BEFORE THE

ILLINOIS POLLUTION CONTROL BOARIIh E

CE

I VE

D

CLERK’S OFFICE

CARROLL SCIENTIFIC, INC.

)

)

AU6262005

Petitioner,

)

STATE OF

ILLINOIS

Pollution Control Board

V.

)

PCB-

)

(Air

—

90 Day Extension)

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

)

Respondent.

)

NOTICE

To:

Sally Carter, Esq.

Assistant Counsel

Special Assistant Attorney General

Illinois Environmental Protection Agency

1021

North Grand Avenue East

P.O. Box

19276

Springfield,

IL 62794-9276

PLEASE

TAKE NOTICE

that today I have filed with the Office of the Clerk of

the Pollution Control Board APPEARANCE ofDavid

L. Rieser on behalfof Carroll Scientific,

Inc.,

the APPEARANCE of Sally Carter on

behalf of the Illinois

Environmental Protection

Agency

arid

a

REQUEST

FOR

EXTENSION

OF

APPEAL

PERIOD

in

the

above

titled

matter.

Copies ofthese documents are hereby served upon you.

CARROLL

CIENTIFI

,

INC..

By:

One of its

orneys

DATED:

August 26, 2005

MCGUIREWOODS LLP

David L.

Rieser

77 West Wacker Drive, Suite 4400

Chicago, Illinois

60601

(312) 849-8100

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

RECEIVED

CARROLL SCIENTIFIC, INC.

)

CLERK’S

OFFICE

Petitioner,

AUG

262005

r

-

STATEOFILLINOIS

v.

)

PCB

-

Pollution Control Board

)

(Air

—

90 Day Extension)

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

)

Respondent.

)

APPEARANCE

I, David

L.

Rieser,

hereby file my

appearance

in

this

matter

on

behalf of CARROLL

SCIENTIFIC, INC.

David L. Rieser

MCGUIREWOODS LLP

David

L. Rieser

77 West Wacker Drive, Suite 4400

Chicago, Illinois

60601

(312) 849-8100

---

RECEIVED

CLERK’S OFFICE

BEFORE THE ILLINOIS

POLLUTION

CONTROL

BOARD

AUG

252005

CARROLL SCIENTIFIC,

INC.

)

p~T~i~ntrolBoard

Petitioner,

)

)

PCB-

Cu’

(Air —90

Day Extension)

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

Respondent.

APPEARANCE

The undersigned, as one of its attorneys, hereby enters

her APPEARANCE

on

behalf of Respondent,

Illinois

Environmental Protection Agency.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY.

41a4s~

(LAz4

Sally Caffer

Assistarft

Counsel

Special

Assistant Attorney General

Division of Legal

Counsel

Date: August 24, 2005

Illinois Environmental Protection Agency

1021

North Grand Avenue East

P.O.

Box

19276

Springfield,

IL 62794-9276

217/782-5544

---

BEFORE

THE ILLINOIS

POLLUTION CONTROL BOARDRECEIVED

CLERK’S OFFICE

CARROLL SCIENTIFIC,

INC.

)

AUG

2

52005

STATE OF ILLINOIS

Petitioner,

)

Pollution Control

Board

v.

)

PCB-OC~

(Air —90

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

)

REQUEST FOR NINETY DAY EXTENSION OF APPEAL PERIOD

Petitioner,

Carroll

Scientific,

Inc.

(‘CSI”),

by

and

through

its

attorneys,

McGuireWoods

LLP,

and

the

Respondent,

Illinois

Environmental

Protection

Agency

(“IEPA”).

pursuant to

Section

40(a)(1) of

the

Illinois

Environmental Protection

Act

(415

ILCS

5/40(a)(1))

and

35

III.

Adm.

Code

105.208(a),

respectfully

requests

the

Illinois

Pollution

Control

Board

(“Board”)

to

grant

an

extension

of the

thirty-five

day

period

for

filing

petitions

to

appeal

the

IEPA’s

issuance

of

an

air

emission

unit

construction

and

operating

permits

until

November 28, 2005.

In

support of

this

Petition,

the

parties

state

as follows:

1.

On July 25, 2005,

the IEPA issued an operating

permit for emissions units

operated

and

to

be

operated

by

CSI

and

on

July

28

the

IEPA

issued

a

construction

permit

for the same

unit.

Copies of these

permits are attached

hereto and

incorporated

herein

as

Exhibit A.

The deadline

for filing an

appeal

of this permit

is August

29, 2005

and

September 1,2005,

respectively.

2.

The

parties

agree

that

additional

time

would

be

useful

to

continue

negotiations and

may eliminate the need to submit permit appeals.

---

WHEREFORE,

the

parties

respectfully request

the

Board

grant

an

extension

of

this period for filing appeals of these permits

until November 28, 2005.

CARROLL

SCIENTIFIC,

INC.

ILLINOIS

ENVIRONMENTAL

PROTECTION AGENCY

By:___

Sally

arter

Special Assistant Attorney General

Assistant Counsel

Dated:

August 24, 2005

David

L.

Rieser,

Esq.

McGuireWoods

LLP

77 West Wacker Drive

Suite 4100

Chicago,

IL

60601

Telephone:

312/849-8100

---

Exhibit

A

ft

---

~UG~15—20D5

MON 04:13 PM CARROLL

SCIENTIFIC

FAX

NO.

708

579

9477

P.

02

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021

Noum

GRAND

AVENUi

EAST,

PD.

Box

19506,

Sr’RIr~CrIrLo,

LLIr1015

62794-9506 —(217)782-2113

ROD

R.

BLAGoJEvIc~I,GovERNOR

DOUGLAS

P.

Scoli,

DIRECTOR

217/782—2113

CONSTRUCTION

PERMIT

~

ONi

y

PERMITTEF,

Carroll Scientific,

Inc.

Attn:

Mr. Richard Bradley

9550 West 55th Street

McCOok,

Illinois

60525

~R~jcationNoL.;

05040066

I.D. No.:

031174ACJ

Applicant’s Designation:

Date Received: April 27,

2005

~B~jact:

Ink Additives Manufacturing

Date Issued: July 28,

2005

Location:

9550

West 55th Street, McCook and 5401 South Dansher Road,

Countryside

Permit is hereby granted to the above-designated Permittee to CONSTRUCT

emission source(s) and/or air pollution control equipment consisting of

a

magnetic filter cleaning system as described in the above-referenced

application.

This Permit

is subject to standard conditions attached hereto

arid the following special condition(s)

1.

This permit

is issued based on the filter cleaning system not being

subject to 35 Ill. Adm. Code 218.182(c)

pursuant to 35 Ill.

Adin.

Code

218.182(g).

2.

The emissions of Hazardous Air Pollutants

(HAP) as listed in Section

112(b)

of the Clean Air hct shall be less than 10 tons/year of any

single HAP and 25 tons/year of any combination of such RAPs.

As a

result of this condition,

this permit is issued based on the emissions

of all HAPs from this source not triggering the requirements

of Section

112(g)

of the Clean Air Act.

3.

Emissions and operation of the magnetic

filter cleaning system shall

not exceed the following limits:

Toluene Throughput

Toluene and VOM Emissions

(Tons/Month)

(Tons/Year)

(Tons/Month)

(Tons/Year)

15

150

1

9.9

These limits are based on all VOM emissions being HAP emissions,

93.4

of toluene remaining in finished product and the information provided

in the permit application.

Compliance with annual limits shall be

determined from a running total

of 12 months of data.

4.

Pursuant

to 35

Ill. Adm. Code 218.301,

the Permittee shall not cause or

allow the discharge of more than 3.6 kg/hour

(8 lb/hour)

of organic

material

into the atmosphere from any emission unit.

---

~4UGH5—2005

NON 04:13

PN

CARROLL SCIENTIFIC

FAX NO.

708 579 9477

P.

03

f~ç:

,~.,..,

..

-

Page 2

~~if\J~jI~

ONLy

5.

The Permittee shall maintain the following records:

a.

Wax dispersion, wax compound and varnish production

(tons/month

and tons/year)

i.

Size

(lb/batch);

ii.

Composition, of batch

(lb/batch); and

iii.

Batch time

(hours/batch)

b.

All throughputs for gravure wax compound processing

(gallons/month and gallons/year);

and

c.

Total VON and HAP emissions using equations from NESHAP for

Pharmaceutical Products,

40 CFR 63.1257

(lb/month and tons/year).

4

6.

All records and logs required by this pernu.t shall be retained at a

readily accessible location at the source for at least

three years from

the date of entry and shall be made available for inspection and

copying by the Illinois EPA upon request.

My records retained in an

electronic format

(e.g., computer)

shall be capable of being retrieved

and printed on paper during normal source office hours so as to be able

to respond to an Illinois EPA request for records during the course of

a source inspection,

7,

If there is an exceedance of the requirements of this permit as

determined by the records required by this permit,

the Permittee shall

submit

a report to the Illinois EPA’s Compliance Section in

Springfield,

Illinois within 30 days after the

exceeciance.

The report

shall include the emissions released in accordance with the

recordkeeping requirements,

a copy of the relevant records,

and

a

description of the exceedance or violation and efforts to reduce

emissions and future occurrences.

8.

Two

(2) copies

of required reports and notifications concerning

equipment operation or repairs, performance testing or a continuous

monitoring system shall be sent

to:

Illinois Environmental Protection Agency

Division of Air Pollution Control

Compliance Section

(#40)

P.O. Box 19276

Springfield,

Illinois

62794—9276

and

one

(1)

copy shall be sent to the Illinois EPA’s regional office at

the following address unless otherwise indicated:

Illinois Environmental Protection Agency

Division of Air Pollution Control

9511 West Harrison

Des Plaines,

Illinois

60016

---

AUG—15—2005 MON 04:14

PM CARROLL SCIENTIFIC

Page

3

FAX

NO.

708 579 9477

(hV~,y

If you have any questions on this, please call Randy Solomon at 217/782—2113.

Donald E. Sutton, P.S.

Manager,

Permit Section

Division of Air Pollution Control

DES:RBS:psj

P.

04

cc:

Region

1

---

AUG—15—2005 MON 04:14

PM CARROLL SCIENTIFIC

FAX

NO.

708 579 9477

F.

05

STATE

OF ILLINOIS

ENVIRONMENTAL PROTECTION AGENCY

DIVISION

OF AIR POLLUTION CONTROL

P.O.

BOX 19506

SPRINGFIELD, ILLINOIS

62794-9506

ti.,if.r,ii/

“~

()iVy

STANDARD

CONDITIONS FOR

CONSTRUCTIONIDEVELOPMENT PERMITS

ISSUED

BY THE ILLINOIS

ENVIRONMENTAL

PROTECTION

AGENCY

July

1,

1985

The Illinois Environmental Protection

Act (Illinois Revised Statutes, Chapter 111.1/2, Section 1039)

authorizes the

Environmental Protection Agency

to impose conditions

on permits

which it issues.

The

following conditions

are

applicable unless

susperseded

by

special condition(s),

1.

Unless this permit

has been extended

or it has been voided by a newly

issued permit, this permit

will expire one

year from the date

of issuance, unless a continuous program of construction

or development on this project has

started

by

such time.

2.

The construction

or development covered by this permit shall be done in compliance with applicable provisions of

the

Illinois Environmental

Protection Act and

Regulations adopted by the Illinois Pollution Control Board,

3.

There shall be no deviations from the

approved plans andspecifications unless

a written request for modification,

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 duly

authorized

agent

of the

Agency

upon

the

presentation

of credentials,

at

reasonable times:

a.

to enter the

permittee’s property where actual or potential

effluent, emission or noise sources are located or

where any activity

is to be conducted pursuant

to this

permit,

b.

to have

access

to and

to copy

any records required to be kept under the terms and conditions

of this permit,

c.

to inspect, including during

any hours

of operation

of equipment constructed or operated under this permit,

such equipment and any equipment required to be kept, used, operated, calibrated and maintained

under this

permit,

d.

to obtain

and

remove samples

of any discharge

or emissions

of pollutants, and

e.

to enter 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

any

m~inneraffecting

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 toperson or property caused by

or resulting from

the construction, maintenance,

or operation

of the proposed

facilities,

c.

doe$ 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,

d.

does not

take into consideration or

attest

to

the structural

stability

of any units

or parts

of the project,

and

XL

532—0226

apr.

166

Rev.

5/99

Printed on Recreled P.p.r

090-006

---

hUG-15—2005 MON 04:14 PM CARROLL SCIENTIFIC

FAX

NO.

108 579 9477

P.

06

c.

in no

monner implies or suggests that the Agency

(or its officers, agents or employees) aäs~4~1nyliability,

directly

or

indirectly,

for

any

loss due

to

damage,

installation,

maintenance,

or

operation of

the

proposed

equipment

or

facility.

6.

a.

Unless

a joint construction/operation permit

has

been issued,

a

permit

for operation shall be obtained-from

the

Agency

before the equipment

covered by this permit

is placed

into

operation.

b.

For

purposes of shakedown

and testing,

unless

otherwise

specified by

a special permit condition,

the equip-

ment

covered under

this permit

may be operated

for a period not to exceed thirty

(30)

days.

1,

The Agency

may file a

complaint with the Board

for

modification, suspension or revocation of a permit:

a.

upon discovery that the permit application containedmisrepresentations, 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 viola Lions of the Environmental Protection Act or any regulation effective thereunder as a result

of

the

construction or

development authorized

by this permit.

---

~UG—1s—2oo5

NON 04:15

PM

CARROLL

SCIENTIFIC

FAX

NO,

708

579 9477

F,

07

ILLINOIS ENVIRONMENTAL PROTECTiON AGENCY

-

P.O. Box 19506

SPRINGFIELD,

ILLINOiS

62794-9506

Douglas

P.

Scott, Director

217/792—2 113

OPERATING

PERMIT

H~:r1J.u.-Ne1:()fqfy

PERMITTEE

Carroll

Scientific,

Inc.

Attn:

Mr.

Richard

Bradley

9550

West

55th

Street

MoCook,

Illinois

60525

Application !~o.: 99040036

I.D

No.:

031174ACJ

~pjicants

Designation:

Date Received: April

18,

2005

Ink

Additives

Manufacturing

-

Date

Issued:

July

25,

2005

Expiration

Date:

July

14,

2006

Location;

9550

West

55th

Street,

NeCook

ai~d 5401

SDuth

Dansher

Road,

Countryside

This

permit

is

hereby

granted

to

the

above-designated

Permit

tee

to

OPERATE

emission unIt(s)

and/or air pollution control equipment consisting of:

A Powdered Polymer Milling Line with 2 Filters and Bag and Drum Filling with

Filter

Cold Blending Processes,

Wax Compound Manufacturing and Varnish Manufacturing

Wax Dispersion

Process

Consisting

of

Three

Mixing

Tanks,

Three-Media

Mills,

a

Product

Filter,

High

Speed

Disperser

DM4

and

Three

Portable

Tanks

3

Cold

Mixers

HM1

2

and

3

with

Baghouse

3

Mixers

VMB.

9

and

10

with

Baghouse

1

Mixer

VMBB

1

Mixer

13)111

1

Disperser

VM13

1

Media

Mill

VM12

1

Ethylene

Glycol

Ether

Storage

Tank

1

Gravure

Wax

Compound

Process

Consisting

of:

2

Jacketed

Ball

Mills

2

Finished

Good

Holding

Tanks

2

Resinate

Storage

Tanks

2

Toluene

Storage

Tanks

4

Finished

Goods

Storage

Tanks

4

Miscellaneous

Storage

Tanks

Truck

Loading

Operation

and

a Magnetic

Filter

Cleaning

System

From

Construction

Permit

05040066

pursuant

to

the

above-referenced

application,

This

permit

is

subject to

standard conditions attached hereto and the following special condition(sl

la.

This permit shall expire 180 days after the Illinois EPA sends a

written

request

for

the

renewal

of

this

permit.

b.

This

permit

shall

terminate

if

it

is

withdrawn

or

is

superseded

by

a

revised

permit.

Roo ft

BLAGOSEVICH, GOVERNOR

---

AUG—15—2005 NON 04:15 PM CARROLL SCIENTIFIC

FAX

NO.

708 579 9477

P.

08

L?L!TRI:N(’1:

ON;.y

Page

2

2a.

This

permit

is

issued

based

on

this

source

not

being

a

participating

source

in

the

Emissions

Reduction

Market

System

(ERMS),

35

Ill.

Mm.

Code

Part

205,

pursuant

to

35

ill.

Adin.

Code

205.200.

This

is

based

on

the

source’s

actual

‘JON

emissions

during

the

seasonal

allotment

period

from

May

1

through

September

30

of

each

year

being

less

than

10

tons

and the source’s baseline emissions also being less than 10 tons.

b.

The Permittee shall maintain the following records to allow the

confirmation of actual VOM emissions during the seasonal allotment

period:

i.

Records

of

operating

data

and

other

information

for

each

individual

emission

unit

or

group

of

related

emission

units

at

the source,

as appropriate,

to determine actual VON emissions

during the seasonal allotment period;

ii.

Records of the VON emissions,

in tons,

during the seasonal

allotment

period,

with

supporting

calculations,

for

each

individual

emission

unit

or

group

of

related

emission

units

at

the

source,

determined

in

accordance

with

the

procedures

that

may

be

specified

in

this

permit;

and

iii.

Total

VOM

emissions

from

the

source,

in

tons,

during

each

seasonal allotment period, which shall be compiled by November

30

of

each

year.

c.

In

the

event

that

the

source’s

VOM emissions during the seasonal

allotment

period

equal

or

exceed

10

tons,

the

source

shall

become

a

participating

source

in

the

ERMS

and

beginning

with

the

following

seasonal

allotment

period,

shall

comply

with

35

ill.

Adm.

Code

Part

205,

by holding allotment trading units

(ATUs)

for its VON emissions

during each seasonal allotment period, unless the source obtains

exemption from the ERNS by operating with seasonal VON emissions of no

more than 15 tons pursuant to a limitation applied for and established

in

a

Clean

Air

Act

Permit

Program

(CAAPP)

permit

or

a

Federally

Enforceable State Operating Permit

(P550?)

d.

Pursuant

to

35

Ill.

Adm.

Code

205.316(a),

any

participating

or

new

participating source shall not operate without a CAAPP permit or PESO?.

Pursuant to 35 Ill.

Adn~,Code 205.316(aH2),

if a participating or new

participating

source does not have a CAAPP permit containing

ERMS

provisions

and the source elects to obtain

a permit other than a CAAPP

permit,

the source shall apply for and obtain

a FESOP that contains,

in

addition to other necessary provisions,

federally enforceable

ERMS

provisions,

including baseline emissions,

allotment for each seasonal

allotment period,

identification of any units deemed to be

insignificant activities for purposes of the ERMS,

emissions

-

calculation methodologies, and provisions addressing all other

-

applicable requirements of 35

Ill, Mm.

Code Part ?05.

3.

Particulate

Matter

emissions

from

the

powdered

polymer

milling

line

with

two

filters

and

bag

and

drum

filling

with

filter

shall

not

exceed

0.82

---

AUG~15—2QQ5 MON

04:15

PM

CARROLL

SCIENTIFIC

FAX

NO,

708

579

9477

P.

09

Page

OMy

lbs/hour and 3.6 tons/year.

these limits are based on manufacturer’s

specifications

of

0.02

gr/dscf,

0.01

gr/dscf,

1400

scfm

and

2000

scfm,

respectively

for

the

two

milling

filters,

0.01

gr/dscf

and

1200

scfm

for

the

filling

filter,

and

continuous

operation

(8,750

hours/year).

4.

The

Permittee

shall,

in

accordance

with

the

manufacturer(s)

and/or

vendor(s)

recommendations,

perform

periodic

maintenance

on

the

pollution control equipment covered under

this permit such that the

pollution

control

equipment

be

kept

in

proper

working

condition

and

not

cause

a

violation

of

the

Environmental

Protection

Act

or

regulations

promulgated

therein.

5.

This

permit

is

issued

based

on

the

filter

cleaning

system

not

being

subject

to

35

Iii. Adm. Code 218.182(c) pursuant

to 35 Ill. Mm. Code

218.182(g).

6.

This

permit

is

issued

based

on

negligible

emissions

of

volatile

organic

material

(VON)

from

all

storage

and

holding

tanks,

and

cold

blending

processes.

For

this

reason,

emissions

from

each

operation

shall

not

exceed

0.1

lb/hr

and

0.44

tons/year.

7.

Emissions

and

operation

of

the

varnish

and

wax

compound

manufacturing

operations

shall

not

exceed

the

following:

Particulate

Matter

Production

VON

Emissions

(PM)

Emissions

Operation

Tons)Mo)

(Tons/Yr)

(Tons/Ma)

(Tons/Yr)

Tons/Mo)

(Tons/Yr)

Wax

Compound

1,673

13,391

0.15

1.18

0.05

0.44

Varnish

857

6,936

0.22

1.73

0.05

0.44

These

limits

are

based

on

a

maximum

vapor

pressure

of

1.0

psia,

a

minimum

molecular

weight

of

201

lb/lb-mole

and

equations

11

and 12 from the

~Jational

Emission

Standards

for

Hazardous

Air

Pollutants

(NESRAP)

,

Subpart

000,

Pharmaceuticals

Production,

40

CPR

63.1257.

Compliance

with

annual

limits

shall

be

determined

from

a

running

total

of

12

months

of

data.

8.

This

permit

is

issued

based

on

negligible

emissions

of

VON

and

NAPs

from

the

Ethylene

Glycol

Ether

storage

tank.

For

this

reason,

emissions

shall

not

exceed

0.1

lb/hr

and

0.44

ton/yr.

9.

Emissions

and

operation

of

the

gravure

wax

compound

process

shall

not

exceed

the

following

limits:

Throughput

VON

Emissions

Equipment

(Oal/Mo)

(Gal/Yr)

(Lb/Mo)

(T/Yr)

2

Finished

Good

Holding

Tanks

(Total)

91,000

910,000

25

0.13

2

Resinate

Storage

Tanks

(Total)

9,100

91,000

16

0.08

2

Toluene

Storage

Tanks

(Total)

55,800

558,000

41

0.21

4

Finished

Goods

Storage

Tanks

(Total)

91,000

910,000

126

0.63

4

Miscellaneous

Storage

Tanks

(Total)

55,700

557,000

51

0.25

---

AUG—15—2005

HON 04:16 PM CARROLL SCIENTIFIC

FAX

NO.

708 579 9477

P,

10

Page

4

(~jy

Throughput

VON

Emissions

Equipment

(Gal/No)

(Gal/Yr)

(Lb/Ho)

(T/Yr)

2

Jacketed

Ball

Mills

(Total)

91,000

910,000

120

0.6

Truck

Loading

155,000

1,550,000

52

0.25

Toluene

&

VON

Toluene

Throughput

Emissions

(Ton/Mo)

(Ton/Yr)

(‘ron/Yr)

(Ton/Yr)

Magnetic

Filter

Cleaning

System

from

Construction

Permit

05040066

15

150

1

9.9

These

limits

are

based

on

standard

AP-4?

emission

factors

for

storage

tanks,

truck

loading,

all

VON

omissions

are

HAP

emissions,

93.4

of

toluene

remaining

in

finished

product,

and

the

information

provided

in

the

permit

application.

Compliance

with

annual

limits

shall

be

determined

from

a

running

total

of

12

months

of

data.

10.

Emissions

and

operation

of

wax

dispersion

process

shall

not

exceed

the

following

limits:

Throughput

Emissions

Process

jj~/pa~

(Tons/Yr)

Pollutant

(Lb/flay)

(Tons/Yr)

Wax Dispersion

13,672

4,990,572

PM

13.20

2.41

VON

2.40

0.42

These

limits

are

based

on standard AP—42 emission

factors

of

0.5

loss

of wax,

a minimum

batch

time

of

8

hours,

8760

hours

of

operation,

emission

rates

determined

through

equations

from

NESHAP,

Subpart

COG,

Pharmaceuticals

Production,

40

CFR

63.1257,

and

the

information

provided

in

the

permit

application.

Compliance

with

annual

limits

shall

be

determined

from

a

running

total

of

12

months

of

data.

11.

Pursuant

to

35

Eli.

Adm.

Code

219.301,

the

permittee

shall

not

cause

or

allow

the

discharge

of

more

than

3.6

kg/hour

(8

lb/hour)

of

organic

material

into

the

atmosphere

from

any

emission

unit.

12.

Pursuant

to

35

Iii.

Mm.

Code

212.321,

emissions

froft~the

4

media

tanks

and

mixing

tank,

each

source

emissions

shall

not

exceed

0.55

lb/hour.

13a.

The

Resinate

storage

tanks,

Toluene

storage

tanks,

finished

goods

storage

tanks,

and

miscellaneous

storage

tank(s)

are

subject

to

New

Source

Performance

Standards

(NSPS),

40

CFR

60

subpart

Kb.

The

Illinois

EPA

is

administering

these

standards

in

Illinois

on

behalf

of

the

United

States

EPA

under

a

delegation

agreement.

b,

At

all

times,

the

Pennittee

shall,

to

the

extent

practicable,

maintain

and

operate

these

tanks,

in

a

manner

consistent

with

good

air

pollution

control

practice

for

minimizing

emissions,

pursuant

to

the

New

Source

Performance

Standard.

---

AUG—15-2005

flOW 04:18

PM CARROLL

SCJENTJFJO

FAX NO.

708 579 9477

P

11

‘F.

Page

s

~

()Ni y

c,

The

Permittee

shall

fulfill

the

monitoring

of

operations

requirements

of

the

New

Source

Performance

Standards,

40

CFR

60.1l6b(a)

and

(b)

for

the

above

listed

storage

tanks.

That

is,

records

showing

the

dimensions

of

the

storage

vessel

and

an

analysis

showing

the

capacity

of

the

storage

vessel

shall

be

maintained

and

readily

accessible

for

the

life

of

the

source.

14a,

This

permit

is

issued

based

on

negligible

PM

emissions

from

all

new

equipment

in

the

Cold

Blending

and

Wax

Dispersion

operations

and

negligible VON emissions

from

all

new

equipment

in

the

Cold

Blending

process

(Mixers mu,

2,

3, VMB,

88,

9,

10,

11, Disperser

Vtul3 and Media

Mill

VM12)

.

For

this

reason,

emissions

of

each

pollutant

shall

not

exceed

0.1

lb/hour

and

0.44

tons/year.

These

limits

are

based

on

all

materials

having

vapor

pressures

less

than

0.5

psia,

and

equations

from

NESHAP

~or

Pharmaceutical

Products,

40

CPR

63.1257

and

Table

6

in

application.

b.

Emissions

of

volatile

organic

material

(VOM)

shall

not

exceed

0.12

tons/month

and

1.2

tons/year

from

the

use

of

Isopropanol,

including

clean-up,

in

the

was

dispersion

process.

These

limits

are

based

on

equations

from

NESHAP

for

pharmaceutical

products,

40

CFR

63.1257,

15.

The

Permittee

shall

maintain

the

following

records:

a.

Wax dispersion, wax compound and varnish production

(tons/month

and

tons/year)

i,

Size

(lb/batch);

ii.

Coznposition

of

batch

(lb/batch);

and

iii.

Batch time

(hour/batch).

b.

All throughputs for gravure wax compound processing,

including

toluene (gallon/month and gallon/year,

tons/month and tons/year);

and

c.

Total

VON

and

HAP

emissions

using

equations

from

NESHAP

for

Pharmaceutical

Products,

40

C?R

63.1257

(lb/month

and

tons/year).

16,

All

records

and

logs

required

by

this

permit

shall

be

retained

at

a

readily

accessible

location

at

the

source

for

at

least

three

years

from

the

date

of

entry and shall

be

made

available

for

inspection

and

copying

by

the

Illinois

EPA

upon

request.

Any

records

retained

in

an

electronic

format

(e.g.,

computer)

shall

be

capable

of

being

retrieved

and

printed

on

paper

during

normal

source

office

hours

so

as

to

be

able

to

respond

to

an

Illinois

EPA

request

for

records

during

the

course

of

a

source

inspection.

17.

If

there

is

an

exceedance

of

the

requirements

of

this

permit

as

determined

by

the

records

required

by

this

permit,

the

Permittee

shall

submit

a

report

to

the

Illinois

EPA’s

Compliance

Section

in

Springfield,

Illinois

within

30

days

after

the

exceedance.

The

report

---

AUG-15-2035 NON 04:17 PN CARROLL

SCIENTiFIC

FAX

NO.

708 519 9477

P.

12

Page

6

shall

include

the

emissions

released

in

accordance

with

the

recordkeeping

requirements,

a

copy

of

the

relevant

records,

and

a

description

of

the

exceedance

or

violation

and

efforts

to

reduce

omissions

and

future

occurrences.

18.

Two

(2)

copies

of

required

reports

and

notifications

concerning

equipment

operation

or

repairs,

performance

testing

or

a

continuous

monitoring

system

shall

be

sent

to;

Illinois

Environmental

Protection

Agency

Division

of

Air

Pollution

Control

Compliance

Section

(~40~

P.O.

Box

19276

Springfield,

Illinois

62794—9276

and one

(1)

copy shall be sent to the Illinois EPA’s regional office at

the

following

address

unless

otherwise

indicated;

Illinois Environmental Protection Agency

Division of Air Pollution Control

9511

West

Harrison

Des

Flames,

Illinois

60016

19.

Persons

with

lifetime

operating

permits

must

obtain

a

revised

permit

for

any

of

the

following

changes

at

the

source;

a.

An increase in emissions above

the amount the emission unit or

the

source

is

permitted

to

emit:

b.

A

modification;

c.

A change in operations that will result in the source’s

noncompliance with conditions in the existing permit; or

d.

A

change

in

ownership,

company

name,

or

address,

so

that

the

application

or

existing

permit

Is

no

longer

accurate.

It

should

be

noted

that

this

permit

has

been

revised

to

incorporate

the

operation

of

the

wax

dispersion

process

from

Construation

Permit

#02010048.

It

should

also

be

noted

that

Lifetime

Permit

95010050

has

been

incorporated

into

this

permit

because

it

is

considered

to

be

part

of

this

same

source.

It

should

be

noted

that

storage

tanks

TK-4

through

TK-9,

A

and

B

and

the

3

natural

gas

heaters

are

exempt

from

state

permit

requirements,

pursuant

to

35

Ill.

Adm. Code 20l.l~6(n) and (c~, respectively.

Also,

please

note

that

corrections

have

been

made

for

number

of

emission

units,

and to VOM

emission

limits

for

wax

and

varnish

manufacturing,

and

wax

dispersion process.

---

AUG—15—2035 NON 04:17 PN

CARROLL

SCIENTIFIC

F~X

NO.

708

579

9477

P.

13

•i.:~

Page

7

Also,

please

note

that

the

powdered

polymer

milling

line

with

two

filters

and

bag

and

drum

filling

with

filter

from

Construction

Permit

05040035

have

been

added

to

this

permit.

Please

also

note

that

equipment

from

Construction

Permit

05040066

has

been

added

to

this

permit.

It

should

be

noted

that

during

the

analysis

of

this

permit

application,

it

was

determined

that

your

facility

has

the

potential

to

emit

more

than

10

tpy

of

a

single

HAP

and

will

be

classified

as

a

major

source

under

the

Clean

Air

hct

Pormit

Program

(CAAPP)

.

To

avoid

the CAAPP permitting requirements, you

nay

want

to

consider

immediately

applying

for

a

Federally

Enforceable

State

Operating

Permit

(PESO?)

.

A

PESO?

is

an

operating

permit

which

contains

E’ederally

enforceable

limits

in

the

form

of

permit

conditions

which

effectively restrict

the potential emissions of a source to below major

source thresholds,

thereby excluding the source from the CAAPP.

Please

contact

the

Permit

Section

at

217/782-2113

to

request

the

necessary

application

forms.

Please

note

that

this

permit

will

expire

one

year

from

the

initial

date

of

issuance.

If

you

have

any

questions

on

this

permit,

please

contact

Randy

Solomon

at

217/702-2113.

Donald

E.

Sutton,

P,E.

Manager,

Permit

Section

Division

of

Air

Pollution

Control

DES :Ri1S

jar

cc:

Region

1

---

AUG—15—2005 NON 04:17 PM CARROLL

SCIENTIFIC

STATE

OF

ILLINOIs

ENVIRONMENTAL PRoTEcTIoN AGENCY

DIVISION OF AIR POLLUTION CONTROL

P.O.

BOX 19506

SPRINGFIELD, ILLINOIS

62794—950’6

FAX

NO.

708 579 9477

M~iT.f?rV~

The

Illinois

Environmental

Protection

Act

(Illinois

Revised

Statutes,

Chapter

111—1/2,

Section

1039)

grants the Environmental Protection hgency authority to impose conditions

on permits which it

issues.

The following conditions are applicable unless superseded by special permit conditions(s).

1.

The

issuance

of

this

permit

does

not

release

the

Permittee

front

compliance

with

state

and

federal regulations which are part

of the

Illinoi5 State Implementation

Plan,

as

well

as with

other applicable statues

and regulations of the United States

or

the State

of Illinois or with

applicable local

laws,

ordinances

and regulations.

2.

The

Illinois EPA

has’ issued

this permit based upon the

information

submitted by the

Permittee

in

the

permit

application.

Any

misinformation,

false

statement or

misrepresentation

in

the

application shall be ground for revocation under

35 Ill.

Mat,

code 201.166.

3.

a.

The Perraittee shall not authorize,

cause,

direct or allow any modification,

as defined in

35

Ill.

Adin.

code 201.102,

of

equipment,

operations

or

practices

which

are

reflected

in

the permit

application

as

submitted

unless

a

new

application

or

request

for

revision

of

the existing permit

is filed with the

Illinois EPA and unless

a new permit or revision of

the existing permit(s~ is issued for such modification.

b.

This permit only covers emission sources and control equipment while physically present at

the indicated plant

location(s)

.

Unless the permit specifically provides

for

equipment

relocation, this permit is void for an item of equipment on the day it is removed from

the

permitted

location(s) or

if all equipment

is

removed,

notwithstanding

the expiration date

specified on the permit.

The Permittee shall

allow any duly authorized agent of the Illinois EPA,

upon the presentation

of credentials,

at reasonable times:

a.

TO enter

the

Pernittee’s

property where

actual

or

pot?ntial

effluent,

emission

or

noise

sources are located or where any activity

is to be conducted pursuant to this permit;

b.

To

have

access

to

and

to

copy

any

records

required

to

be

kept

under

the

terms

and

conditions of this permit;

c,

To inspect,

including

during

any hours

of operation

of

equipment

constructed

or operated

under this

permit,

such equipment

and

any

equipment

required to

be

kept,

used,

operated,

calibrated and maintained under

this permit;

d.

To obtain

and remove samples of any discharge

or emission of pollutants; and

e.

To enter

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 any manner affecting

the

title

of

the premises

upon which

the permitted facilities are located;

IL 532—O2fl

APC

161 new. March,

2001

090--DOS

P

14

May,

1993

STANDARD

CONDITIONS

FOR

OPERATING PERMITS

PRINTE0 ON REcYCLED PAPER

---

AUG—15—2005

MON

04:18

Ff1 CARROLL SCIENTIFIC

FAX

NO.

708 579 9477

P.

15

—~

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 facilities;

c.

Does not take into consideration

or attest to the

structural stability of any unit or part

of

the

project;

and

d,

In

no

manner

implies

or

suggests

that

the

Illinois

EP~//t~f

g.ts

officers,

agents,

or

employees)

assumes

ary

liability,

directly

or

indirectlyj’tf6~/afl~~J,oss

due

to

damage,

installation,

maintenance,

or

operation

of

the

proposed

equipment

6.

The

facilities

covered

by

this

permit

shall

be

operated

in

such

a

manner

that

the

disposal

of

air

contaminants

collected

by

the

equipment

shall

not

cause

a

violation

of

the

Environmental

Protection

Act

or

regulations

promulgated

thereunder.

7.

The

permittee

shall

maintain

all

equipment

covered

under

this

permit

in

such

a

manner

that

the

performance

of

such

equipment

shall

not

cause

a

violation

of

the

Environmental

Protection

Act

or

regulations

promulgated

thereuner.

8.

The

Permittee

shall

maintain

a

maintenance

record

on

the

premises

for

each

item

of

air

pollution

control

equipment.

This

records

shall

be

made

available

to

any

agent

of

the

Environmental

Protection

Agency

at

any

time

during

normal

working

hours

and/or

operating

hours.

As

a

minimum,

this

record

shall

show

the

dates

of

performance

and

nature

of

preventative

maintenance

activities.

9.

No

person

shall

cause

or

allow

continued

operation

during

malfunction,

breakdown

or

startup

of

any

emission

source

or

related

air

pollution

control

equipment

if

such

operation

would

cause

a

violation

of

an applicable

emission

standard

or permit

limitation.

Should

a malfunction,

breakdown

or startup occur

which

results

in

emissions

in

excess

of

any

applicable

standard

or

permit

limitation,

the

Percnittee

shall:

a,

Immediately

report

the

incident

to

the

Illinois

EPA’s

Regional

Field

Operations

Section

Office

by

telephone,

telegraph,

or

other

method

as

constitutes

the

fastest

available

alternative,

and

shall

comply

with

all

reasonable

directives

of

the

Illinois

EPA

with

respect

to

the

incident;

b,

Maintain the following records for

a period of no less than two

(2)

years:

i.

Date and duration of malfunction,

breakdown,

or startup,

ii.

Full and detailed explanation of the cause,

iii. contaminants emitted and an estimate

of quantity of emissions,

iv,

Measures taken

to minimize

the

amount of

emissions

during the malfunction,

breakdown

or startup,

and

-

v,

Measures taken

to reduce future occurrences and frequency of incidents.

If

the

permit

application

contains

a

compliance

progrem

and

project

completion

schedule,

the

Per.-nfttee

shall

submit

a

project

completion

status

report

within

thirty

(30)

days

of

any

date

specified in the compliance program and project completion schedule or

at six month intervals,

•~hichovor

is note

frequent.

11.

The

F-ermittce shall

submit an Annual Emission Report

as

required by

35

Ill. Mm.

Code 201.30?

and

35

Ill. Mm.

code Part

254.

2DiSC

---

CERTIFICATE OF SERVICE

I, David L.

Rieser, an attorney, hereby certify that I caused the attached pleadings to be

served upon all parties

listed on the attached Notice via first class U.S. mail from 77 West

Wacker Drive,

Chicago, IL, on August 26, 2005.

\‘REA\277500.i

David

L.

Rieser