BEFORE THE ILLINOIS POLLUTION
CONTROL BOARD
LONE STAR
INDUSTRIES, INC.,
Petitioner,
v.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent.
Dorothy M. Gunn, Clerk
Illinois Pollution
Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
(VIA ELECTRONIC
MAIL)
(Construction Permit Appeal)
NOTICE
OF FILING
TO:
PCB
Division of Legal Counsel
Illinois Environmental Protection
Agency
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
(VIA FIRST CLASS MAIL)
(PERSONS
ON ATTACHED SERVICE LIST)
PLEASE
TAKE NOTICE that I have today filed with the Office of the Clerk of
the Illinois Pollution Control Board the ENTRY OF APPEARANCE OF
KATHERINE
D. HODGE, ENTRY OF APPEARANCE OF
THOMAS G.
SAFLEY, MOTION TO STAY THE EFFECTIVENESS
OF CONTESTED
PERMIT CONDITIONS
and PETITION FOR REVIEW copies of which are
herewith
served upon you.
Respectfully submitted,
Dated:
May 15, 2007
Katherine D. Hodge
Thomas G. Safley
HODGE DWYER ZEMAN
3150
Roland Avenue
Post Office Box 5776
Springfield, Illinois
62705-5776
(217) 523-4900
LONE STAR INDUSTRIES, INC.,
Petitioner,
By: /s/ Katherine D.
Hodge
Katherine D. Hodge
THIS FILING SUBMITTED ON RECYCLED PAPER
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
CERTIFICATE OF SERVICE
I, Katherine D. Hodge, the undersigned, hereby
certify that I have served the
attached APPEARANCE OF KATHERINE D. HODGE, ENTRY
OF APPEARANCE
OF THOMAS G. SAFLEY, MOTION TO
STAY THE EFFECTIVENESS
OF
CONTESTED PERMIT CONDITIONS and PETITION FOR REVIEW
upon:
Ms. Dorothy M. Gunn
Clerk of the Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago,
Illinois 60601
v ia electronic mail on May 15, 2007; and upon:
Division of Legal Counsel
Illinois Environmental Protection
Agency
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
b y depositing said documents in the United States Mail, postage
prepaid, in Springfield,
Illinois on May 15, 2007.
/s/
Katherine
D. Hodge
Katherine D. Hodge
L ONE:001/FiIMOF-COS -Petition for Review 406120047
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
BEFORE THE
ILLINOIS POLLUTION
CONTROL BOARD
LONE
STAR INDUSTRIES, INC.,
)
Petitioner,
)
v.
)
PCB
-
( C ons
siiuctýion Permit A ppeal)
ILLINOIS ENVIRONMENTAL
)
P ROTECTION AGENCY,
)
Respondent.
)
ENTRY OF APPEARANCE
OF KATHERINE
D HODGE
NOW COMES Katherine
D. Hodge, of the law
firm of HODGE DWYER
ZEMAN,
and hereby enters her appearance
on behalf of Petitioner,
LONE STAR
INDUSTRIES,
INC.
Respectfully
submitted,
LONE STAR INDUSTRIES,
INC,
Petitioner,
By:
/s/ Katherine D
Hodge
Katherine D. Hodge
Dated: May
15, 2007
K atherine
D. Hodge
HODGE
DWYER ZEMAN
3150 Roland
Avenue
Post Office
Box 5776
Springfield, Illinois
62705-5776
(217) 523-4900
L ONE:001/FJ/EOA-KDH
06120047
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
LONE STAR INDUSTRIES, INC.,
)
Petitioner,
)
v.
)
PCB
(Construction
_
Permit
Appeal)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent.
)
ENTRY OF APPEARANCE OF THOMAS
G. SAFLEY
NOW
COMES Thomas G. Safley, of the law firm of HODGE D W YER ZEMAN,
and hereby enters his appearance on
behalf of Petitioner, LONE STAR INDUSTRIES,
INC.
Respectfully submitted,
LONE STAR INDUSTRIES,
INC.,
Petitioner,
By: /s/ Thomas
G. Saflev
Thomas G. Safley
Dated: May 15, 2007
Thomas G. Safley
HODGEDWYERZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois 62705-5776
(217) 523-4900
LONE:001/FII/EOA.TGS 06120047
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
BEFORE THE ILLINOIS POLLUTION
CONTROL BOARD
LONE
STAR INDUSTRIES, INC.,
)
Petitioner,
)
VS.
)
PCB---
)
(Construction Permit Appeal)
ILLINOIS ENVIRONMENTAL
)
P ROTECTION AGENCY,
)
Respondent.
)
M OTION
TO STAY THE EFFECTIVENESS
OF CONTESTED
PERMIT CONDITIONS
NOW
COMES Petitioner, LONE STAR INDUSTRIES,
INC., d/b/a Buzzi
U nicem USA (hereinafter "Lone
Star" or "Petitioner"), by and through its attorneys,
HODGE DWYER ZEMAN,
pursuant to Section 10-65(b) of the Illinois
Administrative
Procedure Act (5 ILCS 100/10-65) and pursuant
to the Illinois Pollution Control Board's
(`Board") authority to grant discretionary stays of permit
conditions (see Community
Landfill Co. and City ofMorris v.
Illinois EPA, PCB Nos, 01-48 and 01.49
(III.Pol.Control.Bd. Oct. 19, 2000)), and hereby
moves the Board to stay the effectiveness
of the
contested conditions of Lone Star's construction permit
at issue in this matter.
In support thereof, Lone Star states as follows:
1.
On April 6, 2007, the Illinois Environmental Protection
Agency ("Illinois
EPA") issued Lone Star a construction
permit (Application No. 06120047),
which
included conditions that are not required
by the Illinois Environmental Protection Act
("Act") or regulations promulgated
thereunder, and are not necessary to correct,
detect, or
prevent noncompliance with, or accomplish
the purpose of, the Act or regulations
promulgated
thereunder.
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
2.
Today, Lone Star filed simultaneously with this Motion a timely Petition
for Review of such permit
conditions.
3.
The Board may grant a stay of contested permit conditions
where a
petitioner has requested such a stay. See Midwest Generation, LLC Will County
Generating Station v. Illinois EPA, PCB No. 06-156 (II1.Pol.Control.Bd.
Jul. 20, 2006)
(granting a request for a partial stay of construction permit conditions), North Shore
Sanitary District v. Illinois EPA, PCB No. 03-146 (III.Po1.Control.Bd. Mar. 20, 2003)
(granting Petitioner's Motion to Stay Condition 1 pending the outcome of the appeal),
Hartford Working Group
v.
Illinois EPA, PCB No. 05-74 (I11.Pol.Control.Bd. Nov. 18,
2004) (granting Petitioner's Motion
to Stay Effectiveness of Special Condition 2.0 until
the Board takes final action in the appeal).
4.
A stay of effectiveness
of Permit Conditions 2a, 2b, and 8 of the
construction permit issued to Lone Star on April 6, 2007, is needed
to prevent irreparable
ham
to Petitioner. Permit Conditions 2a and 2b are not clear regarding
the applicability
of the provisions to Lone Star's activities causing Lone Star uncertainty regarding
operations at its facility. Permit Condition 8 requires Lone Star to incur costs to comply
with Condition 8, where the activities that Condition 8 requires are redundant
and overly
burdensome. See Petition for Review. Further, a stay is necessary to protect Petitioner's
right
to appeal
permit
conditions. That is, Lone Star's appeal would be rendered
meaningless if it must comply with these provisions
while its appeal is pending. Finally,
no
adequate remedy
exists at law,
and Lone Star has a probability of success on the
merits. See Petition for Review.
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
5.
The Illinois EPA,
the public, and the environment will not be harmed if a
stay is granted.
WHEREFORE, Petitioner, LONE STAR INDUSTRIES, INC.,
d/b/a Buzzi
Unicem USA, moves the Illinois Pollution Control Board to grant
a Stay of Effectiveness
of Permit Conditions 2a,
2b, and 8 of Petitioner's April 6, 2007, construction permit until
the Board's final action in this matter.
Respectfully submitted,
LONE STAR INDUSTRIES,
INC,
Petitioner,
By: /s/ Katherine
D. Hodee
Katherine D. Hodge
Dated: May 15, 2007
Katherine D.
Hodge
Thomas G. Safley
H ODGE D W YER ZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois 62705-5776
(217) 523-4900
L ONE:001/Fil/Motion to Slay 06120047
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
LONE STAR INDUSTRIES, INC.,
)
Petitioner,
)
VS.
)
PCB--
)
(Construction Permit
Appeal)
ILLINOIS ENVIRONMENTAL
)
P ROTECTION AGENCY,
)
Respondent.
)
PETITION FOR
REVIEW
N OW COMES Petitioner,
LONE STAR INDUSTRIES, INC.,
d/b/a/ Buzzi
Unicem USA (hereinafter "Lone
Star" or "Petitioner"), by and through
its attorneys,
HODGE DWYER
ZEMAN, pursuant to Section 40 of
the Illinois Environmental
Protection Act ("Act") (415
ILCS 5/40) and 35 Ill. Admin. Code
Part 105, Subpart B, and
petitions the Illinois Pollution Control
Board ("Board") for review of
the Construction
Permit
for the Alternative Material Feed System for the Finish Mill granted
to Lone Star
by the Illinois Environmental Protection Agency
("Illinois EPA") pursuant to
Section
39(a) of
the
Act
on April 6, 2007.
In support thereof, Lone
Star states as follows:
1.
Lone
Star owns and operates a Portland
cement manufacturing facility in
Oglesby, Illinois ("Facility").
2.
On December 12,
2006, Lone Star applied for a construction
permit to
construct emissions sources
and/or air pollution control equipment,
which includes a new
hopper and a conveyor, as well as
an associated increased material
throughput for the
existing finish mill operations.
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
3.
On March 19, 2007, Illinois EPA sent a draft construction permit ("draft
permit") (attached hereto as Exhibit A) via electronic mail to Lone Star.
4.
By letter dated March 23, 2007, Lone
Star
provided
comments on the draft
permit ("Comments") (attached hereto as Exhibit B).
5 .
On March 30, 2007, Illinois EPA provided via electronic mail
another
draft permit (attached hereto as Exhibit C) to Lone Star.
6 .
On April 2, 2007, Illinois EPA provided a brief response (attached hereto
as Exhibit D) to Lone Star's Comments.
7 .
On April 6, 2007, Illinois EPA issued a final Construction Permit, Number
06120047 (attached
hereto
as
Exhibit
E), to construct a new hopper and a conveyor, as
well as authorizing an associated increased material throughput for the existing finish
mill operations at the Facility.
8 .
Lone Star received that final Construction Permit via
U.S. Mail on
April 16, 2007.
9 .
As set forth below, Illinois EPA included conditions
in the Construction
Permit that are not required by the Act or regulations promulgated thereunder,
and are not
necessary to correct, detect, or prevent noncompliance with, or to accomplish the
purposes of, the Act or regulations promulgated thereunder.
1 0. Lone Star files this Petition for Review of the Construction Permit on the
grounds set forth below.
11. First, Permit Condition 2a
provides that the permit "does not authorize
physical changes to the existing affected units." Condition 2a.
The Construction Permit,
however, authorizes the construction of emission sources and/or pollution
control
2
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
equipment, including a new hopper and conveyor, which when constructed, will be
connected to existing
affected
units.
Lone Star seeks clarification of Condition 2a to
indicate that the construction of the permitted activities
is authorized although such
activities
will
physically change existing affected units.
12. Second, Permit Condition
2b provides, in part, that the "permit does not
relax or otherwise revise any requirements or conditions that
apply to existing affected
u nits...
established in the current CAAPP permit issued for
this source." Condition 2b.
Currently, the CAAPP permit for the Facility is stayed pending the outcome
of
Lone
Star's
appeal
of such permit. See Lone Star Industries Inc v Illinois EPA PCB No.
03-
94 (I11.Po1.Control.Bd. Jan.
9, 2003) (granting Lone Star's motion to stay effectiveness of
CAAPP permit until the Board's final action in the matter or until
the Board states
otherwise). Lone
Star requests that Permit Condition 2b be clarified to acknowledge
that
the conditions of the CAAPP permit at issue
currently are stayed.
1 3. Finally, Permit
Condition 8 requires monthly inspections and maintenance
and repair of the "affected units," both the "new affected
units" to be constructed, and
"existing affected units." Conditions 8a and 86. Permit Condition 8 further
requires that
Lone Star maintain records of such inspections, maintenance,
and repair activities.
Condition Sc. Lone Star explained in its Comments that Condition
8 appears to be
similar to requirements
for certain control equipment at the facility, namely
dust
collectors. Comments at 2. However,
no new control equipment is being installed
pursuant
to this permitted project. Id. Lone Star also noted that the new
affected units
are subject to the MACT emissions limitations
and monitoring requirements at 40 C.F.R.
63, Subpart LLL, and since the MACT monitoring requirements will assure
compliance,
3
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
additional inspections
of the affected units are not necessary. Id. Lone
Star further stated
that the
dust collectors for the downstream existing
affected units are subject to the
control equipment inspection
requirements of Section 212.423(d) of the Board's
regulations. Id.; see
also
35 III.
Admin. Code § 212.423(d). Lone Star requests that
Permit Condition 8
be removed from the Construction Permit since
it is redundant of
these other
requirements, and it would be overly burdensome to
maintain detailed records
for each affected unit. d..
14. Lone
Star has no objection to, and does not appeal, any other conditions
included
by Illinois EPA in the Construction Permit.
WHEREFORE, Petitioner,
LONE STAR INDUSTRIES, INC., d/b/a Buzzi
Unicem
USA, petitions the Illinois Pollution
Control Board for a hearing on the Illinois
Environmental Protection
Agency's action issuing the April 6, 2007 Construction Permit
in this fashion.
Respectfully submitted,
LONE STAR INDUSTRIES, INC,
Petitioner,
Dated: May 15, 2007
By: /s/
Katherine D. Hodge
Katherine D. Hodge
K atherine
D. Hodge
Thomas G. Salley
H ODGE DWYER ZEMAN
3150 Roland Avenue
P ost Office Box 5776
Springfield, Illinois 62705-5776
(217) 523-4900
L ONE:001/Piling9/Petition for Review
#06120047
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
Page 1 of 1
M onica T. Rios
F rom:
Kunj Patel [Kunj.Patel@illinois.gov]
Sent:
Monday, March 19, 2007 3:36 PM
To:
Brady, Kathy
Subject:
Lone
Star
Industries
-Oglesby Plant (Appl. #06120047)
Attachments: Buzzi Unicem Lone Star
099816AAF 06120047.doc
Kathy,
Please review the attached draft construction permit for alternative
material feed system for the finished mill
and provide me your comments by Wednesday.
Thanks.
Kunj Patel
Please note that my new Email address is kunj.pabelCalillmcis.go_
EXHIBIT
5/14/2007
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
217/782-2113
CONSTRUCTION
PERMIT - NESHAP SOURCE
PERMITTEE
Lone Star Industries, Inc
d/b/a Buzzi
Unicem (USA)
Attn:
Adam Swercheck, Environmental
Engineer
100 Brodhead Road, Suite 230
Bethlehem,
PA 18017-8989
Application
No.: 06120047
I.D. No.: 099816AAF
Applicant's Designation:
Date Received:
December 22, 2006
Subject: Alternative Material
Feed System for the Finish
Mill
Date Issued:
Location. 490 Portland Avenue, Oglesby,
LaSalle County
Permit is hereby granted
to the above-designated Permittee
to CONSTRUCT
emission source(s)
and/or air pollution control
equipment for an alternative
material
feed system for the finish mill,
including a new hopper
and a
conveyor, and associated increased
material throughput for
the existing
finished mill operations,
as described in the above-referenced
application.
This Permit is
subject to standard conditions
attached hereto and
the
following
special condition(s):
la.
The new affected units for the purpose of this
permit are the hopper
and conveyor in the alternative
material feed system.
b. The existing
affected units are the synthetic
gypsum storage building,
finish
mill, and cement handling and
storage system.
2a. This permit is does
not authorize physical changes
to the existing
affected
units.
b. This permit does not relax
or otherwise revise any requirements
or
conditions that
apply to the existing affected
unite, including
applicable
emission standards, testing,
monitoring, recordkeeping,
and
reporting requirements established
in the current CAAPP permit
issued
for this source.
3a. This
permit is issued based on the
source being a major source
of
hazardous air pollutants (HAPs)
emissions so that it is
subject to
NESHAP regulations, 40 CFR 63, Subpart LLL.
Pursuant to 40
CFR 63.1348, the opacity from
the new affected units
shall not exceed 10 percent.
Pursuant to 35 IAC
212.321(a), the particulate
matter (PM) emissions
from the
new affected units shall not
exceed the applicable limit
of 35
IAC 212.321(c).
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
b. i. The affected units are subject
to the requirements of applicable
rules for Stone,
Clay, Glass and Concrete Manufacturing, 35 IAC
Part 212, Subpart Q.
i. Pursuant to 35 IAC Part 212.421,
the emission of smoke or other
particulate matter
from the affected finish mill shall
not have
opacity greater than 10 percent.
ii. Pursuant to 35 IAC 212.423(c),
there shall be no visible
emissions from affected units other than the finish
mill.
iv. The Permittee
shall, maintain and operate the affected units in a
manner consistent with good air pollution
control practice to
assure that the applicable emission
limits of 35 IAC Part 212
Subpart Q,
are met at all the times, consistent with
the
requirements of 35 IAC 212.423(d).
5a. This permit is issued based on new
affected units are not being subject
to the New Source Performance
Standard (NSPS) for Portland Cement
Plants, 40 CFR 60, Subpart F, pursuant to 40 CFR
63.1356(a).
b. This permit is issued based on this
project, which includes
construction
of
the
affected new units and increase in material
throughput for the existing affected units not being
subject to the
requirements of 40 CFR 52.21, Prevention
of Significant Deterioration
of Air Quality (PSD) because
the
increase
in PM/PM, emissions are less
than 25 and 15 tons/year,
respectively. The limits in Condition
6 are
intended to ensure that this project does not constitute
a major
modification pursuant
to the PSD rules.
6a. The material throughput for the new affected
units shall not exceed
8,760 tons/month and 87,600 tons/year.
b. PM/PM,a
emissions from the new affected units, in total
shall not exceed
0.75 pounds/hour and 3.25 tons/year.
c. The increase in PM/PM,,
emissions from the existing affected units
and
associated increase in vehicle traffic, from this
project, as
determined in accordance with 40 CFR 52.21(r)(6)(iii)
and (iv), shall
not exceed 11 tons/year. (See
also condition 9(b).)
d. Compliance with the annual limits shall be determined
from a running
total of 12 months of data.
7a. for the new affected units, the Permittee shall demonstrate
initial
compliance with
the emission limits Condition 3(b using the test
method and procedures described in 40 CFR 63.1349(b)(2).
b. Within 60 days upon written
request by the Illinois EPA, the Permittee
shall conduct observations of visible emissions or
opacity, from the
affected units during conditions which
are representative of the
maximum performance using
the test method and procedures described in
35 IAC 212.423(£).
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
8a. Inspections of the affected
units shall be conducted
at least monthly
when the affected
units are in operation to verify
compliance with the
requirements
of this permit.
b. Maintenance and repair
of the affected units shall
be performed to
assure that
each unit is functioning properly
when materials are being
handled.
c. The Permittee
shall maintain a log or other records
of the above
inspections
and maintenance/repair activity.
These records shall
contain, at a minimum, the time,
description o£ the inspections
and
maintenance/repair
activity.
9. Pursuant to 40 CPR 63.1350,
the Permittee shall prepare
a written
operations
and maintenance plan for each new
affected unit. The plan
shall
be submitted for review and approval
by the Illinois EPA
as part
of the application for modified
CAAPP permit and shall include
the
information required
in 40 CPR 63.1350(a)(1) through (4).
10a. The
Permittee shall maintain the following
records for the new
and
existing affected units:
The
records required by the NESHAP, 40
CFR 63.1355.
i. The records required
by 35 IAC 212.423(e).
i. Identification
of each type of material
handled, i.e., slag,
gypsum, with fine material (silt)
content and moisture content
(percent
by weight), with supporting documentation.
Records of the amount
of material handled, by type,
tons/month
and tons/year.
vi.
A file containing calculations for
the maximum PM/PM,o emissions
factors of each affected
unit, with supporting documentation
vii. Records
of PM/PM,o emissions (tons/month
and tons/yr) from each
unit, with supporting documentation
and calculations.
b. Records for
any opacity observations performed for
the affected units
using
the test method and procedures described
in 40 CFR 63.1349(b)(2)
that the Permittee conducts or are
conducted on its behalf, including
name of the observer,
date and time, duration of observation,
raw data,
and conclusion.
11. All records
and logs required by this permit shall be retained
at a
readily
accessible location at the
source for at least five years from
the date of entry and
shall be made available for inspection
and
copying by
the Illinois EPA upon request.
12a. The Permittee shall fulfill
all applicable notification
and reporting
requirements of
the NESHAP, 40 CFR 63 Subpart LLL
for the affected
units.
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
b. I£ there is any deviation
from the requirements of this permit, the
Permittee shall submit a report to the Illinois EPA, within 30
days
after the deviation or such other time period
specified in the sources
CAAPP permit. The report shall include
the emissions released, a copy
of the relevant records, and a description of the deviation or
violation and efforts/activities taken to reduce emissions
and future
occurrences.
13.
Two copies of required reports and notifications shall be sent
to the
Illinois EPA's compliance section at the following
address unless
otherwise indicated:
Illinois Environmental Protection
Agency
Division
of Air Pollution Control
Compliance Section (#40)
P.O. Box 19276
Springfield, Illinois 62794-9276
and one 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/ Regional Office
5415 North University
Peoria, Illinois
61614
Telephone: 309/693-5461
Facsimile: 309/693-5467
14a. The Permittee may operate the new and modified emission units addressed
by this permit for a period of 180 days
after commencing operation.
This supersedes Standard
Condition 1.
b. Upon successful completion of the emission testing required
by
Condition 7(a) demonstrating compliance with
the requirement of NESHAP,
40 CFR 63
Subpart
LLL,
the Permittee may continue to operate the new
and modified emissions units, pursuant to this permit until the current
CAAPP permit is modified or renewed to address these units.
If you have any questions
on this permit, please call Kunj Patel at
217/782-2113.
Edwin C. Bakowski, P.E.
Acting Manager, Permit Section
Division
of
Air Pollution
Control
ECB:CPR:KMP:
cc: Region 2
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
Mr. Kunj Patel
Illinois Environmental Protection Agency
Division
of
Air Pollution
Control
Permit
Section
1021 North Grand Avenue East
P.O. Box 19506
Springfield, Illinois 62794-9506
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
NUZZI IJNICEl119 USA
Oglesby Plant
March 23, 2007
Mr. Kunj Patel
Illinois Environmental
Protection Agency
Division of Air Pollution
Control
Permit Section
1021 North
Grand Avenue East
P.O. Box 19506
S pringfield, Illinois 62794-9506
S UBJECT:
Comments on the Draft
Construction Permit Application No. 06120047
Lone Star Industries, Inc. (d/b/a Buzzi
Unicem USA)
F acility ID:
099816 AAF
D ear Mr. Patel:
Lone
Star Industries, Inc. (d.b.a. Buzzi Unicem USA) is submitting these comments
on the
Draft Construction Permit Application
No. 06120047 for the proposed alternative material
feed system for the Finish Mill at its Portland
cement manufacturing facility in Oglesby,
Illinois
(Oglesby Plant, ID: 099816 AAF). Buzzi appreciates the opportunity to provide
comments on the draft permit. Buzzi's
comments are provided below.
Draft Condition 4.b-Most of the requirements from 35 IAC 212,
Subpart Q that are
specifically applicable to the new affected units and the existing downstream
affected units
are listed in Draft Conditions 4.b.ii, iii., and iv. Portions of 35 IAC 212, Subpart
Q are not
applicable
to
the
new and existing affected units (e.g., 35 IAC 212.422 and 212.425), Since
most of the applicable requirements are listed, Buzzi requests that the
Illinois Environmental
Protection
Agency (IEPA) change the general rule reference in this condition
to
include
the
specific
portions of the rule applicable to the new and existing affected units.
Draft Condition 6.c.- The condition references
Condition 9(b); however, the permit does not
contain this condition number. Buzzi requests
that IEPA remove this reference.
Draft Condition
6.d. -
Emissions
estimates submitted in the permit application for the new
affected units and potential increases
at the existing affected units downstream of the new
affected units were based on worst-case
assumptions regarding the material type, material
moisture content and maximum material throughput. As a result,
if the material throughput
remains below the maximum throughput provided in the application,
the emissions will not
exceed the limits in Draft Conditions 6.b. and 6.c. Therefore, it is not necessary
to separately
4 90 Portland Avenue, P.O. Box 130 . Oglesby, IL 61348 " (815) 883-8431 " Fax (815) 883-8721
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
Mr. Kunj Patel-Page 2
March 23, 2007
track emissions
to demonstrate that emissions will not exceed the limits if Buzzi tracks
material throughput for the new affected units. Buzzi requests that this condition be revised
as follows (new language is in bold font):
Compliance
with the annual limits shall be determined from a running total of 12 months
of data of the material throughput for the new affected units.
In addition, Buzzi requests that the associated
record keeping condition, Draft Condition
10.a.vii. be deleted.
Draft Condition
8- This condition appears to be similar to other requirements that apply to
control equipment used at the Oglesby
Plant. No new control equipment will be installed for
this project. In addition, the
new affected units and the existing affected units downstream of
the new affected
units are subject to the limits and monitoring requirements of 40 CFR 63,
Subpart LLL (Portland Cement MACT). Additional inspections of the affected units
will not
be necessary to maintain compliance since the MACT monitoring
requirements will assure
compliance. Finally, the dust collectors for the downstream
existing affected units are
currently subject to control equipment
inspection requirements per 35 IAC 212.423(d).
Buzzi requests that IEPA remove Draft Condition 8 since
it is redundant for control devices
and since it would be overly burdensome to
maintain these detailed records for each affected
unit (e.g., each conveyor belt).
Draft
Condition
9-Buzzi's current Operation and Maintenance (O&M) Plan includes the
information required in 40 CFR 63.1350(a)(1) through (4) for
general types of affected
sources (e.g., conveying system transfer points).
The new affected units will be conveying
system transfer points, and conveying system transfer points
are currently included in the
O&M Plan. As a result, the O&M Plan will not require
revisions to include the new
equipment. Buzzi requests that IEPA revise
Draft Condition 9 to reflect that revisions may
not be necessary as follows (new
language is in bold and deleted language is in strikeout):
Pursuant
to 40 CFR 63.1350, the Permittee shall prepare a written operations and
maintenance plan for each new affected unit or revise the existing
operations and
maintenance plan,
as necessary. If it is necessary to revise the plan to satisfy the
requirements of 40 CFR 63.1350(a)(1) through (4), the The plan shall be submitted for
review and approval by the Illinois EPA as part of the application for modified
CAAPP
permit and shall include the information required in 40 CFR
63.1350(a)(1) through (4).
Draft Condition 10. a.- As previously stated,
emissions estimates submitted in the permit
application for the new affected units and potential increases at the existing affected units
downstream of the new affected units were based on worst-case
assumptions regarding the
material type, material moisture content and maximum
material throughput. In addition, the
silt content does not factor into the emissions
calculations, with the exception of the
calculations for the increases at
the existing storage piles. There will not be changes in the
types and general
characteristics of the materials stored in these existing storage piles as a
result of this project
since this system is simply an alternative method of delivering the feed
material to the Finish Mill system. Therefore,
it is unnecessary to record the type, silt
4 90 Portland Avenue, P.O. Box 130 .Oglesby,
IL 61348 " (815) 883-8431 " Fax (815) 883-8721
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
Mr. Kmj Patel-Page 3
March 23, 2007
content, and moisture content of each
material handled to demonstrate compliance with the
emissions limits. Buzzi requests that
IEPA remove Draft Condition 10.a.iii. Buzzi also
requests that IEPA
modify Draft Condition IO.a.iv. as follows (deleted language is in
strikeout):
v. Records of
the amount of material handled, by-typpeý tons/month and tons/year.
The Condition number formatting will need to be adjusted since IO.a.v.
is missing.
Draft Condition 12.b. -Buzzi requests that this
condition be replaced as follows to be
consistent with similar conditions received in recent construction permits (i.e., Condition
1.1.10.c. of Application No. 06030057):
The Permittee shall notify the Illinois
EPA of deviations from the requirements of this
permit in accordance
with the general provisions of its CAAPP permit that address
reporting ofdeviations.
It should be noted that the
Clean Air Act Permit Program (CAAPP) permit for the Oglesby
Plant is
currently stayed; therefore, Buzzi is not currently required to report deviations.
Finally, the following are minor typographical errors:
Draft Condition
2.a.
-
Remove the word "is".
Draft Condition
5.a. - Remove the word "are".
If you have any questions
concerning these comments, please contact me at 815/883-8431,
extension
237.
S incerely,
BUZZI UNICEM USA
Kathy L.
Brady
Environmental Engineer
cc: Mr. Adam Swercheck,
Buzzi Unicem USA, Inc. -Bethlehem, PA
Mr. James
King, Buzzi Unicem USA, Inc. - Oglesby, IL
Mr. John Krolak, IEPA
\envimnmentaNir
penniisU,oppcr (all reed to FM)\commwls on draft permit 3-23A7.doc
490 Portland Avenue, P.O. Box 130. Oglesby, IL 61348 " (815)
883-8431 " Fax (815) 883-8721
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
Page 1 of 1
M
onica T. Rios
F rom:
Kunj Patel [Kunj.Patel@illinois.gov]
Sent:
Friday, March 30, 2007 2:35 PM
To:
Brady, Kathy
Subject:
Lone Star Industries -Oglesby Plant (Appl. #06120047)
Attachments:
Buzzi
Unicem Lone Star 099816 06120047.doc
Kathy,
Attached is the final draft permit that Agency wants to issue early
next week. If you have any significant
comments let me know by Monday.
Thanks.
Kunj Patel
Please note that my new Email address Is kunj.pateldillino_is_.gov
D
E XHIBIT
c
5/14/2007
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
217/782-2113
CONSTRUCTION PERMIT - NESBAP
SOURCE
PERMITTER
Lone
Star
Industries, Inc
d/b/a Buzzi Unicem (USA)
Attn: Adam Swercheck, Environmental Engineer
100 Brodhead Road,
Suite
230
Bethlehem, Pennsylvania 18017-8989
Application No.: 06120047
I.D No.: 099816AAF
Applicant's Designation:
Date Received: December 22, 2006
Subject: Alternate Material Feed System for the Finish Mill
Date Issued: March
30,
2007
Location: 490 Portland Avenue, Oglesby, LaSalle County
Permit is hereby
granted to the above-designated Permittee to CONSTRUCT
emission source(s) and/or air pollution control equipment for an alternate
material feed system for the finish mill, including a new hopper and a
conveyor, and associated increased material throughput for the existing
finished mill operations, as described in the above-referenced
application.
This Permit is subject to standard conditions attached hereto and the
following special condition(s):
la. The new affected units for the purpose of this permit are the hopper
and conveyor in the alternative material feed system.
b. The existing affected units are the synthetic gypsum storage building,
finish mill, and cement handling and storage system.
2a. This
permit does not authorize physical changes to the existing
affected units.
b. This permit does not relax or otherwise revise any requirements
or
conditions that apply to the existing affected unite, including
applicable emission standards, testing, monitoring, recordkeeping, and
reporting requirements established in the current CAAPP permit issued
for this
source.
This permit is issued based on the source being a major source of
hazardous air pollutants (HAPs) emissions so that it is subject
to
NESHAP regulations, 40 CFR 63, Subpart LLL.
b. Pursuant to 40 CFR 63.1348, the opacity from the new affected units
shall not exceed 10 percent.
4a. Pursuant to 35 IAC 212.321(a), the particulate matter (PM) emissions
from the new affected units shall not exceed the applicable limit of 35
IAC 212.321(c).
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
Page 2
b. The affected
units are subject to certain requirements of applicable
rules for Stone, Clay, Glass and Concrete Manufacturing,
35 IAC Part
212, Subpart Q, as follows:
Pursuant to 35 IAC Part 212.421, the emission of smoke
or other
particulate matter from the affected finish
mill shall not have
opacity greater than 10 percent.
i. Pursuant to 35 IAC 212.423(e), there shall be no visible
emissions from affected units other than
the finish mill.
iii. The Permittee shall, maintain and
operate the affected units in a
manner consistent with good
air
pollution
control practice to
assure that the applicable emission limits of 35 IAC Part 212
Subpart Q, are met at all the times, consistent with
the
requirements of 35 IAC 212.423(d).
5a. This permit is
issued based on new affected units not being subject to
the New Source Performance Standard (NSPS) for Portland
Cement Plants,
40 CFA 60, Subpart F, pursuant to 40 CFR
63.1356(a).
This
permit is issued based on this project, which includes
construction of the affected new units and increase in material
throughput for the existing affected units not
being subject to the
requirements of 40 CFR
52.21,
Prevention
of Significant Deterioration
of Air Quality (PSD)
because the increase in PM/PM1a emissions are less
than 25 and 15 tons/year, respectively. The limits in
Condition 6 are
intended
to ensure that this project does not constitute a major
modification pursuant to the PEP rules.
6a. The material throughput
for the new affected units shall not exceed
8,760 tons/month and 87,600 tons/year.
b.
PM/PM,,
emissions from the new affected
units, in total shall not exceed
0.75 pounds/hour and
3.25 tons/year.
c The increase in PM/PM,, emissions from the existing
affected units and
associated increase in vehicle traffic,
from this project, as
determined
in accordance with 40 CFR 52.21(r)(6)(iii) and (iv),
shall
not exceed 11 tons/year. (See also Condition 10(a).)
d. Compliance with
the annual limits shall be determined from a running
total of 12 months of data.
7a. for the new affected units, the Permittee shall demonstrate initial
compliance with the emission limits
condition 3(b) using the test
method and procedures
described in 40 CFR 63.1349(b)(2).
b. Within 60 days upon written request by the Illinois
EPA, the Permittee
shall conduct observations
of
visible
emissions or opacity, from the
affected units during conditions which are representative of
the
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
Page 3
maximum performance using the test method
and procedures described in
35 IAC 212.423(£).
Ha. Inspections of the affected units shall be
conducted at least monthly
when the affected units
are in operation to verify compliance with the
requirements of this permit.
b. Maintenance and repair of the affected
units shall be performed to
assure that each
unit
is
functioning properly when materials are being
handled.
c. The Permittee shall maintain a log or other records of the above
inspections and maintenance/repair activity. These
records shall
contain, at a minimum, the time,
description of the inspections and
maintenance/repair activity.
9. The Permittee shall comply with applicable requirements
of 40 CFA
63.1350, which addresses preparation
of and compliance with written
operations and maintenance plan for each unit subject to the NESHAP.
10a. The Permittee shall maintain the following records
for the new and
existing affected units:
The records required by the NESHAP, 40 CFR 63.1355.
ii. The records required by
35 IAC 212.423(e).
iii. Identification of each alternate material handled, e.g.,
slag,
flyash, or synthetic gypsum, with relevant data to address the
potential for PM emissions, e.g., typical range of fine
material
and moisture content, with supporting
documentation.
Records of the amount o£ each alternate material handled,
tons/month and tons/year.
A file containing
calculations for the maximum PM/PM10 emissions
factors of each affected unit, with supporting documentation
Records of PM/PM10 emissions (tons/month
and tons/yr) from each
unit, with supporting documentation and calculations.
vii. Records for any opacity observations
performed for the affected
units
using
the test method and procedures described in 40 CFR
63.1349(b)(2) that the Permittee conducts or are conducted on its
behalf, including name of the observer,
date and time, duration
of observation, raw data, and conclusion.
11. All
records and
logs required
by this permit shall be retained at a
readily accessible location at the source for at least five years from
the date of entry and shall be made available for inspection
and
copying by the Illinois EPA
upon request.
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
Page 4
12a. The Permittee shall fulfill all applicable notification and reporting
requirements of the NESHAP, 40 CFR 63 Subpart LLL for the affected units.
b. If there is any deviation from the
requirements o£ this permit, the
Permittee shall submit a report to the Illinois EPA, within 30 days after
the deviation or such other time period specified in the existing permits
for the source. The report shall
include the emissions released, a copy
of the relevant records, and a description of the deviation or violation
and efforts/activities taken to reduce emissions and future occurrences.
13. Two copies of required reports and notifications shall be sent to the
Illinois EPA's compliance
section at the following address unless
otherwise indicated:
Illinois Environmental Protection Agency
Division of
Air Pollution Control
Compliance Section (#40)
P.O. Box 19276
Springfield, Illinois 62794-9276
and one 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/
Regional Office
5415 North University
Peoria, Illinois 61614
Telephone: 309/693-5461
Facsimile: 309/693-5467
14a. The Permittee may operate the new and
modified emission units addressed
by this permit for a period of 180 days after commencing operation.
This supersedes Standard Condition 1.
b. Upon successful completion of the emission testing
required by
Condition 7(a) demonstrating compliance with the requirement of NESHAP,
40 CFR 63 Subpart
LLL, the Permittee may continue to operate the new
and modified emissions units, pursuant
to this permit until the current
CAAPP permit is modified or renewed to address these units.
If you have any questions
on this permit, please call Kunj Patel at 217/782-2113.
Edwin C. Bakowski, P.E.
Acting Manager, Permit Section
Division of Air Pollution Control
ECB:CPR:KMP:psj
cc: Region 2
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
Alternate
Feed System for Finish Mill - Response to March 23,2007 Letter
Page 1 of 1
M onica T. Rios
F rom: Chris Romaine [Chris.Romaine@illinois.gov]
Sent:
Monday, April 02, 2007 4:31 PM
To:
Brady, Kathy
Cc:
Kunj Patel
Subject: Alternate Feed System for Finish Mill - Response to March 23,2007 Letter
The following provides
a
brief response
to each of the points in your
letter dated March 23, 2007
D raft Condition 4(b):
Change
made.
Draft Condition 6(c): Reference corrected
Draft Condition 6(d): No change. Construction permits
for new/modified
units address the emissions consequences of
such units.
Moreover,
as
confirmed by Buzzi's comments,
the emission data provided in the
application is an estimate based
on assumptions. (How does the average
moisture content of a particular class of material constitute a
worst-case assumption for all materials?) If equipment is not operated
properly at all times or different (newly available) alternate materials
are handled, the emissions estimates in the application may understate
emissions.
Draft Condition 8: No change made. This condition only identifies
certain minimum practices m verify proper operation/compliance, which
practices are apparently already being implemented by the source, as
explained by Buzzi's comments. Similarly, the condition only identifies
minimum requirements for associated records. The condition does not
require redundant records, if the records that Buzzi currently keeps
already meet these minimum requirements.
Draft Condition 9: Requested change not made. Condition reworked to
better reflect applicable language of the NESHAP.
Draft Condition 10(a): Condition reworked but not removed. The
application does not identify the "worst-case" assumptions
about the
nature of the alternate materials that would be handled for the finish
mill. For example, it does not identify/address each of the different
types of slag or stone that might be handled. (This recordkeeping would
then be needed to verify that the properties of materials actually being
handled are consistent with the assumptions used to predict emissions.)
In any case, this data is needed to appropriately address actual
emissions of the project ( i.e., very
dusty
=higher concern, less
dusty
=lower concern).
Droll Condition 12(b): A further change will be made, which would
allow the provisions o£ a CAAPP to replace the provisions of the
construction permit. However, the CAAPP permit cannot be relied upon at
this time because the issued CAAPP permit has been stayed and is
currently not in effect.
I
EXHIBIT
D
5/14/2007
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY
1 021 NORTH GRAND AVENUE BAST, P.O. Box 19506, SPRINCRELD,ILLINOIS
62794-9506 -( 217) 782-2113
ROD R. BIAGOIEVICH, GOVERNOR
DOUGLAS P. SCOTT, DIRECTOR
2 17/782-2113
CONSTRUCTION
PERMIT - NESEAP SOURCE
PERMITTEE
Lone Star
Industries, Inc
d/h/a
Buzzi Unicem (USA)
Attn: Adam Swercheck,
Environmental Engineer
100 Brodhead
Road, Suite
230
Bethlehem, Pennsylvania 18017-8989
Application No.: 06120047
I.D. No.: 099916AAF
Applicant's Designation:
Date
Received: December 22, 2006
Subject:
Alternate Material Feed System for the Finish
Mill
Date Issued:
April 6, 2007
Location: 490 Portland Avenue, Oglesby, LaSalle County
Permit is
hereby granted to the above-designated Permittee
to CONSTRUCT
emission source(s) and/or air pollution
control equipment for an alternate
material feed system for the finish
mill, including a new hopper and a
conveyor, and associated increased
material throughput for the existing
finished mill operations, as described
in the above-referenced application.
This Permit is subject to standard
conditions attached hereto and the
following special condition(s):-
La. The new affected units for the purpose of this permit are
the hopper
and conveyor in the alternative material
feed system.
b.
The existing affected units are the synthetic
gypsum storage building,
finish mill, and cement handling and storage system.
2a. This permit does not
authorize physical changes to the existing
affected unite.
b. This permit does not relax or otherwise revise
any requirements or
conditions that apply to the existing affected
units, including
applicable emission Standards, testing, monitoring,
recordkeeping, and
reporting requirements established
in the current CAAPP permit issued
for this source.
3a. This permit is issued based on the
source being a major source of
hazardous air pollutants (HAPs) emissions so
that it is subject to
NESEAP regulations, 40 CFR 63, Subpart LLL.
b. Pursuant
to 40 CFR 63.1348, the opacity from the
new affected. units
shall not' exceed 10 percent.
4a. Pursuant.
to 35 IAC 212.321(a), the particulate
matter
(PM) emissions
from the new affected unite shall not exceed the applicable
limit of 35
IAC 212.321(c).
P RINTED ON RECYCLED PAPE
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
Page
2
b. The affected units are subject to certain
requirements of applicable
rules for Stone,
Clay, Glass and Concrete Manufacturing, 35 IAC Part
212, Subpart Q, as
follows:
i. Pursuant to 35 IAC Part 212.421,
the emission of smoke
or other
particulate matter
from the affected finish mill shall
not have
opacity greater than 10 percent.
Pursuant to 35 IAC 212.423(c), there
shall be no visible
emissions
from affected units other
than the finish mill.
iii. The Permittee
shall, maintain and operate the
affected units in a
manner consistent with good air pollution control practice
to
assure that the applicable emission limits
of 35 IAC Part 212
Subpart
Q, are met at all the times, consistent
with the
requirements
of 35 IAC 212.423(d).
Sa.
This permit is issued based on
new affected units not being subject
to
the New Source Performance Standard (NSPS)
for Portland Cement Plants,
40 CPR 60, Subpart F, pursuant to 40 CPR
63.1356(a).
b.
This
permit
is issued based on this project,
which includes
construction
of the affected new units and increase
in material
throughput for the existing affected units not being
subject to the
requirements of 40 CPR 52.21, Prevention
of Significant Deterioration
of Air Quality (PSD) because the increase
in PM/PM,, emissions are less
than 25
and 15 tons/year, respectively. The limits
in Condition 6 are
intended to
ensure that this project does not constitute
a major
modification pursuant
to the PSD rules.
6a. The material throughput for
the new affected units shall not exceed
5,760 tone/month and 87,600 tons/year.
b. PM/PM,,
emissions from the new affected units,
in total shall not exceed
0.75 pounds/hour and 3.25 tons/year.
C. The
increase in PM/PM,a emissions from the
existing affected units and
associated
increase in vehicle traffic, from this
project, as
determined
in accordance with 40 CPR 52.21 (r) (6)
(iii) and (iv), shall
not exceed
11 tons/year. (See also
condition
30(a).)
d. Compliance with the
annual limits shall be determined
from a running
total of 12 months
of data.
7a. for the new affected
units, the Permittee shall demonstrate
initial
compliance with
the emission limits Condition 3(b) using
the test
method and procedures described in 40 CPR 63.1349(b)(2).
b. Within
60 days upon written request by the
Illinois EPA, the Permittee
shall conduct
observations of visible emissions
or opacity, from the
affected
units during conditions which are representative
of the
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
Page 3
maximum performance
using the test method and procedures
described in
35 IAC 212.423(f).
9a.
Inspections of the affected units shall be
conducted at least monthly
when the affected units are in operation to verify
compliance with the
requirements of this permit.
b. Maintenance
and repair of the affected units shall be performed
to
assure
that each unit is functioning properly when materials
are being
handled.
c. The Permittee shall
maintain a log or other records of the above
inspections and maintenance/repair activity.
These records shall
contain, at a minimum,
the time, description o£ the inspections and
maintenance/repair activity.
The Permittee shall comply with applicable
requirements of 40 CFR
63.1350, which addresses preparation of and compliance
with written
operations and maintenance plan for each unit subject
to the NESHAP.
10a., The Permittee
shall maintain the following records for the new
and
existing affected
units:
i. The records required
by
the
NESHAP, 40 CFR 63.1355.
The
records required by 35 IAC 212.423(e).
iii. Identification
of each alternate material handled, e.g., slag,
flyash, or synthetic gypsum, with
relevant data to address the
potential for PM emissions, e.g., typical
range of fine material
and moisture content, with supporting
documentation.
Records of the amount of each alternate material
handled,
tons/month
and tons/year.
A file containing calculations for the maximum PM/PM10 emissions
factors
of each affected unit, with supporting documentation
i. Records of PM/PM10 emissions
(tons/month and tons/yr) from each
unit, with supporting documentation
and calculations.
vii. Records for any opacity observations
performed for the affected
units using the test method and procedures
described in 40 CFR
63.1349(b)(2) that the Permittee conducts
or are conducted on its
behalf, including name of the observer,
date and time, duration
of observation, raw data, and conclusion.
11. All records and
logs required by this permit shall be retained at a
readily accessible location
at the source for at least five years from
the date of entry and
shall be made available for inspection and
copying by the Illinois EPA
upon request.
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
Page
4
12a.
The Permittee shall fulfill
all applicable notification
and reporting
requirements of the NESHAP,
40 CFR 63 Subpart ILL for
the affected units.
b. If there is any
deviation from the requirements of this permit,
the
Permittee
shall submit a report to the Illinois
EPA, within 30 days after
the deviation or
such other time period specified
in the existing permits
for the source.
The report shall include
the emissions released, a
copy
of the relevant
records, and a description of the
deviation or violation
and efforts/activities
taken to reduce emissions and
future occurrences.
13.
Two copies of required reports
and notifications shall be
sent to the
Illinois EPA's compliance
section at the following address
unless
otherwise
indicated:
Illinois Environmental Protection Agency
Division
of Air Pollution Control
Compliance
Section (#40)
P.O. Box
19276
Springfield,
Illinois 62794-9276
and one 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/ Regional Office
5415 North University
Peoria, Illinois
61614
Telephone: 309/693-5461
Facsimile: 309/693-5467
14a. The Permittee
may operate the new and modified
emission units addressed
by this permit
for a period o£ 180 days after
commencing operation.
This supersedes Standard
Condition 1.
b.
Upon successful completion
of the emission testing required
by
Condition
7(a) demonstrating compliance
with the requirement
of NESHAP,
40 CFR 63 Subpart III, the Permittee may
continue to operate the
new
and
modified emissions units, pursuant
to this permit until the
current
CAA
PP
permit
is modified or renewed
to address these units.
If you have any questions
on this permit, please
call Kunj Patel at
217/782-2113.
2G4V/h C-
E dwin C. Bakowski, P.E.
Acting manager,
Permit Section
Division of Air Pollution
Control
ECB:CPR:KMP:paj
cc: Region
2
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
STATE
OF ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
DIVISION
OF AIR POLLUTION
CONTROL
P.
0.
BOX
19506
SPRINGFIELD,
ILLINOIS
82794-9508
S TANDARD
CONDITIONS FOR CONSTRUCTION/DEVELOPMENT
PERMITS p
ISSUED BY THE ILLINOIS ENVIRONMENTAL
PROTECTION'AGENCY
July 1, 1988
-
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 suaperseded
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
adapted by the Illinois Pollution
Control Board.
3. There
shall be no deviations from the approved plane
and specifications 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 i9 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 o£ this permit,
c. to inspect, including during
any hours of operation of equipment
constructed or operated under this permit,
s uch
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
a. 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 o£ 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 with other applicable statutes and regulations of the United
States, of the State of Illinois,
or with
applicable
local
laws, ordinances and
regulations,
d. dose not take into consideration or attest to the structural stability of any unite or
parts
of the
project, and
I L 532-0226
APO 166 Red. 5/99
Printed onRuydedNever
094005
Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
DIRECTORY
ENVIRONMENTAL
PROTECTION
AGENCY
...BUREAU OF AIR
For assistance
in
preparing
a permit
application
contact
the Permit
Section.
- Fu7`"ý;,nnoxý-
xxu7cuT,ýn
I
llinois Environmental Protection,
Agency
Division
of Air Pollution.
Control
P ermit
Section
1021 N.' Grand
Ave
E.
P,O,Bos,19506:;
'.Springfield, Illinois
62794-9506
or
a regional office of the
Field Operations
Section.'
The regional offices and their
areas' of responsibility are
shown on the map. The
addresses and
telephone,
numbers of
the
regional.
offices are as follows:
Illinois EPA
Region 1
Bureau of
air,
FOS
9511 Nest Harrison
D es Plaines, Illinois, 60016
8470294-4000
-
Illinois EPA
Region 2
5415 North
University
Peoria, Illinois 61614,
309/693-5463,
[rti- Ix"
ý-I
aXa:xý w,: ae
Illinois EPA
.
RLgion
3
2 009
Mall Street
Collinsville,
Illinois 62234
618/346-5120
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Electronic Filing, Received, Clerk's Office, May 15, 2007
* * * * PCB 2007-112 * * * * *
