Pepper Hamilton

LLP

At

torneys at Law

Suite 3600

100 Renaissance Center

Detroit, MI 48243-1157

313.259.7110

Fax 313.259.7926

RECEIVED

C

LEF?K'S OFFICE

MAY 1 9 2008

STATE OF ILLINOIS

Pollution Control Board

Kurt A. Kissling

Direct: 313.393.7313

kisslink@pepperlaw.com

May 15, 2008

BY

U.S.

MAIL

Mr. John Theriault

Clerk of the Illinois Pollution Control Board

James R. Thompson Center

100 W. Randolph – Suite 11-500

Chicago, Illinois 60601

Re:

Pilkington North America v. Illinois EPA; Petition for

Review of CAAPP Permit

Dear Mr. Theriault:

Enclosed please find the following documents to be filed with the Board:

1.

Notice of Filing;

2.

Petition for Review;

3.

Motion for Pro Hac Vice Admission of Kurt A. Kissling;

4.

Appearance of Kurt A. Kissling;

5.

Appearance of Hannah McCollum; and

6.

A $75.00 check for the filing fee.

Also enclosed are ten (10) courtesy copies of the documents listed above. Please stamp

one of these courtesy copies as "filed" and return them to the courier in the self-addressed

envelope so that we may include them in our files.

Sincerely,

c:

Hannah McCollum

Philadelphia

Boston

Washington, D.C.

Detroit

New York

Pittsburgh

Berwyn

Harrisburg

Orange County

Princeton

Wilmington

---

C/ZR. F

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

?

OFFICE

AY 1 9

2008

S

TATc op

1

, ,

Pollution

?

Control

"4-INOIS

Board

(Permit Appeal – Air)

Respondent.

NOTICE OF FILING

PLEASE TAKE NOTICE that on May 15, 2008, I filed with the Office of the Clerk of

the Pollution Control Board an original and nine copies of the following (on recycled paper):

1.

Petition for Review;

2.

Motion for Pro Hac Vice Admission of Kurt A. Kissling;

3.

Appearance of Kurt A. Kissling; and

4.

Appearance of Hannah McCollum.

Copies of the above are being served, via U.S. Mail, on the following:

PILKINGTON NORTH AMERICA, INC.,

Petitioner,

v.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

PCB

Pollution Control Board

Attn: Clerk

James R. Thompson Center

100 W. Randolph – Suite 11-500

Chicago, Illinois 60601

Division of Legal Counsel

Illinois Environmental Protection Agency

1021 N. Grand Avenue, East

P.O. Box 19276

t

Springfield,

d-

Illinois 62794-9276

Kurt

Ku

' . Kisslinig (pr ac vice)

Hannah McCollum (ARDC #6278091)

Counsel for Petitioner,

Pilkington North America, Inc.

PEPPER HAMILTON LLP

100 Renaissance Center – Suite 3600

Detroit, Michigan 48243-1157

313.259.7110

THIS FILING SUBMITTED ON RECYCLED PAPER

#9628924 vl (113814.70)

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

Fi

cam

.

,

IF

0

PILICINGTON NORTH AMERICA, INC.,?

)?

MAY 19 2008

Petitioner,?

)

)?

447-6

utton

OF

Controi

/LL/NolBoard

v.?

)?

PCB(Permit ?

Appeal

0

——

9

aAir)

ILLINOIS ENVIRONMENTAL? )

PROTECTION AGENCY,

?

)

Respondent.

?

)

PETITION FOR REVIEW

Petitioner, PILKINGTON NORTH AMERICA, INC. (hereinafter "Pilkington"),

through its attorneys, PEPPER HAMILTON, LLP, and pursuant to Section 40.2 of the Illinois

Environmental Protection Act (415 ILCS 5/40.2) ("Act") and 35 Ill. Admin. Code § 105 Subpart

C, petitions the Board for review of the Clean Air Act Permit Program ("CAAPP") permit

granted to Pilkington by the Illinois Environmental Protection Agency ("Illinois EPA") under

Section 39.5 of the Act on April 10, 2008.

In support thereof, Pilkington states:

I. BACKGROUND

1.

Pilkington owns and operates a flat glass manufacturing facility in Ottawa,

Illinois ("the Facility"), which is classified as a "major source" for purposes of Title V of the

Clean Air Act and Section 39.5 of the Act. The facility is located at Center & 20

th

Street, P.O.

Box 578, Ottawa, LaSalle County, Illinois.

2.

The Facility first obtained a CAAPP permit on September 6, 1995.

---

3

Since the Facility's CAAPP permit was last renewed on September 5,

2003, it has obtained several construction permits from Illinois EPA, including permit nos.

05010008, 07030023, and 07070036 ("the Construction Permits").

4.

On April 10, 2008, the Illinois EPA issued a revised CAAPP permit for

the Facility ("the Revised CAAPP Permit"), which purported to incorporate changes from the

Construction Permits. The Revised CAAPP Permit is attached as

Exhibit A.

5.

Pilkington did not receive advance notice of Illinois EPA's revision and

did not receive a draft copy of the Revised CAAPP Permit prior to its issuance.

II. ISSUES ON APPEAL

6.

The Revised CAAPP permit contains a number of errors and, as a result,

does not accurately describe the Facility's equipment or applicable requirements.

7.

The Revised CAAPP Permit errors include, without limitation, the

following issues:

(a)

Section 5.5.2 of the permit (page 14) states "[t]his permit is issued

based on the emissions of HAPs ... not being equal to or exceeding 10 tons per year,"

despite the fact that Pilkington notified Illinois EPA in its application materials for permit

no. 07030023 that the Facility's HAP emissions likely exceed 10 tons/year.

(b)

The permit has a number of internal inconsistencies, including

several in Section 7.2:

(i)

the reference in Section 7.2.9(c) (page 27) to a nonexistent

Section 7.2.3(e);

(ii)

the reference in Section 7.2.12(b) (page 28) to Section

7.2.3(c) (which only addresses SO2

rather than addressing the other

compounds listed in 7.2.12); and

(iii)

the reference in the Emission Factor table in Section 7.2.12

(page 29) that purports to require the use of an 8.0 lb/ton NOx emission

factor rather than the 6.67 lb/ton emission factor that was actually used

and is reflected in Section 7.2.6.

---

(c)

The charts in Sections 4.0 and 7.1.2, in the fourth row of the

section for Unit 01, incorrectly identify the "#4 Dust Collector" when DC-8 (in cullet

return area #4) was authorized for replacement and reference a replacement that has not

taken place.

(d)

Certain activities addressed in Section 7.2 of the Revised CAAPP

Permit that were addressed in the Construction Permits were intended as temporary

measures for use prior to a furnace cold repair, but were never intended as permanent

operating conditions.

8.

Due to the errors in the Revised CAAPP Permit, it is inconsistent with the

Clean Air Act and its underlying regulations as well as the Act and its underlying regulations.

9.

As such, the Illinois EPA did not meets its statutory and regulatory duties.

10.

Once an Assistant Attorney General is assigned to this case, Pilkington

desires to reach an agreement with Illinois EPA to stay this proceeding so the parties can attempt

to negotiate changes to the Revised CAAPP Permit that will allow for the dismissal of this case.

WHEREFORE, for the reasons set forth herein, Petitioner requests that the Board

direct Illinois EPA to correct the deficiencies in the Revised CAAPP Permit.

Resp

x

dully submitted,

K A. Kiss

c vice)

Hannah

Mc

oll (ARDC #6278091)

Counsel for Petitioner,

Pilkington North America, Inc.

PEPPER HAMILTON LLP

100 Renaissance Center – Suite 3600

Detroit, Michigan 48243-1157

313.259.7110

Dated: May 15, 2008

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

PILKINGTON NORTH AMERICA, INC.,

PCB

Petitioner,

v.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

(Permit Appeal – Air)

CERTIFICATE OF SERVICE

I, the undersigned, certify that on the 15

th

day of May, 2008, I served the attached Notice

of Filing, Petition for Review, Motion for Pro Hac Vice Admission of Kurt A. Kissling, and

Appearances of Kurt A. Kissling and Hannah McCollum via first-class mail upon the following:

Pollution Control Board

Attn: Clerk

James R. Thompson Center

100 W. Randolph – Suite 11-500

Chicago, Illinois 60601

Division of Legal Counsel

Illinois Environmental Protection Agency

1021 N. Grand Avenue, East

P.O. Box 19276

Springfield, Illinois 62794-9276

Dated: May 15, 2008

#9629524 vl (113814.70)

---

Attachment A

Pilkington's May 15, 2008 Petition for Review

The Revised CAAPP Permit

Issued by Illinois EPA on April 10, 2008

---

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021

NORTH GRAND AVENUE EAST, P.O. Box 19506,

SPRINGFIELD, ILLINOIS

62794-9506 - ( 217) 782-2113

ROD R. BLAGOJEVICH, GOVERNOR?

DOUGLAS P.

SCOTT, DIRECTOR

217/782-2113

"REVISED"

TITLE V - CLEAN AIR ACT PERMIT PROGRAM (CAAPP) PERMIT

and

TITLE I PERMIT1

PERMITTEE

Pilkington North America, Inc.

Attn: Tom Bretag, Environmental Manager

Center & 20th Street

Ottawa, Illinois 61350

Application No.: 95090029 ? I.D. No.: 099825AAG

Applicant's Designation: Glass Mfg. ?

Date Received: September 6, 1995

Operation of: Glass Mfg.

Date Issued: September 5, 2003

?

Expiration Date': September 5, 2008

Source Location: Center & 20th Street P.O. Box 578, Ottawa, LaSalle County

Responsible Official: Robert Stevens, Plant Manager

This permit is hereby granted to the above-designated Permittee to OPERATE Process Emission

Unit 1, Float Glass Melting Furnace, Float Glass Melting Furnace Tin Bath, Low-E Vapor

Deposition Coating Process, Float Glass Annealing Lehr, and a Gasoline Storage Tank

pursuant to the above referenced permit application. This permit is subject to the

conditions contained herein.

Revision Date Received: July 3, 2006

Revision Date Issued: April 10, 2008

Purpose of Revision: Minor Modification

This minor modification consists of incorporating language into this permit from

Construction Permit 05010008 - replacement of dust collectors, Construction Permit

07030023 - modification to float glass furnace, and Construction Permit 07070036 -

rebricking project for float glass furnace.

The previous permit issued April 15, 2005 is incorporated herein by reference.

If you have any questions concerning this permit, please contact Sunil Suthar at

217/782-2113.

Edwin

ecttAn

C.

?

Bakowski,

el0.642t,

P.E.

fe.

tem

Acting Manager, Permit Section

Divisjon of Air Pollution Control

ECB:SIS:psj

cc:?

Illinois EPA, FOS, Region 2

CES

Lotus Notes

This permit may contain terms and

conditions which address the applicability, and compliance if

determined applicable, of Title I of the CAA and regulations promulgated thereunder, including 40 CFR

52.21 - federal PSD and 35 IAC Part 203 - Major Stationary Sources Construction and Modification. Any

such terms and conditions are identified within this permit.

2?

Except as provided in Condition 8.7 of this permit.

PRINTED ON RECYCLED PAPER

---

TABLE OF CONTENTS

PAGE

1.0 SOURCE IDENTIFICATION ?

4

1.1?

Source

1.2 Owner/Parent Company

1.3

?

Operator

1.4 General Source Description

2.0 LIST?

OF ABBREVIATIONS/ACRONYMS USED IN THIS PERMIT

?

5

3.0 INSIGNIFICANT ACTIVITIES

?

7

?3.1?

Identification of Insignificant Activities

3.2 Compliance with Applicable Requirements

3.3?

Addition of Insignificant Activities

4.0 SIGNIFICANT 'EMISSION UNITS AT THIS

SOURCE?

9

5.0 OVERALL SOUR;CE CONDITIONS

?

11

5.1 Source Description

5.2 Applicable Regulations

5.3 Non-Applicability of Regulations of Concern

5.4 Source-Wide Operational and Production Limits and Work

Practices

5.5?

Source-Wide Emission Limitations

5.6 General Recordkeeping Requirements

5.7 General Reporting Requirements

5.8 General Operational Flexibility/Anticipated Operating

Scenarios

5.9 General Compliance Procedures

6.0 NOT?

APPLICABLE TO THIS PERMIT?

17

?7.0 UNIT?

SPECIFIC CONDITIONS?

18

7.1 Unit 01: Process Emission Unit 1

Control: Dust Collectors

7.2?

Unit 02: Float Glass Melting Furnace

Control: None

7.3?

Unit 03: Float Glass Melting Furnace Tin Bath

Control: None

7.4?

Unit 04: Low-E Vapor Deposition Coating Process

Control: Afterburner, Heat Exchanger, Lime Neutralization

System, Baghouse

7.5

?

Unit 05: Float Glass Annealing Lehr

Control: None

7.6?

Unit 06: Gasoline Storage Tank

Control: None

2

---

PAGE

8.0 GENERAL PERMIT CONDITIONS

?

46

8.1?

Permit Shield

8.2 Applicability of Title IV Requirements

8.3 Emissions Trading Programs

8.4 Operational Flexibility/Anticipated Operating Scenarios

8.5?

Testing Procedures

8.6 Reporting Requirements

8.7 Obligation to Comply with Title I Requirements

9.0 STANDARD PERMIT CONDITIONS

?

51

9.1

?

Effect of Permit

9.2?

General Obligations of Permittee

9.3. Obligation to Allow Illinois EPA Surveillance

9.4 Obligation to Comply with Other Requirements

9.5?

Liability

9.6 Recordkeeping

9.7 Annual Emissions Report

9.8 Requirements for Compliance Certification

9.9?

Certification

9.10 Defense to Enforcement Actions

9.11 Permanent Shutdown

9.12 Reopening and Reissuing Permit for Cause

9.13 Severability Clause

9.14 Permit Expiration and Renewal

10.0?

ATTACHMENTS

10.1

?

Attachment 1

10.2?

Attachment 2

Emissions of Particulate Matter from

Existing Process Emission Units

Emissions of Particulate Matter from New

1-1

2-1

Process Emission Units

10.3

Attachment 3 Example Certification by a Responsible

3-1

Official

10.4

Attachment 4

Guidance on Revising This Permit

4-1

10.5 Attachment 5

Form 199-CAAPP, Application For

5-1

Construction Permit (For CAAPP Sources Only)

10.6

Attachment 6

Guidance on Renewing This Permit

6-1

10.7 Attachment 7

Evaluation of the Change in Emissions from 7-1

Construction Permit 07030023 for Unit 7.2 -

Glass Furnace Modification Project

10.8

Attachment 8 -

Past Actual Emissions (Tons/year)

8-1

3

---

1.0 SOURCE IDENTIFICATION

1.1?

Source

Pilkington North America, Inc.

Center & 20th Street

Ottawa, Illinois 61350

815/433-0932

I.D. No.: 099825AAG

Standard Industrial Classification: 3211, Glass Manufacturing

1.2 Owner/Parent Company

Pilkington North America, Inc.

811 Madison Ave., P.O. Box 799

Toledo, Ohio 43697-0799

1.3?

Operator

Pilkington North America, Inc.

811 Madison Avenue, P.O. Box 799

Toledo, Ohio 43697-0799

Tom Btetag, Environmental Manager

815/433-0932

1.4 General Source Description

Pilkington North America, Inc. is located at Center & 20th Street

P.O. Box 578, Ottawa. The facility manufactures architectural

flat glass for sale in the architectural and residential

construction markets. There are three main structures on the

218-acre LOF property: Plant #5, Plant No 7, and the Power

House. Currently, Plant No 7 and Power House are not in

operation.

4

---

2.0 LIST OF ABBREVIATIONS/ACRONYMS USED IN THIS PERMIT

Act

Illinois Environmental Protection Act ?

[415 ILCS 5/1 et seq.]

AP-42

Compilation of Air Pollutant Emission Factors, Volume 1,

Stationary Point and Other Sources (and Supplements A

through F), USEPA, Office of Air Quality Planning and

Standards, Research Triangle Park, NC

?

27711

BAT

Best Available Technology

Btu

British thermal unit

CAA

Clean Air Act?

[42 U.S.C. Section 7401 et seq.]

CAAPP

Clean Air Act Permit Program

CAM

Compliance Assurance Monitoring

CFR

Code of Federal Regulations

dscf

Dry standard cubic feet

ERMS

Emissions Reduction Market System

gal

gallon

gr

grams

°F

Fahrenheit

ft

cubic feet

HAP

Hazardous Air Pollutant

hr

hour

IAC

Illinois Administrative Code

I.D. No.

Identification Number of Source, assigned by Illinois EPA

ILCS

Illinois Compiled Statutes

Illinois

EPA

Illinois Environmental Protection Agency

kg

kilogram

kW

kilowatts

LAER

Lowest Achievable Emission Rate

lb

pound

MACT

Maximum Achievable Control Technology

Mft 3

Million cubic feet

mmBtu

Million British thermal units

mo

month

MW

Megawatts

NESHAP

National Emission Standards for Hazardous Air Pollutants

NO.

Nitrogen Oxides

NSPS

New Source Performance Standards

PM

Particulate Matter

PM

10

Particulate matter with an aerodynamic diameter less than or

equal to a nominal 10 microns as measured by applicable test

or monitoring methods

ppm

parts per million

PSD

Prevention of Significant Deterioration

RMP

Risk Management Plan

so

t

Sulfur Dioxide

T

ton

T1

Title I - identifies Title I conditions that have been

carried over from an existing permit

T1N

Title I New - identifies Title I conditions that are being

'established in this permit

5

---

T1R

Title I Revised - identifies Title I conditions that have

been carried over from an existing permit and subsequently

revised in this permit

USEPA

United States Environmental Protection Agency

VOL

Volatile organic liquid

VOM

Volatile Organic Material

VPL

Volatile petroleum liquid

yr

year

---

3.0 INSIGNIFICANT ACTIVITIES

3.1?

Identification of Insignificant Activities

The following activities at the source constitute insignificant

activities as specified in 35 IAC 201.210:

3.1.1 Activities determined by the Illinois EPA to be

insignificant activities, pursuant to 35 IAC 201.210(a)(1)

and 201.211,

as

follows:

None

3.1.2 Activities that are insignificant activities based upon

maximum emissions, pursuant to 35 IAC 201.210(a)(2) or

(a)(3), as follows:

Degreasers

Imperfection Ink Marking System

Adipic Acid Application Process

3 1.3 Activities that are insignificant activities based upon

their type or character, pursuant to 35 IAC 201.210(a)(4)

through (18), as follows:

Direct combustion units designed and used for comfort

heating purposes and fuel combustion emission units

as follows: (A) Units with a rated heat input

capacity of less than 2.5 mmBtu/hr that fire only

natural gas, propane, or liquefied petroleum

gas;

(B)

Units with a rated heat input capacity of less than

1.0 mmBtu/hr that fire only oil or oil in combination

with only natural gas, propane, or liquefied

petroleum gas; and (C) Units with a rated heat input

capacity of less than 200,000 Btu/hr which never burn

refuse, or treated or chemically contaminated wood

[35 IAC 201.210(a)(4)].

Storage tanks of organic liquids with a capacity of

less than 10,000 gallons and an annual throughput of

less

than 100,000 gallons per year, provided the

storage tank is not used for the storage of gasoline

or any material listed as a HAP pursuant to Section

112(b) of the CAA [35 IAC 201.210(a) (10)].

Storage tanks of any size containing virgin or re-

refined distillate oil, hydrocarbon condensate from

natural gas pipeline or storage systems, lubricating

oil, or residual fuel oils [35 IAC 201.210(a)(11)].

Gas turbines and stationary reciprocating internal

combustion engines of less than 112 kW (150

horsepower) power output [35 IAC 201.210(a)(15)].

7

---

Gas turbines and stationary reciprocating internal

combustion engines of between 112 kW and 1,118 kW

(150 and 1,500 horsepower) power output that are

emergency or standby units [35 IAC 201.210(a)(16)].

3.1.4 Activities that are considered insignificant activities

pursuant to 35 IAC 201.210(b).

3.2 Compliance with Applicable Requirements

Insignificant activities are subject to applicable requirements

notwithstanding status as insignificant activities. In

particular, in addition to regulations of general applicability,

such as 35 IAC 212.301 and 212.123 (Condition 5.2.2), the

Permittee shall comply with the following requirements, as

applicable:

3.2.1 For each cold cleaning degreaser, the Permittee shall

comply with the applicable equipment and operating

requirements of 35 IAC 215.182, 218.182, or 219.182.

3.2.2 For each particulate matter process emission unit, the

Permittee shall comply with the applicable particulate

matter emission limit of 35 IAC 212.321 or 212.322. For

example, the particulate matter emissions from a process

emission unit shall not exceed 0.55 pounds per hour if the

emission unit's process weight rate is 100 pounds per hour

or less, pursuant to 35 IAC 266.110.

3.2.3 For each organic material emission unit that uses organic

material, e.g., a mixer or

printing

line, the Permittee

shall comply with the applicable VOM emission limit of 35

IAC 215.301, 218.301, or 219.301, which requires that

organic material emissions not exceed 8.0 pounds per hour

or do not qualify as photochemically reactive material as

defined in 35 IAC 211.4690.

3.3 Addition of Insignificant Activities

3.3.1 The Permittee is not required to notify the Illinois EPA

of additional insignificant activities present at the

source of a type that is identified in Condition 3.1,

until the renewal application for this permit is

submitted, pursuant to 35 IAC 201.212(a).

3.3.2 The Permittee must notify the Illinois EPA of any proposed

addition

of a new insignificant activity of a type

addressed by 35 IAC 201.210(a) and 201.211 other than

those identified in Condition 3.1, pursuant to Section

39.5(12)(b) of the Act.

3.3.3 The Permittee is not required to notify the Illinois EPA

of additional insignificant activities present at the

source of a type identified in 35 IAC 201.210(b).

8

---

4.0 SIGNIFICANT EMISSION UNITS AT THIS

SOURCE

Emission

Unit

Description

Date

Constructed

Emission Control

Equipment

Unit 01

Batch Hall Storage

Modified Per

Construction Permit

05010008: replacement

of 2 dust collectors

1935/2005

Dust Collectors (24

total)

Batch Mixer

1969

Dust Collectors (4

total)

Furnace Fill System

1969/1975

Dust Collectors (2

total?

(in

parallel))

Cullet Return

Crossover Area Dust

Collector (DC-4)

Cullet Return System

Area 1

Modified Per

Construction Permit

05010008:?

replacement

of #4 Dust Collector

Pre-

1972/2005

Cullet Return System

Area #2

Pre-1972

Capping Area Dust

Collector (DC-5)

Cullet Return System

Area #3

Pre-1975

Float Wareroom East

-

?

Dust Collector

(DC-6)

Cullet Return System

Area #4

Pre-1972

Float Wareroom East

Dust Collector

(DC-8)

Unit 02

Float Glass Melting

Furnace:?

Natural Gas

Fired

1969

None

Modifications to Float

Glass

Melting Furnace

per Construction Permit

07030023 as Follows:

Oxygen Lancing will

Replace Oxygen

Enrichment

With Incremental

Increases in Oxygen

Supply as Required to

Maintain Furnace

Conditions

Oxygen Plant will

Supply up to 80,000 CFH

of Total Oxygen

2007

Proprietary

3R System

9

---

Emission

Unit

Description

Date

Constructed

Emission Control•

Equipment

Unit 02

(Continued)

Modifications to Float

Glass Melting Furnace

Per Construction Permit

07070036 as Follows:

Rebricking the 5F1

Glass Furnace,

Install of Low-NO,

Burners,

Replace Ejectors with

Natural Draft Chimney,

Rebrick Regenerators,

Install 3R System (a

Proprietary System

Designed to Reduce

Nitrogen Oxide (NO.)

Emissions)

2007

Proprietary

3R System

Unit 03

Float Glass Melting

Furnace Tin Bath

1969

None

Unit 04

Low-E Vapor Deposition

Coating Process

1988

Afterburner, Heat

Exchanger, Lime

Neutralization

System, Baghouse

Unit 05 Float Glass Annealing

Lehr

1992

None

Unit 06

1000 Gallon Gasoline

Storage Tank

1975

None

10

---

5.0 OVERALL SOURCE CONDITIONS

5.1 Source Description

5.1.1 This permit is issued based on the source requiring a

CAAPP permit as a major source of Nitrogen Oxide, Sulfur

Dioxide, and Particulate Matter emissions.

5.2 Applicable Regulations

5.2.1 Specific emission units at this source are subject to

particular regulations as set forth in Section 7 (Unit-

Specific Conditions) of this permit.

5.2.2 In addition, emission units at this source are subject to

the following regulations of general applicability:

a.

No person shall cause or allow the emission of

fugitive particulate matter from any process,

including any material handling or storage activity,

that is visible by an observer looking generally

overhead at a point beyond the property line of the

source unless the wind speed is greater than 40.2

kilometers per hour (25 miles per hour), pursuant to

35 IAC 212.301 and 212.314.

Compliance with this requirement is considered to be

assured by the inherent nature of operations at this

source, as demonstrated by historical operation.

b. No person shall cause or allow the emission of smoke

or other particulate matter, with an opacity greater

than 30 percent, into the atmosphere from any

emission unit other than those emission units subject

to the requirements of 35 IAC 212.122, pursuant to 35

IAC 212.123(a), except as allowed by 35 IAC

212.123(b) and 212.124.

5.2.3 Ozone Depleting Substances

The Permittee shall comply with the standards for

recycling and emissions reduction of ozone depleting

substances pursuant to 40 CFR Part 82, Subpart F, except

as provided for motor vehicle air conditioners in Subpart

B of 40 CFR Part 82:

a.

Persons opening appliances for maintenance, service,

repair, or disposal must comply with the required

practices pursuant to 40 CFR 82.156.

b. Equipment used during the maintenance, service,

repair, or disposal of appliances must comply with

the standards for recycling and recovery equipment

pursuant to 40 CFR 82.158.

11

---

c.

Persons performing maintenance, service, repair, or

disposal of appliances must be certified by an

approved technician certification program pursuant to

40 CFR 82.161.

5.2.4 Risk Management Plan

Should this stationary source, as defined in 40 CFR

Section 68.3, become subject to the Accidental Release

Prevention regulations in 40 CFR Part 68, then the owner

or operator shall submit [40 CFR 68.215(a)(2)(i) and

(ii)]:

a.

A compliance schedule for meeting the requirements of

40 CFR Part 68 by the date provided in 40 CFR

68.10(a); or

b.

A certification statement that the source is in

compliance with all requirements of 40 CFR Part 68,

including the registration and submission of the Risk

Management Plan (RMP), as part of the annual

compliance certification required by 40 CFR Part 70

or 71.

5.2.5 a.

?

Should this stationary source become subject to a

regulation under 40 CFR Parts 60, 61, or 63, or 35

IAC after the date issued of this permit, then the

owner or operator shall, in accordance with the

applicable regulation(s), comply with the applicable

requirements by the date(s) specified and shall

certify compliance with the applicable requirements

of such regulation(s) as part of the annual

compliance certification, as required by 40 CFR Part

70 or 71.

b.?

No later than upon the submittal for renewal of this

permit, the owner or operator shall submit, as part

of an application, the necessary information to

address either the non-applicability

of,

or

demonstrate compliance with all applicable

requirements of any potentially applicable regulation

which was promulgated after the date issued of this

permit.

5.2.6 Episode Action Plan

a.?

If the source is required to have an episode action

plan pursuant to 35 IAC 244.142, the Permittee shall

maintain at the source and have on file with the

Illinois EPA a written episode action plan (plan) for

reducing the levels of emissions during yellow

alerts, red alerts, and emergencies, consistent with

safe operating procedures. The plan shall contain

the information specified in 35 IAC 244.144.

12

---

b.?

The Permittee shall immediately implement the

appropriate steps described in this plan should an

air pollution alert or emergency be declared.

c

?

If a change occurs at the source which requires a

revision of the plan (e.g., operational change,

change in the source contact person), a copy of the

revised plan shall be submitted to the Illinois EPA

for review within 30 days of the change. Such plans

shall be further revised if disapproved by the

Illinois EPA.

d.?

For sources required to have a plan pursuant to 35

IAC 244.142, a copy of the original plan and any

subsequent revisions shall be sent to:

i.

Illinois EPA, Compliance Section; and

ii.

For sources located in Cook County and outside

of the city of Chicago: Cook County

Department of Environmental Control; or

iii. For sources located within the city of

Chicago: Chicago Department of Environmental

Control.

5.2.7 CAM Plan

This stationary source has a pollutant-specific emissions

unit that is subject to 40 CFR Part 64, Compliance

Assurance Monitoring (CAM) for Major Stationary Sources.

The source must submit a CAM plan for each affected

pollutant-specific emissions unit upon application for

renewal of the initial CAAPP permit, or upon a significant

modification to the CAAPP permit for the construction or

modification of a large pollutant-specific emissions unit

which has the potential post-control device emissions of

the applicable regulated air pollutant that equals or

exceeds major source threshold levels.

5.3 Non-Applicability of Regulations of Concern

None

5.4

?

Source-Wide Operational and Production Limits and Work Practices

In addition to the source-wide requirements in the Standard

Permit Conditions in Section 9, the Permittee shall fulfill the

following source-wide operational and production limitations

and/or work practice requirements:

None

13

---

5.5?

Source-Wide Emission Limitations

5.5.1 Permitted Emissions for Fees

The annual emissions from the source, not considering

insignificant activities as addressed by section 3.0 of

this permit, shall not exceed the following limitations.

The overall source emissions shall be determined by adding

emissions from all emission units. Compliance with these

limits shall be determined on a calendar year basis.

These limitations (condition 5.5.1) are set for the

purpose of establishing fees and are not federally

enforceable.

Permitted Emissions of Regulated Pollutants

Pollutant

Tons/Year

Volatile Organic Material (VOM)

50.37

Sulfur Dioxide (SO,)

321.39

Particulate Matter (PM)

218.35

Nitrogen Oxides

(NO

r

)

799.01

HAP, not included in VOM or PM

10.284

Total

1,399.40

5.5.2 Emissions of Hazardous Air Pollutants

This permit is issued based on the emissions of HAPs as

listed in Section 112(b) of the CAA not being equal to or

exceeding 10 tons per year of a single HAP or 25 tons per

year of any combination of such HAPs, so that this source

is considered a minor source for HAPs.

5.5.3 Other Source-Wide Emission Limitations

Other source-wide emission limitations are not set for

this source pursuant to either the federal rules for

Prevention of Significant Deterioration (PSD), 40 CFR

52.21, Illinois EPA rules for Major Stationary Sources

Construction and Modification, 35 IAC Part 203, or Section

502(b) (10) of the CAA. However, there may be unit

specific emission limitations

set

forth

in

Section 7 of

this permit pursuant to these rules.

5.6 General Recordkeeping Requirements

5.6.1 Emission Records

The Permittee shall maintain records of the following

items for the source to demonstrate compliance with

Condition 5.5.1, pursuant to Section 39.5(7)(b) of the

Act:

Total annual emissions on a calendar year basis for

the emission units covered by Section 7 (Unit

Specific Conditions) of this permit.

14

---

5.6.2 Records for VOM and HAP Emissions

a. Total annual emissions of each individual HAP and of

total HAPs on a calendar year basis for the

applicable emission units covered by Section 7 (Unit

Specific Conditions) of this permit.

b. Total monthly and running 12 month total VOM

emissions for the whole source based on the

applicable emission units covered by Section 7 (Unit

Specific Conditions) of this permit.

5.6.3 Records for Operating Scenarios

N/A

5.6.4 Retention and Availability of Records

a.

All records and logs required by this permit shall be

retained for at least five years from the date of

entry (unless a longer retention period

is

specified

by the particular recordkeeping provision herein),

shall be kept at a location at the source that is

readily accessible to the Illinois EPA or USEPA, and

shall be made available for inspection and copying by

the Illinois EPA or USEPA upon request.

b.

The Permittee shall retrieve and print, on paper

during normal source office hours, any records

retained in an electronic format (e.g., computer) in

response to

an

Illinois EPA or USEPA request for

records during the course of a source inspection.

5.7 General Reporting Requirements

5.7.1 General Source-Wide Reporting Requirements

The Permittee shall promptly notify the Illinois EPA,

Compliance Section, of deviations of the source with the

permit requirements as follows, pursuant to Section

39.5(7)(f)(ii) of the Act. Reports shall describe the

probable cause of such deviations, and any corrective

actions or preventive measures taken.

5.7.2 Annual Emissions Report

The annual emissions report required pursuant to Condition

9.7 shall contain emissions information for the previous

calendar year.

5.8 General Operational Flexibility/Anticipated Operating Scenarios

N/A

15

---

5.9 General Compliance Procedures

5.9.1 General Procedures for Calculating Emissions

Compliance with the source-wide emission limits specified

in Condition 5.5 shall be based on the recordkeeping and

reporting requirements of Conditions 5.6 and 5.7, and

compliance procedures in Section 7 (Unit Specific

Conditions) of this permit.

16

---

6.0 NOT APPLICABLE TO THIS PERMIT

17

---

7.0 UNIT SPECIFIC CONDITIONS

7.1 Unit 01: Process Emission Unit 1

Control: Dust Collectors

7.1.1 Description

Batch Hall Storage - raw material unloading, storage,

weighing, and discharging to the process.

Batch Mixer - mix raw material before discharging into furnace.

Furnace Fill System - discharge mixed batch and recycled

glass (cullet) into glass melting furnace.

Cullet Return System Area 1 - Handling of cullet off the

line; return cullet to storage areas.

Cullet Return System Area 2 - Transfer and storage of cut

glass sheets, breaking

glass,

and handling of the

cullet of the line.

Cullet Return System Area 3 - Transfer and storage of cut

glass sheets, breaking glass, and handling of the

cullet of the line.

Cullet Return System Area 4 - Handling of cut glass and

cullet of the line.

7.1.2 List of Emission Units and Air Pollution Control Equipment

Emission

Unit

Description

Date

Constructed/

Modified

Emission Control

Equipment

Dust Collectors

(24 total)

Unit 01

Batch Hall

Storage

Modified Per

Construction

Permit 05010008:

Replacement of 2

Dust Collectors

1935/2005

Batch Mixer

1969

Dust Collectors

(4 total)

Furnace Fill

System

1969/1975

Dust Collectors

(2 total?

(in

parallel)).

Cullet Return

System Area 1

Modified Per

Construction

Permit 05010008:

Replacement of #4

Dust Collector

Pre-1972/2005

Cullet Return

Crossover Area

Dust Collector

(DC-4)

18

---

Emission

Unit

Description

Date

Constructed/

Modified

Emission Control

Equipment

Capping Area Dust

Collector (DC-5)

Unit 01

(Cont.)

Cullet Return

System Area #2

Pre-1972

Cullet Return

System Area #3

Pre-1975

Float Wareroom

East Dust

Collector (DC-6)

Cullet Return

System Area #4

Pre-1972

Float Wareroom

East Dust

Collector (DC-8)

7.1.3 Applicability Provisions and Applicable Regulations

a.

The 'fl affected process emission unit 1" for the

purpose of these unit-specific conditions, are the

units described in 7.1.1 and 7.1.2.

b. The affected process emission unit 1 is subject to

the emission limits identified in Condition 5.2.2.

c. Units within process emission unit 1 are subject to

35 IAC 212.322, which provides that:

No person shall cause or allow the emission of

particulate matter into the atmosphere in any one

hour period from any process emission unit for which

construction or modification commenced prior to April

14, 1972, which, either alone or in combination with

the emission of particulate matter from all other

similar process emission at a source or premises,

exceeds the allowable emission rates specified in

subsection (c) of 35 IAC 212.322. (See also

Attachment 1) (35 IAC 212.322(a))

7.1.4 Non-Applicability of Regulations of Concern

Construction Permit 05010008 for replacement of dust

collectors was issued based on no increase of emissions

from the new dust collectors because there was no change

in production and the efficiency of the new dust

collectors equals or exceeds the efficiency of the

replaced dust collectors. The unit is therefore subject

to no new regulations other than those in condition 7.1.3.

7.1.5 Operational and Production Limits and Work Practices

None

7.1.6 Emission Limitations

In addition to Condition 5.2.2 and the source wide

emission limitations in Condition 5.5, the process

,mission unit 1 is subject to the following:

19

---

Emissions and operation of the following process shall not

exceed the following limits:

Operation Particulate Matter

Equipment

(Hours/Year)

(Lb/Hour) (Tons/Year)

Batch Hall?

(DC-1)

8,760

0.29

1.26

Cullet System #2

(DC-5)

8,760

0.51

2.24

Cullet System #3

(DC-6)

8,760

0.31

1.37

Cullet System #4

(DC-8)

8,760

0.24

1.06

Compliance with the annual limit shall be based on a

monthly basis from the sum of the data for the current

month plus the preceding 11 months (running 12 month

total. [T1]

The above limitations were established in permit 72120139,

pursuant to Title I of the Clean Air Act, specifically 35

IAC Part 203, Major Stationary Sources Construction and

Modification and 40 CFR 52.21, Prevention of Significant

Deterioration (PSD). These limits ensure that the

construction and/or modification addressed in the

aforementioned permit does not constitute a new major

source or major modification pursuant to these rules.

[T1]

For other sources within this unit there are no specific

emission limitations, however, there are source wide

emission limitations in Condition 5.5 that include these

sources.

7.1.7 Testing Requirements

Upon reasonable request by the Illinois EPA, pursuant to

Section 39.5(7)(d) of the Act and 35 IAC 212.107, for both

fugitive and non-fugitive particulate matter emissions, a

determination as to presence or absence of visible

emissions from emission units shall be conducted in

accordance with Method 22, 40 CFR Part 60, Appendix A,

except that the length of the observing period shall be at

the discretion of the observer, but not less than one

minute. This test method shall be used to determine

compliance with 35 IAC 212.123 [35 IAC 212.107].

7.1.8

Monitoring Requirements

None

7.1.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the

Permittee shall maintain records of the following items

for the process emission unit 1 to demonstrate compliance

20

---

with 5.5.1, 7.1.3(c), and 7.1.6, pursuant to Section

39.5(7)(b) of the Act:

a.

Records addressing use of good operating practices

for the dust collectors:

Records for periodic inspection of the bag

collectors with date, name of individual

performing the inspection, and the nature of

the inspection.

ii.

Records of prompt repair of defects, with

identification and description of defect,

effect on emissions, date identified, date

repaired, and nature of repair.

b.

Raw Material Usage, lb/day.

c.

Operating hours per day.

7.1.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA,

Compliance Section, of deviations of the process emission

unit 1 with the permit requirements as follows, pursuant

to Section 39.5(7)(f)(ii) of the Act. Reports shall

describe the probable cause of such deviations, and any

corrective actions or preventive measures taken.

7.1.11 Operational Flexibility/Anticipated Operating Scenarios

None

7.1.12 Compliance Procedures

Compliance of the process emission unit 1 with conditions

7.1.3(c) and 7.1.6 shall be based on the recordkeeping

requirements of 7.1.9, and by the use of the emission

factors and formula listed below:

For Particulate and Particulate HAPs emissions:

A = R X EF X (1 -

C/100)

B= A X 1 T/2000 lb X operating hours/year

Where:

A = Particulate or Particulate HAPs emissions, lb/hr

B = Particulate or Particulate HAPs emissions, T/yr

R = Raw material usage, lb/hr

21

---

EF Emission factor and control efficiencies as listed in

the following table:

Process

Emission Factor*

Control*

Efficiency

(%)

Particulate

Lb/Ton Raw

Materials Used

Particulate HAPs

Lb/Ton Raw

Materials Used

Batch Hall

Storage

1.264

0.00105

99

Batch Mixer

0.351

0.00105

99

Furnace Fill

System

0.106

0.000198

99

Cullet Return

System Area 1

0.2276

99

Cullet Return

System Area 2

2.27

---

99

Cullet Return

System Area 3

1.39

99

Cullet Return

System Area 4

1.0798

---

99

As

provided in the Title V Permit Application

---

7.2 Unit 02: Float Glass Melting Furnace

Control: None

7.2.1 Description

Mixed raw material and cullet is melted in the Float Glass

Melt Furnace under natural gas flame to produce molten

glass. Natural gas is the fuel used in the furnace burner.

Propane fuel shall be used as back up fuel in float glass

melting furnace.

7.2.2 List of Emission Units and Air Pollution Control Equipment

Emission

Unit

Description

Date

Constructed/

Modified

Emission

Control

Equipment

Unit 02

Float Glass Melting

Furnace:?

Natural

Gas Fired

1969

None

Modifications to

Float Glass Melting

Furnace per

Construction Permit

07030023

as

Follows:

Oxygen Lancing will

Replace Oxygen

Enrichment

With Incremental

Increases in Oxygen

Supply as Required

to Maintain Furnace

Conditions

Oxygen Plant will

Supply up to 80,000

CFH of Total Oxygen

2007

Proprietary

3R System

---

Emission

Unit

Description

Date

Constructed/

Modified

Emission

Control

Equipment

Unit 02

Modifications to

2007

(Continued) Float Glass Melting

Furnace per

Construction Permit

07070036 as Follows:

Rebricking the 5F1

Glass Furnace,

Install of Low-NOx

Burners,

Replace Ejectors

with Natural Draft

Chimney,

Rebrick

Regenerators,

Install 3R System (a

Proprietary System

Designed to Reduce

Nitrogen Oxide (NO.)

Emissions)

7.2.3 Applicability Provisions and Applicable Regulations

a.

The "affected furnace" for the purpose of these unit-

specific conditions, is the emission unit described

in conditions 7.2.1 and 7.2.2.

b.

The affected furnace is subject to 35 /AC 212.322,

which provides that: '

No person shall cause or allow the emission of

particulate matter into the atmosphere in any one

hour period from any process emission unit for which

construction or modification commenced prior to

April 14, 1972, which, either alone or in combination

with the emission of particulate matter from all

other similar process emission at a source or

premises, exceeds the allowable emission rates

specified in subsection (c) of 35 IAC 212.322. (See

also Attachment 1) [35 IAC 212.322(a)]

c.

The affected furnace is subject to 35 IAC 214.301

which provides that no person shall cause or allow

the emission of sulfur dioxide into the atmosphere

from any process emission sources to exceed 2000 ppm.

d. Startup Provisions

The Permittee is authorized to operate the affected

furnace in violation of the applicable limit of 35

24

---

IAC 212.322, 216.121, and 214.301 during startup of

the furnace pursuant to 35 IAC 201.262, as the

Permittee has affirmatively demonstrated that all

reasonable efforts have been made to minimize startup

emissions, duration of individual starts, and

frequency of startups. This authorization is subject

to the following:

This authorization only extends for a period

of up to 3 days once every 8 to 12 years

following initial firing of fuel during the

startup event.

ii.

?

The Permittee shall take the following

measures to minimize startup emissions, the

duration of startups, and minimize the

frequency of startups:

A.

Implementation of established startup

procedures; and

B.

Operating the affected furnace according

to manufacturer's recommendations.

iii.

The Permittee shall fulfill the applicable

recordkeeping requirements of Condition

7.2.9(c)

7.2.4 Non-Applicability of Regulations of Concern

a.

The affected furnace is not subject to a New Source

Performance Standard (NSPS) for glass manufacturing

plants, 40 CFR 60, Subparts A and CC, since the

affected furnace was constructed in 1969;

applicability requires construction or modification

after June 15, 1979.

b.

The affected furnace is not subject to 35 IAC 214.142.

Sulfur Limitations: Small Sources Located Outside

Metropolitan Areas since the furnace does not burn

solid fuel exclusively, as' applicability requires.

c.

The affected furnace is not subject to 35 IAC

216.121, Carbon Monoxide Emissions from Fuel

Combustion Sources, since the furnace is not engaged

in production of heat or power by indirect heat

transfer.

d.

Construction Permit 07070036 (rebricking project) was

issued based on the project not constituting a major

modification in accordance with 40 CFR 52.21,

Prevention of Significant Deterioration of Air

Quality (PSD), because the potential increases in

emissions from the affected furnace are less than the

25

---

PSD significant net emission increase thresholds.

(See also Attachment 8.)

e.

Construction Permit 07030023 for the modifications

detailed in Condition 7.2.2 was based on the

modifications to the furnace not being a major

modification subject to the PSD rules because they

will not be accompanied by significant increases in

emissions of PSD pollutants, as defined under the PSD

rules. In particular, the projected increase in

emissions of NO. is only 39 tons/year. (See

Attachment 7)

7.2.5 Operational Production Limits and Work Practices

a.

Propane fuel shall be used as back up fuel in float

glass melting furnace and shall not exceed 15,000

gallons/month and 157,600 gallons/year.

[Tax]

b.

The Permittee shall, for a period of 5 years following

resumption of regular operation after the modifications

per Construction Permit 07070036 (detailed in condition

7.2.2) are made, operate the affected changes in such a

manner that this project does not result in a

significant increase in emissions and qualify as a

major modification for such emissions, including NOR,

SO2 , VOM, CO PM, PM"

and HAPs.

c.

Natural gas shall be the only fuel fired in the

affected furnace during normal operation.

d.

The Permittee shall, for a period of 10 years

following resumption of regular operation after the

modifications entailed detailed in 7.2.2 per

Construction Permit 07030023 are made, operate the

affected changes in such a manner that this project

does not result in a significant increase in

emissions of NO, and qualify as a major modification

for No,.

7.2.6 Emission Limitations

In addition to Condition 5.2.2 and the source wide

emission limitations in Condition 5.5, the affected

furnace is subject to the following:

Pollutant

.

NO,

SO2

VOM

CO

H2

SO4

PM

PM"

Lb/Ton of Draw 6.67 3.23

0.105

0.175

0.517

1.19

1.13

Lb/Hr

148.10

72.69

2.36

3.93

11.63

36.97

26.42

Tons/Year

649

318

10.34

17.21

51.00

162.00

111.00

The above limitations were established in Permit

07070036, pursuant to 35 IAC Part 203. These limits

ensure that the construction and/or modification

addressed in the aforementioned permit does not

26

---

constitute a new major source or major modification

pursuant to Title I of the CAA, specifically 35 IAC

Part 203. [T1]

Compliance with annual limits shall be determined on

a monthly basis from the sum of the data for the

current month plus the preceding 11 months (running

12 month total).

7.2.7 Testing Requirements

None

7.2.8 Monitoring Requirements

None

7.2.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the

Permittee shall maintain records of the following items

for affected furnace to demonstrate compliance with 5.5.1

and 7.2.3(b)(c) and (d), pursuant to Section 39.5(7)(b) of

the Act:

a.

Hours of operation

b.

Material throughput, ton/day

c.

Records for Startup

The Permittee shall maintain the following records,

pursuant to Section 39.5(7)(b) of the Act, for the

affected furnace subject to Condition 7.2.3(e), which

at a minimum shall include:

The following information for each startup of

the affected furnace:

A.

Date and duration of the startup, i.e.,

start time and time normal operation

achieved;

B.

If normal operation was not achieved

within 22 days, an explanation why startup

could not be achieved;

C.

A detailed description of the startup,

including reason for operation and why

measures to minimize emissions, to

minimize the duration and to minimize the

frequency of startups failed;

27

---

D.

An explanation why established startup

procedures could not be performed, if not

performed;

E.

The nature of opacity, i.e., severity and

duration, during the startup and the

nature of opacity at the conclusion of

startup, if above normal; and

F. Whether exceedance of Condition 5.2.2 may

have occurred during startup, with

explanation and estimated duration

(minutes).

ii.

A maintenance and repair log for the affected

furnace, listing each activity performed with

date.

iii.

Fuel consumption, as determined directly from

fuel meters or indirectly from operating hours

of the burners and their rated capacity.

iv. The Permittee shall also fulfill the

applicable recordkeeping and reporting

requirements of the PSD rules, 40 CFR

52.21(r)(6), for modifications per condition

7.2.2.

7.2.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA,

Compliance Section, of deviations of the affected furnace

with the permit requirements as follows, pursuant to

Section 39.5(7)(f)(ii) of the Act. Reports shall describe

the probable cause of such deviations, and any corrective

actions or preventive measures taken.

7.2.11 Operational Flexibility/Anticipated Operating Scenarios

None

7.2.12 Compliance Procedures

a. Compliance with Condition 7.2.3(d) is demonstrated

under inherent operating conditions of an affected

furnace, so that no compliance procedures are set in

this permit addressing this requirement.

b.

Compliance of the affected furnace with Conditions

7.2.3(c) shall be based on the recordkeeping

requirements of 7.2.9, and by the use of the emission

factors and formula listed below:

A =

?

Material throughput X appropriate

emission

factor* X 1 day/hrs

28

---

B=?

A T

hr/year X 1 Ton/2000 lb

Where:

A =

Emission rate, lb/hr

B = Emission rate, ton/year

Emission factor tables (as provided in the

Title V app)

Pollutant

Emission Factor (lb/Ton

throughput)

NO,

8.0

Particulate

2.0

SO2

3.2

VOM

0.1

Lead

0.0003

Sulfuric Acid

0.515

CO

0.1

HAPs

Emission Factor (lb/Ton

throughput)

Chromium Compounds

0.0041

Hexavalent Chromium

0.0004

Metal HAP 1

0.00092

Metal HAP 2

0.00481

Metal HAP 3

0.130

---

7.3 Unit 03: Float Glass Melting Furnace Tin Bath

Control: None

7.3.1 Description

Molten glass is cooled on a bath of molten tin. Chlorine

gas is injected into the molten tin bath above the glass

to reduce the surface tension of the condensed tin about 1

to 2 times a week. No reactions occur; all gas is assumed

to be a HAP emission.

7.3.2 List of Emission Units and Air Pollution Control Equipment

Emission

Emission

Date

Control

Unit

Description

Constructed Equipment

Unit 03 Float Glass Melting

1969

None

Furnace Tin Bath

7.3.3 Applicability Provisions and Applicable Regulations

The "affected tin bath" for the purpose of these unit-

specific conditions, is the unit described in conditions

7.3.1 and 7.3.2.

7.3.4 Non-Applicability of Regulations of Concern

The affected tin bath is not subject to 40 CFR 60 Subpart

CC (Standards of Performance for Glass Manufacturing

Plants) since the affected tin bath is used to cool molten

glass; applicability requires that the unit be defined as

a glass melting furnace comprising a refractory vessel in

which raw materials are charged, melted at high

temperature, refined and conditioned to produce molten

glass.

7.3.5 Operational Production Limits and Work Practices

Chlorine gas usage in the tin bath shall not exceed 0.30

lb/hour and 1.32 tons/year. Chlorine gas shall be ducted

to roof ventilators no more than 20 times a year. [TM)

7.3.6 Emission Limitations

In addition to Condition 5.2.2 and the source wide

emission limitations in Condition 5.5, the affected tin

bath is subject to the following:

Emissions of hydrogen chloride from the tin bath

shall not exceed 0.31 lb/hour and 1.36 tons/year.

(T1N)

The above limitations were established in Permit

04010035, pursuant to 35 IAC Part 203. These limits

ensure that the construction and/or modification

30

---

addressed in the aforementioned permit does not

constitute a new major source or major modification

pursuant to Title

I of the CAA, specifically 35 IAC

Part 203. [MN]

7.3.7 Testing Requirements

None

7.3.8 Monitoring Requirements

None

7.3.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the

Permittee shall maintain records of the following items

for the affected tin bath to demonstrate compliance with

condition 5.5.1, pursuant to Section 39.5(7)(b) of the

Act:

Chlorine usage, lb/mo

Operating hours per year.

7.3.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA,

Compliance Section, of deviations of the affected tin bath

with the permit requirements as follows, pursuant to

Section 39.5(7)(f)(ii) of the Act. Reports shall describe

the probable cause of such deviations, and any corrective

actions or preventive measures taken.

7.3.11 Operational Flexibility/Anticipated Operating Scenarios

None

7.3.12

Compliance Procedures

Compliance with the limits of condition 7.3.6 shall be

based on the recordkeeping requirements in Condition 7.3.9

and the emission factors and formulas listed below:

As provided in the Title 5 application all chlorine

gas fed to the system becomes an emission.

•

HAP Emissions = Chlorine Usage

HAPs

?

Emission Factor (lb/lb chlorine used)

Chlorine gas

?

1.

0

31

---

7.4 Unit 04: Low-E Vapor Deposition Coating Process

Control: Afterburner, Heat Exchanger, Lime Neutralization

System, Baghouse Scrubbers I and I

7.4.1 Description

Chemical vapor deposition of materials onto glass surface

as it is drawn from the furnace.

7.4.2 List of Emission Units and Air Pollution Control Equipment

Emission

Unit

Description

Date

Constructed

Emission Control

Equipment

Afterburner, Heat

Exchanger, Lime

Neutralization

System, Baghouse

Unit 04

Low-E Vapor

Deposition

Coating Process

1988

7.4.3 Applicability Provisions and Applicable Regulations

a.

The "affected low-e deposition coating process" for

the purpose of these unit-specific conditions, is the

emission unit identified in conditions 7.4.1 and

7.4.2.

b.

The affected low-e deposition coating process is

subject to 35 IAC 215.301 which states that no person

shall cause or allow the discharge of more than 3.6

kg (8 lb/hr) of organic material into the atmosphere

from any emission source, except as provided in

Sections 215.302, 215.303, 215.304 and the following

exception: If no odor nuisance exists the limitation

of this Subpart shall apply only to photochemically

reactive material. [35 IAC 215.301]

c. The affected low-e deposition coating process is

subject to 35 IAC 215.302 which states that emissions

of organic material in excess of those permitted by

35 IAC 215.301 (condition 7.4.3(b)) are allowed if

such emissions are controlled by flame, thermal or

catalytic incineration so as either to reduce such

emissions to 10 ppm equivalent methane (molecular

weight 16), or less, or to convert 85 percent of the

hydrocarbons to carbon dioxide and water. (35 IAC

215.302(a)]

d.

The affected low-e deposition coating process is

subject to 35 IAC 212.321, which provides that:

No person shall cause or allow the emission of

particulate matter into the atmosphere in any one

hour period from any process emission unit for which

construction or modification commenced on or after

April 14, 1972, which, either alone or in combination

with the emission of particulate matter from all

32

---

other similar process emission at a source or

premises, exceeds the allowable emission rates

specified in subsection (c) of 35 IAC 212.321. (See

also Attachment 2) [35 IAC 212.321(a)]

7.4.4 Non-Applicability of Regulations of Concern

The affected low e deposition coating process is not

subject to 35 IAC 214.204, VOM Emission Limitations for

Manufacturing Plants due to applicability of 35 IAC

214.205(b) which provides that emissions of VOM from

emission units subject to 35 IAC 214.204, are allowable,

notwithstanding the limitations in Section 215.204 if

emissions are controlled by an afterburner system which

provides 81% reduction in the overall emission of VOM from

the coating lines and oxidation to carbon dioxide and

water of 90% of nonmethane VOM (measured at total

combustible carbon) which enters the afterburner.

7.4.5 Operational and Production Limits and Work Practices

None

7.4.6 Emission Limitations

In addition to Condition 5.2.2 and the source wide

emission limitations in Condition 5.5, the affected low-e

deposition coating process is subject to the following:

a.

?

Emissions and operation of the CVD Glass Coating

System shall not exceed the following limits:

Usage

Emissions

Material

(Lb/Mo)

?

(Tons/Yr)

(Lb/Mo)

(Tons/Yr)

VOM

133,515

802

6,676

39.9

Chlorides

26,881

162

1,390

8.29

Fluorides

2,267

13.6

113.4

0.68

The above limitations contain revisions to previously

issued Permit 88110041. The source has requested

that the Illinois EPA establish conditions in this

permit that allow various refinements from the

conditions of this aforementioned permit, consistent

with the information provided in the CAAPP

application. The source has requested these

revisions and has addressed the applicability and

compliance of Title I of the CAA, specifically 35 IAC

Part 203, Major Stationary Sources Construction and

Modification and/or 40 CFR 52.21, Prevention of

Significant Deterioration (PSD). These limits

continue to ensure that the construction and/or

modification addressed in this permit does not

constitute a new major source or major modification

pursuant to these rules. These

limits are the

33

---

primary enforcement mechanism for the equipment and

activities permitted in this permit and the

information in the CAAPP application contains the

most current and accurate information for the source.

Specifically, VOM limit of 40.06 ton/yr was reduced

to 39.9 ton/yr, below levels deemed "Significant" per

40 CFR 52.21, fluoride emission rates were amended

from 45 lb/mo and 0.27 ton/yr to 113.4 lb/mo and 0.68

ton/yr. [T1R]

These limits are based on the maximum VOM, chlorides,

and fluorides content of the "worst case" raw

material usage as provided in the permit application

and a minimum 95% control efficiency from the dry

scrubbing/afterburner system in reducing VOM,

chlorides, and fluorides emissions. Compliance with

annual limits shall be determined from a running

total of 12 months of data. [T1R]

b.?

Emissions of particulate matter from the CVD Glass

Coating System baghouse of the dry scrubbing system

shall not exceed 764.4 pounds per month and 4.59 tons

per year. These limits are based on the baghouse

manufacturer's emission guarantee of 0.015 gr/dscf

and the maximum gas flow rates through the baghouse.

The majority of these emissions are due to the

injection of lime during the dry scrubbing process

for the purpose of air pollution control. As a

result, usage limits are not established. [Ti]

Note: Permit 88110041,

Low

E Chemical Vapor Deposition

Coating Process, was issued based on the CVD Glass Coating

System not constituting a major modification under the

federal rules for Prevention of Significant Deterioration

(PSD), 40 CFR 52.21, because it was

,

developed as two

projects. The initial project was addressed

by

Construction Permit 94070074 and the subsequent expansion

was addressed by Construction Permit 97030136.

7.4.7 Operating Requirements

a.

The afterburner shall be in operation at all times

when the CVD glass coater is in operation and

emitting air contaminants.

b. The afterburner combustion chamber shall be preheated

to at least the manufacturer's recommended

temperature but no less than the temperature at which

compliance was demonstrated in the most recent

compliance test, or 1400°F in the absence of a

compliance test. This temperature shall be

maintained during operation.

c.

At least two weeks prior to the initiation of any

research and development product runs on the CVD

34

---

glass coater involving experimental materials not

described in the application, the Permittee shall

submit a written notification to perform such

experimentation to the IEPA. The written

notification shall include the following information:

i.

A description of the proposed experiments;

ii. The expected duration of the experiment;

iii. The types and amounts of raw materials to be

used during the experiment; and

iv.

The estimated maximum quantities and

characteristics of any emissions that could

result from the proposed experiments and the

means and extent to which these emissions will

be controlled.

7.4.8 Monitoring and Testing Requirements

a.

The afterburner shall be equipped with a continuous

monitoring device which

is

installed, calibrated,

maintained, and operated according to

vendor's/manufacturer's specifications at all times

that the afterburner is in use. This device shall

monitor the afterburner combustion chamber

temperature.

b.

Within 90 days of a written request by the Illinois

EPA, the Permittee

shall

perform testing to measure

concentrations of organic material, particulate'

matter, chlorides, and/or fluorides concentrations in

the effluent stream of the control device on the CVD

glass

coater by using the following USEPA Reference

Methods, pursuant to 35 Ill. Adm. Code 215.105:

Volumetric Flow Rate?Method 1 and 2

Dry Molecular Weight?

Method 3

Moisture

?

Method 4

Particulate Matter

?

Method 5

Volatile Organic Material

?

Method 25 or 25A

Chlorides

?

Method 26

Fluorides?

Method 13B

These tests shall be conducted during circumstances

which are representative of maximum emissions, and

equipment data and material usage during the test

shall be recorded.

7.4.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the

?ermittee shall maintain records of the following items

or the affected low-e deposition coating process to

35

---

demonstrate compliance with conditions 5.5.1, 7.4.3(b) and

(c), and 7.4.6, pursuant to Section 39.5(7)(b) of the Act:

a.?

i.?

Raw material usage for each product run in

pounds per run.

ii.

?

VOM usage, in pounds per month and tons per

year, calculated from the VOM content and

usage of each raw material for each run during

the given month. Annual usage shall be

determined from data for the given month plus

the previous eleven months.

VOM emissions, in pounds per month and tons

per year, calculated from the VOM usage for

the given month controlled by 95%. Annual

emissions shall be determined from data for

the given month plus the previous eleven

months.

iv. Chloride usage, in pounds per month and tons

per year, calculated from the chlorine content

and usage of each raw material for each run

during the given month. Annual usage shall be

determined from data for the given month plus

the previous eleven months.

v.

HCL emissions, in pounds per month and tons

per year, calculated from the chlorine usage

for the given month controlled by 95%. Annual

emissions shall be determined from data for

the given month plus the previous eleven

months.

vi. Fluoride usage, in pounds per month and tons

per year, calculated from the fluorine content

and usage of each raw material for each run

during the given month. Annual usage shall be

determined from data for the given month plus

the previous eleven months.

vii.

HF emissions, in pounds per month and tons per

year, calculated from the fluorine usage for

the given month controlled by 95%. Annual

emissions shall be determined from data for

the given month plus the previous eleven

months.

viii.

Lime usage by the lime injection system, in

pounds per month and tons per year. Annual

emissions shall be determined from data for

the given month plus the previous eleven

months.

36

---

ix.

A log of inspections, monitoring, shutdowns,

and maintenance of the dry scrubbing system

and its individual components including the

afterburner, lime injection system, and

baghouse.

x.

The results of any stack test(s) performed on

the dry scrubbing system including capture and

control.

b.

Operating hours per year.

c.

Total natural gas usage for the afterburner

(ft3/month).

Records addressing use of good operating practices

for the dust collector:

i.

Records for periodic inspection of the bag

collector with date, name of individual

performing the inspection, and the nature of

the inspection.

ii.

Records of prompt repair of defects, with

identification and description of defect,

effect on emissions, date identified, date

repaired, and nature of repair.

7.4.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA,

Compliance Section, of deviations of the affected low-e

deposition coating process with the permit requirements as

follows, pursuant to Section 39.5(7)(0(ii) of the Act.

Reports shall describe the probable cause of such

deviations, and any corrective actions or preventive

measures taken.

7.4.11 Operational Flexibility/Anticipated Operating Scenarios

None

7.4.12 Compliance Procedures

a. Compliance of the affected low-e deposition coating

process with the particulate emissions limitations of

Conditions 7.4.3(d) and 7.4.6 shall be demonstrated

by the inherent operating conditions of the coating

process and the recordkeeping requirements in

condition 7.4.9.

b.

Compliance of the affected low-e deposition coating

process

with the Conditions 7.4.3(b) and (c) and

7.4.6 shall be based on the recordkeeping

37

---

requirements in Condition 7.4.9 and the emission

factors and formulas listed below:

For VOM/HAPs Emissions:

C?

Rate of feed VOM (lb/mo) X (1 - afterburner

removal efficiency)

D=?

A X

1 T/2000 lb X

hours per year

Where:

C VOM Emissions, lb/month

D

VOM emissions, T/yr

E

?

Rate of chlorides or fluorides, lb/mo x (1 -

scrubber removal efficiency)

F = E/2000

Where:

E = Chlorides or Fluoride Emissions, lb/mo

F = Chlorides or Fluoride Emissions, T/yr

c.?

Compliance of the afterburner of the affected low-e

deposition coating process with condition. 5.5.1 shall

be determined by the recordkeeping requirements of

7.4.9 and the formulas and emission factors as

follows:

Emissions from the afterburner burning natural

gas shall be calculated based on the following

emission factors:

Emission Factor

Pollutant? (lb/We)

Nox

?100

PM?

7.6

SO

2

?0.6

VOM

?

5.5

CO

?

84

These are the emission factors for

uncontrolled natural gas combustion in

commercial boilers (< 100 mmBtu/hr), Tables

1.4-1, 1.4-2, and 1.4-3, AP-42, Volume I,

Supplement D, July 1998.

VOM

emission factor

based on TOC factor corrected for 52% methane

contribution.

38

---

Fuel Combustion Unit Emissions (ton) = natural

gas consumed multiplied by the appropriate

emission factor/2000.

39

---

7.5 Unit 05: Float Glass Annealing Lehr

Control: None

7.5.1 Description

Float glass is heat treated to remove strains developed

during the molding or shaping operations and then

subjected to slow, controlled cooling.

7.5.2 List of Emission Units and Air Pollution Control Equipment

Emission

Emission

Date

Control

Unit

Description

Constructed Equipment

Unit 05 Float Glass Annealing

1992

None

Lehr:

?

18 Burners, Max.

Firing Rate 10 mmBtu/hr

7.5.3 Applicability Provisions and Applicable Regulations

a.

The "affected float

glass

annealing lehr" for the

purpose of these unit-specific conditions, is the

unit described in conditions 7.5.1 and 7.5.2.

b. No person shall cause or allow the emission of carbon

monoxide (CO) into the atmosphere from any fuel

combustion emission unit with actual heat input

greater than 2.9

MW

(10 mmBtu/hr) to exceed 200 parts

per million, corrected to 50 percent excess air [35

IAC 216.121].

7.5.4 Non-Applicability of Regulations of Concern

a.

The affected float glass annealing lehr is not

subject to 35 IAC 217.121, Nitrogen Oxides Emissions

for New Fuel Combustion Emission Sources, since the

affected float glass annealing lehr has a maximum

firing rate of 10 mmBtu/hr; rule applicability

requires greater than 250 mmBtu/hr.

b. The affected float glass annealing lehr is not

subject to 40 CFR 60, Subpart CC (Standards of

Performance for Glass Manufacturing Plants) since the

lehr functions as a unit used to remove strains

developed during the molding or shaping operations;

applicability requires that the unit be classified as

a glass melting furnace comprising a refractory

vessel in which raw materials are charged, melted at

high temperature, refined and conditioned to produce

molten glass.

7.5.5 Operational and Production Limits and Work Practices

None

40

---

7.5.6 Emission Limitations

In addition to Condition 5.2.2 and the

emission limitations in Condition 5.5,

glass annealing lehr is subject to the

Nitrogen Oxides?

Carbon Monoxide

(Lb/Hr) (Tons/Yr) (Lb/Hr) (Tons/Yr)

source wide

the affected float

following:

Sulfur Dioxide

(Lb/Hr) (Tons/Yr)

1.0

?

4.32?

0.832

?

3.65

?

1.1?

4.8

The above limitations contain revisions to previously

issued Permit 72120139. The source has requested that the

Illinois EPA establish conditions in this permit that

allow various refinements from the conditions of this

aforementioned permit, consistent with the information

provided in the CAAPP application. The source has

requested these revisions and has addressed the

applicability and compliance of Title I of the CAA,

specifically 35 IAC Part 203, Major Stationary Sources

Construction and Modification and/or 40 CFR 52.21,

Prevention of Significant Deterioration (PSD). These

limits continue to, ensure that the construction and/or

modification addressed in this permit does not constitute

a new major source or major modification pursuant to these

rules. These limits are the primary enforcement mechanism

for the equipment and activities permitted in this permit

and the information in the CAAPP application contains the

most current and accurate information for the source.

Specifically, CO emissions have been increased to 0.832

lb/hr and 3.65 T/yr and emission limitations for Sulfur

Dioxide have been added. [T1R]

7.5.7 Testing Requirements

None

7.5.8 Monitoring Requirements

None

7.5.9 Recordkeeping Requirements

In addition to the records required by

Permittee shall maintain records of the

for the affected float glass annealing

compliance with condition 5.5.1 and 7.5

Section 39.5(7)(b) of the Act:

Condition 5.6, the

following items

lehr to demonstrate

.6, pursuant to

a. NON, CO, and SO

2

emissions in pounds per month and

tons per year.

b. Total natural gas usage for the burners (ft3/month).

c. Operating hours per year.

41

---

7.5.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA,

Compliance Section, of deviations of the affected float

glass annealing lehr with the permit requirements as

follows, pursuant to Section 39.5(7)(f)(ii) of the Act.

Reports shall describe the probable cause of such

deviations, and any corrective actions or preventive

measures taken.

7.5.11 Operational Flexibility/Anticipated Operating Scenarios

None

7.5.12 Compliance Procedures

Compliance of the affected float glass annealing lehr with

conditions 5.5.1, and 7.5.6 is demonstrated by the

recordkeeping requirements of 7.5.9 and the following

formulas and emission factors:

Emissions from the combustion of natural gas shall be

calculated based on the following emission factors:

Pollutant

Emission Factor

(lb/106 ft3)

CO

84

PM

7.6

SO2

0.6

VOM

5.5

NO.

100

These are the emission factors for

uncontrolled natural gas combustion in small

boilers (<100 mmBtu/hr), Tables 1.4-1 and

1.4-2, AP-42, Volume I, Fifth Edition, July,

1998.

Combustion Emissions (ton) = natural gas consumed

multiplied by the appropriate emission factor/2000.

---

7.6 Unit 06: Gasoline Storage Tank

Control: None

7.6.1 Description

The facility operates a 250 gallon gasoline storage tank.

7.6.2 List of Emission Units and Pollution Control Equipment

Emission

Emission

Date

Control

Unit

Description

Constructed

Equipment

Unit 06

250 Gallon Gasoline

1975

None

Storage Tank

7.6.3 Applicability Provisions and Applicable Regulations

a.

Gasoline tank is an "affected tank" for the purpose

of these unit-specific conditions.

b.

No person shall cause or allow the discharge of more

than 3.6 kg/hr (8 lb/hr) of organic material into the

atmosphere from any emission unit, except as provided

in 35 IAC 215.302, 215.303, or 215.304 and the

following exemption: If no odor nuisance exists the

limitation of 35 IAC 215 Subpart G shall only apply

to photochemically reactive material [35 IAC

215.301].

7.6.4 Non-Applicability of Regulations of Concern

a.

The affected tank is not subject to the

NSPS

for

volatile organic liquid storage vessels (including

petroleum liquid storage vessels) for which

construction, reconstruction, or modification

commenced after July 23, 1984, 40 CFR 60 Subpart Kb;

the affected tank was constructed prior to 1984.

b.

The affected tank is not subject to the requirements

of 35 IAC 215.123, petroleum liquid storage tanks,

pursuant to 35 IAC 215.123(a)(2), which exempts

storage tanks with a capacity less than 151.42 m3.

c.

The affected tank is not subject to the requirements

of 35 IAC 215.122(b) since the rule applies only to

tanks with capacities of 250 gallons or greater.

7.6.5 Operational and Production Limits and Work Practices

The affected

tank shall only be used for the storage of

gasoline.

43

---

7.6.6 Emission Limitations

There are no specific emission limitations for this unit,

however, there are source wide emission limitations in

Condition 5.5 that include this unit.

Emission limits for VOM are not set for the affected tank,

as potential to emit in the absence of permit limit is

less than the significant and major source thresholds for

these pollutants pursuant to Title I of the CAA,

specifically the federal rules for the Prevention of

Significant Deterioration (PSD), 40 CFR 52.2/.

7.6.7 Testing Requirements

None

7.6.8 Monitoring Requirements

None

7.6.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the

Permittee shall maintain records of the following items

for the affected tank to demonstrate compliance with

Conditions 5.5.1, 7.6.3, and 7.6.5, pursuant to Section

39.5(7)(b) of the Act:

a.

The throughput of the affected tank, gal/mo and

gal/yr; and

b. The monthly and aggregate annual VOM emissions from

the affected tank based on the material stored, the

tank throughput, and the applicable emission factors

and formulas with supporting calculations.

7.6.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA,

Compliance Section, of deviations of the affected tank

with the permit requirements as follows, pursuant to

Section 39.5(7)(f)(ii) of the Act. Reports shall describe

the probable cause of such deviations, and any corrective

actions or preventive measures taken:

a.?

The storage of any VOL or VPL other than the material

specified in Condition 7.6.5(a) within 30 days of

becoming aware of the non-compliance status. This

notification shall include a description of the

event, the cause for the non-compliance, actions

taken to correct the non-compliance, and the steps to

be taken to avoid future non-compliance.

44

---

7.6.11 Operational Flexibility/Anticipated Operating Scenarios

N/A

7.6.12 Compliance Procedures

Compliance with the emission limits shall be based on the

recordkeeping requirements in Condition 7.6.9 and the

emission factors and formulas listed below;

For the purpose of estimating VOM emissions from the

affected tanks to determine compliance with

Conditions 5.5.1 and 7.6.3(c), Versions 3.1 or 4.0 of

the TANKS program are acceptable.

---

8.0 GENERAL PERMIT CONDITIONS

8.1 Permit Shield

Pursuant to Section 39.5(7)(j) of the Act, the Permittee has

requested and has been granted a permit shield. This permit

shield provides that compliance with the conditions of this

permit shall be deemed compliance with applicable requirements

which were applicable as of the date the proposed permit for this

source was issued, provided that either the applicable

requirements are specifically identified within this permit, or

the Illinois EPA, in acting on this permit application, has

determined that other requirements specifically identified are

not applicable to this source and this determination (or a

concise summary thereof) is included

in

this permit.

This permit shield does not extend to applicable requirements

which are promulgated after July 3, 2003 (the date of issuance of

the draft permit) unless this permit has been modified to reflect

such new requirements.

8.2 Applicability of Title IV Requirements (Acid Deposition Control)

This source is not an affected source under Title IV of the CAA

and is not subject to requirements pursuant to Title IV of the

CAA.

8.3 Emissions Trading Programs

No permit revision shall be required for increases in emissions

allowed under any USEPA approved economic incentives, marketable

permits, emissions trading, and other similar programs or

processes for changes that are provided for elsewhere in this

permit and that are authorized by the applicable requirement

(Section 39.5(7)(o)(vii) of the Act).

8.4 Operational Flexibility/Anticipated Operating Scenarios

8.4.1

Changes Specifically Addressed by Permit

Physical or operational changes specifically addressed by

the Conditions of this permit that have been identified as

not requiring Illinois EPA notification may be implemented

without prior notice to the Illinois EPA.

8.4.2 Changes Requiring Prior Notification

The Permittee is authorized to make physical or

operational changes that contravene express permit terms

without applying for or obtaining an amendment to this

permit, provided that [Section 39.5(12)(a)(i) of the

Act]:

a.?

The changes do not violate applicable requirements;

46

---

b.

The changes do not contravene federally enforceable

permit terms or conditions that are monitoring

(including test methods), recordkeeping, reporting,

or compliance certification requirements;

c. The changes do not constitute a modification under

Title I of the CAA;

d.

Emissions will not exceed the emissions allowed under

this permit following implementation of the physical

or operational change; and

e.

The Permittee provides written notice to the Illinois

EPA, Division of Air Pollution Control, Permit

Section, at least 7 days before commencement of the

change. This notice shall:

i.

Describe the physical or operational change;

ii.

Identify the schedule for implementing the

physical or operational change;

iii. Provide a statement of whether or not any New

Source Performance Standard (NSPS) is

applicable to the physical or operational

change and the reason why the NSPS does or

does not apply;

iv.

Provide emission calculations which

demonstrate that the physical or operational

change will not result in a modification; and

v. Provide a certification that the physical or

operational change will not result in

emissions greater than authorized under the

Conditions of this permit.

8.5 Testing Procedures

Tests conducted to measure composition of materials, efficiency

of pollution control devices, emissions from process or control

equipment, or other parameters shall be conducted using standard

test methods. Documentation of the test date, conditions,

methodologies, calculations, and test results shall be retained

pursuant to the recordkeeping procedures of this permit. Reports

of any tests conducted

as

required by this permit or as the

result of a request by the Illinois EPA shall be submitted as

specified in Condition 8.6.

8.6 Reporting Requirements

8.6.1 Monitoring Reports

If monitoring is required by any applicable requirements

or conditions of this permit, a report summarizing

the

47

---

required monitoring results, as specified in the

conditions of this permit, shall be submitted to the Air

Compliance Section of the Illinois EPA every six months as

follows [Section 39.5(7)(f) of the Act):

Monitoring Period

?

Report Due Date

January - June

?

September 1

July - December

?

March 1

All instances of deviations from permit requirements must

be clearly identified in such reports. All such reports

shall be certified in accordance with Condition 9.9.

8.6.2 Test Notifications

Unless otherwise specified elsewhere in this permit, a

written test plan for any test required by this permit

shall be submitted to the Illinois EPA for review at least

60 days prior to the testing pursuant to Section

39.5(7)(a) of the Act. The notification shall include at

a minimum:

a.

The name and identification of the affected unit(s);

b.

The person(s) who will be performing sampling and

analysis and their experience with similar tests;

c.

The specific conditions under which testing will be

performed, including a discussion of why these

conditions will be representative of maximum

emissions and the means by which the operating

parameters for the source and any control equipment

will be determined;

d.

The specific determination of emissions and operation

which are intended to be made, including sampling and

monitoring locations;

e. The test method(s) which will be used, with the

specific analysis method, if the method can be used

with different analysis methods;

f.

Any minor changes in standard methodology proposed to

accommodate the specific circumstances of testing,

with justification; and

g.

Any proposed use of an alternative test method, with

detailed justification.

8.6.3 Test Reports

Unless

otherwise specified elsewhere in this permit, the

results of any test required by this permit shall be

48

---

submitted to the Illinois EPA within 60 days of completion

of the testing. The test report shall include at a

minimum [Section

39.5(7)(e)(1)

of the Act]:

a. The name and identification of the affected unit(s);

b. The date and time of the sampling or measurements;

c.

The date any analyses were performed;

d.

The name of the company that performed the tests

and/or analyses;

e. The test and analytical methodologies used;

f. The results of the tests including raw data, and/or

analyses including sample calculations;

g.

The operating conditions at the time of the sampling

or measurements; and

h. The name of any relevant observers present including

the testing company's representatives, any Illinois

EPA or USEPA representatives, and the representatives

of the source.

8.6.4 Reporting Addresses

a?

The following addresses should be utilized for the

submittal of reports, notifications, and renewals:

i.

Illinois EPA - Air Compliance Section

Illinois Environmental Protection Agency

Bureau of Air

Compliance Section (MC 40)

P.O. Box 19276

Springfield, Illinois 62794-9276

ii.

Illinois EPA - Air Regional Field Office

Illinois Environmental Protection Agency

Division of Air Pollution Control

5415 North University

Peoria, Illinois 61614

iii.

Illinois EPA - Air Permit Section

Illinois Environmental Protection Agency

Division of Air Pollution Control

Permit Section (MC 11)

P.O. Box 19506

Springfield, Illinois 62794-9506

49

---

iv.?

USEPA Region 5 - Air Branch

USEPA (AE - 17J)

Air & Radiation Division

77 West Jackson Boulevard

Chicago, Illinois 60604

b.?

Unless otherwise specified in the particular

provision of this permit, reports shall be sent to

the Illinois EPA - Air Compliance Section with a copy

sent to the Illinois EPA - Air Regional Field Office.

8.7 Obligation to Comply with Title I Requirements

Any term, condition, or requirement identified in this permit by

Tl, T1R, or T1N is established or revised pursuant to 35 IAC Part

203 or 40 CFR 52.21 ("Title I provisions) and incorporated into

this permit pursuant to both Section 39.5 and Title I provisions.

Notwithstanding the expiration date on the first page of this

permit, the Title I conditions remain in effect pursuant to Title

I provisions until the Illinois EPA deletes or revises them in

accordance with Title I procedures.

50

---

9.0 STANDARD PERMIT CONDITIONS

9.1 Effect of Permit

9.1.1 The issuance of this permit does not release the Permittee

from compliance with State and Federal regulations which

are part of the Illinois State Implementation Plan, as

well as with other applicable statutes and regulations of

the United States or the State of Illinois or applicable

ordinances, except as specifically stated in this permit

and as allowed by law and rule [Section 39.5(7)(j)(iv) of

the Act].

9.1.2 In particular, this permit does not alter or affect the

following:

a.

The provisions of Section 303 (emergency powers) of

the CAA, including USEPA's authority under that

Section;

b.

The liability of an owner or operator of a source for

any violation of applicable requirements prior to or

at the time of permit issuance;

c.

The applicable requirements of the acid rain program

consistent with Section 408(a) of the CAA; and

d.

The ability of USEPA to obtain information from a

source pursuant to Section 114 (inspections,

monitoring, and entry) of the CAA.

9.1.3 Notwithstanding the conditions of this permit specifying

compliance practices for applicable requirements, any

person (including the Permittee) may also use other

credible evidence to establish compliance or noncompliance

with applicable requirements.

9.2 General Obligations of Permittee

9.2.1 Duty to Comply

The Permittee must comply with all terms and conditions of

this permit. Any permit noncompliance constitutes a

violation of the CAA and the Act, and is grounds for any

or all of the following: enforcement action, permit

termination, revocation and reissuance, modification, or

denial of a permit renewal application [Section

39.5(7)(0)(1) of the Act].

The Permittee shall meet applicable requirements that

become effective during the permit term in a timely manner

unless an alternate schedule for compliance with the

applicable requirement is established.

51

---

9.2.2 Duty to Maintain Equipment

The Permittee shall maintain all equipment covered under

this permit in such a manner that the performance or

operation of such equipment shall not cause a violation of

applicable requirements.

9.2.3 Duty to Cease Operation

No person shall cause, threaten or allow the continued

operation of any emission unit during malfunction or

breakdown of the emission unit or related air pollution

control equipment if such operation would cause a

violation of an applicable emission standard, regulatory

requirement, ambient air quality standard or permit

limitation unless such malfunction or breakdown is allowed

by a permit condition [Section 39.5(6)(c) of the Act].

9.2.4 Disposal Operations

The source shall be operated in such a manner that the

disposal of air contaminants collected by the equipment

operations, or activities shall not cause a violation of

the Act or regulations promulgated thereunder.

9.2.5 Duty to Pay Fees

The Permittee must pay fees to the Illinois EPA consistent

with the fee schedule approved pursuant to Section

39.5(18) of the Act, and submit any information relevant

thereto [Section 39.5(7)(0)(vi) of the Act]. The check

should be payable to "Treasurer, State of Illinois" and

sent to: Fiscal Services Section, Illinois Environmental

Protection Agency, P.O. Box 19276, Springfield, Illinois

62794-9276.

9.3 Obligation to Allow Illinois EPA Surveillance

Upon presentation of proper credentials and other documents, the

Permittee shall allow the Illinois EPA, or an authorized

representative to perform the following [section 39.5(7)(a) and

(p) (ii) of the Act and 415 ILCS 5/41:

a.

Enter upon the Permittee's premises where an actual or

potential emission unit is located; where any regulated

equipment, operation, or activity is located or where

records must be kept under the conditions of this permit;

b.

Have access to and copy, at reasonable times, any records

that must be kept under the conditions of this permit;

c.

Inspect during hours of operation any sources, equipment

(including monitoring and air pollution control

equipment), practices, or operations regulated or required

under this permit;

52

---

d.?

Sample or monitor any substances or parameters at any

location:

i.

At reasonable times, for the purposes of assuring

permit compliance; or

ii.

As otherwise authorized by the CAA, or the Act.

e.?

Obtain and remove samples of any discharge or emission of

pollutants authorized by this permit; and

f.?

Enter and utilize any photographic, recording, testing,

monitoring, or other equipment for the purposes of

preserving, testing, monitoring, or recording any

activity, discharge or emission at the source authorized

by this permit.

9.4 Obligation to Comply with Other Requirements

The issuance of this permit does not release the Permittee from

applicable State and Federal laws and regulations, and applicable

local ordinances addressing subjects other than air pollution

control.

9.5

?

Liability

9.5.1 Title

This permit shall not be considered as in any manner

affecting the title of the premises upon which the

permitted source is located.

9.5.2 Liability of Permittee

This permit does not release the Permittee from any

liability for damage to person or property caused by or

resulting from the construction, maintenance, or operation

of the sources.

9.5.3 Structural Stability

This permit does not take into consideration or attest to

the structural stability of any unit or part of the

source.

9.5.4 Illinois EPA Liability

This permit in no manner implies or suggests that the

Illinois EPA (or its officers, agents or employees)

assumes any liability, directly or indirectly, for any

loss due to damage, installation, maintenance, or

operation of the source.

53

---

9.5.5 Property Rights

This permit does not convey any property rights of any

sort, or any exclusive privilege [Section 39.5(7)(o)(iv)

of the Act].

9.6 Recordkeeping

9.6.1 Control Equipment Maintenance Records

A maintenance record shall be kept on the premises for

each item of air pollution control equipment. As a

minimum, this record shall show the dates of performance

and nature of preventative maintenance activities.

9.6.2 Records of Changes in Operation

A record shall be kept describing changes made at the

source that result in emissions of a regulated air

pollutant subject to an applicable requirement, but, not

otherwise regulated under this permit, and the emissions

resulting from those changes [Section 39.5(12)(b)(iv) of

the Act).

9.6.3 Retention of Records

a.

Records of all monitoring data and support

information shall be retained for a period of at

least 5 years from the date of the monitoring sample,

measurement, report, or application. Support

information includes all calibration and maintenance

records, original strip-chart recordings for

continuous monitoring instrumentation, and copies of

all reports required by this permit [Section

39.5(7)(e)(ii) of the Act).

b.

Other records required by this permit shall be

retained for a period of at least 5 years from the

date of entry unless a longer period is specified by

a particular permit provision.

9.7 Annual Emissions

Report

The Permittee shall submit an annual emissions report to the

Illinois EPA, Compliance Section no later than May 1 of the

following year, as required by 35 IAC Part 254.

9.8 Requirements for Compliance Certification

Pursuant to Section 39.5(7)(p)00 of the Act, the Permittee shall

submit annual compliance certifications. The compliance

certifications shall be submitted no later than May 1 or more

frequently as specified in the applicable requirements or by

permit condition. The compliance certifications shall be

submitted to the Air Compliance Section, Air Regional Field

54

---

Office, and USEPA Region 5 - Air Branch. The addresses for the

submittal of the compliance certifications are provided in

Condition 8.6.4 of this permit.

a.

The certification shall include the identification of each

term or condition of this permit that is the basis of the

certification; the compliance status; whether compliance

was continuous or intermittent; the method(s) used for

determining the compliance status of the source, both

currently and over the reporting period consistent with

the conditions of this permit.

b.

A11 compliance certifications shall be submitted to USEPA

Region 5 in Chicago as well as to the Illinois EPA.

c.

All compliance reports required to be submitted shall

include a certification in accordance with Condition 9.9.

9.9 Certification

Any document (including reports) required to be submitted by this

permit shall contain a certification by a responsible official of

the POrmittee that meets the requirements of Section 39.5(5) of

the Adt [Section 39.5(7)(p)(i) of the Act). An example

Certification by a Responsible Official is included as an

attachment to this permit.

9.10 Defense to Enforcement Actions

9.10.1 Need to Halt or Reduce Activity Not a Defense

It shall not be a defense for the Permittee in an

enforcement action that it would have been necessary to

halt or reduce the permitted activity in order to maintain

compliance with the conditions of this permit (Section

39.5(7) (o) (ii) of the Act).

9.10.2 Emergency Provision

a.

?

An emergency shall be an affirmative defense to an

action brought for noncompliance with the technology-

based emission limitations under this permit if the

following conditions are met through properly signed,

contemporaneous operating logs, or other relevant

evidence:

i. An emergency occurred as provided in Section

39.5(7)(k) of the Act and the Permittee can

identify the cause(s) of the emergency.

Normally, an act of God such as lightning or

flood is considered an emergency;

ii.

The permitted source was at the time being

properly operated;

55

---

iii.

The Permittee submitted notice of the

emergency to the Illinois EPA within two

working days of the time when emission

limitations were exceeded due to the

emergency. This notice must contain a

detailed description of the emergency, any

steps taken to mitigate emissions, and

corrective actions taken; and

iv. During the period of the emergency the

Permittee took all reasonable steps to

minimize levels of emissions that exceeded the

emission limitations, standards, or

regulations in this permit.

b.?

This provision is in addition to any emergency or

upset provision contained in any applicable

requirement. This provision does not relieve a

Permittee of any reporting obligations under existing

federal or state laws or regulations.

9.11 Permanent Shutdown

This permit only covers emission units and control equipment

while physically present at the indicated source location(s).

Unless this permit specifically provides for equipment

relocation, this permit is void for the operation or activity of

any item of equipment on the date it is removed from the

permitted location(s) or permanently shut down. This permit

expires if all equipment is removed from the permitted

location(s), notwithstanding the expiration date specified on

this permit.

9.12 Reopening and Reissuing Permit for Cause

9.12.1 Permit Actions

This permit may be modified, reopened, and reissued, for

cause pursuant to Section 39.5(15) of the Act. The filing

of a request by the Permittee for a permit modification,

revocation, and reissuance, or of a notification of planned

changes or anticipated noncompliance does not stay any

permit condition [Section 39.5(7) (o) (iii) of the Act] .

9.12.2 Reopening and Revision

This permit must be reopened and revised if any of the

following occur [Section 39.5(15)(a) of the Act]:

a.

Additional requirements become applicable to the

equipment covered by this permit and three or more

years remain before expiration of this permit;

b.

Additional requirements become applicable to an affected

source for acid deposition under the acid rain program;

56

---

C.

The Illinois EPA or

USEPA

determines that this permit

contains a material mistake or inaccurate statement when

establishing the emission standards or limitations, or

other terms or conditions of this permit; and

d.?

The Illinois

EPA

or

USEPA

determines that this permit

must be revised to ensure compliance with the

applicable requirements of the Act.

9.12.3 Inaccurate Application

The Illinois EPA has issued this permit based upon the

information submitted by the Permittee

in

the permit

application. Any misinformation, false statement or

misrepresentation in the application shall be grounds for

revocation under Section 39.5(15)(b) of the

Act.

9.12.4 Duty to Provide Information

The Permittee shall furnish to the Illinois

EPA,

within a

reasonable time specified by the Illinois

EPA

any

information that the Illinois

EPA

may request in writing

to determine whether cause exists for modifying, revoking

and reissuing, or terminating this permit, or to determine

compliance with this permit. Upon request, the Permittee

shall also furnish to the Illinois

EPA

copies of records

required to be kept by this permit, or for information

claimed to be confidential, the Permittee may furnish such

records directly to

USEPA

along with a claim of

confidentiality [Section 39.5(7)(o)(v) of the Act].

9.13 Severability Clause

The provisions of this permit are severable, and should any one

or more be determined to be illegal or unenforceable, the

validity of the other provisions shall not be affected. The

rights and obligations of the Permittee shall be construed and

enforced as if this permit did not contain the particular

provisions held to be invalid and the applicable requirements

underlying these provisions shall remain in force [Section

39.5(7)(i) of the Act].

9.14 Permit Expiration and Renewal

The right to operate terminates on the expiration date unless the

Permittee has submitted a timely and complete renewal

application. For a renewal to be timely it must be submitted no

later than 9 and no sooner than 12 months prior to expiration.

The equipment may continue to operate during the renewal period

until final action is taken by the Illinois EPA, in accordance

with

,

the original permit conditions [Section 39.5(5)(1), (n),

and (o) of the Act].

57

---

10.0 ATTACHMENTS

10.1 Attachment 1 - Emissions of Particulate Matter from Existing

Process Emission Units

a.

?

Except as further provided in this Part, no person shall

cause or allow the emission of particulate matter into the

atmosphere in any one hour period from any process

emission unit for which construction or modification

commenced prior to April 14, 1972, which, either alone or

in combination with the emission of particulate matter

from all other similar process emission units at a source

or premises, exceeds the allowable emission rates

specified in subsection (c) of this Section.

b.

?

Interpolated and extrapolated values of the data in

subsection (c) of this Section shall be determined by

using the equation:

Where:

P = Process weight rate; and

E = Allowable emission rate; and,

1.?

For process weight rates up to 27.2 Mg/hr (30 T/hr):

P

E

A

B

C

Metric

Mg/hr

kg/hr

1.985

0.67

0

English

T/hr

lb/hr

4.10

0.67

0

2.?

For process weight rates in excess of 27.2 Mg/hr (30

T/hr):

E

A

B

C

Metric

Mg/hr

kg/hr

25.21

0.11

-18.4

English

T/hr

lbs/hr

55.0

0.11

-40.0

c.?

Limits for Process Emission Units For Which Construction

or Modification Commenced Prior to April

14, 1972

Metric

?

English

P

Mg/hr

kg/hr

P

T/hr

lbs/hr

0.05

0.27

0.05

0.55

0.1

0.42

0.10

0.87

0.2

0.68

0.20

1.40

0.3

0.89

0.30

1.83

0.4

1.07

0.40

2.22

1-1

---

Metric

P

Mg/hr

E

kg/hr

English

P

T/hr

E

lbs/hr

0.5

1.25

0.50

2.58

0.7

1.56

0.75

3.38

0.9

1.85

1.00

4.10

1.8

2.9

2.00

6.52

2.7

3.9

3.00

8.56

3.6

4.7

4.00

10.40

4.5

5.4

5.00

12.00

9.

8.7

10.00

19.20

13.

11.1

15.00

25.20

18.

13.8

20.00

30.50

23.

16.2

25.00

35.40

27.2

18.15

30.00

40.00

32.0

18.8

35.00

41.30

36.0

19.3

40.00

42.50

41.0

19.8

45.00

43.60

45.0

20.2

50.00

44.60

90.0

23.2

100.00

51.20

140.0

25.3

150.00

55.40

180.0

26.5

200.00

58.60

230.0

27.7

250.00

61.00

270.0

28.5

300.00

63.10

320.0

29.4

350.00

64.90

360.0

30.0

400.00

66.20

400.0

30.6

450.00

67.70

454.0

31.3

500.00

69.00

Where:

P = Process weight rate in Mg/hr or T/hr, and

E = Allowable emission rate in kg/hr or lb/hr.

---

10.2 Attachment 2 Emissions of Particulate Matter from New Process

Emission Units

10.2.1 Process Emission Units For Which Construction or

Modification Commenced On or After April 14, 1972

a.?

Except as further provided in this Part, no person

shall cause or allow the emission of particulate

matter into the atmosphere in any one hour period

from any new process emission unit which, either

alone or in combination with the emission of

particulate matter from all other similar process

emission units for which construction or modification

commenced on or after April 14, 1972, at a source or

premises, exceeds the allowable emission rates

specified in subsection (c) of this Section.

b.?

Interpolated and extrapolated values of the data in

subsection (c) of this Section shall be determined

by

using the equation:

E

?

A (P)B

Where:

P = Process weight rate; and

E = Allowable emission rate; and,

i.

?

Up to process weight rates of 408 Mg/hr (450

T/hr):

Metric

?

English

P

Mg/hr? T/hr

E

kg/hr

?

lbs/hr

A?

1.214

?

2.54

B

0.534

?

0.534

ii.?

For process weight rate greater than or equal

to 408 Mg/hr (450 T/hr):

Metric

?

English

P

Mg/hr? T/hr

E

kg/hr

?

lbs/hr

A

?

11.42?

24.8

B

0.16

?

0.16

c.?

Limits for Process Emission Units For Which

Construction or Modification Commenced On or After

April 14, 1972.

2-1

---

Metric

P

Mg/hr

E

kg/hr

P

T/hr

English

E

lbs/hr

0.05

0.25

0.05

0.55

0.1

0.29

0.10

0.77

0.2

0.42

0.20

1.10

0.3

0.64

0.30

1.35

0.4

0.74

0.40

1.58

0.5

0.84

0.50

1.75

0.7

1.00

0.75

2.40

0.9

1.15

1.00

2.60

1.8

1.66

2.00

3.70

2.7

2.1

3.00

4.60

3.6

2.4

4.00

5.15

4.5

2.7

5.00

6.00

9.

3.9

10.00

8.70

3.

4.8

15.00

10.80

18.

5.7

20.00

12.50

23.

6.5

25.00

14.00

27.

7.1

30.00

15.60

32.

7.7

35.00

17.00

36.

8.2

40.00

18.20

41.

8.8

45.00

19.20

45.

9.3

50.00

20.50

90.

13.4

100.00

29.50

140.

17.0

150.00

37.00

180.

19.4

200.00

43.00

230.

22.

250.00

48.50

270.

24.

300.00

53.00

320.

26.

350.00

58.00

360.

28.

400.00

62.00

408.

30.1

450.00

66.00

454.

30.4

500.00

67.00

---

10.3 Attachment 3 - Example Certification by a Responsible Official

I certify under penalty of law that this document and all

attachments were prepared under my direction or supervision in

accordance with a system designed to assure that qualified

personnel properly gather and evaluate the information submitted.

Based on my inquiry of the person or persons directly responsible

for gathering the information, the information submitted is, to

the best of my knowledge and belief, true, accurate, and

complete. I am aware that there are significant penalties for

submitting false information, including the possibility of fine

and imprisonment for knowing violations.

Signature:

Name:

Official Title:

Telephone No.:

Date Signed:

---

10.4 Attachment 4 - Guidance on Revising This Permit

The Permittee must submit an application to the Illinois EPA

using the appropriate revision classification in accordance with

Sections 39.5(13) and (14) of the Act and 35 IAC 270.302.

Specifically, there are currently three classifications for

revisions to a CAAPP permit. These are:

1.

Administrative Permit Amendment;

2.

Minor Permit Modification; and

3.

Significant Permit Modification.

The Permittee must determine, request, and submit the necessary

information to allow the Illinois EPA to use the appropriate

procedure to revise the CAAPP permit. A brief explanation of

each of these classifications follows.

1.?

Administrative Permit Amendment

•

Corrects typographical errors;

•

Identifies a change in the name, address, or phone

number of any person identified in the permit, or

provides a similar minor administrative change at the

source;

•

Requires more frequent monitoring or reporting by the

Permittee;

•

Allows for a change in ownership or operational

control of the source where no other change in the

permit is necessary, provided that a written

agreement containing a specific date for transfer of

permit responsibility, coverage, and liability

between the current and new Permittees has been

submitted to the Illinois EPA. This shall be handled

by completing form 272-CAAPP, REQUEST FOR OWNERSHIP

CHANGE FOR CAAPP PERMIT; or

•

Incorporates into the CAAPP permit a construction

permit, provided the conditions of the construction

permit meet the requirements for the issuance of

CAAPP permits.

2.

?

Minor Permit Modification

• Do not violate any applicable requirement;

•

Do not involve significant changes to existing

monitoring, reporting, or recordkeeping requirements

in the permit;

4-1

---

•

Do not require a case-by-case determination of an

emission limitation or other standard, or a

source-specific determination of ambient impacts, or

a visibility or increment analysis;

•

Do not seek to establish or change a permit term or

condition for which there is no corresponding

underlying requirement and which avoids an applicable

requirement to which the source would otherwise be

subject. Such terms and conditions include:

•

A federally enforceable emissions cap assumed

to avoid classification as a modification

under any provision of Title I of the CAA; and

An alternative emissions limit approved

pursuant to regulations promulgated under

Section 112(i)(5) of the CAA.

• Are not modifications under any provision of Title I

of the CAA;

•

Are not required to be processed as a significant

permit modification; and

• Modifications involving the use of economic

incentives, marketable permits, emissions trading,

and other similar approaches.

An application for a minor permit modification shall

include the following:

•

A description of the change, the emissions resulting

from the change, and any new applicable requirements

that will apply if the change occurs;

The source's suggested draft permit/conditions;

• Certification by a responsible official that the

proposed modification meets the criteria for use of

minor permit modification procedures and a request

that such procedures be used; and.

•

Information as contained on form 271-CAAPP, MINOR

PERMIT MODIFICATION FOR CAAPP PERMIT for the Illinois

EPA to use to notify USEPA and affected States.

Significant Permit Modification

•

Applications that do not qualify as either minor

permit modifications or as administrative permit

amendments;

•

4-2

---

•

Applications requesting a significant change in

existing monitoring permit terms or conditions;

•

Applications requesting a relaxation of reporting or

recordkeeping requirements; and

•

Cases in which, in the judgment of the Illinois

.

EPA,

action on an application for modification would

require decisions to be made on technically complex

issues.

An application for a significant permit modification shall

include the following:

•

A detailed description of the proposed change(s),

including all physical changes to equipment, changes

in the method of operation, changes in emissions of

each pollutant, and any new applicable requirements

which will apply as a result of the proposed change.

Note that the Permittee need only submit revised forms

for equipment and operations that will be modified.

The Illinois EPA requires the information on the following

appropriate forms to be submitted in accordance with the proper

classification:

•

Form 273-CAAPP, REQUEST FOR ADMINISTRATIVE PERMIT

AMENDMENT FOR CAAPP PERMIT; or

•

Form 271-CAAPP, MINOR PERMIT MODIFICATION FOR CAAPP

PERMIT; or

•

Form 200-CAAPP, APPLICATION FOR CAAPP PERMIT (for

significant modification).

Application forms can be obtained from the Illinois EPA website

at http://www.epa.state.il.us/air/forms.

Note that the request to revise the permit must be certified for

truth, accuracy, and completeness by a responsible official.

Note that failure to submit the required information may require

the Illinois EPA to deny the application. The Illinois EPA

reserves the right to require that additional information be

submitted as needed to evaluate or take final action on

applications pursuant to Section 39.5(5)(g) of the Act and 35 IAC

270.305.

---

Application For Construction

Permit

(For CAAPP Sources Only)

For Illinois EPA use only

I.D. number:

Permit number:

Date received:

This form Is to be used by CAAPP sources to supply Information necessary to obtain a construction permit. Please attach other

necessa

ry

Information and completedCAAPP formsregardingthis construction/modification

?ect.

10.5 Attachment 5

Form 199-CAAPP, Application For Construction

Permit (For CAAPP Sources Only)

Illinois Environmental Protection Agency

Division Of Air Pollution Control — Permit Section

P.O. Box 19506

Springfield, Illinois 62794-9506

Source.:InfOrMatio

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1.?

Source name:

2.?

Source street address:

3.?

City:?

4.

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Zip code:

5.

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Is the source located within city limits?

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Yes?

q

No

6.

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Township name:

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7.?

County:

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8.

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I.D. number:

Oivner Informatlen

,

;

9.?

Name:

10.?

Address:

11.?

City:?

12.

?

State:

?

13.?

Zip code:

Operator Information (If different from owner) ,

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,

14.?

Name

15.?

Address:

16.?

City:

?

17.

?

State:?

18.?

Zip code:

Ap licant Information

19.?

Who is the applicant??

20.?

All correspondence to: (check one)

q

Owner

?

q

Operator

?

q

Owner?

0 Operator?

q

Source

21.

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Attention name and/or title for written correspondence:

22.?

Technical contact person for application:?

23.

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Contact person's telephone number:

This Agency Is authorized to require nd you must disclose this Information under 415 ILCS 5/39. Failure to do so could result In the application

being denied and penalties under 41 ILCS 5 et seq. It is not necessary to use this form in providing this Information. This form has been

approved by the forms management center.

Printed on Recycled Paper

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Page 1 of 2

199-CAAPP

5-1

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sitinatutk

e

100*

This certification must be signed by a responsible official. Applications without a signed

certification will be returned as incomplete.

30. I certify under penalty of law that, based on information and belief formed after reasonable

inquiry, the statements and information contained in this application are true, accurate and

complete.

Authorized Signature:

BY:

AUTHORIZED SIGNATURE

TITLE OF SIGNATORY

TYPED OR PRINTED NAME OF SIGNATORY

?

DATE

Note 2: An operating permit for the construction/modification permitted in a construction permit must be

obtained by applying for the appropriate revision to the source's CAAPP permit, if necessary.

Summary Of Application-Contents

.

24.

Does the application address whether the proposed project would

constitute a new major source or major modification under each of the

following programs:

a)?

Non-attainment New Source Review – 35 IAC Part 203;

b)?

Prevention of Significant Deterioration (PSD) – 40 CFR 52.21;

c)?

Hazardous Air Pollutants: Regulations Governing Constructed or

Reconstructed Major Sources – 40 CFR Part 63?

El Yes?

■ No

25.

Does the application identify and address all applicable emissions

standards, including those found in the following:

a)?

Board Emission Standards – 35 IAC Chapter I, Subtitle B;

b) Federal New Source Performance Standards – 40 CFR Part 60;

c)

?

Federal Standards for Hazardous Air Pollutants – 40 CFR Parts 61

and

63?

•?

Yes?

■ No

26.

Does the application include a process flow diagram(s) showing all

emission units and control equipment, and their relationship, for which a

permit is being sought?

Yes?

■ No

27.

Does the application Include a complete process description for the

emission units and control equipment for which a permit Is being sought?

0

Yes

?

■ No

28.

Does the application include the information as contained In completed

CAAPP forms for all appropriate emission units and air pollution control

equipment, listing all applicable requirements and proposed exemptions

from otherwise applicable requirements, and identifying and describing

any outstanding legal actions by either the USEPA or the Illinois EPA?

Note: The use of "APC" application forms is not appropriate for

applications for CAAPP sources. CAAPP forms should be used to

supply information.

•

?

Yes?

■ No

29.

If the application contains TRADE SECRET information, has such

information been properly marked and claimed, and have two separate

copies of the application suitable for public inspection and notice been

submitted, in accordance with applicable rules and regulations?

o

Yes

?

■ No

Not Applicable,

No

TRADE

SECRET

information In

this application

Note 1: Answering

"No'

to any of the above may result In the application being deemed incom

te.

Printed on Recycled Paper

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Page 2 of 2

199-CAAPP

5 - 2

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10.6 Attachment 6 - Guidance on Renewing This Permit

Timeliness - Pursuant to Section 39.5(5)(n) of the Act and 35 IAC

270.301(d), a source must submit to the Illinois EPA a complete

CAAPP application for the renewal of a CAAPP permit not later

than 9 months before the date of permit expiration of the

existing CAAPP permit in order for the submittal to be deemed

timely. Note that the Illinois EPA typically sends cut renewal

notices approximately 18 months prior to the expiration of the

CAAPP permit.

The CAAPP application must provide all of the following

information in order for the renewal CAAPP application to be

deemed complete by the Illinois EPA:

1.

A completed renewal application form 200-CAAPP,

APPLICATION FOR CAAPP PERMIT.

2.

A completed compliance plan form 293-CAAPP, COMPLIANCE

PLAN/SCHEDULE OF COMPLIANCE FOR CAAPP PERMIT.

3.

A completed compliance certification form 296-CAAPP,

COMPLIANCE CERTIFICATION, signed by the responsible

official.

4.

Any applicable requirements that became effective during

the term of the permit and that were not included in the

permit as a reopening or permit revision.

5.

If this

is

the first time this permit is being renewed and

this source has not yet addressed CAM, the application

should contain the information on form 464-CAAPP,

COMPLIANCE ASSURANCE MONITORING (CAM) PLAN.

6.

Information addressing any outstanding transfer agreement

pursuant to the ERMS.

a.?

If operations of an emission unit or group of

emission units remain unchanged and are accurately

depicted in previous submittals, the application may

contain a letter signed by a responsible official

that requests incorporation by reference of existing

information previously submitted and on file with the

Illinois EPA. This letter must

also

include a

statement that information incorporated by reference

is also being certified for truth and accuracy by the

responsible official's signing of the form 200-CAAPP,

APPLICATION FOR CAAPP PERMIT and the form 296-CAAPP,

COMPLIANCE CERTIFICATION. The boxes should be marked

yes on form 200-CAAPP, APPLICATION FOR CAAPP PERMIT,

as existing information is being incorporated by

reference.

7.

6-1

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b.?

If portions of current operations are not as

described in previous submittals, then in addition to

the information above for operations that remain

unchanged, the application must contain the necessary

information on all changes, e.g., discussion of

changes, new or revised CAAPP forms, and a revised

fee form 292-CAAPP, FEE DETERMINATION FOR CAAPP

PERMIT, if necessary.

8.

Information about all off-permit changes that were not

prohibited or addressed by the permit to occur without a

permit revision and the information must be sufficient to

identify all applicable requirements, including

monitoring, recordkeeping, and reporting requirements, for

such changes.

9.

Information about all changes made under 40 CFR

70.4(b)(12)(i) and (ii) that require a 7-day notification

prior to the change without requiring a permit revision.

The Illinois EPA will review all applications for completeness

and timeliness. If the renewal application is deemed both timely

and complete, the source shall continue to operate in accordance

with the terms and conditions of its CAAPP permit until final

action is taken on the renewal application.

Notwithstanding the completeness determination, the Illinois EPA

may request additional information necessary to evaluate or take

final action on the CAAPP

renewal application. If such

additional information affects your allowable emission limits, a

revised form 292-CAAPP,

FEE DETERMINATION FOR

CAAPP

PERMIT must

be submitted with the requested information. The failure to

submit to the Illinois EPA the requested information within the

time frame specified by the Illinois EPA, may force the Illinois

EPA to deny your

CAAPP

renewal application pursuant to Section

39.5 of

the Act.

Application forms may

be obtained from the Illinois EPA website

at http://www.epa.state.il.us/air/forms.html.

If you have any questions regarding this matter, please contact a

permit analyst at

217/782-2113.

Mail renewal applications to:

Illinois Environmental Protection Agency

Division of

Air

Pollution Control

Permit Section (MC 11)

P.O. Box 19506

Springfield, Illinois

62794-9506

SIS:psj

6-2

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10.7 Attachment 7 - EVALUATION OF THE CHANGE IN EMISSIONS FROM CONSTRUCTION

PERMIT 07030023 FOR UNIT 7.2 GLASS

FURNACE

MODIFICATOIN PROJECT

Table 1: Past Actual Emissions of the Glass Furnace

Highest two year average.

Past Actual Emissions (Tons)

Time Period

NOx Losses

February 1999 - January 2001

_

?610 TPY

Table 2: Future Projected Emissions of the Glass Furnace

Future Annual Emissions (Tons)

NOx

649

Table 3: Change

.

in Emissions

Time Period

Annual Emissions (Tons)

Future

649.0

Past

610.0

Change

39.0

PSD Sign.

40.0

SIS:psj

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10.8 Attachment 8 - Past Actual Emissions (Tons/Year)

Based on 24 Months of Continues Operation

February 1999 - January 2001

Pollutant

Baseline Actual

Emissions

Projected Actual

Emissions

Net Emissions

Increase

NOx

610

648

38

SO2

295

318

23

VOM

9

10

1

CO

9

17

8

B2SO4

47

51

4

PM

109

118

9,

PM10

104

112

8

SIS:psj

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

PILKINGTON NORTH AMERICA, INC.,

Petitioner,

v.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

RECEIVED

CLERK'S OFFICE

MAY 19 2008

STATE OF ILLJN s

S

PQ) Kon?

rd

(Permit Appeal – Air)

MOTION FOR

PRO HAC

VICEADMISSION OF KURT A. KISSLING

Pursuant to 35 Ill. Adm. Code § 101.400(a)(3), I, Kurt A. Kissling, respectfully request

that the Illinois Pollution Control Board authorize me to appear

pro hac vice

in the above-

captioned matter on behalf of Petitioner Pilkington North America, Inc. The grounds for this

Motion are as follows:

1.

I am a licensed attorney in the State of Michigan, where I was admitted to the

practice of law in 2000. My attorney registration number in Michigan is P61937, and I am in

good standing.

2.

I am a member in good standing of the bars of the following federal courts: U.S.

District Court for the Western District of Michigan; U.S. District Court for the Eastern District of

Michigan.

3.

No disciplinary proceedings are pending or have ever been brought against me.

4.

I have never been disbarred or subject to disbarment proceedings.

5.

Petitioner Pilkington North America, Inc. is represented by the law firm of Pepper

Hamilton LLP, and I am an attorney of the firm.

#9629400 vl (113814.70)

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Subscribed and sworn to before me

tks 15LIQ May, 2008

At/Acksow ter;

_ KftARY PUBLIC, STATE OF UV

COUNTY OF WAYNE

•

.

1

,07:1NG

my

co

1N

mmis§ON

-

ODUNTY OF

EX

AM 6, S,01-3

6.

I am familiar with the provisions of the Illinois Code of Civil Procedure, the

Illinois Supreme Court Rules, and the Rules of the Illinois Pollution Control Board; and I

understand and agree to be bound by them in all proceedings before the Illinois Pollution Control

Board.

7.

With the Board's permission, attached is my Appearance in this matter.

WHEREFORE, I, Kurt A. Kissling, respectfully request permission to appear

pro hac

vice

on behalf of Petitioner Pilkington North America, Inc.

Respectfully submitted,

A. K. sling/I

PEPPER HAMILTON LLP

100 Renaissance Center – Suite 3600

Detroit, Michigan 48243-1157

313.259.7110

Dated: May 15, 2008

#9629400 vl (113814.70)

-2-

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EXIFED

BEFORE THE ILLINOIS POLLUTION CONTROL

AK

K,

.

PILKINGTON NORTH AMERICA, INC.,

?

)?

MAY 1 9

2008

Petitioner

,

)

Pollution

STATE OF

Control

ILLINOIS

Board

v.

)

)

PCB

weib

)

(Permit Appeal – Air)

ILLINOIS ENVIRONMENTAL

?)

PROTECTION AGENCY,

?

)

Respondent.

)

APPEARANCE

I hereby file my appearance in this proceeding on behalf of Petitioner Pilkington North

America, Inc.

Ku A. Kissling

PEPPER HAMIL ON LLP

100 Renaissance Center – Suite 3600

Detroit, Michigan 48243-1157

313.259.7110

Dated: May 15, 2008

#9629490 vl (113814.70)

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Pollution Control Board

PCB

(Permit

03

Appeal

40

– Air)

STATE OF ILLINOIS

America, Inc.

ol

(ARDC #6278091)

BEFORE THE ILLINOIS POLLUTION CONTROL B ?

E1VED

'S OFFICE

MAY 19 2008

PILKINGTON NORTH AMERICA, INC.,

)

Petitioner,

v.

)

)

)

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

Respondent.

)

APPEARANCE

I hereby file my appearance in this proceeding on behalf of Petitioner Pilkington North

Counsel o etitioner,

Pilkington North America, Inc.

PEPPER HAMILTON LLP

100 Renaissance Center – Suite 3600

Detroit, Michigan 48243-1157

313.259.7110

Dated: May 15, 2008

#9629507 vl (113814.70)