January 20, 2009

Mr.

John Theniault

Assistant Clerk

of the Board

1021 North Grand Avenue East

P.O. Box 19274

Springfield,

II.,

62794-9274

,.,..,nth

SAINT-GOBAIN

IN THE MATTER OF:

NITROGEN OXIDES EMISSIONS FROM

VARIOUS SOURCE CATEGORIES:

AMENDMENTS TO 35 ILL. ADM. CODE

PARTS

211 AND 217

)

)

)

)

)

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R08-19

(Rulemaking - Air)

PRE-HEARING COMMENTS OF SAINT-GOBAIN CONTAINERS, INC.

Saint-Gobain Containers, Inc. ("SGCT") respectfully submits the following

pre-

hearing comments

in the above rulemaking proceeding (these comments supplement

those filed on February 14, and November

25,2008):

SGCI

owns and operates glass melting furnaces at its facility in Dolton, Ulinois. With

respect

to the 5.0 lbslton emission limit in proposed Section 217.

204, SGCI believes that

a narrow exception should be made to the May I,

20

to

compliance date for entities that

enter into

an enforceable agreement with LEPA to install control technology that can

achieve

NO

x

emission rates significantly below the 5.0 lbs/ton limit pursuant to an

enforceable sc hedule extending beyond 2010. SGCI is currently in the process of

negotiating such an agreement with LEPA. SGCI respectfully suggests the following

changes;

Section

21l.2625 Glass Melting Furnace

"Glass melting furnace" means, for purposes of Part 217, a unit comprising a refractory

vessel

in which raw materials are charged and melted at high temperature to produce

molten g

lass.

Section

21 1.1 57.b)4) Testing and Monitoring

Add a sentence at the end,

"If compliance with NOx limitations is demonstrated by

CEMS as required by Section 217.b)J), thi s paragraph does not apply.

"

SOlnt-Goboin Contame,s

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Electronic Filing - Received, Clerk's Office, January 20, 2009

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Section 217.1S2.d) Compliance Date

Notwithstanding subsections (a), (b), and (c)

of this Section, compliance with the

requirements

of Subpart F of this PaIt by an owner or operator of an emission unit subject

to Subpart F

of this Part shall be extended until December 31, 2014, if such units are

required to meet emissions limitations for

NOx, as measured using a continuous

emissions monitoring system, and included within a legally enforceable order on or

before December 31,

2009, whereby such emissions limitations are less than 30 percent

of the emissions limitations set forth under Section 217.204 of Subpart F of this PlUto

Section 217.202 Exceptions

Add a sentence: Section 217.

204 shall not apply during glass furnace startup (not to

exceed

70 days) or idling (operation at less than 35% of furnace capacity). DUling such

periods the furnace shall meet

alb/day NOx limit calculated as:

NOx lb/day limit

=

(5.0 lb/ton NOx) X (MFDC)

Where:

NOx lb/day limit

=

the NOx pound per day limit

5.0 lb/ton

NOx = NOx Emission Limitation (lb/ton glass

produced) from Section 217.204

MFDC

= Maximum furnace daily capacity in tons"

Consistent with our letters to the Illinois Pollution Control Board, we have been and

continue to work through these issues to develop mutually agreeable language.

cc:

S. Segebarth, Esq .

Respectfully submitted,

;'

.

Steven B. SmIth

V.P. Environmental Health

&

Safety

Saint-Gobain Containers, Inc

1509

S. Macedonia Avenue

Muncie,

In 47307

Electronic Filing - Received, Clerk's Office, January 20, 2009

* * * * * PC #4 * * * * *