must

notify the illinois EPA in writing that developmenthas been completed in accordance with

the supplemental permit and submit an application for

an

operating

permit

before a pre-

operation inspection can

be

cotiducted or an operating permit can be. issued. The

modifications shall not be implemented until an operating

permit

is approved.

Within 35 days after the date ofmailing ofthe Illinois EPA’s final decision, the applicant may

petition for a hearing before the illinois Pollution Control Board to contest the-decision- ofthe

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periodillinoisofEPA,timehowever,not to exceedthe

35-day90

daysperiodby writtenforpetitioningnotice providedfor a hearingto themayBoardbefromextendedthe applicantfora

and the illinois EPA within the 35-day initial appeal period.

Sincerely,

Edwin C. Bakowski,

P.E.

Manager, Permit Section

Bureau ofLand

ECB:MAS :bjh\9730

1

2S.WPD

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STANDARD

CONDITIONS FOR CONSTRUCTION/DEVELOPMENT PERMITS

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ISSUED BY THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

July 1, 1979

The Illinois Environmental Protection Act (Illinois Revised Statutes,

Chapter 111-1/2, ~Section1039) grants the Environmental Protection AQency~

authority to impose conditions on permits which it issues.

These standard conditions shall apply to all permits which the Agency

issues for co.nstruction or development projects whicn require aermits

under the Divisions of Water Pollution Control,. Air Pollution Control,

Public Water Supplies, and Land and Noise Pollution Control. Special

conditions may also be imposed by the separate divisions in addition

to

these standard conditions.

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1. Unless this permit has been extended or it has, been voided by a

newely issued permit, this permitwill expire two years after date

of

issuance unless construction or development on this project has

started on or prior to that date.

2. The construction or development of facilities covered by this permit

shall be done in compliance with applicable provisiOns of Federal

laws and regulations,- the Illinois Environmental Protection Act,

and Rules and Regulations adopted by the Illinos Pollution Control

Board.

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j~

There shall be no deviations from the approved plans and specifi-

cations unless a written request for modification of the project,

along with plans and specifications as required, shall have been

submitted to the Agency and a supplemental written permit issued.

4. The permittee shall allow any agent duly authorized by the Agency

upon the presentation of credentials:

a. to enter at reasonable times the permittee’s premises-

where actual or potential effluent, emission or noise

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sources are located or where any activity is to be con-

ducted pursuant to this permit.

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b. to have access to and copy at reasonable times any

records required to be kept under the terms and con-

ditions of this permit.

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C.

to inspect at reasonable times, including during

any hours of operation of equipment constructed or

operated under this permit, such equipment or monitoring

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methodology or equipment required to be kept, used, operated,

calibrated and maintained -under this permit.

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.

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Printed

on

Recycled Pa~r

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d. to obtain and remove at reasonable times samples of any

discharge or emission of pollutants.

e. to enter at reasonable times and utilize any photographic,

recording, testing, monitoring or other equipment for the

purpose of preserving, testing, monitoring, or recording

any activity, discharge, or emission5 authorized by this

permit.

5. The issuance 0f this permit:

a. shall not be considered as in any manner affecting the title

of the premises upon which the permitted facilities are to

be located;

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b.

‘

does not release the permiittee from any liability for

damage to person or property caused by or resulting from

tht~construction, maintenance, or operation of the proposed

facil ities;

c. does not release the permittee from compliance with other

applicable statutes and regulations of the United States,

of the State of Illinois, or with

applicable local laws,

ordinances and regulations;

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d. does not take into consideration or attest to the structural

stability of any units or parts of the project;

e. in no manner implies or suggests that the Agency (or its

officers, agents or employees) assumes any liability, directly

or indirectly, for any loss due to damage, installation,

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maintenance, or operation of the proposed equipment or

facility.

6. Unless a joint construction/operation permit has been issued, a

permit for operating shall be obtained from the Agency before the

facility or equipment covered by this permit is placed into

operati on.

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7. These standard conditions shall prevail unless modified by special

conditions.

8. The Agency may file a compliant with the Board for modification,

suspension or revocation of a permit:

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a. upon discovery that the permit application contained

misrepresentations, misinformation or false statements

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or that all relevant facts were not disclosed; or

b. upon finding that any standard or special conditions have

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been violated; or

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c.

upon any violation of the Environmental Protection Act or

any Rule or Regulation effective thereunder as a result

of the construction or development authorized by this

permit.

MLK:dh/17

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ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021

North Grand Avenue East, P.O. Box

19276,

217/524-3300

Springfield, Illinois

62794-9276

Mary A. Gade, Director

July 31, 1998

OWNER

-

Property

Village ofRobbins

3327 W.

-

137th Street

Robbins, Illinois 60472

OPERATOR

Foster Wheeler Illinois, Inc.

13400 South Kedzie Avenue

Robbins, Illinois 60472

CERTIFIED MAIL

P 344 292 513

P 344 292 514

P 344 292 515

OWNER

-

Facility

Robbins Resource Recovery Partners, L.P.

Perryville Corporate Park

Clinton, New Jersey 08809-4000

Re: 0312700001

—

Cook County

Robbins Resource Recovery

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Permit No.

I

990-068-DE

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Permit No. 1997-072-OP

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Supplemental Permit 1998-208-OP/SUP

Log No. 1998-208, (1998-078, 1998-038, 1998-030, 1997-072, 1994-300, 1989-189)

State Permit File

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Gentlemen:

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This supplemental permit is hereby granted to Village ofRobbins as property owner, Robbins

Resource Recovery Partners, L.P. as owner ofthe facility, and Foster Wheeler illinois, Inc. as the

operatorto modify the operation ofthe solid waste management site to allow operation ofa

portable conveyor, two discharge hoppers and two modified conveyors which were authorized for

construction in supplemental permits 1998-078-DE and 1998-030-DE. The site consists of a 16

acre site in the Village ofRobbins, Cook County, Illinois.

All plans, specifications, application and supporting documents as submitted and approved shall

constitute part ofthis permit and are identified on the’records ofthe Illinois Environmental

Protection Agency, Division ofLand Pollution Control by the permit number(s) and log

number(s) designated in the heading above.

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The permit i~issued subjectto the standard conditions attached he~eth~.rdincorj~oratedherein by

reference, and further subject to the following special conditions:

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1. This permit allows for

the operation ofthe units listed below.

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Page2

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Unit

Desi~ation

Approximate Size

Proposed Use

a.

Tipping area

3000

ton capacity

storage of waste

prior to processing

b.

Portable shredder

5

tons per hour.

to shred bulky

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waste

c.

Processing Lines (2) -

80 to 100 tons per hour

i.

primary trommel

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screening of

waste

ii.

shredder

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shreds wastes over

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5

inches in size

iii. magnets (7)

to remove ferrous

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5

material

iv. secondary trommel

separation ofwaste

into sizes

-

-

v.

air classifier -

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removalofinert

material

vi. eddy currei~it

to remove

separator

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aluminum cans

vii. picking station

to remove

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unacceptable

material for waste

removal and

recovery of

-

-

recyclable

S

materials

viii. glass and compost

to

separate organic

recovery system

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material from the

glass material

d.

Circulating

fluidized

600 ton per day (ave.)

bed boiler trains (2)

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Page 3

i. combustion chamber

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waste to

energy

ii. cyclone

to remove

entrained material

iii. a superheater

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to

raise

steam

S

temperature above

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saturation

iv.

economizers

preheat boiler

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feedwater

v.

urea injection

to. control NO~

-

5

emissions

e.

Spray dryer absorber

size to handle approximately

to remove acid

baghouse system (2)

85,500 SCFM each

gases and

S

particulate

S S

f.

Ash storage silos (2)

storage ofash prior

S

-

to disposal

Sg.

Ash conditioner

mixes waterwith

-

S

ash to controldust

h.

RDF storage building

3000 ton capacity

storage ofRDF

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prior to burning

i.

All corresponding sumps,

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pumps, piping, controls,

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loading and unloading

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areas and appurtenances

-

.

-

2.

The Permitteemay accept wasteat the facility during periods of curtailed facility operations

-

under the following

condition&. ~SS~5~

SS 5

5

-

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a.

During the first 14 days ofcurtailed operations

waste

may be accepted normally;

b.

After fourteen days:

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Page 4

i.

if one incinerator is in service, no more than 1120 tons per day (nominal) ofwaste

may be accepted unless the excess amount can be processed or stored on site; and

ii.

if both incinerators are out of service, no waste may be accepted until one

-

incineratoris placed backin service.

c.

-

Not withstanding the above, the Permittee may accept waste for additional periods

during extended curtailed facility operations caused by unusual circumstances only as

approved in writing by the illinois EPA.

-

3.

This facility shall not accept special waste (i.e., hazardous waste, potentially infectious

medical waste, pollution control waste or industrial process waste). Special waste does not

include uncontaminated corrugated cardboard, wooden crates and pallets, plastics (both

packaging and rigidmaterials), office waste (primarily paper and plastic) and cafeteria

waste.

.5

-

4.

Special wastes (incineratorash) generated at the site sent for disposal, storage, incineration

or further treatment elsewhere shall be transported to the receiving facility utilizing the

Illinois EPA’s supplemental permit system and manifest system. The receiving state’s

manifest if required may be used in place of an Illinois manifest.

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5.

- A copy of all records and reports required by this permit shall be maintained in the facility’s

operating record. The operating record shall be made available by the illinois EPA upon

request. All information shall be maintained in the record fora period ofat least three years

beyond the date ofthe report.

6.

The following information shall be included in the operating record and recorded daily:

a.

the amount

of

waste delivered,

b.

the amount

of

RDF produced (as calculated),

c.

the amount ofwaste rejected,

d.

the amount ofunacceptable waste removed,

e.

the amount ofmaterials recovered (e.g., Fe,-Al, glass),

f.

the amount ofbottom and fly ash removed,

g.

where the above materials were takento, and

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h.

the date and time any event

results

in the bypassing ofthe air pollution equipment,

i.

an inspection certification. The operator shall certif~’daily that all incoming railroad

ties were visually inspected.

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7.

On an annual basis, the Permittee shall familiarize local emergency response units with the

contingency plan and document the date, time and contents ofmeetings heldto comply with

these requirements.

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Page

5

8.

This permit is subject to review and modification by the illinois EPA as deemed necessary

to fulfill the intent and purpose ofthe Environmental Protection Act and all applicable

environmental rules and regulations.

9.

The Permittee shall notify the illinois EPA ofany changes from the information submitted

to the illinoisSEPA in its application for a development and operating permit for this site.

Any modifications to the facilities shall be the subject ofan application or supplement

permit submitted to the Illinois EPA for those changes.

10. The incinerator ash destined for disposal shall be disposed of only in a properly permitted

landfill.

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11. All

of the

ash meets the definitioti ofan industrial process waste and the fly ash portion is-

also cQnsidered a pollution control waste. The Permittee shall establish a reliable method of

determining the amount offly ash sent for disposal.

12. The Pemrittee shall submit a quarterly report to the Solid Waste Management Section,

Division ofLand Pollution Control which summarizes the amount ofindustrial process

waste and pollution control waste for purposes ofthe solid waste fee system. The portion

which is a pollution co~itrolwaste will be exempt from fees.

13.

-

The Permittee shall collect a weekly grab sample ofthe incinerator ash. The results from

the analysis shall be made a part ofthe operating record. The weekly samples shall be

composited quarterly and analyzed forthe characteristics ofa hazardous waste by TCLP as

described in 35 Ill. Adm. Code 72 1.124 for the parameters; arsenic, barium, cadmium,

chromium, lead, meràury, selenium and silver.

14. The following conditions are included pursuant to Section 22.16b(b):

a.

The incinerator must be designed to provide continuous monitoring while in operation,

with direct transmission ofthe resultant data to the Illinois EPA, until the Illinois EPA

determines the best available control technology formonitoring the data. The illinois

EPA shall establish the test methods, procedures and averaging periods, as certified by

the form and frequencyofreport containing results ofthe monitoring. Compliance and

enforcement shall be based on such reports. Copies ofthe results ofsuch monitoring

shall be maintained on file at the facility concerned for one year, and copies shall be

made available for inspection and copying by interested members ofthe public during

business hours.

Also, please refer to operating permit 8812055 issued by the Illinois EPA’s Bureau of

Air.

-

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Page 6

b.

The facility shall comply with the emission limits adopted by the illinois EPA under

subsection (c).

Also, please refer to

operating

permit 8812055 issued by the illinois EPA’s Bureau of

Air.

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c.

-

The operator ofthe facility shall take reasonable measures to ensure that waste

accepted for incineration complies with all legal requirements forincineration. The

incinerator operator shall establish contractual requirements or other notification and

inspection procedures sufficient to assure compliance with this subsection (b)(3) which

may include, but not be limited to, routine inspections ofwaste, lists ofacceptable and

unacceptable waste provided to haulers and notification to the Agency when the

facility operator reject and sends loads away. The notification shall contain at least the

name ofthe hauler and the site from where the load was hauled.

Also, please refer to Special Condition Nos. 15, 16 and 21 herein.

d.

The operator may5 not accept for incineration any waste generated orcollected in a

municipality that has not implemented a recycling plan or is party to an implemented

county plan, consistent with State goals and objectives. Such plans shall include

provisions for collecting, recycling or diverting from landfills and municipal

-

S

incinerators landscape waste, household hazardous waste and batteries. Such

- provisions may be performed at the site ofthe new municipal incinerator.

Also, please refer to Special Condition No. 18 and 19, herein.

15. Waste may be received for segregation into waste categories, one ofwhich will be

incinerated on site and the other sent off-site. The Permittee shall not accept waste which

does not comply withthe waste screening/analysis plan in the approved application Section

9.4 and Special Condition ~3 herein. The procedures shall be modified to include screening

for all unacceptable or prohibited waste arid comply with the following conditions:

a.

-

Upon unloading, the Permittee shall inspect each incoming load ofwaste to determine

-

if the load contains waste which this facility is not permitted to receive in accordance

with the procedures in the approvedpermit application Log 1989-189.

-

b.

The Perrnittee shall inspect all wastes prior to placement into the incinerator feed

system to remove waste which is unacceptable for incineration. Ifunacceptable waste

is discovered, it shall be diverted from the incinerator feed and transported to a unit

which is properly permitted to receive the waste.

c.

The Permittee shall notify the Illinois EPA in writing within 48 hours of rejection of a

load ofunacceptable waste as described in the facilities waste inspectionlanalysis plan.

---

Page7

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The notification shall include at least the name ofthe hauler and site from where the

load was hauled.

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d.

The Permittee shall visually inspectwastes which are processed to become part ofthe

refuse derived fuel (RDF) system to remove wastes identified as prohibited waste in

the Waste ManagementPractice Plan. Such wastes shall include but not be limited to:

1.

explosives or ammunitions,

2.

combustible liquids

S

or gas containers, bottles or cylinders or cans,

3.

batteriesof any type including dry cell, wet cell, motor vehicle or marine,

4.

special wastes(i.e., industrial process waste, hazardous waste, pollution control

waste orpotentially infectious waste),

5.

radioactive wastes,

-

S

6.

asbestos,wastes,

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7.

waste regulated by the Toxic Substance Control Act,

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8.

landscape waste,

9.

household hazardous waste,

10. railroad ties treated with a material other than creosote,

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11. telephone poles, and

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12. tires.

-

S

S

e.

The Permittee shall provide a list ofwastes which are unacceptable for receipt at this

facility and list ofexamples ofacceptable waste to each hauler before the hauler

collects waste for transport to this facility.

16. The Permittee shall visually inspect used creosote-treated wood to verify that the wood is

weathered and contains no surface deposits or stains. Unweathered wood, or wood which

-

contains surfa~estaining or deposits, is subject to the requirements of35 ill. Adm. Code

722.111 (bytesting) to verify the wood is not characteristicallyhazardous.

17.

-

Waste generated in illinois municipalities and Illinois counties outside ofHamilton County,

illinois as ofJune 2, 1997 are deemed to have complied with the requirements in Special

Condition 14(d) and no further documentation is required. Provisions forcollecting,

recycling or diverting from landfills and municipal incinerators landscape waste, household

hazardous waste arid batteries may be performed at this site may be used to comply with

theserequirements.

--

5

5

-

S S

18. Prior to receipt ofwaste from out-of-state or Hamilton County, illinois, the Pemmittee shall

obtain a certification from the hauler that the waste was generated or collected in a

municipality that has provisions forcollecting, recycling or diverting household hazardous

waste from landfills and municipal incinerators.

---

Page8

19. The facility shall perform routine housekeeping as outlined in Section 9.3.2 ofthe approved

application Log #1989-189, to control litter. Routine housekeepingmeasures at a minimum

shall include:

S

a.

inspection and maintenance ofthe equipment in accordance with the

manufacturer’s

recommendations;

b.

periodic sweeping and cleaning oftipping floor, RDF residue loading area, and bottom

and fly ash loading area;

c.

daily janitorial cleaning ofadministrative office, sanitary and employee facilities, and

control room; -

d.

periodic sweeping and cleaning of floors in RDF production area and boiler building;

e.

periodic cleaningofturbine generator room;

f.

daily inspection and cleanup ofyard areafrom spillage, litter, and other foreign

materials;

g.

weekly cleaning and inspection ofmaintenance areas fororderliness and safety

-

S

compliance with, industrial standards;

S

h.

weekly inspection and cleaning ofdrainage basins, oil-water separators, sumps, etc.

i.

weekly fire and safety inspections.

The time and resultsdate ofeach inspection shall be maintained in the operating record.

20. The facility shall be maintained and operated to preventnuisance odors and litter outside the

building by drawing air from inside the waste receiving, RDF processing and RDFstorage

buildings for combustion air in the combustors (or venting air through the combustors when

they are not operational) and other necessary measures. Any litter present outside ofthe

building shall be collected daily.

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21. The load checking program shall consist

of,

at a minimum, the following components:

1)

Random inspections

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A. An inspector designated by the facility shall examine at least three random loads

of solid waste delivered to the landfill on a random day each week. The drivers

randomly selected by the inspector shall be directed to discharge their loads at a

---

Page9

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separate,

designated location within the facility. The facility shall conduct a

-

detailed inspection ofthe discharged material fOr any regulated hazardous or

otherunacceptable wastes that maybe present. Cameras or other devices may be

used

to recordthe visible contents ofsolid

waste

shipments. Where such devices

are employed, their use should be designated on a sign posted near the entrance of

the facility.

B.

Ifregulated hazardous wastes or other unacceptable wastes are suspected, the

facility shall

communicate

with the generator,. hauler or other

party

responsible

for shipping the waste to the facility to determine the identity- of the waste.

2)

Recording inspection results

Information and observations.derived from each randominspection shall be recorded

in writing and retained at the facility for at leastthree years. The recorded information

shall include, at a minimum the date and time ofthe inspection; the names ofthe

hauling firm and tli. driver ofthe vehicle; the vehicle license plate number; the source

ofthe waste, as stated by the driver; and observations made by the inspector during the

detailed inspection. The written record shall be signed by both the inspector and the

driver.

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-

-

The “security wastes” are excluded from the random inspection program.

22. The permittee shall transpärt the compostable waste stream to a

properly permitted facility.

The only fatilities in Illinois which may receive this waste stream for composting are mixed

municipal waste composting facilities. Ifthe compostable stream includes landscape waste

that is not separated at the point ofgeneration and collected and processed separately from

the rest ofthe municipal waste stream, it is subject to the disposal prohibitions in Section

22.22(c) ofthe Environmental Protection Act.

23. The Permittee(s) shall notify the illinois EPA’s Bureau ofLand in writing of its intent to

close at least 45 days prior to the date closure is expected to begin. Along with this

notification, the Permittee(s) shall submit the procedure and the sampling and analysis plan

to be used in demonstrating the area has been properly decontaminated. This plan shall be

approved by the Illinois EPA’s Bureau ofLand in writing prior to being implemented.

24. The operator shall notify the illinois EPA within 30 days after receiving the final volume of

waste.

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25. The operator shall initiate implementation ofthe closure planwithin 30 days afterthe site

receives its final volume of waste.

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Page 10

26. The operatorshall not file any application to modify the closure plan less than 180 days

prior to receipt ofthe final volume ofwaste.

27. Uponcompletion ofclosure activities, the operator will

notify

the Illinois EPA that the site

has been closed in accordance with the approved closure plan utilizing the Illinois EPA’s

“Affidavit for Certification ofCompletion ofClosure ofNon-Hazardous Waste Facilities.”

28. The Permittee is prohibited from placing white goods in the shredder unless the white goods

components have been removed.

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-

29. The Permittee may only bum waste that has been processed into RDFon site except for

those wastes identified as “security waste”. A security waste is defined as municipal waste

where the origin or circumstances effectively exclude the presence ofundesirable

components, such as household batteries; preclude recycling ofthe material; and generally

assure that the waste is ofa specific character or nature, as certified by the generator ofthe

waste and verified by the Permittee. Examples ofsecurity wastes include garbage from

international airline flights, which must be incineratedpursuant to US Department of

Agri~ultureRules, and bank

or medical

records, which must be destroyed to maintain

clientlpatient privacy. Securitywastes must be managed in compliance with the following

S

conditions:

-

a.

The

constituents

in security waste must be readily identified by visual inspection

S

notwithstanding any shredding or size reduction performed off-site;

b.

The Permittee shall implement practices forhandling ofsecurity waste at the facility

that reasonablyprovide for identification and removal ofany prohibited materials in

the waste. At a minimum, these procedures shall include continuous oversight ofeach

shipment of security waste at the facility by-designated facilitypersonnel until

unloading is complete and the waste is mixed with other waste orRDF; and

c.

The Peimittee shall maintain records for each source and type ofsecurity waste

S

accepted by the facility and confirm that such waste is properly considered security

-

waste and define the specific practices established for handling suchwaste at the

facility, accompanied by reasonable supporting documentation and explanation. The

Pennittee shall also maintain records for each shipment ofsecuritywaste that is

received at the facilitythat include the date,-time, waste. source, hauler, type and

amount ofwaste for the shipment and that document implementation ofthe specified

handling procedures by the facility, including the names and personnel ofsupervising

the handling ofthe shipment.

30. Only “security waste” as defined in condition no. 29 and railroad ties may be placed into the

portable conveyor device.

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Pagell

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-

Within

35

days after the date of mailing ofthe Illinois EPA1s final decision, the applicant may

petition for a hearing before the illinois Pollution Control Board to contest the decision ofthe

illinois EPA, however, the 35-day period forpetitioning for a hearing may be extended for a

period oftime not to exceed 90 days by written notice provided to the Board from the applicant

and the illinois EPA within the 35-day initial appeal period.

Sincereiy~,

S

S

Edwin C. Bakowski, P.E.

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Manager, Permit Section

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Bureau of Land

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-

.-~--~

ECB:~S:bjh\9730l2S.WPD

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bcc: Bureau File

-

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Maywood Region~

DLC- Kyle Davis

Ted Dragovich

Dennis

McMurray

S

S

-

Don

Sutton

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Mark Schol 1 enberger

-

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STANDARD

CONDITIONS

FOR CONSTRUCTION/DEVELOPMENT PERMITS

ISSUED BY THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

July 1, 1979

The Illinois Environmental Protection Act (Illinois Revised Statutes,

Chapter 111-1/2, Section 1039) grants the Environmental Protection Agency

authority to impose conditions

on

permits whichit issues.

These standard conditions shall ap~ly to all permits which the Agency

issues for construction or development projects which require permits

under the Divisions of Water Pollution Control, Air Pollution Control,

Public Water Supplies, and Land and Noise Pollution Control. Special

conditions may also be imposed by the separate divisions in addition

to

these standard

conditions.

S

S

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1. Unless this permit has been extended or it has been voided by a

newely issued permit,

this

permit

will

expire two years after date

of

issuance unless construction or development on this project has

started on or prior to that date.

2. The construction or development

Of -facilities

covered by this permit

shall be done

its’

compliance with applicable provisions of Federal

laws and regulations, the Illinois Environmental Protection Act,

and Rules and Regulations adopted by the Illinos Pollution Control

Board.

-

3.

There shall

be no deviations from the approved plans and specifi-

cations sunless a written request for modification of the project,

along with plans and specifications as required, shall have been

-submitted, to the Agency and a supplemental written permit issued.

4.

The perTnittee shall alldw any agent duly authorized by the Agency

upon the presentàtion of credentiaFs:

S

a. to enter at”réasonable times the permitte&s premises

where actual or potential effluent, emission or noise

sources are

located

or

where

any

activity is to be

con-

ducted pursuant to this permit.

b.

to have access to and copy at reasonab’e times any

records requiredto be kept under the terms and con-

ditions of this permit.

c. to inspect at reasonable times, including during

any hours of operation of equipment constructed or

operated under this permit, such equipment or monitoring

-

methodology, or equipment re4üi~d’to’be’kept, used, operated,

calibrated and maintained under this permit.

Printed on Recycled Paper

---

d. to obtain and remove at reasonable times samples of any

S

discharge or emission of pollutants.

e. to enter at reasonable time’s and utilize any photographic,

recording, testing, monitoring or other equipment for the

purpose of preserving, testing, monitoring, or recording

any activity, discharge, or emission authorized by this

S

permit.

S

S.

The issuance of this permit:

a. shall not be considered as in any manner affecting the title

of the premises upon which the permitted facilities are to

be located;

b. 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 proposed

facilities;

c. does not release the

permittee from compliance wi-th other

applicable statutes and regulations of the United States,

of the State of Illinois, or with applicable local laws,

ordinances and regulations;

d. does not take into consideration or attest to the structural

stability of any units or parts of the project;

e. in no manner implies or suggests that the Agency (or its

officers, agents or employees) assumes any liability, directly

- or indirectly, for

any ‘loss due to damage, installation,

maintenance, or operation of the proposed equipment or

facility.

6.

Unless a joint construction/operation permit has been issued, a

permit for operating shall be obtained from the Agency before the

facility .,or equipment covered by this permit

is placed into

operati on.;~

7.

These standard conditions shall prevail unless modified by special

condi ti ons.

8. The Agency may file a compliant with~the Board for *~odification,

suspension or revocatio,n of

a permit:

a. upon discovery that the permit application contained

misrepresentations, misinformation or false statements

or that all

relevant facts were not disclosed; or

b. upon finding that any standard or special conditions have

been violated; or

c. upon any violation of the Environmental Protection Act or

any Rule or Regulation effective thereunder as a result

of the construction or development authorized by this permit.

MLK:

dh/

17

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-,

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ftLINOIS ENVIRONMENTAL PROTECTiON

AGENCY

1021 NORTH GRAND AVENUE EAST, P.O. Box 19276, SPRINGFIELD, ILINOIS 62794.9276

THOMAS V. SKINNER, DIRECTOR

217/524-3300

S

CERTIFIED MAIL

June 10, 1999

P 344 301 927

P 344

301

928

~p 344

301 929

OWNER

-

Property

,

S

OWNER

-

Facility

Village ofRobbins

-

Robbins Resource Recovery Partners, L.P.

3327 W. 137th Street

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Perryville Corporate Park

-

Robbins, Illinois 60472

Clinton, New Jersey 08809-4000

OPERATOR

- ,

-

Foster Wheeler illinois, Inc.

13400 South Kedzie Avenue

Robbins, Illinois 60472

Re: 0312700001—Cook County

Robbins Resource Recovery

Permit

No. 1990-068-DE

Permit No. 1997-072-OP

Supplemental Permit 1998-3 14-DE/SUP

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Log Nos. 1998-314, 1998-409, (1998-208, 1998-078, 1998-038, 1998-030, 1997-072, 1994-

300, 1989-189)

State Permit File

Gentlemen:

This supplemental permit is hereby granted to Village of Robbins as property owner, Robbins

Resource Recovery Partners, LP. as

owner

ofthe facility, and Foster Wheeler Illinois, Inc. as the

operator to modify the operation ofthe solid waste management site by modifying the conveyors

for the trommel system (Log No. 1998-314) and installating (development only) an emergency

feedwater pump (Log No. 1998-409). The site consists of a 16 ‘acre site in the Village ofRobbins,

Cook County, Illinois.

All plans, specifications, application and supporting documents as submitted and approved shall

constitute part ofthis permit and are identified on the records ofthe Illinois Environmental

Protection Agency, Division ofLand Pollution Control by the permit number(s) and log

number(s) designated in the heading above.

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The permit is issued subjectto the standard conditions attached hereto and incorporated herein by

I

~

reference, and further subject to the following special conditions:

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Page 2

1.

This permit allows for the operation ofthe units listed below.

Unit Designation

Approximate Size

Proposed Use

a.

Tipping area

3000 ton capacity

storage ofwaste

prior to processing

b.

Portable shredder

-

5

tons per hour.

to shred bulky

waste

c.

Processing Lines (2)

80 to 100 tons per hour

i.

primary trornmel

screening ofwaste

‘ii.

shredder

shreds wastes over

5

inches in size

5

iii. magnets (7)

to remove ferrous

material

iv.

secondary trommel

separation ofwaste

into’ sizes

v.

air classifier

removal of inert

material

vi. eddy current

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to remove

-

separator

aluminum cans

vii. picking station

to remove

unacceptable

material for waste

removal and

recovery of

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recyclable

materials

viii. glass and compost

to separate organic

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S

recovery

,

system

materialglass materialfrom the

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Page 3

d.

Circulating fluidized

600 ton per day (ave.)

bed boiler trains (2)

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j~ combustion chamber

waste to energy

ii.

cyclone

to remove

S

-

entrained material

iii.

a superheater

-

to raise steam

temperature above

S

saturation

iv. economizers

preheat boiler

feedwater

v.

urea injection

to controlNO~

S

emissions

S

e.

baghouseSpray

dryersystemabsorber(2)

size85,500to handleSCFMapproximatelyeach

togasesremoveand acid

particulate

f.

Ash storage silos (2)

storage of ash prior

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to disposal

g.

Ash conditioner

mixes water with

ash to control dust

h.

RDF storage building

3000 ton capacity

storage ofRDF

S

prior to burning

i.

All corresponding sumps,

pumps, piping, controls,

S

S ‘

, loading and unloading

S

areas and appurtenances

2.

The Permittee may only develop (install) the emergency feedwater pump. Units authorized

S

for development only may not be placed into operation until an operating permit for these

5

,

units is granted by the Bureau of Land.

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3.

underThe

Permitteethe

followingmay

acceptconditions:waste at the facility during periods ofcurtailed facility operations

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Page 4

a.

During the first 14 days of curtailedoperations waste may be accepted normally;

b.

After fourteen days:

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i.

if one incinerator is in service, no more than 1120 tons per day (nominal) ofwaste

may be accepted unless the excess amount can be processed or stored on site; and

ii.

if both incinerators are out of service, no waste may be accepted until one

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‘incinerator is placed back in service.

c.

Not withstanding the above, the Permittee may accept 1~astefor additional periods

during extended curtailed facility operations caused by unusual circumstances only as

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approved in writing by the Illinois EPA.

4.

‘I’his facility shall not accept special waste (i.e., hazardous waste, potentially infectious

medical waste, pollution control waste or industrial process waste). Special waste does not

include uncontaminated corrugated cardboard, wooden crates and pallets, plastics (both

S

5

packaging and rigid materials), office waste (primarily paper and plastic) and cafeteria

5

5

waste.,

5.’ Special wastes (incinerator ash) generated at the site sent for disposal, storage, incineration

or further treatment elsewhere shall be transported to the receiving facility utilizing the

Illinois EPA’s supplemental’permit system and manifest system. The receiving state’s

manifest ifrequired may be used in place ofan Illinois manifest.

6.

A copy ofall records and reports required by this permit shall be maintained in the facility’s

operating record. The operating record shall be made available by the Illinois EPA upon

request. All information shall be maintained in the record for a period of at least three years

beyond

the date of the report.

-

7.

The following information shall be included in the operating record and recorded daily:

a.

the amount ofwaste delivered,

b.

the amount of RDF produced (as calculated),

c.

the amount of waste rejected,

d.

the amount ofunacceptable waste removed,

e.

the amount ofmaterials recovered (e.g., Fe, Al, glass),

.

f.g.

thewhereamountthe

above

of bottommaterialsand flywereashtakenremoved,to,

‘and

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h.

the date and time any event results in the bypassing ofthe air pollution equipment,

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i.

tiesan

inspectionwere

visuallycertification.inspected.The

operator shall certify

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daily that all incoming railrOad

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.

Page 5

8.

On an annual basis, the Permittee shall familiarize local emergency response units with the

contingency plan and document the date, time and contents of meetings held to comply with

these requirements.

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9.

This permit is subject to review and modification by the Illinois EPA as deemed necessary to

fulfill the intent and purpose ofthe Environmental Protection Act and all applicable

environmental rules and regulations.

10. The Permittee shall notify the Illinois EPA ofany changes from the information submitted to

the Illinois EPA in its -application for a development and operating permit for this site. Any

modifications to the facilities shall be the subject of an application or supplement permit

S

submitted to the Illinois EPA for those changes.

5

5

5

11. The incinerator ash destined for disposal shall be disposed of only in a properly permitted

landfill.

12. All ofthe ash meets the definition ofan industrial process waste and the fly ash portion is

5

also ‘considered a pollution control waste. The Permittee shall establish a reliable method of

5

determining the amount offly ashsent for disposal.

13. The Permittee shall submit a quarterly report to the Solid Waste Management Section,

Division ofLand Pollution Control which summarizes the amount ofindustrial process

waste and pollution control waste for purposes ofthe solid waste fee system. The portion

which is a pollution control waste will be exempt from fees.

14. The Permittee shall collect a weekly grab sample ofthe incinerator ash. The results from the

analysis shall be made a part ofthe operating record. The weekly samples shall be

composited quarterly and analyzed for the characteristics ofa hazardous waste by TCLP as

described in 35 111. Adm. Code 721.124 forthe parameters; arsenic, barium, cadmium,

chromium, lead, mercury, selenium and silver.

I

15. The following conditions are included pursuant to Secti’on 22.1 6b(b):

a.

The incineratormust be designed to provide continuous monitoring while in operation,

with direct transmission ofthe resultant datato the Illinois EPA, until the Illinois EPA

determines the best available control technology for monitoring the data. The Illinois

EPA shall establish the test methods, procedures and averaging periods, as certified by

the form and frequency ofreport- containing results ofthe monitoring. Compliance and

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shallenforcementbe maintainedshall

beonbasedfile

atonthesuchfacilityreports.concernedCopiesforoftheoneresultsyear, andof

suchcopiesmonitoringshall

be

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madebusinessavailablehours. for inspection and copying by interested members ofthe public during

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5

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Page 6

Also, please refer to operating permit

8812055 issued by the Illinois EPA’s Bureau of

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Air.

b. The facility shall comply with the emission limits adopted by the Illinois EPA under

subsection (c).

-

Also, please refer to operating permit 8812055 issued b-y the Illinois EPA’s Bureau of

Air.

-

-

c.

The operator ofthe facility shall take reasonable measures to ensure that waste

accepted for incineration complies with all legal requirements for incineration. The

incinerator operator shall establish contractual requirements or other notification and

inspection

procedures sufficient to assure compliance with this subsection (b)(3) which

may include, but not be limited to, routine inspections of waste, lists ofacceptable and

unacceptable waste provided to’ haulers and notification to the Agency when the facility

operatorreject and sends loads away. The notification shall contain at leastthe name

ofthe haulerand the site from where the load was hauled.

5

‘Also, pleaserefer to Special Condition Nos. 16, 17 and 22 herein.

-

d.

The operator may not accept for incineration any

waste

generated or collected in a

municipality that has not implemented a recycling plan or is party to an implemented

county plan, consistent with State goals and objectives. Such plans shall include

provisions for collecting, recycling or diverting from landfills and municipal

incinerators landscape waste, household hazardous waste and batteries. Such

provisions may be performed at the site ofthe new municipal incinerator.

Also, pleaserefer to Special Condition No. 19 and 20, herein.

16. Waste may be received for segregation into waste categories, one of which will be

incinerated

on site

and the other sent off-site. The Perrnittee shall not accept waste which

does not comply with

the

waste

screening/analysis plan in the approved application Section

9.4 and Special Condition ~4 herein. The procedures shall be modified to include screening

for all unacceptable or prohibited waste and

comply

with the following conditions:

-

a.

Upon unloading, the Permittee shall inspect each incoming load ofwaste to determine

if the load contains waste which this facility is not-permitted to receive in accordance

with the procedures in the approved permit application Log 1989-189.

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b.

The Permittee shall inspect all wastes prior to placement into the incinerator feed

S

systemis

discovered,to

removeit

shallwastebe

whichdivertedis

fromunacceptablethe incineratorfor

incineration.feed

and

transportedIfunacceptableto a

unitwaste

which is properly permitted to receive the waste.

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5

Page7

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c.

The Perrnittee shall notify the Illinois EPA in writing within 48 hours of rejection of a

load ofunacceptable waste as described in the facilities waste inspection/analysis plan.

The notification shall include at least the name ofthe hauler and site from where the

load was hauled.

d.

The Perrnittee shall visually inspect wastes which are processed to become part ofthe

refuse derived fuel (RDF) system to remove wastes identified as prohibited waste in the

Waste Management Practice Plan. Such wastes shall include but not be limited to:

1.

explosives or ammunitions,

2.

combustible liquids or gas containers, bottles or cylinders or cans,

3.

batteries ofany type including dry cell, wet cell, motor vehicle or marine,

4.

special wastes (i.e., industrial process waste, hazardous waste, pollution control

waste or potentially infectious waste),

5.

radioactive wastes,

6.

asbestos wastes,

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7.8.

wastelandscaperegulatedwaste,by the Toxic Substance Control Act,

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9.

household hazardous waste,

10. railroad ties treated with a material other than creosote,

11. telephone poles, and

12. tires.

e.

The Permittee shall provide a list ofwastes which are unacceptable for receipt at this

facility

and list of examples of acceptable waste to each hauler before the hauler

collects waste for

transport

to this facility.

17. The Permittee shall visually inspect used creosote-treated wood to verify that the wood is

weathered and contains no surface deposits or stains. Unweathered wood, or wood which

contains surface staining

or deposits, is subject to the requirements of 35 Ill.

Adm. Code

722.111

(by testing)

to verify the wood is

-not characteristically hazardous.

18. Waste generated in Illinois municipalities and Illinois counties outside of Hamilton County,

Illinois as ofJune 2, 1997 are deemed to have complied with the requirements in Special

Condition 15(d) and no further documentation is required. Provisions for collecting,

- recycling or diverting from landfills and municipal incinerators landscape waste, household

hazardous waste and batteries may be performed at this site may be used to comply with

these requirements.

19. Prior to receipt ofwaste from out-of-state or Hamilton County, Illinois, the Permittee shall

S

municipalityobtain

a certificationthat

has

fromprovisionsthe haulerfor,collecting,that the wasterecyclingwas generatedor

divertingor

collectedhouseholdinhazardousa

waste from landfills and municipal incinerators.

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.5

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Page8

20.

The facility shall perform routine housekeeping as outlined in Section 9.3.2 ofthe approved

application Log #1989-189, to control litter. Routine housekeeping measures at a minimum

shall

include:

-

a.

inspection and maintenance ofthe equipment in a.ccordance with the manufacturer’s

recommendations;

b.

periodic sweeping and cleaning oftipping floor, RDF residue loading area, and bottom

and fly ash loading area;

c.

daily janitorial cleaning ofadministrative office, sanitary and employee facilities, and

control room;

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d.

periodic sweeping and cleaning offloors in RDF production area and boiler building;

e.

periodic cleaning ofturbine generator room;

f.

daily inspection and cl~anupofyard area from spillage, litter, and other foreign

5

materials;

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g.

weekly cleaning and inspection ofmaintenance areas for orderliness and safety

compliance with industrial standards;

h.

weekly inspection and cleaning ofdrainage basins, oil-water separators, sumps, etc.

i.

weekly fire and safety inspections.

The time and results date ofeach inspection shall be maintained in the operating record.

21. The facility shall be maintained and operated to prevent nuisance odors and litter outside the

building by drawing air from inside the waste receiving, RDF processing and RDF storage

buildings for combustion air in the combustors (or venting air through the combustors when

they are not operational) and other necessary measures. Any litter present outside ofthe

building shall be collected daily.

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22. The load checking program shall consist of, at a minimum, the following components:

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i)

Random inspections

A. An inspector designated by the facility shall examine at’least three random loads

ofsolid waste delivered to the landfill on a random day each week. The drivers

randomly selected by the inspector shall be directed to discharge their loads at a

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Page 9

separate, designated location within

the facility. The facility shall conduct a

detailed inspection ofthe discharged material for’ any regulated hazardous or other

unacceptable wastes that may be present. Cameras or other devices may be used

to record the visible contents of solid waste shipments. Where such devices are

employed, their use should be designated. on a sign posted near the entranceofthe

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facility.

5

B.

Ifregulated hazardous wastes or other unacceptable wastes are suspected, the

facility shall communicate with the generator, hauler or other party responsible for

S

shipping the waste to the facility to determine the identity ofthe waste.

2)

Recording inspection results

Information and observations derived from eachrandom inspection shall be recorded in

writing and retained at the facility for at least three years. The recorded information

shall include,

at a minimum the date

and time

ofthe

inspection;

the

names

ofthe

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ofhaulingthe waste,firm andas stated

the

driverby theofdriver;the

vehicle;and

observationsthe

vehicle licensemade

byplatethe inspectornumber;

theduringsourcethe

detailed inspection. The written record shall be signed by both the inspector and the

driver.

The “security wastes” are

excluded from the random

inspection program.

23. The permittee shall transport the compostab’le waste stream to a properly permitted facility.

The only facilities in Illinois which may receive this waste stream for composting are

mixed

municipal waste composting facilities. Ifthe compostable stream includes landscape waste

that is not separated at the point ofgeneration and collected and processed separately from

the rest ofthe municipal waste stream, it is subject to the disposal prohibitions in Section

22.22(c) ofthe Environmental Protection Act.

-

24. The Permittee(s) shall notify the Illinois EPA’s Bureau ofLand in writing ofits intent to

close at least45 daysprior to the date closure is expected to begin. Along with this

notification, the Permittee(s) shall submit the procedure and the sampling and analysis plan

S

to be used in demonstrating the area has been properly decontaminated. This plan shall be

approved by the Illinois EPA’s Bureau ofLandin writing prior to being implemented.

25. The operator shall notify the Illinois EPA within 30 days after receiving the finalvolume of

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waste.

26. The Operator shall initiate implementation ofthe closure plan within 30 days after the site

5

receives its final volume ofwaste.

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5

Page 10

27. The operator shall not file any application to modify the closure plan less than 180 days

prior

to receipt ofthe final volume ofwaste.

28. Upon completion ofclosure activities, the operator will notify the Illinois EPA that the site

has been closed in accordance with the approved closure plan utilizing the Illinois EPA’s

“Affidavit for Certification ofCompletion ofClosure ofNon-Ha.zardous Waste Facilities.”

29.

The Permittee is prohibited from placing white goods in the shredder unless the white goods

components have been removed.

30. The Permittee may only bum waste that has been processed into RDF on site except for

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those wastes identified as “security waste”. A security waste is defined as municipal waste

where the origin or circumstances effectively exclude the presence ofundesirable

components, such as household batteries; preclude recycling ofthe material; and generally

assure that the waste is of a specific character or

nature, as

certified by the

generator of the

waste and verified by the Permittee. Examples ofsecurity wastes include garbage from

S

AgricultureinternationalRules,airlineandflights,bankwhichor medicalmust records,be incineratedwhichpursuantmust be destroyedto US Departmentto maintainof

-

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conditions:clientipatient privacy. Security wastes must be managed in compliance with the following

a~ The constituents in security waste must be readily identified by visual inspection

notwithstanding any shr~ddingor size reduction performed off-site;

b.

The Permittee shall implement practices for handling of security waste at the facility

that reasonably provide for identificationand removal ofany prohibited materials in the

waste. At a minimum, these procedures shall include continuous oversight ofeach

shipment ofsecurity waste at the facility by designated facility personnel until

S

unloading is complete and the waste is mixed with other waste or RDF; and

c.

The Permittee shall maintain records for each source and type ofsecurity waste

accepted by the facility and confirm that such waste is properly consideied security

waste and defme the specific practices established for handling such waste at the

facility, accompanied by reasonable supporting documentation and explanation. The

Permittee shall also maintain records for each shipment ofsecurity waste that is

received at the facility that include the date, time, waste source, hauler, type and

amount of waste for the shipment

and thatdocument implementation ofthe specified

S

handling procedures by the facility, including the names and personnel of supervising

the handling ofthe shipment.

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-

31.

portableOnly

“securityconveyorwaste”device.as defmed in condition No. 30 and railroad ties may be placed

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into the

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5

Page 11

Within 35 days after the date of mailing ofthe Illinois EPA’s final decision, the applicantmay

petition for a hearing before the Illinois Pollution Control Board to contest the decision of the

Illinois EPA, however, the 35-day period forpetitioning for a hearing may be extended for a

period oftime not to exceed 90 days by written notice provided to the Board from the applicant

and the Illinois EPA within the 35-day initial appeal period.

Work required by this permit, your application orthe regulations may also be subject to other

laws governingprofessional services, such as the Illinois Professional Land Surveyor Act of 1989,

the Professional Engineering Practice Act of 1989, the Professional Geologist Licensing Act, and

-

the Structural Engineering Licensing Act of 1989. This permit does not relieve anyone from

compliance with these laws and the regulations adopted pursuant to these laws. All work that

falls within the scope and definitions ofthese laws must be performed in compliance with them.

-

The Illinois EPA may refer any discoveredviolation ofthese lawsto the appropriate regulating

authority.

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Manager,

S id Waste Branch

Permit Section

Bureau of Land

JLM:~~S:bjh\992052S .WPD

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STANDARD

CONDITIONS

FOR CONSTRUCTION/DEVELOPMENT PERMITS

ISSUED BY THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

July 1, 1979

The Illinois Environmental Protection Act (Illinois Revised Statutes, Chapter 111-1/2, Section

1039) grants the Environmental Protection Agency authority to impose conditions on permits

which it issues.

5

These standard conditions shall apply to all permits which the Agency issues for construction or

development projects which require permits under the Division ofWater Pollution Control, Air

Pollution Control, Public Water Supplies, and Land and Noise Pollution Control. Special

conditions may also be imposed by the separate divisions in addition to these standard

conditions.

~1. Unless this permit has been extended orit has been voided by a newly issued permit, this

permit will expire two years after date of issuance unless construction or development on

this project has started on or prior to that date.

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2.

The construction or development offacilities covered by this permit shall be done in

5

EnvironmentalcompliancewithProtectionapplicableAct,provisionsandRulesofandFederalRegulationslawsandadoptedregulations,bythetheIllinoisIllinoisPollution

Control Board.

3.

There shall be no deviations from the approved plans and specifications unless a written

request for

modification of the project, along

with plans and specifications as required, shall

have been submitted to the Agency and a supplemental written permit issued.

4.

The permittee shall, allow any agent duly authorized by the Agency upon the presentation of

credentials:

a.

to enter at reasonable times the permittee’s premises where actual orpotential effluent,

emissions or noise sources are located or where any activity is to be conducted pursuant

to this

permit.

b.

to have access to and copy at reasonable times any records required to be kept under the

terms and conditions of this permit.

c.

to inspect at reasonable times, including during any hours ofoperation ofequipment

constructed or operated under this permit, such equipment or monitoring

methodology

or equipment requiredto be kept, used, operated, calibrated and maintained under this

permit.

S

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5

d.

to obtain and remove at reasonable times samples ofany discharge or emission of

S

pollutants.

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-

e.

to enter at reasonable times and utilize any photographic, recording, testing, monitoring

or other equipment for the purpose of preserving, testing, monitoring, or recording any

activity, discharge, or emission authorized by this permit.

5.

The issuance ofthis permit:

a.

shall not be considered as in any manner affecting the title of the premises upon which

the permitted facilities are to be located;

b.

does not release the ‘permittee from any liability for damage to person or property

caused by orresulting from the construction, maintenance, or operation ofthe proposed

S

facilities;

c.

does not release the permittee from compliance with other applicable statutes and

regulations ofthe United States, ofthe State ofIllinois, or with applicable local laws,

ordinances and regulations;

d.

does not take into consideration or attest to the structural stability ofany units Or parts

ofthe project;

5

e.

in no maimer implies or suggests that the Agency (or its officers, agents or employees)

5

assumes any liability, directly or indirectly, for any loss due to damage, installation,

maintenance, or operation ofthe proposed equipment or facility.

5

6.

Unless ajoint construction/operation permit has been issued, a permit for operating shall be

obtained from the Agency before the facility or equipment covered by this permit is placed

into operation.

7.

These standard conditions shall prevail unless modified by special conditions.

8.

The Agency may file a compliant with the Board formodification, suspension orrevocation

5

ofaperrnit:

a.

upon discovery that the permit application contained misrepresentations,

misinformation or false statements or that all relevant facts were not disclosed; or

b.

upon finding that any standard or special conditions have been violated; or

S

c.

upon any violation of the Environmental Protection Act or any Rule or Regulation

effective thereunder as a result ofthe construction or development authorized by this

.

S

permit.

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TA:bjh\9831 1S.WPD

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5

5

~1L~

ILLINOIS ENVIRONMENTAL PRoTECTION AGENCY

1021

NORTH GRAND AVENUE

EAST,

P.O. Box

19276,

SPRINGFIELD, ILLINOIS

62794-9276

-

THOMAS V. SKINNER, DIRECTOR

S

5

217/524-3300

5

CERTIFIED M~4.IL

October 14, 1999

Z 416 153 195

Z 416 153 196

Z 416 153 197

OWNER

-

Property

OWNER

-

Facility

S

Village ofRobbins

Robbins Resource Recovery Partners, L.P.

3327 W. 137th Street

Perryville Corporate Park

Robbins, Illinois 60472

Clinton, New Jersey 08809-4000

OPERATOR

S

S

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Foster Wheeler Illinois, Inc.

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13400 South Kedzie Avenue

Robbins, Illinois 60472

Re: 0312700001 -- Cook County

Robbins Resource Recovery

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Perrni~No. 1990-068-DE

‘~

5

Permit No. 1997-072-OP

Supplemental Permit 1998-313-DE/STJP

Log Nos. 1998-31.3, -1998-315, 1998-410, (1998-314, 1998-409, 1998-208, 1998-078, 1998-

038, -1998-030, 1997-072, 1994-300, 1989-189)

State Permit File~

Gentlemen:

S

This supplemental permit is hereby granted to Village ofRobbins as property owner, Robbins

Resource Recovery Partners, L.P. as owner ofthe facility, and Foster Wheeler Illinois, Inc. as the

operator to modify the operation of the solid waste management site to allow the construction and

operation ofthe boilerreturn recirculation conveyors (Log No. 1998-313), the dry ash loadout

system (Log No. 1998-315) and four (4) new conveyors for transferring bottom ash from the

boiler building to the ash loadout building (Log No. 1998-410). The site Consists of

Sa

16 acre site

in the Village ofRobbins, Cook County, Illinois.

All plans, specifications, application and suppdrting documents as submitted and approved shall

constitute part ofthis permit and are identified on the records of the Illinois Environmental

Protection Agency, Division of Land Pollution Control by the permit number(s) and log

number(s) designated in the heading above.

The permit is issued subject to the standard conditions attached hereto and incorporated herein by

reference, and further subject to the following special conditions:

-

SSCRE~N

MED.

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Page 2

This permit

allows for the

operation ofthe units listed below.

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Unit Designation

Approximate Size

Proposed Use

a.

Tipping area

3000 ton

capacity

storage ofwaste

-

prior

to processing

b.

Portable shredder

5 tons per hour.

to

shred

bulky

5

waste

c.

Processing Lines (2)

80 to 100 tons per hour

i.

primary trommel

screening of waste

ii. shredder

5

5

shreds wastes over

S

5 inches in size

iii. magnets (7)

to remove ferrous

-

S

material

iv. secondary trommel

separation of waste

5 5

iflto sizes

v.

air classifier

removal of

inert

-

5

5

5

-

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material

-

vi.

eddy currnnt

to remove

separator

aluminum cans

vii. picking station

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to remove

unacceptable

S

material for waste

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removal and

5

5

recovery of

-

recyclable

materials

viii. glass and compost

5

to separate organic

recovery system

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material from the

glass

material

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Page 3

d.

Circulating fluidized

600 ton per day (ave.)

bed boiler trains (2)

i.

combustion chamber

waste to energy.

ii.

cyclone

to remove

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entrained.

iii. a superheater

to raise steam

temperature above

saturation

iv. economizers

preheat boiler

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S

feedwater

v.

urea injection

to control NO~

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5

emissions

e.

Spray dryer absorber

to handle approximately

to remove acid

baghouse system (2)

85,500 SCFM each

gases and

- -

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particulate

f.

Ash storage silos. ~2)

storage ofash prior

S

todisposal

-

g.

Ash conditioner

mixes water with

- -

ash to control dust

-

h.

RDF storage building

3000 ton capacity

storage ofRDF

S

prior to burning

i.

All corresponding sumps,

S

S

pumps, piping, controls,

-

loading and unloading

5

areas and appurtenances

2.

The Permittee may develop the following units:

S

a.

an emergency feedwater pump

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Page4

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Units authorized for development only may not be placed into operation until an operating

permit for these units is granted by the Bureau ofLand.

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3.

The Permittee may accept waste at the facility during periods of curtailed facility operations

under the following conditions:

S

a.

During the first 14 days of curtailed operations waste may be acceptednormally;

b.

After fourteen days:

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i.

if one incinerator is in service, no more than 1120 tons per day (nominal) of waste

may be accepted unless the excess amount can be processed or stored on site; and

ii.

if both incinerators are out of service, no waste may be accepted until one

incinerator is placed back in service.

c.

Not withstanding the above, the Permittee may accept waste for additional periods

during extended curtailed facility operations caused by unusual circumstances only as

approved in writing by the Illinois EPA.

-

4.

This facility shall not accept special waste (i.e., hazardous waste, potentially infectious

medical waste, pollution control waste or industrial process waste). Special waste does not

include uncontaminatedcorrugated cardboard, wooden crates and pallets, plastics (both

packaging and rigid materials), office waste (primarily paper and plastic) and cafeteria

waste.

-~

:..

5.

Special wastes (incineraior ash) generated at the site sent for disposal, storage, incineration

or further treatment elsewhere shall be transported to the receiving facility utilizing the

Illinois EPA’s supplemental permit system and manifest system. The receiving state’s

manifest if required may be usedin place of an illinois manifest.

6.

A copy ofall records and reports required by this permit shall be maintained in the facility’s

operating record. The operating record shall be made available by the illinois EPA upon

request. All information shall be maintained in the record for a period of at least three years

beyond the date of the report.

S

7.

The following information shall be included in the operating record and recorded daily:

a.

the amount of waste delivered,

b. the amount of

RDF

produced (as calculated),

c.

the amount of waste rejected,

d.

the amount of unacceptable waste removed,

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Page

5

e.

the amount of materials recovered (e.g., Fe, Al, glass),

f.

the amount ofbottom and fly ash

removed,.

g.

where the above materials were taken to, and

h.

the date and time any event results in the bypassing ofthe air pollution equipment,

i.

an inspection certification. The operator shall certify daily that all incoming railroad

ties were visually inspected.

8.

On an annual basis, the Permittee shall familiarize local emergency response units with the

contingency plan and document the date, time and contents of meetings held to comply with

these requirements.

9.

This permit is subject to review and modification by the Illinois EPA as deemed necessary to

fulfill the intent and purpose ofthe Environmental Protection Act and all applicable

environmental rules and regulations.

10. The Permittee shall notify the Illinois EPA of any changes from the information submitted to

the Illinois EPA in its application for a development and operating permit for this site. Any

modifications to thefacilities shall be the subject ofan application or supplement permit

submitted to the Illinois EPA forthose changes.

11. The incinerator ash destined for disposal shall be disposed of only in a properly permitted

landfill.

H

12. All of the ash meets the definition of an industrial process waste and the fly ash portion is

also considered a pollution control waste. The Permittee shall establish a reliable method of

determining the amount of fly ash sent for disposal.

13. The Permittee shall submit a quarterly report to the Solid Waste Management Section,

Division of Land Pollution Control which summarizes the amount of industrial process

waste and pollution control waste for purposes of the solid waste fee system. The portion

which is a p Ilution control waste will be exempt from fees.

14. The Permittee shall collect a weekly grab sample ofthe incinerator ash. The results from the

analysis shall be made a part ofthe operating record. The weekly samples shall be

composited quarterly and analyzed for the characteristics of a hazardous waste by TCLP as

described in 35 Ill. Adm. Code 721.124 fOr the parameters; arsenic, barium, cadmium,

chromium, lead, mercury,

selenium and silver.

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--

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15. The following conditions are included pursuant to Section 22.16b(b):

a.

The -incinerator must be designed to provide continuous monitoring while in operation,

with direct transmission of the resultant data to the Illinois EPA, until the Illinois EPA

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Page 6

determines the best available control technology for monitoring the data. The illinois

EPA shall establish the test methods, procedures and averaging periods, as certified by

the form and frequency ofreport containing results ofthe monitoring. Compliance and

enforcement shall be based on such reports. Copies of the results of such monitoring

shall be maintained on file at the facility concerned for one year, and copies shall be

made available for inspection and copying by interested members of the public during

business hours.

S

Also, please refer to operating permit 8812055 issued by the Illinois EPA’s Bureau of

Air.

S

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b.

The facility shall comply with ‘the emission limits adopted by the illinois EPA under,

subsection (c).

Also, please refer to operating permit 8812055 issued by the Illinois EPA’s Bureau of

Air.

c.

The operator of the facility shall take reasonable measures to ensure that waste

accepted

for incineration complies with all legal requirements for incineration. The

incinerator operator shall establish contractual requirements

or

other notification and

inspection procedures sufficient to assure compliance with this subsection (b)(3) which

may include, but not be limited to, routine inspections of waste, lists of acceptable and

unacceptable waste provided to haulers and notification to the Agency when the facility

operator reject and, -sends. loads away. The notification shall contain at least the name

ofthe hauler and the site from where the load was hauled.

Also, please refer to Special Condition Nos. 16, 17 and 22 herein.

d.

The operator may not accept for incineration any waste generated or collected in a

municipality that has not implemented a recycling plan or is party to an implemented

county plan, consistent with State goals and objectives. Such plans’shall include

provisions for collecting, recycling or diverting from landfills and municipal

incinerators landscape waste, household hazardous waste and batteries. Such

provisions may be performed at the site ofthe’ new municipal incinerator.

AlsO, please refer to Special Condition No. 19 and 20, herein.

16. Waste may be received for segregation into waste categories, one of which will be

incinerated on site and the other sent off-site. The Permittee shall not accept waste which

does not comply with the waste screening/analysis plan in the approved application Section

9.4 and Special Condition #4 herein. The procedures shall

be modified to include screening

for all unacceptable or prohibited waste and comply with the following conditions:

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~a.-_ Upon.unloading, the .Permitteeshall inspect each incoming load of waste

to determine

if

the load contains waste which this facility is not permitted to receive in accordance

with the procedures in the approved permit application Log 1989-189.

b.

The Permittee shall inspect all, wastes prior to placement into the incinerator feed

system’ to remove

waste

which is unacceptable for incineration. If unacceptabl.e waste

is discovered, it shall be diverted from the incineratorfeed and transportedto a unit

which is properly permitted to receive the waste.

c. The Permittee shall notify the Illinois EPA in writing

within 48 hours of rejection of a

load of unacceptable waste as described in the facilities waste inspection/analysis plan.

The notification shall include at least the name of the hauler and site from where the

load was hauled.

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d.

The Permittee shall visually inspect wastes which are processed to become part of-the

refuse derived fuel (RDF) system to remove wastes identified as prohibited waste in the

Waste Management Practice Plan Such wastes shall include but not be limited to

1.

explosives or ammunitions,

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2.

combustible liquids or gas containers, bottles or cylinders Or cans,

3.

batteries of any.type including dry cell, wet cell, motor vehicle or marine,

4.

special wastes (i.e., industrial process waste, hazardous waste, pollution control

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waste or potër~tially.infectiouswaste),

5.

vadioactive wastes,

6.

asbestos wa~tes~

7.

waste regulated by the Toxic Substance Control Act,

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8.

landscape Waste,

9. household hazardous

waste,

10. railroad ties treated with a material other than creosote,

11. telephone poles, and

12. tires:

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e.

The Permittee shall provide a list of wastes which are unacceptable for receipt at this

facility and list of examples of

acceptable waste to each hauler before the hauler

collects waste for transport to this facility.

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17. The Permittee shall visually inspect used creosote-treated wood to verify that the wood is

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weathered

and contains no

surface deposits or stains. Unweathered wood, or wood which

contains surface staining or deposits, is subject to the requirements of 35 Iii. Adm. Code

722.111 (by testing) to verify the wood is not characteristically hazardous.

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Page 8

18. Waste generated in Illinois municipalities and Illinois counties outside of Hamilton County,

Illinois as of June 2, 1997 are deemed to have complied with the requirements in Special

Condition 15(d) and

no further documentation is required. Provisions for collecting,

recycling or diverting from landfills and municipal incinerators landscape waste, household

hazardous waste and batteries may be performed at this site may be usedto comply with

these requirements.

19. Prior to receipt of waste from out-of-state or Hamilton County, Illinois, the Perrnittee shall

obtain a certification from the hauler that the waste was generated or collected in a

municipality that has provisions for collecting, recycling or diverting household hazardous

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waste from landfills and municipal incinerators.

20. The facility shall perform

routine housekeeping as ‘outlined in Section 9.3.2 ofthe approved

application Log #1989-189, to control litter. Routine housekeeping measures at a minimum

shall include:

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a.

inspection and maintenance ofthe equipment in accordance with the manufacturer’s

recommendations;

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b.

periodic sweeping and cleaning oftipping floor, RDF residue loading area, and bottom

and fly ash loading area;

c.

daily janitorial cleaning of administrative office, sanitary and employee facilities, and

control room;

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d.

periodic sweeping and cleaning offloors in RDF production area and boiler building;

e. periodic cleaning of turbine generator room;

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f.

daily inspection and cleanup of yard area from spillage, litter, and other foreign

materials;

g. weekly cleaning

and inspection of maintenance

areas for orderliness and safety

compliance with industrial standards;

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h.

weekly inspection and cleaning of drainage basins, oil-water separators, sumps, etc.

i.

weekly fire and safety inspections.

The time and results date ofeach inspection shall be maintained in the operating record.

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Page 9

21. The facility shall be maintained and operated to prevent nuisance odors and litter outside the

building by drawing air from inside the waste receiving, RDF processing and RDF storage

buildings for combustion air in the combustors (or venting air through the combustors when

they are not operatio~iaI)and other necessary measures. Any litter present outside of the

building shall be collected daily.

22. The load checking program shall consist of, at a minimum, the following components:

1)

Random inspections

A. An inspector designated by the facility shall examine at least threerandom loads

of solid waste delivered to the landfill on a random day each week. The drivers

randomly selected by the inspector shall be directed to discharge their loads at a

separate, designated location within the facility. The facility shall conduct a

detailed inspection of the discharged material for anyregulated hazardous or other

unacceptable wastes that may be present. Cameras or other devices may be used

to record the visible contents ofsolid waste~shipments.Where such devices are

employed., their use should be designated on a sign posted near the entrance of the

facility. ,

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B.

Ifregulated hazardous wastes or other unacceptable wastes are suspected, the

facility shall communicate with the generator, hauleror other party responsible for

shipping the waste to

the facility to determine the identity of the waste.

2) Recording inspection

results

Information and observations derived from each random inspection shall be recorded in

writing

and retained at the facility for at least three years. The recorded information

shall include, at.a minimum the date and time of the inspection; the names of the

hauling firm and the driver-of the vehicle; the vehicle license plate number; the source

ofthe waste, as stated by the driver; and observations made by the inspector during the

detailed inspection. The written record shall be signed by both the inspector and the

driver.

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The “security wastes” are excluded from the random inspection program.

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23. The permittee:shall transport-the .comp,ostable waste stream -to a properly permitted facility.

The only facilities in Illinois which may receive this waste stream forcomposting are mixed

municipal waste

composting facilities. If the compostable stream includes landscape waste

that is not separated at the point of

generation and

collected andprocessed separately from

the rest ofthe municipal waste stream, it is subject to the disposal prohibitions in Section

22.22(c) ofthe Environmental Protection Act.

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Page 10

24. The Permittee(s) shall

notify

the Illinois EPA’s Bureau ofLand in writing of its intent to

close at least45 days prior to the date closure is expected to begin. Along with this

notification, the Permittee(s) shall submit the procedure and the sampling and analysis plan

to be used in demonstrating the area has been properly decontaminated. This plan shall be

approved by the Illinois EPA’s Bureau ofLand in writing prior to being implemented.

25. The operator shall notify the illinois EPA within 30 days after receiving the final volume of

waste.

26. The operator shall initiate implementation of the closure plan. within 30 days afterthe

site

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receives its final volume of waste.

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27. The operator shall not file any application to modify the closure plan less than 180.days prior

to receipt ofthe final volume ofwaste.

28. Upon completion of closure .activities, the operatorwill notify the Illinois EPA that the site

has been closed in accordance with the approved closure plan utilizing the illinois EPA’s

“Affidavit for Certification of Completion of Closure of Non-Hazardous Waste Facilities.”

29. The Permittee is prohibited from placing white goods in the shredder unless the white goods

compohents have been removed.

30. The Permittee may only burn waste that has been processed into RDF on site except for

those Wastes identified as “security waste”. A securitywaste is defined,as municipal waste

where the origin Or circumstances effectively exclude the presence of undesirable

components, such as household batteries; preclude recycling ofthe material; and generally

assure that the waste is of a specific character or nature, as certified by the generator ofthe

waste and verified by thePermittee. Examples of security wastes include garbagefrom

international airline flights, which must be incinerated pursuant to US Department of

Agriculture Rules, and bank or medical records, which must be destroyed to maintain

client/patient privacy. Security wastes must be managed in compliance with the following

conditiOns:

a.

The constituents in security waste must be readily identified by visual inspection

notwithstanding any shredding or size reduction performed off-site;

b.

The Permittee shall implement practices for handling of security wTâste at the

facility

that reasonably provide for identification and removal of any prohibited materials in the

waste. At a minimum, these procedures shall include continuous oversight ofeach

shipment of

security waste

at the .facility by designated facility personnel

until

unloading is complete and the waste is. mixed with other waste or RDF; and

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Page 11

c.

The Perrnittee shall maintain records for each source and type of security waste

accepted by the facility and confirm that such waste is properly considered security

waste and’define the specific practices established for handling such waste at the

facility; accompanied by reasonable supporting documentation and explanation. The

Permittee shall also maintain records for each shipment of security waste that is

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received at the facility that include the date,.time, waste source, hauler, type and

amount of waste for the shipment and.that document implementation ofthe specified

handling procedures by the facility, including the names and personnel of supervising

the handling of the shipment.

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31. Only “security waste” as defined in condition No. 30 and railroad ties may be placed into the

portable conveyor device.

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32. The permittee shall notify the Illinois EPA Maywood Field Office at 7Q8/338-7900 upon

completion of the construction activities authorized through Log Number 1998-3 13, 1998-

315 and 1998-410 and prior to the newly constructed unit being placed into operation. If

within three days-after notification the permittee does not receive notice of the Illinois EPA’s

intent to inspect (verbal or written), prior inspection is waived and the permittee may

commence operation of the unit.

Within 35 days after the date pf mailing of the Illinois EPA’s final decision, the applicant may

petition for a hearing before the Illinois Pollution Control Board to contest the decision ofthe

Illinois EPA, however, the 35-day period for petitioning for a hearing may be extended for a

period of time not to exceed 90 days by

written notice provided to the Board

from the applicant

and the illinois EPA within the 35-day initial appeal period.

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Work required by this permit, your application or the regulations may also be subject to other

laws governing professional services, such as the Illinois Professional Land Surveyor Act of 1989,

the Professional Engineering Practice Act of 1989, the

Professional Geologist Licensing Act, and

the Structural

Engineering Licensing Act of 1989.

This permit dOes not relieve anyone from

compliance with these laws and the regulations adopted pursuant to these laws. All work that

falls within the scope and definitions ofthese lawsmust be performed in compliance with them.

The Illinois EPA may refer any discovered violation of these laws to the appropriate regulating

authority.

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Joyce L. Munie, PJE.

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Manaoer Permit Section

bcc: Bureau File

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Dureau

Oi

~

~.anu

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DLC-MarkMaywood

RegionGurnik,

J-ulie Armitage

JEM:

~~bjh\992052S

.WPD

Mark Schoiieiiberger

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STANDARD CONDITIONS FOR CONSTRUCTION/DEVELOPMENT PERMITS

ISSUED BY THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

Julyl, 1979

The Illinois Environmental Protection Act (Illinois Revised Statutes, Chapter 111-1/2, Section

1039)

grants the Environmental

Protection Agency

authority to impose conditions on permits

which

it issues.

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These standard conditions shall apply to all permits which the Agency issues for.construction or

development projects which require permits under the Division ofWater Pollution Control, Air

Pollution Control, Public Water Supplies, and Land and Noise Pollution Control. Special

conditions may also-be imposed by the separate divisions in addition to these standard conditions.

1.

Unless this permit has been extended or it has been voided by a newly issued permit, this

permit

will expire two years after date ofissuance unless construction or development on

this project has started

on or prior to that date.

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2.

The construction or development of-facilities covered by this permit shall be done in

compliance with applicable provisions ofFederal laws and regulations, the Illinois

Environmental Prote~tionAct, and

Rules

and Regulations adopted by the Illinois Pollution

Control Board.

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3.

There shall be no deviations from the approved plans and specifications unless a written

request for modification of the project, along with plans and specifications as required, shall

have been submitte~lto the Agency and a supplemental written permit issued.

4.

The perniittee shall allow any agent duly authorized by the Agency upon the presentation of

credentials:

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a.

to enter at reasonable times the perrnittee’s premises where actual or potential effluent,

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emissions or noise sources are located or where any

activity

is to be conducted pursu.ant

to

this permit.

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b. to have access to

and copy at reasonable times any

records required to be kept

under the

terms and conditions ofthis permit.

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c. to inspect at reasonable

times, including during any hours ofoperation of equipment

constructed or

operated under this permit, such equipment or monitoring methodology

or equipment required to be kept, -used, operated, calibrated and maintained under this

permit;

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d.

to obtain and remove at reasonable times samples of any discharge or emission of

pollutants.

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,

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e.

to enter at reasonable times and utilize any photographic, recording, testing, monitoring

or

other equipment for the purpose ofpreserving, testing, monitoring, or

recording

any

activity, discharge,or emission authorized by this permit.

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5.

The issuance ofthis permit:

a,

shall not be considered as in any manner affecting the title ofthe premises upon which

the permitted facilities are

to be located;

b.

does not release the

permittee

from any liability for damage to person or property

caused by or resulting from the construction, maintenance, or operation ofthe proposed

facilities;

c.

does not release the permitte.e from compliance with other applicable statutes and

regulations ofthe United States, ofthe State ofIllinois, or with applicable local laws,

ordinances and regulations;

d.

does not take into consideration or attest to the structural stability ofany units or parts

ofthe project;

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e.

in no maimer implies or suggests that the’Agency (or its officers,

agents or employees),.

,assumes any liability, directly or indirectly, for any

loss due

to damage, installation,

maintenance, or operation ofthe proposed equipment or facility.

6.

Unless a joint consti-uctionloperation permit has been issued, a permit for operating shall be

obtained from-the Agency before the facility or equipment covered by this permit is placed

into operation;

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7.

These standard conditions shall prevail unless’modified by special conditions.

8. The Agency may file a compliant

with the Board for modification, suspension orrevocation

ofapermit:

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a.

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upon discovery that the permit application contained misrepresentations,

misinformation

or false statements ‘or that all relevant facts were not disclosed; or

b. upon finding that any standard

or special conditions have been violated; or

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upon anyviolation of the Environmental Protection Act or ai-iy Rule or Regulation

effective thereunder as a result ofthe construction or development authorized by this

permit.

TA:bjh\983 I IS.WPD