e
ILLINOIS ENVIRONMENTAL
PRoTEcTIoN
AGENCY
1021
NORTH
GRAND
AvENuE
EAST,
P.O.
Box
19276,
SPRINGFIELD,
ILLINOIS
62794-9276
—(217)
782-2829
JAMES
R.
THOMPSON
CENTER,
100 WEST
RANDOLPH,
SUITE
11-300,
CHICAGo,
IL 60601
—(312)
814-6026
-
DOUGLAS
P. ScOTF,
DIREcToR
217-782-5544
February
16,
2009
RECEIVEO
CLERK’S
OFFICE
FEB
2009
Mr.
Mark
Madsen
STATE
OF
LuNOIS
Corn
Products
U.S.
Pollution
Control
Board
6400
South
Archer
Avenue
Bedford
Park,
IL
60501
Re:
Provisional Variance
Application
Corn
Products
Argo
Plant
Source
I.D. No.
031012AB1
Dear
Mr. Madsen;
On
February
6,
2009,
the
Illinois
Environmental Protection
Agency
(“Illinois
EPA”)
received
an
application
for
a
provisional
variance
from
Corn
Products
U.S.
(“Corn
Products”)
(attached
hereto
as
Exhibit
A)
relating
to
Boilers
6
and
10 at
its
Argo
Plant,
located
in
Bedford
Park,
Illinois.
Corn
Products
supplemented
this
application
on
February
11,
2009
(attached
hereto
as
Exhibit
B),
and
Illinois
EPA
accepted
the
application and
supplement
thereto
on this
date.
In its
submissions,
Corn
Products
requested
a
provisional
variance
from
certain
conditions
in
its
CAAPP
permit
(permit
no. 96010009),
including
its
application
for
minor
modification
of
this
permit
received
by
the
Illinois
EPA
on
March
3,
2008,
and
the
construction
permit
for
Boiler
10
(permit
no.
03090020).
The
Illinois
EPA
has
reviewed
the
request
pursuant
to the
illinois
Environmental
Protection
Act
(“Act”)
and
corresponding regulations
at 35
Ill. Adm.
Code
Parts
104
and
180.
The
request
is
approved
pursuant
to
Section
35(b)
of
the Act
and
35
Ill.
Adm.
Code
104.302,
for
the
reasons
and
condition
stated
below,
for
a
45-day
period
commencing
on
the
date
of this
decision
letter.
This
provisional variance
is granted
on
the
condition
that
within
15
days
after
expiration
of
the
provisional variance
term,
Corn
Products
shall
submit
to Illinois
EPA,
Bureau
of
Air,
Compliance Section,
a
report
of actual
emissions
of
NOx
for
each
of Boiler
6
and
Boiler
10,
and
S02
and
CO
for
Boiler
10,
in tons
over
the period
of
the
provisional
variance.
Provisional variances
may
be granted
by
the
Illinois
EPA
when
compliance
on
a short-term
basis
with
any
rule
or regulation,
requirement
or order
of
the Illinois
Pollution
Control
Board,
or
with
R0CKFORD
— 4302
North
Main
Street,
Rockford,
IL
61103
— (815)
987-7760
DES
PLAINEs
— 9511
W.
Harrison
St., Des
Plaines,
IL 60016
—
(847)
294-4000
ELGIN
—595
South
State,
Elgin, IL
60123—
(847) 608-3131
.
PEORIA
—5415
N.
University
St., Peoria,
IL
61614 —(309)
693-5463
BUREAU
OF
LAND
- PEORIA
— 7620
N.
University
St.,
Peoria,
IL
61614 —
(309) 693-5462
.
CHAMPAIGN
— 2125
South
First
Street,
Champaign,
IL
61820
— (217)
278-5800
C0LLIN5vILLt
— 2009
MalI
Street,
Collinsville,
IL
62234
— (618)
346-5120
.
MARION
— 2309
W.
Main St.,
Suite 116,
Marion,
IL 62959
— (618)
993-7200
PRINTED
ON
RECYCLED
PAPER
any
permit
requirement,
would
impose
an
arbitrary
or
unreasonable
hardship.
415
ILCS
5/35(b).
Corn
Products
has
requested
a
provisional
variance
from
the
following
permit
conditions:
CAAPP
Permit
No.
9601009
Condition
7.9.6(a):
Boiler
6
NOx
limit
of
30 lb/hr
Construction
Permit
No.
03090020
Condition
1.1.3
d. iv.,
and
35111.
Adm.
Code
214.121:
1.2
lb/mmbtu
S02
(lhr)
Condition
1.1.6
a. i.
(and
ii.):
501
lb/br
S02
24-hr
block
average
Condition
1.1.6
a.
i.:
CO
167
lb/hr
24-hr
block
average
Condition
1.1.6
b.:
S02
0.30
lb/mrnbtu
30
day
rolling
average
Condition
4.0
c.
i.:
Table
II
S02
limits
0.30
lb/mmbtu
and
501
lb/hr
Corn
Products
has
requested
a
provisional
variance
from
the
above-referenced
permit
conditions
due
to
a
sudden
failure
of
a
limestone
system
that
supports
operation
of
the
Argo
plant’s
primary
boiler,
Boiler
10.
The
failure
of the
limestone
system
resulted
in
an
inability
to
generate
sufficient
steam
to
operate
the
plant,
which
has
risked
damage
to
the
plant
infrastructure
from
potential
freezing.
In
addition,
the
coal
stored
in
the
bunkers
for
Boiler
10
is wet,
which
presents
a
danger
of
spontaneous
combustion
if
the
coal
is
left
in
place
for
an
extended
period
of
time.
Corn
Products
has
presented
a
plan
whereby
it
will
empty
the
remaining
coal
by
firing
it
in
Boiler
10,
without
also
using
limestone.
This
will
result
in
exceedances
of
permitted
S02
limits
over
a
period
of
one
week
and
roughly
90
hours.
While
Boiler
10
is
operating
at
low
loads
on
natural
gas,
Corn
Products
has
also
indicated
it expects
exceedances
of
CO
permitted
limits.
Corn
Products
will
need
to perform
further
adjustments
to
Boiler
10
to
operate
efficiently
on
natural
gas.
Exceedances
of
SO2
emission
rates,
in
lb/mrnBtu,
may
also
be
experienced
due
to
the
need
to
reuse
stored
ash
as the
bed
material
for
the
boiler.
Finally,
with
respect
to
Boiler
6,
at
the
time
of
the
limestone
system
failure,
the
firing
rate
of
Boiler
6,
a
natural
gas
fired
backup
boiler,
was
increased
to
prevent
damage
at
the
plant
from
freezing.
However,
due
to
a problem
with
flue
gas
recirculation
dampers
on
Boiler
6,
it
is
not
operating
properly, resulting
in
exceedances
of
the
applicable
hourly
limit
for
NOx
emissions.
As
a
result,
Corn
Products
also
has
included
a request
to exceed
such
NOx
limits
until
it
is
able
to
effect
repairs
on
Boiler
6.
This
likely
will
not
be
able
to
occur
until
the
time
coal
is
emptied
from
the
bunkers
and
fired
in
Boiler
10.
Therefore,
Corn
Products’
request
includes
addressing
removal
of the
remaining wet
coal
and
adjustments
to
Boiler
10
to
operate
properly
on
natural
gas,
and
repairs
to
Boiler
6.
Corn
Products
has
met
the
application
requirements
of
35
Ill.
Adm.
Code
180.202.
In
addition,
even
though
Boiler
6
will
exceed
the
pounds
per
hour
permitted
limit
for
emissions
of
NOx,
the
combined
emissions
of NOx
from
Boilers
6
and
10
over
the
variance
period
are
expected
to
be
approximately
60
tons
whereas
the
combined
permitted
NOx
limit
is
approximately
151
tons
over
the
variance
period.
Further,
even
though Boiler
10
will
exceed
the
pounds
per
hour
permitted
limit
for
emissions
of
SO2,
it
is only
expected
to emit
approximately
220
tons
of
S02
over
the
period of
the
variance
whereas
the
permitted
S02
limit
is approximately
270
tons
over
this
period.
In
addition,
even
though
Boiler
10
will
exceed
permitted
limits
for
CO
over
the
24
hour
block
average,
it
is
only
expected
to
emit
approximately
60
tons
of CO
over
the
period
of
2
the
variance
whereas
the
permitted
CO
limit
for
this
period
is approximately
90
tons.
The
Illinois
EPA
agrees
with
these
calculations
as
presented
in Table
2
of
Corn
Products’
initial
application
and
as
further
clarified
in its
supplement
thereto.
Therefore,
the
Illinois
EPA
agrees
that
no
adverse
environmental
impacts
are
likely
to
result
from
granting
the
requested
relief
as the
total
emissions
required
for the
period
of
the
variance
are
less
than
the
total
emissions
that
are
allowed
by the
respective
permits,
and
due
to
the
relatively
short
duration to address
the
safety issue
on
Boiler
10
and
execute
repairs
on Boiler
6.
In addition,
Corn
Products
has
sufficiently
endeavored
to
locate
viable
alternative
methods
of
compliance
and
no
such
viable
alternatives
exist.
Furthermore,
inaction
now
presents
serious
safety
issues
and
danger
of
damage
to
overall
plant
operation.
Therefore,
the
Illinois
EPA
agrees
that
any
impacts
relating to
the
requested
provisional
variance
are
certainly
outweighed
by
the
arbitrary
and
unreasonable
hardship
Corn
Products
would
suffer
if
it
were
denied
the
provisional
variance.
If you
have
any
questions
regarding
this
decision,
please
contact
Kent
E.
Mohr
Jr.
at 2
17-782-
5544.
Very
truly
yours,
Managing
Attorney
Air
Regulatory
Unit
JJK:kem
Enclosures
Cc:
N. LaDonna Driver,
HDZ
David
Bloomberg,
IEPA
Chris
Romaine,
[EPA
Rob
Kaleel,
IEPA
Dean
Hayden,
[EPA
Kent
Mohr,
IEPA
in
Therriault,
Assistant
Clerk,
IPCB
JohnJ.
3
—
yN,8’r4
—
orn
products
.,
Trusted
Ingredients.
Trusted
Poop
Jo
Mr.
John
Kim,
Regulatory
Manager
Legal
Counsel
#21
Illinois
Environmental
Protection
Agency
1021
North
Grand
Avenue
East
Springfield,
illinois
62794
Subject:
Corn Products
Argo
Plant
IDO3IOI2ABI
Application
for
Provisional
Variance
-
Boiler
6
and
Boiler
10
Dear Mr.
Kim
Corn
Products
Argo
plant
has
experienced
a
sudden
failure
of
a
limestone
system
that
supports
the operation
of
the
plant’s
primary
boiler.
To
allow
us
to
protect
our
plant
from
freezing
weather
and
enable
us
to
recover
from this
event
in
compliance
with
our
IEPA
air
permit
and
State
requirements
we
have
prepared
an
application
for a
provisional
variance.
Attached
please
find
two
copies
of
an
application
for
a
provisional
variance
prepared
in
accordance
with
35
IAC
Subtitle
A,
Chapter
II,
Section
180.202.
If
you
have
any
questions
or
need
additional
information
please
contact
Mark
Bosse
of
my
staff
at
708-563-6751.
Sincerely
Mark Madsen
Argo Plant
Manager
cc: David
Bloomberg,
1EPA
N.
LaDonna
Driver,
HDZ
Alan
Jirik,
Corn
Products
International
Inc.
Corn
Products
U.S.
6400
South
Archer
Avenuel
Bedford
Park,
IL
605O1J
www.cornproductuus.com
Phone:
(708)
563-2400
business
unit
of
Corn
Products
Interatiunat,
Inc.
Request
for
Provisional
Variance
February
6,
2009
Corn
Products
Argo Plant
Boilers
6
&
10
3)
The
quantity
and
types
of
materials
used
in
the
process
or
activity
for
which
the
variance
is
requested,
as
appropriate;
Response:
The
variance
is
for
2
fossil
fuel
boilers.
One boiler
fires
natural
gas
and
the
other
one
coal. During
the
requested
45
day
pendency
of
this
variance
request
approximately
770
tons
of
coal
would
be
combusted
in
Boiler
10
as
explained
in
our
response
to
question
7. During
normal
operations,
Boiler
10
would
typically
bum
50,000
tons of
coal in
a
45
day
period.
Boiler
6
has
a
rated firing
capacity
of
0.6
mmscf
of
natural
gas
per
hour.
Actual
operation
varies
and
is
less
than
this
amount.
4)
The
quantity,
types
and
nature
of
materials
or
emissions
to
be
discharged,
deposited
or
emitted
under
the
variance,
and
the
identification
of
the
receiving
waterway
or
land,
or
the
closest
receiving
Class
A
and
Class
B
land use,
as
appropriate;
Response: For
the
reasons
provided
in
our response
to
questions
7
&
8
below,
a
period
of
time
is
likely
to
occur
where
emissions
of
S02
from
boiler
10
are
expected
to
be
in
excess
of
the
permit
allowed
hourly
rate.
However
the
total
S02
emissions
for
the
period
of
the
provisional
variance
are
not
expected
to
exceed
the
period
total
allowable
tons
established
by
the
permit.
Emissions
of
NOx
on
Boiler
6
will
exceed
the
hourly
limit
established in
the
permit
for
the
period
of
this
provisional
variance.
However,
total
NOx
emissions
from
the
combination
of
boiler
6
and
10
will
not
exceed
the
overall
amount
of
NOx
that
is
authorized
by
the
combined
boiler
6
and
10
permits,
due
to
considerably
reduced
NOx
emissions
from
Boiler
10
during
this
emergency
period.
Because
Boiler
10
is
being
operated
at
very
low
loads
on
natural
gas
we
anticipate
that
periods
of
combustion
instability,
resulting
in
elevated
CO
levels,
may
occur.
We expect
these
to
be
infrequent
but
to
account
for
these
we
have
include
CO
in
the
provisional
variance
request.
The
Table
2
below
provides
additional
details
on
the
quantity
of
materials
to
be
discharged.
Table
2
Boiler
6
NOx
limit:
30
lb/hr
Boiler
6
NOx expected:
30
to
55
lb/hr
(typical)
Boilers
6+10
NOx limit:
151
tons/45
days
Boilers
6+10
NOx
expected:
60
tons/45
days
Boiler
10
S02
limit:
501
lb/hr
Boiler
10
S02
expected:
2400 lb/hr
(90
hours
maximum)
Boiler
10
802
limit:
270
tonsl45
days
Boiler
10
S02
expected:
220
tons/45
days
Boiler
10
CO limit:
167
lb/hr (24
hour
block
average)
Boiler
10
CO
expected:
280
lb/hr
(24
hour
block
average)
Boiler
10
CO limit:
90
tons/45
days
Boiler
10
CO expected:
60
tons/45
days
Page
2
Request
for
Provisional
Variance
February
6,
2009
Corn
Products
Argo
Plant
Boilers
6
&
10
for
an
internal
investigation.
Given
the
loss
of
boiler
10,
it
has
not
been
possible
to
shut
down gas
boiler
6
for
these
inspections
and
repairs
due
to
the
risk
of
freezing
damage
to
the
plant. During
the
time
the
coal
bunkers
are
being
emptied,
additional
steam
will
be
available
for
a
short
time
to
heat
the
plant.
We
plan
to
take
boiler
6
down
during
that
brief window
to
affect
repairs.
At
the
conclusion
of
these
activities
we
anticipate
that
boiler
6
will
return
to
compliance
with
the
NOx
limit.
8)
A
description
of
the
proposed
methods
to
achieve
compliance
with
the
Act,
regulations
or
Board
Order,
and
a
timetable
for
achieving
such
compliance;
Response:
We
propose
to
run
the
coal
out
of
the
bunkers
to
eliminate
the
safety
issue
on
boiler
10,
and
create enough
steam
to
allow
boiler
6 to
be
safely
shut
down
and
repaired
without
risking
damage
to
our
plant.
9)
A
discussion
of
alternate
methods
of
compliance
and
of
the
factors
influencing
the
choice
of
applying
for
a
provisional
variance;
Response:
None
have
been
identified.
10)
A
statement
of
the
period, not
to
exceed
45
days,
for
which
the
variance
is
requested;
Response:
The
provisional
variance
is
requested
for
45
days commencing
January
28,
2009.
11)
A
statement
of
whether
the
applicant
has
been
granted
any
provisional
variances
within
the
calendar
year,
and
the
terms
and
duration
of
such
variances;
Response:
Corn
Products
has
never
before requested
a provisional
variance.
This
is
our
first
request.
12)
A
statement
regarding
the
applicant’s
current permit
status
as
related
to
the
subject
matter
of
the
variance
request;
Response:
As
this
matter
relates
solely
to
air,
please
be
advised
that
we
are
a
Title
V
source.
A timely
application
for
renewal
was filed
and
is being
reviewed
by
the
Agency.
13)
Any Board
orders
in
effect
regarding
the
applicant’s
activities
and
any
matters
currently
before
the
Board
in
which
the
applicant
is
a
party.
Response:
None
Page 4
—
Ex”/
f
7
I’
I.
will
products
TiutecI
Ingretherts.
Trusted
Peop(e
February
11, 2009
Mr.
Kent
Mohr
Division
of
Legal
Counsel
Illinois
Environmental
Protection
Agency
1021 North
Grand
Avenue
East
Springfield,
Illinois
62794
Subject:
Corn
Products
Argo
Plant
ID
031012AB1
Supplemental
Information
Application
for
Provisional
Variance
-
Boiler
6
and
Boiler
10
Dear
Mr.
Mohr:
Corn
Products
is
providing
the following
supplemental
information
relative
to
the
provisional
variance
request
as
referenced
above.
1)
The
Title
V
minor
modification
noted
in
our
request
did
not
change
or
modify
any
of
the
terms
or
numerical
limits
listed
in
Table
1
item
I
of
the
provisional
variance
application.
2)
The
Boiler
6
NOx
limit in
table 1
item
1
specifically
relates
only
to
condition
7.9.6
a.
in
Title
V
permit
960100009.
3)
The
reference
for
condition
1.1.3 d.
iv.
should
correctly
be
35
IAC
214.121.
4)
In
item
I
Table
1
of
the
provisional
variance
application
Corn
Products
withdraws
its
request
for
provisional
variance
from
1.1.3
b.
ii.
A.,
condition
1.1.3
e.,
and
condition
1.1.7 b.
ii.
5)
The statement
in
item
7
regarding
the
need
to
inspect
the
coal
bunkers
was
for
informational
purposes
only
and
is
not an
actionable
request.
This
statement
supports
the
need
to
empty
the
bunkers
of
coal
so
that
they
can
be
internally
inspected.
Similarly
information
provided
regarding
the
limestone
system
is
for
informational
purposes
only
and
is
also
not
an
actionable
request.
6)
On
item
8,
the
timetable
requested
is
to
accommodate
multiple
needs
and issues.
We
envision
that
the
coal
can
be
run
out
of
the
bunker
in
90
hours
or
less
over the
period
of
about
a
week.
During
this
time boiler
6
will
be
repaired.
We expect
that
to
happen
within
2
weeks
of
receiving
a
provisional
variance.
After
the
coal
is
run
out,
there
may
be
issues
of
flame
stability
as
we
better
understand
operation
of
the
boiler
at
minimal
loads
on
natural
gas.
One
concern
we
have
identified
is
the
need
to
refresh,
maintain
and
manage
the
boiler
bed
materials.
There
may
be
brief
elevated
periods
of
carbon
Corn
Product5
US.
6400
South
Archer
Avenue
Bedford
Park,
IL
60501
www.cornprodvctsus.com
Phone
(708)
563-2400
business
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Corn
Products
International,
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