217/782-2113

    CLEAN AIR ACT PERMIT PROGRAM (CAAPP) PERMIT

[`PERMITTEE`]{.underline}

    Trilla Steel Drum Corporation

    Attn:  Andrew Sedlacek, Purchasing Manager

    2959 West 47th Street

    Chicago, Illinois  60632

[`Application No.`]{.underline}`:  95100014``	``	``	`[`I.D. No.`]{.underline}`:  031600DBZ`

[`Applicant``’``s Designation`]{.underline}`:  ``	``	``	`[`Date Received`]{.underline}`:  October 4, 1995`

[`Operation of`]{.underline}`:  Manufacturing of Steel Drums`

[`Date Issued`]{.underline}`:  ``F``ebruary`` 26, 1999``	``	``	`[`Expiration Date`]{.underline}`:  February 26, 2004`

[`Source Location`]{.underline}`:  2959 West 47th Street, Chicago, Cook County, Illinois, 60632`

[`Responsible Official`]{.underline}`:  Andrew Sedlacek`

    This permit is hereby granted to the above-designated Permittee to OPERATE a Steel Drum Manufacturing plant, pursuant to the above referenced permit application.  This permit is subject to the conditions contained herein.

    If you have any questions concerning this permit, please contact Rizwan Syed at 217/782-2113.

    Donald E. Sutton, P.E.

    Manager, Permit Section

    Division of Air Pollution Control

    DES:RS:jar

    cc:	Illinois EPA, FOS, Region 1

    USEPA

    TABLE OF CONTENTS

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                                                                         [`PAGE `]{.underline}                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           
                                                                         `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`                             `6`                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    
                                                                                                                                `3.1`    `Identification of Insignificant Activities`                                                                                   `3.2`    `Addition of Insignificant Activities`                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  
  `4.0`    `SIGNIFICANT EMISSION UNITS AT THIS SOURCE`            `8`                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         
  `5.0`    `OVERALL SOURCE CONDITIONS`                            `9`                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    
                                                                                                                                `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`    `EMISSION REDUCTION MARKET SYSTEM (ERMS)`              `15`                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   
                                                                                                                                `6.1`    `Description of ERMS`                                                                                                          `6.2`    `Applicability`                                                               `6.3`   `Obligation to Hold Allotment Trading Units (ATUs)`         `6.4`   `Market Transaction`                                                       `6.5`   `Emission Excursion Compensation`          `6.6`   `Quantification of Seasonal VOM Emissions`         `6.7`   `Annual Account Reporting`               `6.8`   `Allotment of ATUs to the Source`                                         `6.9`   `Recordkeeping for ERMS`                `6.10`   `Federal Enforceability`                                                                                                                                                                                                                 
  `7.0`    `UNIT SPECIFIC CONDITIONS`                             `20`                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   
                                                                                                                                `7.1`    `Coating Line #1 with dry filters and water wash scrubbers and Coating lines #2 and #3 with water wash scrubbers`              `7.2`    `Grinder with cyclone`                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         
                                                                         [`PAGE `]{.underline}                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           
                                                                         `8.0`                   `GENERAL PERMIT CONDITIONS`    `29`                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     
                                                                                                                                `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`                                                                                                                                                                                                                                                                                                                                                                                                                                                                
                                                                         `9.0`                   `STANDARD PERMIT CONDITIONS`   `33`                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     
                                                                                                                                `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 - Summary of Equipment`                                                                               `1-1`      `10.2`   `Attachment 2 - Example Certification by a Responsible Official`   `2-1`                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         
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`1.0``	``SOURCE IDENTIFICATION`

    1.1	Source

    Trilla Steel Drum Corporation

    2959 West 47th Street

    Chicago, Illinois  60632

    773/847-7588

    I.D. No.:  031600DBZ

    Standard Industrial Classification:	3412, Metal Drum Manufacturing

    1.2	Owner/Parent Company

    Trilla Steel Drum Corporation

    2959 West 47th Street

    Chicago, Illinois  60632

    1.3	Operator

    Trilla Steel Drum Corporation

    2959 West 47th Street

    Chicago, Illinois  60632

    Andrew Sedlacek, Purchasing Manager

    773/847-7588

    1.4	General Source Description

    Trilla Steel Drum Corporation is located at 2959 West 47th Street, Chicago in Cook County.  The source manufactures 55-gallon steel drums from coiled steel stock. Coatings are used to provide a durable, protective finish that resist weathering, abrasion, impacts, and in the case of interior linings, provide chemical resistance to the contents of the container. Sheets of drum-stock steel metal are trimmed, rolled to form a cylinder, and then

    lap-welded forming the body shell. The body shell ends are then flanged and hoops may be added to add strength and rigidity. Top and bottom pieces are blanked from coil stock in a single stamping operation. The circle is then pressed in the desired shape and then is seamed to the drum shell to form the chime. A viscous seaming compound is concurrently applied during the process to ensure a tight seal and provide resistance to the product to be packed. In case of open-headed drum, a closing ring secures the cover to the drum by means of a nut and bolt arrangement or a lever device. The source has three coating lines, two for interior coatings, and one for exterior coatings.

`2.0``	``LIST OF ABBREVIATIONS/ACRONYMS USED IN THIS PERMIT`

  -- -------- ------------------------------------------------------- -- --------- -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- -- ------- -------------------------- -- ------- ----------------------------- -- ------- ------------------------ -- ------- -------------------------------------------------- -- --------- -------------------------------- -- ------- ------------------------------- -- ------ ------------------- -- -------- ------------------------------------ -- ----------- -------------- -- ------- ---------- -- ------- --------------------------- -- ------ -------- -- ------- -------------------------------- -- ------------ ------------------------------------------------------------- -- ---------------- -------------------------------------------- -- ------ ------------ -- ----- --------- -- ------ --------- -- ----- --------- -- -------- ----------------------------------------- -- ------- ---------------------- -- ------ ------------- -- --------- --------------------------------- -- ------ --------- -- ---------- ------------------------------------------------------------ -- ----------- ------------------- -- -------- ------------------------------------ -- ------ ---------------------- -- ------- --------------------- -- ------- ------------------------------------------- -- -------- ----------------------------------- -- ------- ------------------------ -- ------- -------------------------------------- -- ----------- ------------------ -- ----- -------- -- ------- ------------------------ -- --------- ------------------------------------------------- -- ------- ------------------------------ -- ------- ----------------------------- -- --------- ------------------
     `ACMA`   `Alternative Compliance Market Account`                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              
     `Act`    `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`      `ATU`   `Allotment Trading Unit`      `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`      `CFR`   `Code of Federal Regulations`      `CO`   `Carbon Monoxide`      `ERMS`   `Emission reduction Market System`      `ft`^`3`^   `cubic foot`      `gal`   `Gallon`      `HAP`   `Hazardous Air Pollutant`      `hr`   `hour`      `IAC`   `Illinois Administrative Code`      `I.D. No.`   `Identification Number of Source, assigned by Illinois EPA`      `Illinois EPA`   `Illinois Environmental Protection Agency`      `kg`   `Kilogram`      `l`   `Liter`      `lb`   `pound`      `m`   `meter`      `MACT`   `Maximum Achievable Control Technology`      `mcf`   `million cubic feet`      `Mg`   `Megagrams`      `mmBtu`   `Million British thermal units`      `mo`   `Month`      `NESHAP`   `National Emission Standards for Hazardous Air Pollutants`      `NO`~`x`~   `Nitrogen Oxides`      `NSPS`   `New Source Performance Standards`      `PM`   `Particulate Matter`      `ppm`   `parts per million`      `PSD`   `Prevention of Significant Deterioration`      `psia`   `pounds per square inch absolute`      `RMP`   `Risk Management Plan`      `SIC`   `Standard Industrial Classification`      `SO`~`2`~   `Sulfur Dioxide`      `T`   `Tons`      `TOC`   `Total Organic Carbon`      `USEPA`   `United States Environmental Protection Agency`      `VOC`   `Volatile Organic Compounds`      `VOM`   `Volatile Organic Material`      `wt. %`   `weight percent`
     `yr`     `year`                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               
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`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:

`2.9 ``	``mmBtu/hr gas fired washer`

`2.9 ``	``mmBtu/hr gas fired dryer`

`4.875 ``	``mmBtu/hr gas fired fresh air heaters`

    10,000 gallon capacity diesel storage tank

    Batch Still

    Furnaces

    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:

    Welding operation

    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)].

    3.1.4	Activities that are considered insignificant activities pursuant to 35 IAC 201.210(b).

    3.2	Addition of Insignificant Activities

    3.2.1	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).

    3.2.2	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.

    3.2.3	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).

`4.0``	``SIGNIFICANT EMISSION UNITS AT THIS SOURCE`

<table>
<tbody>
<tr class="odd">
<td><p><code>Emission</code></p>
<p><code>Unit</code></p></td>
<td><p><code>Description</code></p></td>
<td><p><code>Date</code></p>
<p><code>Constructed</code></p></td>
<td><p><code>Emission</code></p>
<p><code>Control</code></p>
<p><code>Equipment</code></p></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
</tr>
<tr class="even">
<td><p><code>Coating Line #3</code></p></td>
<td><p><code>Exterior Coating Line For Drums Includes Two Spray Booths (SB5 &amp; SB6) </code></p></td>
<td><p><code>January, 1994</code></p></td>
<td><p><code>Water Wash Scrubbers</code></p></td>
<td><p><code>Bake Oven For Coating Line #3 (O1)</code></p></td>
<td><p><code>Gas Fired Bake Oven For Drying Coated Metal Parts</code></p></td>
<td><p><code>June, 1973</code></p></td>
<td><p><code>None</code></p></td>
<td><p><code>Coating Line #1</code></p></td>
<td><p><code>Interior Coating Line For Lids Includes Two Spray Booths (SB1 &amp; SB2) </code></p></td>
<td><p><code>April, 1980</code></p></td>
<td><p><code>Dry Air Filters &amp; Water Wash Scrubbers</code></p></td>
<td><p><code>Bake Oven For Coating Lines #1 &amp; #2 (O3)</code></p></td>
<td><p><code>Gas Fired Bake Oven For Drying Coated Metal Parts</code></p></td>
<td><p><code>June, 1973</code></p></td>
<td><p><code>None</code></p></td>
<td><p><code>Coating Line #2</code></p></td>
<td><p><code>Interior Coating Line For Drumshells Includes Two Spray Booths (SB3 &amp; SB4)</code></p></td>
<td><p><code>June, 1993</code></p></td>
<td><p><code>Water Wash Scrubbers</code></p></td>
<td><p><code>Drying Oven For Coating Line #2 </code></p></td>
<td><p><code>Gas Fired Drying Oven For Coated Metal Parts </code></p></td>
<td><p><code>June, 1973</code></p></td>
<td><p><code>None</code></p></td>
</tr>
<tr class="odd">
<td><p><code>Grinder (G1)</code></p></td>
<td><p><code>Grinding Of Steel Edges</code></p></td>
<td><p><code>October, 1982</code></p></td>
<td><p><code>Cyclone</code></p></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
</tr>
</tbody>
</table>

`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 Volatile Organic Material and HAP emissions.

`5.2``	``A``pplicable 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.

    b.	i.	This source shall be operated under the provisions of an operating program prepared by the Permittee and submitted to the Illinois EPA for its review.  Such operating program shall be designed to significantly reduce fugitive particulate matter emissions  [35 IAC 212.309(a)].

    ii.	The operating program shall be amended from time to time by the Permittee so that the operating program is current.  Such amendments shall be consistent with the requirements set forth by this Condition and shall be submitted to the Illinois EPA [35 IAC 212.312].

    iii.	All normal traffic pattern roads and parking facilities located at this source shall be paved or treated with water, oils, or chemical dust suppressants.  All paved areas shall be cleaned on a regular basis.  All areas treated with water, oils, or chemical dust suppressants shall have the treatment applied on a regular basis, as needed, in accordance with the operating program [35 IAC 212.306].

    c.	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.

    d.	No person shall cause or allow the emission of sulfur dioxide into the atmosphere from any process emission unit to exceed 2,000 ppm  [35 IAC 214.301].

    5.2.3	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.

    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	Should this stationary source, as defined in 40 CFR Section 68.3, become subject to the Accidental Release Prevention regulations in Part 68, then the owner or operator shall submit a Risk Management Plan (RMP) by the date specified in Section 68.10 and shall certify compliance with the requirements of Part 68 as part of the annual compliance certification as required by 40 CFR Part 70 or 71.

    5.2.5	Should this stationary source, as defined in 40 CFR Part 63, become subject to 40 FRR Part 63, then the owner or operator shall comply with the applicable requirements of 40 CFR Part 63 by the date(s) specified in the NESHAP and shall certify compliance with the applicable requirements of 40 CFR Part 63 as part of the annual compliance certification as required by 40 CFR Part 70 or 71.

    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

`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`]{.underline}

  -- ----------------------------------- ------------- -- ------------------------------ ---------- -- --------------------------- ---------- -- ------------------------------- ---------- -- ---------------------------------- ---------
     `Pollutant`                         `Tons/Year`                                                                                                                                                                              
     `Volatile Organic Material (VOM)`   `122.59`         `Sulfur Dioxide (SO`~`2`~`)`   `  0.04`      `Particulate Matter (PM)`   `  2.58`      `Nitrogen Oxides (NO`~`x`~`)`   `  6.39`      `HAP, not included in VOM or PM`   `-----`
     `TOTAL`                             `131.60`                                                                                                                                                                                 
  -- ----------------------------------- ------------- -- ------------------------------ ---------- -- --------------------------- ---------- -- ------------------------------- ---------- -- ---------------------------------- ---------

    5.5.2	Emissions of Hazardous Air Pollutants

    Source-wide emission limitations for HAPs as listed in Section 112(b) of the CAA are not set. This source is considered to be a major source of HAPs.

    5.5.3	Other Source-Wide Emission Limitations

    The annual emissions from the source, not considering gas combustion emissions from the bake ovens and drying oven, shall not exceed the following limitations:

  -- ------------- --------------- -------------------
                   `Emissions`     `Underlying`
     `Pollutant`   `(Tons/Year)`   `Rules`
                                   
     `VOM`         `122.24`        `35 IAC Part 203`
  -- ------------- --------------- -------------------

    The limits on VOM emissions are limitations established in Construction Permit 93030049 pursuant to 35 IAC Part 203.  These limits ensure that the construction/modification addressed in the aforementioned Construction Permit does not constitute a new major source or major modification pursuant to 35 IAC Part 203.  See Condition 7.1.6.

    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).

`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.

`5.6.2``	``Records for Operating Scenarios`

    N/A

`5.6.3``	``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 noncompliance 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

`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.

    Total VOM emissions from the source shall be calculated based on the following:

`E`~`T`~` = E`~`c`~` + E`~`o`~

    Where:

`E`~`T`~`   = ``	``Total VOM emissions, in pounds/month`

`E`~`c`~`   = ``	``VOM emissions from all coatings, in pounds/month`

`E`~`o`~`   = ``	``VOM emissions from all other VOM-containing materials (e.g., cleanup solvents), in pounds/month,`

    and

`	``	``	``	``    `~` n`~

`	``	``	``	``E`~`c`~` = `` U`~`i`~` V`~`i`~` W`~`i`~

`	``	``	``	``    `^`i=1`^

    Where:

`U`~`i`~`   =``	``Usage of coating i, in gallons/month`

`V`~`i`~`   =``	``Density of coating i, in lb/gal`

`W`~`i`~`   =``	``VOM content of coating i, in weight percent`

    and the summation  is over all coatings i; and

`	``	``	``	``    `~` n`~

`	``	``	``	``E`~`o`~` = `` U`~`j`~` V`~`j`~

`	``	``	``	``    `^`j=1`^

    Where:

`U`~`j`~`   =``	``Usage of VOM-containing material j, in lb/month`

`V`~`j`~`   =``	``VOM content of VOM-containing material j, in weight percent`

    and the summation  is over all VOM-containing materials j (other than coatings).

    Gas combustion emissions 

    					Emission Factor

[`Pollutant`]{.underline}`	``	``	``	``  `[`(lb/10`]{.underline}^[`6`]{.underline}^[` ft`]{.underline}^[`3`]{.underline}^[`)`]{.underline}

`NO`~`x`~`	``	``	``	``	``	``100.0`

    CO						 84.0

    PM						  7.6

    VOM						  5.5

`SO`~`2`~`	``	``	``	``	``	``  0.6`

    These are emission factors for uncontrolled natural gas combustion for small boilers (less than 100 mmBtu/hr), Tables 1.4.1, and 1.4.2, AP-42, Volume I, Supplement D, March, 1998. 

    Particulate matter emissions from the grinding operation

    PM generated by grinding multiplied by the control efficiency of the cyclone controlling the grinding operation

`(PM generated) X (1 -``	`[`Control Efficiency`]{.underline}`)`

    					100

    Particulate matter emissions from coating operation

    [(lbs of solids in coating)X(% Overspray)X

`(1- `[`Control equipment efficiency`]{.underline}`)]`

    			100

    6.0	EMISSION REDUCTION MARKET SYSTEM (ERMS)

    6.1	Description of ERMS

    The ERMS is a “cap and trade” market system for major stationary sources located in the Chicago ozone nonattainment area.  It is designed to reduce VOM emissions from stationary sources to contribute to further reasonable progress toward attainment, as required by Section 182(c) of the Clean Air Act.

    The ERMS addresses VOM emissions during a seasonal allotment period from May 1 through September 30.  Once the ERMS begins, participating sources must hold “allotment trading units” (ATUs) for their actual seasonal VOM emissions.  Each year participating sources are issued ATUs based on allotments set during initial issuance of the sources’ CAAPP permits.  These allotments are established from historical VOM emissions or “baseline emissions” lowered to provide the emission reduction from stationary sources required for further progress.

    By December 31 of each year, the end of the reconciliation period following the seasonal allotment period, each source shall have sufficient ATUs in its account to cover its actual VOM emissions during the preceding season.  An account’s balance as of December 31 will include any valid ATU transfer agreements entered into as of December 31 of the given year, provided such agreements are promptly submitted to the Illinois EPA for entry into the account database.  The Illinois EPA will then retire ATUs in sources’ accounts in amounts equivalent to their seasonal emissions.  When a source does not appear to have sufficient ATUs in its account, the Illinois EPA will issue a notice to the source to begin the process for Emissions Excursion Compensation.

    In addition to receiving ATUs pursuant to their allotments, participating sources may also obtain ATUs from the market, including ATUs bought from other participating sources and general participants in the ERMS that hold ATUs (35 IAC 205.630) and ATUs issued by the Illinois EPA as a consequence of VOM emission reductions from an Emission Reduction Generator or an Intersector Transaction (35 IAC 205.500 and 205.510).  During the reconciliation period, sources may also buy ATUs from a secondary reserve of ATUs managed by the Illinois EPA, the Alternative Compliance Market Account (35 IAC 205.710).  Sources may also transfer or sell the ATUs that they holds to other sources or participants (35 IAC 205.630).

    6.2	Applicability

    This source is considered a “participating source” for purposes of the ERMS, 35 IAC Part 205.

    6.3	Obligation to Hold Allotment Trading Units (ATUs)

    a.	Pursuant to 35 IAC 205.150(c)(1) and 205.720, and as further addressed by Condition 6.8, as of December 31 of each year, this source shall hold ATUs in its account in an amount not less than its VOM emissions during the preceding seasonal allotment period (May 1 - September 30) not including VOM emissions from the following, or the source shall be subject to “emissions excursion compensation,” as described in Condition 6.4.

    i.	VOM emissions from insignificant units and activities as identified in Section 3 of this permit, in accordance with 35 IAC 205.220;

    ii.	Excess VOM emissions associated with startup, malfunction or breakdown of an emission unit as authorized elsewhere in this permit, in accordance with 35 IAC 205.225;

    iii.	Excess VOM emissions to the extent allowed by a Variance, Consent Order, or Compliance Schedule, in accordance with 35 IAC 205.320(e)(3);

    iv.	Excess VOM emissions that are a consequence of an emergency as approved by the Illinois EPA, pursuant to 35 IAC 205.750; and

    v.	VOM emissions from certain new and modified emission units as addressed by Section 6.7(b), if applicable, in accordance with 35 IAC 205.320(f).

    b.	Notwithstanding the above condition, in accordance with 35 IAC 205.150(c)(2), if a source commences operation of a major modification, pursuant to 35 IAC Part 203, the source shall hold ATUs in an amount not less than 1.3 times its VOM emissions attributable to such major modification during the seasonal allotment period, determined in accordance with the construction permit for such major modification or applicable provisions in Section 7.0 of this permit.

    6.4	Market Transaction

    a.	The source shall apply to the Illinois EPA for and obtain authorization for a Transaction Account prior to conducting any market transactions, as specified at 35 IAC 205.610(a).

    b.	The Permittee shall promptly submit to the Illinois EPA any revisions to the information submitted for its Transaction Account, pursuant to 35 IAC 205.610(b).

    c.	The source shall have at least one account officer designated for its Transaction Account, pursuant to 35 IAC 205.620(a).

    d.	Any transfer of ATUs to or from the source from another source or general participant must be authorized by a qualified Account Officer designated by the source and approved by the Illinois EPA in accordance with 35 IAC 205.620 and the transfer must be submitted to the Illinois EPA for entry into the Transaction Account database.

    6.5	Emission Excursion Compensation

    Pursuant to 35 IAC 205.720, if the source fails to hold ATUs in accordance with Condition 6.3, it shall provide emissions excursion compensation in accordance with the following:

    a.	Upon receipt of an Excursion Compensation Notice issued by the Illinois EPA, the source shall purchase ATUs from the ACMA in the amount specified by notice, as follows:

    i.	The purchase of ATUs shall be in an amount equivalent to 1.2 times the emissions excursion; or

    ii.	If the source had an emissions excursion for the seasonal allotment period immediately before the period for the present emission excursion, the source shall purchase ATUs in an amount equivalent to 1.5 times the emissions excursion.

    b.	If requested in accordance with paragraph (c) below or in the event that the ACMA balance is not adequate to cover the total emissions excursion amount, the Illinois EPA will deduct ATUs equivalent to the specified amount or any remaining portion thereof from the ATUs to be issued to the source for the next seasonal allotment period.

    c.	Pursuant to 35 IAC 205.720(c), within 15 days of receipt of an Excursion Compensation Notice, the owner or operator may request that ATUs equivalent to the amount specified be deducted from the source’s next seasonal allotment by the Illinois EPA, rather than purchased from the ACMA.

    6.6	Quantification of Seasonal VOM Emissions

    a.	The methods and procedures specified in Section 5 and 7 of this permit for determining VOM emissions and compliance with VOM emission limitations shall be used for determining seasonal VOM emissions for purposes of the ERMS, with the following exceptions  [35 IAC 205.315(b)]:

    No exceptions

    b.	The Permittee shall report emergency conditions at the source to the Illinois EPA in accordance with 35 IAC 205.750, if the Permittee intends to deduct VOM emissions in excess of the technology-based emission rates normally achieved that are attributable to the emergency from the source’s seasonal VOM emissions for purposes of the ERMS.  These reports shall include the information specified by 35 IAC 205.650(a), and shall be submitted in accordance with the following:

    i.	An initial emergency condition report within two days of the time when such excess emissions occurred due to the emergency; and

    ii.	A final emergency condition report, if needed to supplement the initial report, within 10 days after the conclusion of the emergency.

    6.7	Annual Account Reporting

    a.	For each year in which the source is operational, the Permittee shall submit, as a component of its Annual Emission Report, seasonal VOM emission information to the Illinois EPA for the seasonal allotment period. This report shall include the following information  [35 IAC 205.300]:

    i.	Actual seasonal emissions of VOM from the source;

    ii.	A description of the methods and practices used to determine VOM emissions, as required by this permit, including any supporting documentation and calculations;

    iii.	A detailed description of any monitoring methods that differ from the methods specified in this permit, as provided in Section 205.337 of this Subpart;

    iv.	If a source has experienced an emergency, as provided in 35 IAC 205.750, the report shall reference the associated emergency conditions report that has been approved by the Illinois EPA;

    v.	If a source’s baseline emissions have been adjusted due to a variance, consent order or CAAPP permit compliance schedule, as provided for in 35 IAC 205.320(e)(3), the report shall provide documentation quantifying the excess VOM emissions during the season that were allowed by the Variance, Consent Order, or Compliance Schedule, in accordance with 35 IAC 205.320(e)(3); and

    vi.	If a source is operating a new or modified emission unit for which three years of operational data are not yet available, as specified in 35 IAC 205.320(f), the report shall specify seasonal VOM emissions attributable to the new emission unit or the modification of the emission unit.

`b.``	``This report shall be submitted by October 31`**` `**`of each year, for the preceding seasonal allotment period.`

    6.8	Allotment of ATUs to the Source

    a.	i.	The allotment of ATUs to this source is 332 ATUs per seasonal allotment period.

    ii.	This allotment of ATUs reflects the Illinois EPA's determination that the source's baseline emissions were 37.6298 tons.

    iii.	The source's allotment reflects 88% of the baseline emissions (12% reduction) except for the VOM emissions from specific emission unit excluded from such reduction, pursuant to 35 IAC 205.405 including units complying with MACT or using BAT, as identified in Section 7 of this permit.

    iv.	ATUs will be issued to the source's Transaction Account by the Illinois EPA annually.  These ATUs will be valid for the seasonal allotment period following issuance and, if not retired in this season, the next seasonal allotment period.

    v.  	Condition 6.3(a) becomes effective beginning in the seasonal allotment period following the initial issuance of ATUs by the Illinois EPA into the Transaction Account for the source.

    b.	Contingent Allotments for New or Modified Emission Units

    Not applicable

    c.	Notwithstanding the above, part or all of the above ATUs will not be issued to the source in circumstances as set forth in 35 IAC Part 205, including:

    i.	Transfer of ATUs by the source to another participant or the ACMA, in accordance with 35 IAC 205.630;

    ii.	Deduction of ATUs as a consequence of emission excursion compensation, in accordance with 35 IAC 205.720; and

    iii.	Transfer of ATUs to the ACMA, as a consequence of shutdown of the source, in accordance with 35 IAC 205.410.

    6.9	Recordkeeping for ERMS

    The Permittee shall maintain copies of the following documents as its Compliance Master File for purposes of ERMS [35 IAC 205.700(a)]:

    a.	Seasonal component of the Annual Emission Report;

    b.	Information on actual VOM emissions, as specified in detail in Sections 5 and 7 of this permit and Condition 6.6(a); and

    c.	Any transfer agreements for the purchase or sale of ATUs and other documentation associated with the transfer of ATUs.

    6.10	Federal Enforceability

    Section 6 becomes federally enforceable upon approval of the ERMS by USEPA as part of Illinois' State Implementation Plan.

`7.0``	``UNIT SPECIFIC CONDITIONS`

    7.1	Group 1 	Coating Line #3 [Exterior coating line for drums, includes two spray booths (SB5 & SB6) with water wash scrubbers and a bake oven (O1)].

    Group 2 	Coating Line #1 [Interior coating line for lids, includes two spray booths (SB1 & SB2) with dry filters and water wash scrubbers and a bake oven (O3)].

    Group 3 	Coating Line #2 [Interior coating line for drumshells, includes two spray booths (SB3 & SB4) with water wash scrubbers and a drying oven (O2) and the bake oven (O3)].

    7.1.1	Description

    The Permittee is a manufacturer of steel drums. After preliminary metal fabrication, coating operations are conducted with paint spray booths, bake oven and cleanup solvents.

    7.1.2	List of Emission Units and Pollution Control Equipment

  -- ------------------- ----------------------------------------------------------------------------------------------------------------------- ------------------------------ -- ------------------- ---------------------------------------------------------------------------------------------- ----------------------------------------
     `Emission Unit`     `Description`                                                                                                           `Emission Control Equipment`                                                                                                                         
     `Coating Line #3`   `Exterior Coating Line For Drums Includes Two Spray Booths (SB5 & SB6) And A Bake Oven(O1) `                            `Water Wash Scrubbers`            `Coating Line #1`   `Interior Coating Line For Lids Includes Two Spray Booths (SB1 & SB2) And A Bake Oven (O3) `   `Dry Filters And Water Wash Scrubbers`
     `Coating Line #2`   `Interior Coating Line For Drumshells Includes Two Spray Booths (SB3 & SB4), A Drying Oven (O2) And A Bake Oven (O3)`   `Water Wash Scrubbers`                                                                                                                               
  -- ------------------- ----------------------------------------------------------------------------------------------------------------------- ------------------------------ -- ------------------- ---------------------------------------------------------------------------------------------- ----------------------------------------

    7.1.3	Applicability Provisions and Applicable Regulations

    a.	An “affected coating line” for the purpose of these unit specific conditions is a coating operation that includes the spray booths and baking oven for coating lines #1 and #3, and that includes spray booths, drying oven and baking oven for coating line #2 which is used to apply coating to drums and lids.  As of the “date issued” as shown on page 1 of this permit, the affected coating lines are identified in Condition 7.1.2.

    b.	Each affected coating line is subject to the limits identified in Condition 5.2.2.

    c.	Each affected coating line at the source is subject to 35 IAC 212.321(a), which requires that:

    i.	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, 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 35 IAC 212.321 [35 IAC 212.321(a)].

    ii.	The emissions of particulate matter into the atmosphere in any one hour period from the affected coating lines shall not exceed the allowable emission rates specified in the following equation

`	``	``	``	``E = A(P)`^`B`^

    Where:

    P = process weight rate; and,

    E = allowable emission rate; and,

    1.	For process weight rates up to 408 MG/hr (450 T/hr):

`	``	``	``	``	``	`[`Metric `]{.underline}`              `[`English`]{.underline}

    				P		Mg/hr	                T/hr

    					E		kg/hr	                lbs/hr

    					A		1.214	                2.54

    					B		0.534	                0.534

    2.	For process weight rates in excess of 408 MG/hr (450 T/hr):

`	``	``	``	``	``	`[`Metric `]{.underline}`              `[`English`]{.underline}

    				P		Mg/hr	                T/hr

    					E		kg/hr	                lbs/hr

    					A		11.42	                24.8

    					B		0.16	                0.16

    Where:

    P =	Process weight rate in metric or English tons per hour, and

    E =	Allowable emission rate in kilograms or pounds per hour.

    [35 IAC 212.321]

    d.	The exterior coating line (coating line #3) at the source is subject to 35 IAC 218.204(j)(2)(B) for Miscellaneous Metal Parts and Products Coatings for extreme performance coating which provides that:

    i.	No owner or operator of an affected coating line shall apply at any time any coating in which the VOM content    exceeds the following emission limitations for the coating as applied to Miscellaneous Metal Parts and Products for extreme performance. The following emission limitation is expressed in units of VOM per volume of coating (minus water and any compounds which are specifically exempted from the definition of VOM) as applied at each coating applicator:

`        `[`kg/liter`]{.underline}`                    `[`lbs/gallon`]{.underline}

              0.4                         3.3

    ii.	Compounds which are specifically exempted from the definition of VOM should be treated as water for the purpose of calculating the “less water” part of the coating composites.

    e.	The interior coating lines (coating lines #1 & #2) at the source are subject to 35 IAC 218.204(j)(3)for Miscellaneous Metal Parts and Products Coatings for steel pail and drum interior coating which provides that:

    i.	No owner or operator of an affected coating line shall apply at any time any coating in which the VOM content exceeds the following emission limitations for the coating as applied to Miscellaneous Metal Parts and Products for steel pail and drum interior. The following emission limitation is expressed in units of VOM per volume of coating (minus water and any compounds which are specifically exempted from the definition of VOM) as applied at each coating applicator:

`        `[`kg/liter`]{.underline}`                    `[`lbs/gallon`]{.underline}

              0.52                         4.3

    ii.	Compounds which are specifically exempted from the definition of VOM should be treated as water for the purpose of calculating the “less water” part of the coating composites.

    7.1.4	Non-Applicability of Regulations of Concern

    a.	The affected coating lines are not subject to 35 IAC 218.301, use of organic material, pursuant to 35 IAC 218.309, Exemption From General Rule on Use of Organic Material which excludes affected coating lines from this requirement.

    7.1.5	Operational and Production Limits and Work Practices

    7.1.5.1	The bake ovens and drying oven shall only be operated with natural gas as the fuel.

    7.1.5.2	The Permittee shall follow good operating practices for the dry filters and water wash scrubbers, including periodic inspection, routine maintenance and prompt repair of defects.

    7.1.6	Emission Limitations

    In addition to Condition 5.2.2 and the source wide emission limitations in Condition 5.5, the affected coating lines are subject to the following:

    a.	Emissions of VOM from the affected coating lines (emissions from coatings and cleanup solvent combined) shall not exceed the following:

    				VOM Emissions From Coating and

    				 Cleanup Operation Combined 

[`Coating Line`]{.underline}`	``	``	`[`tons/mo`]{.underline}`     `[`tons/yr`]{.underline}

    Exterior Coating

    Line (#3) and interior		 12.2        122.24

    Coating lines (#1&#2)

    All combined 

    The emissions from the coating lines are based on the coating usage and the corresponding VOM content of the coatings used on the affected coating lines. The emissions from the cleanup operation are based on the cleanup solvent usage and the VOM content of the cleanup solvent used.

    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 months total).

    The above limitations contain revisions to previously issued Construction Permit 93030049. The source has requested that the Illinois EPA establish conditions in this permit that allow various refinements from the conditions of this construction permit, consistent with the information provided in the CAAPP application. The source has requested these revisions and has addressed the applicability and compliance of 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 construction 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 construction permit and the information in the CAAPP application contains the most current and accurate information for the source. Specifically, the emission limits on all coating lines are combined without an increase in the total allowable emissions.

    7.1.7	Testing Requirements

    Testing for VOM content of coatings and other materials shall be performed as follows [35 IAC 218.105(a), 218.204, and Section 39.5(7)(b) of the Act]

    a.	Upon reasonable request by the Illinois EPA, the VOM content of specific coatings and cleaning solvents used on the affected coating lines shall be determined according to USEPA Reference Methods 24 and 24A of 40 CFR 60 Appendix A and the procedures of 35 IAC 218.105(a).

    i.	The VOM content of representative coatings “as applied” on the affected coating lines shall be determined according to USEPA Reference Methods 24 and 24A of 40 CFR 60 Appendix A and the procedures of 35 IAC 218.105(a)

    ii.	This testing may be performed by the supplier of a material provided that the supplier provides appropriate documentation for such testing to the Permittee and the Permittee’s records pursuant to Condition 7.1.9(b) directly reflect the application of such material and separately account for any additions of solvent [35 IAC 218.105(a)].

    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 each affected coating line to demonstrate compliance with Conditions 5.5.1 and 7.1.3 and 7.1.6 of this section, pursuant to Section 39.5(7)(b) of the Act:

    a.	i.	The name and identification number of each coating as applied on each affected coating line.

    ii.	The usage of each coating on each affected coating line, in units of gallons/month and gallons/year.

    iii.	Density of each coating in units of lb/gallon.

    iv.	VOM content of each coating in weight percent.

`v.``	``The weight of VOM per volume of each coating (minus water and any compounds which are specifically exempted from the definition of VOM) as applied each day on each affected coating line.`

    vi.	VOM emissions from the use of coatings in tons/month and tons/year. This shall be calculated using the data from Condition 7.1.9 (a)(i),(ii),(iii)and (iv).

    b.	i.	Name and identification of each cleanup solvent used.

    ii.	VOM content of each cleanup solvent used in lbs/gal.

    iii.	Amount of each cleanup solvent used in gal/month and gal/year.

    iv.	VOM emissions from the use of cleanup solvents in lbs/month and tons/year. This shall be calculated using the data from Condition 7.1.9 (b)(i),(ii) and (iii).

`c.``	``Records of the testing of VOM and HAP content (wt. %) of each coating and cleaning solvent as tested pursuant to the conditions of this section`**`,`**` which include the following [Section 39.5(7)(e) of the Act]:`

    i.	Identification of material tested;

    ii.	Results of analysis;

    iii.	Documentation of analysis methodology; and

    iv.	Person performing analysis.

    d.	The operating schedule of each affected coating line.

    e.	Records addressing use of good operating practices for the dry filters and water wash scrubbers:

`i.``	``Records for periodic inspection of the dry filters and water wash scrubbers with date, individual performing the inspection, and nature of inspection; and`

    ii.	Records for prompt repair of defects, with identification and description of defect, effect on emissions, date identified, date repaired, and nature of repair.

    7.1.10	Reporting Requirements

    The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of an affected coating line 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:

    Pursuant to 35 IAC 218.211 (c )(3)(A), the Permittee shall notify the Illinois EPA of any record showing violation of Condition 7.1.3 (d) and (e) within 30 days of such an occurrence.

    7.1.11	Operational Flexibility/Anticipated Operating Scenarios

    The Permittee is authorized to make the following physical or operational change with respect to the affected coating lines without prior notification to the Illinois EPA or revision of this permit. This condition does not affect the Permittee’s obligation to properly obtain a construction permit in a timely manner for any activity constituting construction or modification of the source, as defined in 35 IAC 201.102:

    Usage of coatings at this source with various VOM contents provided that the materials are tested in accordance with the conditions of this section, the source wide emission limitations in Condition 5.5.1 are not exceeded and the affected coating lines remain in compliance.

    7.1.12	Compliance Procedures

    a.	Compliance provisions addressing particulate matter limitations in this section are not set by this permit as compliance is assumed to be achieved by the normal work practices inherent in operation of an affected coating line.

    b.	Compliance of coatings with the VOM emission Limitations of Condition 7.1.3 (d) and (e) shall be determined from the testing required by this section.

    c.	Compliance with emission limitations of Condition 7.1.6 shall be determined based on the recordkeeping requirement of Condition 7.1.9 (a) and (b) and using the procedure identified in Condition 5.9.1.

    7.2	Unit	G1 - Grinder

    Control C1 - Cyclone

    7.2.1	Description

    The Permittee is a manufacturer of steel drums. During preliminary metal fabrication, sheet metal edges are de-burred with this grinder.

    7.2.2	List of Emission Units and Pollution Control Equipment

+---+-----------------+--------------------+--------------------+
|   | `Emission Unit` | `Description`      | `Emission          |
|   |                 |                    | Control Equipment` |
+---+-----------------+--------------------+--------------------+
|   | `Sheet Grinder` | `Steel Shee        | `Cyclone (C1)`     |
|   |                 | t Edge De-Burring` |                    |
|   | `(G1)`          |                    |                    |
+---+-----------------+--------------------+--------------------+

    7.2.3	Applicability Provisions and Applicable Regulations

    The grinding operation of the source is subject to 35 IAC 212 Subpart K “Fugitive Particulate Matter”. The requirements of this subpart are listed in Section 5.2.2 (a) and (b).

    7.2.4	Non-Applicability of Regulations of Concern

    N/A

    7.2.5	Control Requirements 

    The Permittee shall operate, maintain, and operate the cyclone in a manner that assures compliance with the conditions of this section.

    7.2.6	Emission Limitations

    In addition to Condition 5.2.2 and the source wide emission limitations in Condition 5.5, the affected sheet grinder is subject to the following:

    N/A

    7.2.7	Operating Requirements 

    None

    7.2.8	Inspection 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:

    None

    7.2.10	Reporting Requirements

    The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of an affected grinder 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

    N/A

`7.2.12``	``Compliance Procedures`

    None

`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 21, 1998 (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 without applying for or obtaining an amendment to this permit, provided that the changes do not constitute a modification under Title I of the CAA, emissions will not exceed the emissions allowed under this permit following implementation of the physical or operational change and 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  [Section 39.5(12)(a) of the Act].  This notice shall:

    a.	Describe the physical or operational change;

    b.	Identify the schedule for implementing the physical or operational change;

    c.	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;

    d.	Provide emission calculations which demonstrate that the physical or operational change will not result in a modification; and

`e.``	``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

    A report summarizing required monitoring 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`]{.underline}      [`Report Due Date`]{.underline}                                                     
                                                                                 `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 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)(i) 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 (MC 40)

    Bureau of Air

    Compliance Section

    P.O. Box 19276

    Springfield, Illinois  62794-9276

    ii.	Illinois EPA - Air Regional Field Office

    Illinois Environmental Protection Agency

    Division of Air Pollution Control

    Eisenhower Tower

    1701 First Avenue

    Maywood, Illinois  60153

    iii.	Illinois EPA - Air Permit Section (MC 11)

    Illinois Environmental Protection Agency

    Division of Air Pollution Control

    Permit Section

    P.O. Box 19506

    Springfield, Illinois  62794-9506

    iv.	USEPA Region 5 - Air Branch

    USEPA (AR - 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.

`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)(o)(i) 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.

    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)(o)(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)(p)(ii) of the Act]:

    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;

    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; 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.

    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.

    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)(v) of the Act, the Permittee shall submit compliance certifications annually or more frequently as specified in the applicable requirement or by permit condition.

    a.	The certifications shall include descriptions of means to monitor the compliance of the source including emissions limitations, standards, and work practices in accordance with applicable requirements and permit conditions.  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.	All 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 Permittee that meets the requirements of Section 39.5(5) of the Act  [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;

    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;

    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)(l), (n), and (o) of the Act].

    10.0	ATTACHMENTS

    10.1	Attachment 1	Summary of Equipment

    TABLE 1-1

  ---------------- ------------------ ------------------------ --------------------------------------------------------------------------------------------------- ----- --------------- ------------------- ------------------------------------------------------------------------------------------------------------------- ----- -------------- ------------------- ----------------------------------------------------------------------------------------------------------------------------
  `Group Number`   `Date Installed`   `Emission Unit Number`   `Description`                                                                                                                                                                                                                                                                                              
  `1`              `January, 1994`    `Coating Line #3`        `Exterior Coating Line, Includes Two Spray Booths With Water Wash Scrubbers And A Bake Oven`^`*`^   `2`   `April, 1980`   `Coating Line #1`   `Interior Coating Line, Includes Two Spray Booths With Dry Filters And Water Wash Scrubbers And A Bake Oven`^`*`^   `3`   `June, 1993`   `Coating Line #2`   `Interior Coating Line, Includes Two Spray Booths With Water Wash Scrubbers And A Drying Oven`^`*`^` And A Bake Oven`^`*`^
  `4`              `October, 1982`    `Grinder (G1)`           `Grinder With A Cyclone For Grinding Steel Edges Of Cut Steel Pieces To Make Drumshells`                                                                                                                                                                                                                   
  ---------------- ------------------ ------------------------ --------------------------------------------------------------------------------------------------- ----- --------------- ------------------- ------------------------------------------------------------------------------------------------------------------- ----- -------------- ------------------- ----------------------------------------------------------------------------------------------------------------------------

    *	Bake ovens and drying oven installed in June, 197310.2	Attachment 2     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:	______________________________________________

    RS:jar