BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    IN THE MATTER OF:
    NITROGEN OXIDES EMISSIONS
    FROM
    VARIOUS SOURCE CATEGORIES:
    AMENDMENTS
    TO 35 ILL. ADM. CODE
    PARTS
    211 AND 217
    )
    )
    )
    )
    )
    )
    R08-19
    (Rulemaking
    - Air)
    POST-HEARING COMMENTS OF SAINT-GOBAIN CONTAINERS, INC.
    Saint-Oobain Containers, Inc. ("SOCI") respectfully submits the following post-
    heating comments in the above rulemaking proceeding (these comments supplement those filed
    on February 14,2008):
    SOCI owns and operates glass melting furnaces at its facility in Dolton, IIlinois.
    With respect to the 5.0 lbs/ton emission limit in proposed Section 217.204, SOCI believes that a
    narrow exception should be made to the May
    1, 2010 compliance date for entities that enter into
    an enforceable agreement with IEPA to install control technology that can achieve NO
    x
    emission
    rates significantly below the 5.0 lbs/ton limit pursuant to an enforceable schedule extending
    beyond 2010. SOCI is currently in the process of negotiating such an agreement with IEPA.
    SOCI suggests the following addition to the Exemption provision in proposed Section 217.202:
    Notwithstanding the compliance date set forth in Sections
    217.155(b) and 217.204, a compliance date
    ofDecelrlber 31,2014
    shall apply when the owner or operator of a container glass
    melting furnace subject
    to Subpart F has executed a binding and
    enforceable agreement by December
    31,
    2009 with the State of
    Illinois that requires compliance with a NO
    x
    limit that is less than
    30 percent
    ofthe emission limit in Section 217.204.
    Without a relief mechanism in these narrow circumstances, SOCI would
    effectively be required to implement a much less effective control device, when substantially
    greater reductions from the installation of alternative NOx control technology are currently being
    discussed with the State
    of IIlinois. SOCI cannot afford to install the technology required to
    meet
    an intetim limit of 5.0 lb/ton for the petiod between the compliance date under Section
    217.204 and the anticipated schedule for installation of the alternative technology at the end
    of
    2014, and thus the opportunity for substantially greater long-term emission reductions may be
    lost if a limited exemption from the May
    1,2010 compliance date is not adopted. Additionally,
    the Dolton facility has three furnaces, with two exhaust stacks on each furnace.
    Early
    installation
    of CEMS would require six devices (rather than as few as one CEMs which may be
    Saint-Gobain Containers
    1509 Soulh Ivloceclonio Avenue. PO Box
    ~200.
    lvIuncie
    I~I ~7307-~200.
    T("I
    765-7~1-7000.
    Fox
    765-7~1-7012
    Electronic Filing - Received, Clerk's Office, November 25, 2008
    * * * * * PC #2 * * * * *
    required for altemative technology), and would serve no compliance purpose. We therefore urge
    the deletion of a requirement to install CEMS until the altemative technology is installed. Thank
    you for the opportunity to comment on this important rulemaking.
    Respectfully submitted,
    A~::::::'--:::::=~
    Steven B. Smith
    ;;;======--
    V.P. Environmental Health
    &
    Safety
    Saint-Gobain Containers, Inc
    1509
    S. Macedonia Avenue
    Muncie,
    In
    47307
    Dated: November 25,2008
    cc: S. Segebarth, Esq.
    -2-
    Electronic Filing - Received, Clerk's Office, November 25, 2008
    * * * * * PC #2 * * * * *

    Back to top