217/785-1705

CONSTRUCTION PERMIT -- PSD APPROVAL

NSPS SOURCE

PERMITTEE

Cronus Chemicals, LLC
Attn: Donald Gill 150 North Michigan Avenue Chicago, Illinois 60601

Application No.: 13060007 I.D. No.: 041804AAF Applicant’s Designation: Urea Plant Date Received: February 14, 2014 Date Issued: Sept ember 5, 2014 Subject: Urea and Ammonia Production Facility Location: 785 East Highway 36, Tuscola

Permit is hereby granted to the above-designated Pe rmittee to CONSTRUCT emission units and air pollution control equipment consisting of a urea and ammonia production facility, as described in the ab ove referenced application. This permit is granted based upon and subject to the findings
and conditions that follow.

In conjunction with this permit, approval is given with respect to the federal regulations for Prevention of Significant D eterioration of Air Quality (PSD) for the facility, as described in the application, in that the Illinois EPA finds that the application fulfills al l applicable requirements of 40 CFR 52.21. This approval is issued pursuant to the federal Clean Air Act, the federal PSD rules at 40 CFR 52.21, and a D elegation of Authority agreement between the USEPA and the Illinois EPA fo r the administration of the PSD Program. This approval becomes effective i n accordance with the provisions of 40 CFR 124.15 and may be appealed in accordance with provisions of 40 CFR 124.19. This approval is based upon the findings that follow. This approval is subject to the following condition s. This approval is also subject to the general requirement that the facilit y be developed and operated consistent with the specifications and dat a included in the application and any significant departure from the terms expressed in the application, if not otherwise authorized by this pe rmit, must receive prior
written authorization from the Illinois EPA.

If you have any questions on this permit, please ca ll Bob Smet at 217/785-1705

Raymond E. Pilapil Date Signed: __________________

_ Acting Manager, Permit Section
Division of Air Pollution Control

REP:RPS:psj2 TABLE OF CONTENTS

Page

FINDINGS 3

PART 1: SOURCE-WIDE PERMIT CONDITIONS 5
1.1 Effect of Permit 1.2 Validity of Permit and Commencement of Constru ction 1.3 Natural gas Used at the Facility 1.4 Fixed-Roof Storage Tanks 1.5 Emissions of Hazardous Air Pollutants (HAPs)
1.6 Good Air Pollution Control Practice 1.7 Compliance with Emission Standards and Emissio n Limits 1.8 Records for Monitoring Systems and Instrumenta tion 1.9 Records for Opacity Measurements 1.10 Retention and Availability of Records
1.11 Addresses for the Illinois EPA 1.12 Authorization to Operate Emission Units
1.13 Standard Conditions

PART 2: UNIT-SPECIFIC CONDITIONS FOR PARTICULAR EMI SSION UNITS 11

2.1 Ammonia Plant
2.2 Reformer Furnace
2.3 Boiler 2.4 Startup Heater 2.5 Ammonia Storage Flare

2.6 Urea Plant 2.7 Cooling Tower 2.8 Equipment Components 2.9 Handling of Urea Product 2.10 Roadways 2.11 Engines

PART 3: GENERAL PERMIT CONDITIONS 86 3.1 General Requirements for Emission Testing 3.2 General Requirements for “Logs” or Similar Rec ords 3.3 General Requirements for Records for Deviation s 3.4 General Requirements for Reporting of Deviatio ns 90

ATTACHMENTS 84 1. Summary of Permitted Emissions 2. Summary of the Permitted HAP Emissions of the F acility
3. Standard Permit Conditions3

Findings

1. Cronus Chemicals, LLC (Cronus) has requested a p ermit for a facility

that would produce urea and ammonia. Natural gas w ould be both the feedstock and fuel for the facility. The principal product of the facility would be urea and the facility would have a nominal daily urea production capacity of 4880 tons. Ammonia wou ld be an intermediate material used in the production of ure a. The facility
would also be able to make ammonia for direct sale but this would be limited to 25 percent of the annual ammonia product ion capacity of the facility. This mode of operation would most li kely occur in the spring and fall to supply the seasonal demand for a mmonia.

2. The facility would be located in Douglas County, which is attainment

for all criteria pollutants.

3a. The proposed facility is a major source under t he PSD rules. This

is because the facility will have potential emissio ns of nitrogen oxides (NOx), particulate matter (as PM, PM 10 and PM 2.5 ), and carbon monoxide (CO) that are more than 100 tons per year. The facility will also be subject to PSD for volatile organic ma terial (VOM) greenhouse gases (GHG) because the facility’s poten tial emissions of these pollutants exceed the applicable significant emission rates under the PSD rules. (Refer to Attachment 1 for a summary of the potential emissions of the facility.)

b. The proposed facility is not a major source for emissions of

hazardous air pollutants (HAPs), i.e., as limited b y this permit, the potential emissions from the facility will be l ess than 10 tons
of an individual HAP and will be less than 25 tons in aggregate for total HAPs. Therefore, the facility is not subject to National Emission Standards for Hazardous Air Pollutants (NE SHAP), adopted by USEPA under 40 CFR 63 that apply to major sources o f HAPs. A caseby-case determination of Maximum Achievable Control Technology (MACT) is also not required for the proposed facili ty pursuant to Section 112(g) of the federal Clean Air Act.

4. After reviewing the materials submitted by Cronu s, the Illinois EPA

determined that the facility will be designed to: (i) comply with applicable state emission standards, (ii) comply wi th applicable federal emission standards, and (iii) utilize Best Available Control Technology (BACT) on emission units as required by PSD.

Note: The determinations of BACT made by the Illin ois EPA for the various emission units at the proposed facility are contained in the permit conditions for specific emission units that are headed by “Control Technology Determination - BACT”.

5. The Illinois EPA determined that the application for the proposed

facility complies with all applicable Pollution Con trol Board Air Pollution Control Regulations, the applicable feder al New Source Performance Standards (NSPS), and the federal PSD r ules, 40 CFR
52.21.4

6. The air quality analyses submitted by Cronus and reviewed by the

Illinois EPA shows that the proposed project will n ot cause or
contribute to violations of the National Ambient Ai r Quality

Standards for NO 2 , PM 10 /PM 2.5 and CO. The air quality analysis also shows compliance with the applicable allowable incr ement levels
established under the PSD rules.

7. Other impact analyses were also submitted by Cro nus, as required by

the PSD rules, to address other potential impacts f rom the emissions of the proposed facility.

8. A copy of the application, the project summary p repared by the

Illinois EPA, and a draft of this construction perm it were placed in a nearby public repository, and the public was give n notice and an opportunity to examine this material and to partici pate in a public hearing and to submit comments on these matters.5

PART 1: SOURCE-WIDE PERMIT CONDITIONS

CONDITION 1.1: EFFECT OF PERMIT

a. This permit does not relieve the Permittee of th e responsibility to

comply with all local, state and federal regulation s that are part of the applicable Illinois’ State Implementation Pl an, as well as all other applicable federal, state and local requi rements.

b. In particular, this permit does not relieve the Permittee from the

responsibility to carry out practices during the co nstruction and operation of the facility, such as application of w ater or dust suppressant sprays to unpaved traffic areas, as nec essary to minimize fugitive dust and prevent an air pollution nuisance from fugitive dust, as prohibited by 35 IAC 201.141.

CONDITION 1.2: VALIDITY OF PERMIT AND COMMENCEMENT OF CONSTRUCTION

a. This permit shall become invalid if construction is not commenced

within 18 months after this permit becomes effectiv e, if construction is discontinued for a period of 18 mon ths or more, or if construction is not completed within a reasonabl e period of time, pursuant to 40 CFR 52.21(r)(2). The Illinois EPA m ay extend the 18- month period upon a satisfactory showing that an ex tension is justified. This condition supersedes Standard Cond ition 1.

b. For purposes of the above provisions, the defini tions of

“construction” and “commence” at 40 CFR 52.21 (b)(8 ) and (9) shall apply, which requires that a source must enter into a binding agreement for on-site construction or begin actual on-site construction. (See also the definition of “begin a ctual construction,” 40 CFR 52.21 (b)(11).)

CONDITION 1.3: NATURAL GAS USED BY THE FACILITY

a. The natural gas used as fuel in the emission uni ts at the facility

shall be “pipeline natural gas” as defined by 40 CF R 72.2.

b. The Permittee shall keep copies of fuel receipts from the suppliers

of natural gas to the facility or other documentati on for the natural gas fired in the emission units at the faci lity that
confirms that it meets the criteria in the definiti on of pipeline natural gas in 40 CFR 72.2.

CONDITION 1.4: FIXED-ROOF STORAGE TANKS

a. The emissions of volatile organic material (VOM) and hazardous air

pollutants (HAPs) from the storage tanks for organi c liquids at the facility, including the tanks for CO 2 absorption solvent, ureaformaldehyde additive and diesel fuel, combined, sh all not exceed 0.20 tons/year.

Note: This condition constitutes the determination of BACT for VOM emissions of these tanks, as required under the PSD rules.6

b. The emissions of sulfuric acid mist from storage tanks for sulfuric

acid, combined, shall not exceed 0.44 tons/year.

CONDITION 1.5: EMISSIONS OF HAZARDOUS AIR POLLUTAN TS (HAPs)

a. This permit is issued based on this facility not being a major

source of hazardous air pollutants (HAPs), i.e., th e emissions of individual HAPs will each be less than 10 tons per year and the total emissions of HAPs will be less than 25 tons p er year so that the facility is not subject to the provisions of 40 CFR Part 63 that are applicable to major sources of HAPs.

b. The HAP emissions from the various emission unit s at the facility

and the facility as a whole shall not exceed the li mits in Attachment 2. Compliance with these limits for var ious emission units shall be determined based on activity and ope rating data for
those units and emission factors that do not unders tate actual emissions of those units, as developed from represe ntative sourcespecific testing or analysis, USEPA methodology, or other
authoritative source.

c. The Permittee shall keep records of the HAP emis sions of the various

units at the facility and the facility as a whole t o verify that the facility is not a major source of emissions of HAPs . For this purpose, in addition to other records required by o ther provisions of this permit, the Permittee shall keep a file con taining the
emission factors that it uses to calculate emission s of HAPs from the various emission units at the affected facility , with supporting documentation. The Permittee shall keep records of the actual emissions of HAPs from emissions units, which shall be prepared on at least a monthly basis.

CONDITION 1.6: GOOD AIR POLLUTION CONTROL PRACTICE

The Permittee shall operate and maintain all emissi on units at this facility, including associated air pollution control equipmen t, in a manner consistent with good air pollution control practice, as follow s:

a. At all times, including periods of startup, shut down, malfunction or

breakdown, operate as practicable to minimize emiss ions.

b. Conduct routine inspections and perform appropri ate maintenance and

repairs to facilitate proper functioning of equipme nt and minimize or prevent malfunctions and breakdowns.

c. Install, calibrate and maintain required monitor ing devices and

instrumentation in accordance with good monitoring practices, following the manufacturer’s recommended operating and maintenance procedures or such other procedures as otherwise ne cessary to assure reliable operation of such devices.7

CONDITION 1.7: COMPLIANCE WITH EMISSION STANDARDS AND EMISSION LIMITS

a. The emission limits set by this permit, includin g BACT limits and

other permit limits for emissions, apply at all tim es unless otherwise specified in a particular provision.

b. i. Unless otherwise provided by applicable rules , emission

standards for particulate matter under applicable r egulations that are referenced in the conditions of this permi t address only filterable particulate, as would be measured b y USEPA Method 5 or 5I or other appropriate USEPA Test Meth ods.

ii. Emissions limits for particulate matter 10 (PM 10 ) and particulate

matter 2.5 (PM 2.5 ) set by this permit address both filterable and condensable particulate.

c. Emission limits for greenhouse gases (GHG) set b y this permit

address GHG as carbon dioxide equivalents (CO 2 e).

d. Emission limits set by this permit in pounds/mil lion Btu (lbs/mmBtu)

are in terms of the higher heating value of the fue l burned in an
emission unit.

e. When emission testing is conducted, compliance w ith hourly limits

set by this permit shall be determined from the ave rage of the test results, commonly three runs, each nominally one ho ur in duration.

f. For annual limits set by this permit, unless oth erwise specified in

a particular provision of this permit, compliance s hall be
determined as follows:

i. Compliance with annual emission limits for emiss ion units and pollutants for which continuous emissions monitorin g is required by the permit shall be determined from emi ssion data collected by such monitoring systems, including use of substitute data for periods of missing data. Compl iance with annual emission limits for emission units and pollu tants for which continuous emission monitoring is not require d shall be determined from emission data calculated as the pro duct of activity or operating data and emission factors tha t do not understate emissions, as developed from representat ive sourcespecific testing or analysis, USEPA methodology or other
authoritative source.

ii. Compliance with annual limits established by th is permit shall be calculated from a running total of 12 months of data, i.e.,

from the sum of the data for the current month and data for the preceding 11 months (12 month total) and shall cons ider all emissions, including emissions during startup, shut down, and malfunction and breakdown, provided however, that f or the first year (12 months) of operation, compliance shall be calculated for a cumulative total of monthly data, i.e., from the sum of the data for the current month and data for all pre ceding

months.8

CONDITION 1.8: RECORDS FOR MONITORING SYSTEMS AND INSTRUMENTATION

a. The Permittee shall keep records of the data mea sured by required

monitoring systems and instrumentation. Unless oth erwise provided in a particular condition of this permit, the follo wing requirements shall apply to such recordkeeping:

i. For required monitoring systems, data shall be a utomatically recorded by a central data system, dedicated data l ogging system, chart recorder or other data recording devi ce. If an electronic data logging system is used, the recorde d data shall be the hourly average value of the particular param eter for each hour. During periods when the automatic recor ding device is out of service, data shall be recorded at least once per shift for periods when the associated emission unit (s) are in
service.

ii. For required instrumentation, the measured data shall be recorded manually at least once per day, unless oth erwise specified, with data and time both recorded, for pe riods when the associated emission unit(s) are in service, pro vided
however that if data from an instrument is recorded automatically, the above provisions for recording o f data from monitoring systems shall apply and manual recording of data is not required.

b. The Permittee shall keep records for the operati on, calibration

maintenance and repair of required monitoring syste ms and instrumentation. These operating records shall, at a minimum, identify the date and duration of any time when a r equired monitoring instrument or device was not in operatio n, with explanation; the performance of manual quality cont rol and quality assurance procedures for the system; and maintenanc e and repair activities performed for the system.

c. The Permittee shall maintain a file containing a copy of the

specifications for each required monitoring device or instrument and the recommended operating and maintenance procedure s for the device as provided by its manufacturer.

CONDITION 1.9: RECORDS FOR OPACITY MEASUREMENTS

a. The Permittee shall keep records for all opacity measurements made

in accordance with USEPA Method 9 for emission unit s at the facility
that it conducts or that are conducted on its behes t by individuals who are qualified to make such observations. For e ach occasion on which such measurements are made, these records sha ll include the formal report for the measurements if conducted pur suant to this permit or a request from the Illinois EPA, or other wise the identity of the observer, a description of the measurements that were made, the operating condition of the affected operations, the observed opacity, and copies of the raw data sheets for the measurements.9

CONDITION 1.10: RETENTION AND AVAILABILITY OF RECO RDS

a. The Permittee shall retain all records and logs required by this

permit for at least five years from the date of ent ry (unless a longer retention period is specified by a particula r provision), keep the records at a location at the facility that is readily accessible to the Illinois EPA and USEPA, and make records available for inspection and copying by the Illinois EPA or U SEPA upon request.

b. The Permittee shall retrieve and print on paper during normal

facility office hours any records retained in an el ectronic format (e.g., computer) in response to an Illinois EPA or USEPA request for records during the course of a facility inspection.

CONDITION 1.11: ADDRESSES FOR THE ILLINOIS EPA

a. Any required reports and notifications shall be sent to the Illinois

EPA at the following address unless otherwise indic ated:

Illinois Environmental Protection Agency
Division of Air Pollution Control Compliance and Enforcement Section (#40)

P.O. Box 19276 Springfield, Illinois 62794-9276

Telephone: 217/782-5811 Fax: 217/524-4710

b. A copy of all required reports and notifications , except the Annual

Emission Report required by 35 IAC Part 254, shall also be sent to the Illinois EPA Air Regional Field Office at the f ollowing address:

Illinois Environmental Protection Agency
Division of Air Pollution Control

2009 Mall Street Collinsville, Illinois 62234

Telephone: 618/346-5120 Fax: 618/346-5155

CONDITION 1.12: AUTHORIZATION TO OPERATE EMISSION UNITS

a. i. Under this permit, the ammonia plant may be o perated for a

period that ends 180 days after initial startup to allow for equipment shakedown and required emission testing. This period may be extended by Illinois EPA for up to an additi onal 365 days upon request of the Permittee if additional ti me is needed to complete shakedown or perform emission testing.

ii. The remainder of the facility, excluding the am monia plant, may be operated under this construction permit for a pe riod of 365 days after initial startup of the ammonia plant. T his period of time may be extended by the Illinois EPA upon wr itten request by the Permittee as needed to reasonably ac commodate unforeseen difficulties experienced during shakedow n of the facility.10

b. Upon successful completion of required emission testing, the

Permittee may continue to operate emission units at the facility provided that the Permittee submits a complete and timely application for Clean Air Act Permit Program (CAAPP ) permit for the facility, as provided for by Section 39.5(5) of the Environmental
Protection Act.

c. These conditions supersede Standard Condition 6.

CONDITION 1.13: STANDARD CONDITIONS

Standard conditions for issuance of construction pe rmits, attached hereto and incorporated herein by reference, shall apply to th is project, unless superseded by other conditions in the permit. (Ref er to Attachment 3.)11

PART 2: UNIT-SPECIFIC CONDITIONS FOR PARTICULAR EM ISSION UNITS

SECTION 2.1: UNIT-SPECIFIC CONDITIONS FOR THE AMM ONIA PLANT

2.1.1 Description

The ammonia plant produces ammonia (NH 3 ) from nitrogen and hydrogen. The nitrogen comes from the atmosphere. The hydrog en is made in the first part of the ammonia plant from natural gas by “steam reforming”. In steam reforming for production of am monia, a hydrogen-rich stream of synthesis gas is made from natural gas and steam in a reformer furnace. The amount of hydroge n in this stream is increased in a secondary reformer where air is a dded to the stream. This is followed by shift-conversion to fu rther increase the hydrogen content of the stream.

The majority of the carbon dioxide (CO 2 ) in the stream of synthesis gas is then removed using an amine absorbent soluti on. This absorbent solution is then processed in a regenerat or system that
drives the CO 2 out of the solution. This process also removes organic compounds from the gas stream, which are se nt back to the

reformer furnace for use as fuel.

The remaining carbon monoxide (CO) and CO 2 in the stream of synthesis gas are then reacted with some of the hydrogen in t his stream to

convert the CO and CO 2 into methane and water. These are removed from the stream and the methane off-gas is used as a fuel in the reformer furnace. The stream of synthesis gas, whi ch is now essentially only hydrogen and nitrogen, is then con verted into ammonia in a catalytic converter.

When urea is being produced by the facility, most o f the CO 2 from the regenerator system is fed to the urea plant where i t is used in making urea and is not emitted. Only a small amoun t of CO 2 is emitted to regulate operational pressure, either th rough the CO 2 vent in the ammonia plant or another CO 2 vent that is physically located in the urea plant. The full CO 2 stream from the regenerator system is only emitted when ammonia is produced for direct sale, when the

CO 2 stream is vented through the CO 2 vent at the ammonia plant. This mode of operation would address the seasonal demand for ammonia and is limited to 25 percent of the annual ammonia prod uction capacity of the facility.

During startup, shutdown and upsets or “malfunction s” of the ammonia plant, process gases from various units in the plan t, including the reforming operations, may be ducted to two flares, where these gases
are combusted. The “Front End Flare” handles these releases from the reforming operations. The “Back End Flare” han dles releases from the later process steps, including regeneratio n, methanation and ammonia synthesis. The flares have emissions f rom combustion of both process gases and from the fuel needed for ope ration of the

flares.

For purposes of these unit-specific conditions, the “affected process gas vents” are the vents that release proce ss gases from the12 ammonia plant during startup, shutdown and malfunct ion, which are to be ducted to the Front End and Back End Flares, i.e ., “the affected
flares”. The “affected CO 2 vents” are the main CO 2 vent at the ammonia plant and the pressure control CO 2 vent at the urea plant, which is used to regulate the operation of the urea synthesis process. The reformer furnace, as it is a process heater with emissions from combustion of fuel, is addressed in Section 2.2 of this permit.

2.1.2-1 Control Technology Determination – BACT: A ffected CO 2 Vents

a. As the operation of the ammonia plant affects th e emissions of CO, VOM, methane and GHG from the CO 2 vents, the ammonia plant shall be operated and maintained in conformance wit h its physical and process design.

b. The emissions of CO, VOM and methane from the af fected CO 2 vents, combined, shall not exceed 3.11, 13.1 and 31 .1 pounds/hour, respectively.

2.1.2-2 Control Technology Determination – BACT:

Ammonia Plant and Affected Flares

a. As the operation of the ammonia plant affects th e occurrence of flaring and emissions from flaring, the ammonia pla nt, including the affected flares, shall be operated an d maintained in conformance with its physical and process design

.

i. The ammonia plant shall be designed and operated to comply with the following requirements to reduce emissions from the affected process gas vents, i.e.
, vents other than the affected CO 2 vents and the vents for off-gas streams that are ducted to the reformer fur nace:

A. Process gas streams shall not be discharged from process gas vents except during startup or shutdown or during malfunction due to either failure of equipment or planning that precludes the safe handling of the stream within the ammonia plant.

B. All discharges from affected process gas vents s hall
be ducted to a flare or other combustion device through a closed vent system, except when a failure of equipment or planning preclude the safe disposal of a gas stream in this manner.

C. During periods when the ammonia plant is not operating, the above requirements do not apply to venting of air or nitrogen introduced into equipmen t in the plant, as may be needed to prepare for maintenance or startup.

ii. The operating practices for the ammonia plant s hall
include:13 A. Operation in accordance with written operating procedures that include startup, shutdown and malfunction plan(s), as further addressed in
Condition 2.1.5-2.

B. Implementation of practices to minimize flaring, as further addressed in Condition 2.1.5-3.

b. The affected flares shall be designed, operated and maintained to comply with the following requirements:

i. The design destruction efficiencies of the flare s shall be at least 98 percent for CO and VOM and at least 99 percent for methane.

ii. All relevant requirements of 40 CFR 60.18 shall be met for the flares except that when the heat content of a process gas stream is below the specified value in 40 CFR 60.18(b)(3), compliance with the requirements of 40 CFR 60.18 may be demonstrated by conducting periodic vi sual observations to show compliance with 40 CFR 60.18(c )(1), which addresses the presence of visible emissions f rom a flare.

iii. The only fuel used in the pilot burners of the flares shall be natural gas. These burners shall be equip ped with automatic igniter devices for the pilot flame.

iv. The only purge gas used in the flare system whe n the ammonia plant is operating shall be nitrogen.

c. The design emission rates of the pilot burners i n the affected flares shall not exceed 0.07 and 0.37 lb/mmBtu for NOx and CO, respectively.

d. The emissions of NOx, CO, VOM, PM, PM 10 /PM 2.5 and GHG from the
affected flares shall not exceed the limits in Cond ition 2.1.6. that apply to the flares. For the purpose of deter mining compliance with these limits for CO and VOM, emissi ons shall be
determined from the CO and VOM content of the flare d process gas using destruction efficiencies for a properly o perating flare of no more than 98 percent. For the purpose of determining compliance with the limits for GHG, met hane
emissions shall be determined from the methane cont ent of the flared process gas using a destruction efficiency f or a properly operating flare of no more than 99 percent

.

2.1.2-3 Control Technology Determination – BACT:

Limit for GHG from the CO 2 Vent in the Ammonia Plant and from the CO 2 Vent in the Urea Plant, the Reformer Furnace and th e Boiler

a. The GHG emissions, as carbon dioxide equivalents (CO 2 e), of the
combination of the affected CO 2 vents in the ammonia plant and the urea plant, the reformer furnace and the boiler , on an14 annual average basis, rolled monthly, shall not exc eed a limit
determined as follows:

E = {(P
u x R u ) + (P
a x R a )} ÷ (P
u + P a )

Where

E = Limit on GHG emissions, as CO 2 e, tons/ton ammonia produced, annual average, rolled monthly.

P u = Ammonia production sent to the urea plant (tons/ year, rolled monthly).

P a = Ammonia production for direct sale (tons/year, r olled monthly), determined as ammonia sent to storage.

R u = 0.92 tons per ton of ammonia sent to the urea pl ant.

R a = 2.22 tons per ton of ammonia sent to storage.

b. i. Notwithstanding the above, alternative values for R
u and

R a shall be used in the above equation, as follows, t o determine the applicable limit for GHG emissions:

A. Until the commissioning of the ammonia plant is complete or one year after initial startup of the ammonia plant, whichever occurs first, the values o f Ru and Ra shall be 1.15 and 2.45 tons per ton of ammonia, respectively.

B. Alternative values for Ru and Ra shall be used a s provided for by Condition 2.1.11, which provides fo r a reduction in these values based on the demonstrated performance of the facility.

ii. For this purpose, if different values of R

u and R
a apply in a year, the data for ammonia production for each portion of the year shall be multiplied by the appropriate values of R

u and R
a for that portion of the year and the sum of these results shall serve as th e numerator in the above equation.

c. For the purpose of determining compliance with t his limit and other limits for GHG emissions set by this permit f or the CO 2 vents, the reformer and the boiler, the Permittee s hall
determine GHG emissions as follows:

i. For the reformer furnace and boiler, emissions s hall be determined in accordance with 40 CFR Part 98 Subpar t C, except that emissions of CH 4 and N 2 O shall be determined using emission factors developed from testing of th ese units, if such testing indicates that emissions are higher than the default factors in 40 CFR Part 98 S ubpart

C.

ii. For the CO 2 vents, CO 2 emissions shall be determined in accordance with 40 CFR Part 98 Subpart PP and emiss ions of methane shall be determined using data from samp ling15 and analysis of the stream(s) that are emitted from these

vents.

2.1.3 Applicable Emission Standards

a. The emission of smoke or other PM from the affec ted units shall not have an opacity greater than 30 percent, 6 minu te average, except as allowed by 35 IAC 212.124. [35 IAC 212.1 09 and 212.123(a)]

b. The affected units are subject to 35 IAC 212.321 (a), which provides that no person shall cause or allow the em ission of particulate matter into the atmosphere in any one h our period from any new process emission unit which, either al one or in combination with the emissions of particulate matte r from all other similar new process emission units at a sourc e or premises, exceeds the allowable emission rates spec ified in 35 IAC 212.321(c).

2.1.4 Non-Applicability Provisions

This permit does not address the requirements of 35 IAC 215.301, Use of Organic Material, for emission units in the ammo nia plant as any direct emissions of organic material from such unit s are to be flared or otherwise combusted, which will assure co mpliance with the alternative standard of 35 IAC 215.302, providing a t least 85 percent control of emissions of organic material.

2.1.5-1 Operating Requirements

a. The annual production of ammonia by the ammonia plant shall not exceed the following limits:

i. Total production: 1,018,000 tons/year.

ii. Production for direct sale (stored): 255,000 t ons/year.

b. The total flow of pilot gas to each flare in the ammonia plant shall not exceed 14,500 scf/day, 30-day rolling ave rage.

2.1.5-2 Startup, Shutdown and Malfunction Plan

a. i. The Permittee shall develop, implement, and m aintain a

written Startup, Shutdown, and Malfunction Plan (SS M Plan) that describes, in detail, procedures for ope rating and maintaining the various emission units in the a mmonia plant during periods of startup, shutdown, and malfunction and a program of corrective action for malfunctioning equipment used to comply with the re levant emission standards and emission control requirement s. This SSM Plan shall be developed to satisfy the pur poses set forth in 40 CFR 63.6(e)(3)(i)(A), (B) and (C). In this regard, with respect to startups, this SSM Pla n shall address readily foreseeable startup scenarios

. With respect to malfunction, this SSM Plan shall id entify16 and address likely malfunction events with specific programs of corrective actions, and provide that up on occurrence of a malfunction that will result in a deviation, that the Permittee shall, as soon as practicable, repair the affected equipment or reduc e the operating rate of the plant so that the deviation c eases.

ii. For the purpose of this condition, the definiti ons of the terms “startup,” “shutdown” and “malfunction” under the NESHAP, at 40 CFR 63.2, shall apply and be used. I n addition, as related to the scope of the SSM Plan w ith respect to malfunctions, the plan shall also addres s and apply to failures of equipment that could reasonabl y be preventable and that may be attributable to poor maintenance or careless operation, and shall not be restricted to malfunctions as defined by 40 CFR 63. 2. Similarly, requirements for recordkeeping, notifica tion and reporting related to malfunctions shall be appl icable for failures of equipment irrespective of the cause of
such failure.

Note: Although the ammonia plant is not a major so urce of HAPs for purposes of Section 112 of the Clean Ai r Act, this permit refers to provisions of the federal NES HAP to establish appropriate work practices for the startu p, shutdown and malfunction of the ammonia plant.

b. The Permittee shall at all times, including peri ods of startup, shutdown, and malfunction as defined at 40 CFR 63.2 , operate and maintain the ammonia plant, in a manner consist ent with safety and good air pollution control practice for minimizing emissions to the levels required by the applicable standards and limits or comply with the applicable SSM Plan, as provided below. Determination of whether such operation and maintenance procedures are being used will be based on informat ion available to the Illinois EPA and USEPA, which may include, but is not limited to, monitoring results, review of op eration and maintenance procedures (including the SSM Plan), re view of operation and maintenance records, and inspection o f units. [Reflects 40 CFR 63.6(e)(1)(i)]

i. During periods of startup, shutdown, and malfunc tion of unit(s) in the ammonia plant, the Permittee shall o perate and maintain such unit(s), in accordance with the procedures specified in the SSM Plan. The Permitte e shall correct malfunctions as soon as practicable a fter
their occurrence in accordance with the SSM Plan. To the extent that an unexpected event arises during a sta rtup, shutdown, or malfunction, the Permittee shall compl y by minimizing emissions during such event consistent w ith safety and good air pollution control practice. [Reflects 40 CFR 63.6(e)(1)(ii) and (3)(ii)]

ii. When actions taken by the Permittee during a st artup, shutdown, or malfunction (including actions taken t o17 correct a malfunction) are consistent with the proc edures specified in the applicable SSM Plan, the Permittee shall keep records for that event which demonstrate that the procedures specified in the Plan were followed. In addition, the Permittee shall keep records of these events as specified in 40 CFR 63.10(b), including r ecords of the occurrence and duration of each startup, shu tdown, or malfunction of operation. Furthermore, the Perm ittee shall confirm in the periodic compliance report (re fer to Condition 2.1.10(b)) that actions taken during peri ods of startup, shutdown, and malfunction were consistent with the SSM Plan. [Reflects 40 CFR 63.6(e)(3)(iii)]

iii. If an action taken by the Permittee during a s tartup, shutdown, or malfunction (including an action taken to correct a malfunction) of unit(s) is not consistent with the procedures specified in the applicable SSM Plan , and the unit(s) exceeds a relevant emission standard or limit, then the Permittee must record the actions t aken for that event and must promptly report such action s as specified by 40 CFR 63.6(d)(5), unless otherwise specified elsewhere in this permit or when supersed ed in the Clean Air Act Permit Program (CAAPP) Permit for the plant. [Reflects 40 CFR 63.6(e)(3)(iv)]

c. i. The Permittee shall develop its initial SSM P lan prior to

the initial startup of the ammonia plant. The Perm ittee shall make changes to the SSM Plan if required by t he Illinois EPA or as necessary to satisfy the require ments of this permit or address other changes to procedur es for the ammonia plant. [Reflects 40 CFR 63.6(e)(3)(vii ) and (viii)]

ii. This SSM Plan is a record required by this perm it, which the Permittee must retain in accordance with the ge neral requirements for retention and availability of reco rds. In addition, when the Permittee revises the SSM Pla n, the
Permittee must also retain and make available the previous (i.e., superseded) versions of the SSM Pla n for a period of at least 5 years after such revision. [Reflects 40 CFR 63.6(e)(v) and 63.10(b)(1)]

2.1.5-3 Work Practices to Minimize Flaring

a. The work practices to minimize flaring conducted by the Permittee for the ammonia plant pursuant to Conditi on 2.1.2- 2(a)(ii)(B) shall include the preparation and maint enance of a Flare Minimization Plan (Plan) for the ammonia plan t that include the following:

i. Technical information for the ammonia plant, in cluding a general description of the ammonia plant, including process flow diagram(s) depicting all process units
, detailed process flow diagram(s) for the affected f lares, including process gas lines, knockout pots, surge d rums,18 seal drums, and other significant components of the

flares.

ii. A general description of the Permittee’s writt en procedures for the operation of the ammonia plant.

iii. A detailed description of the Permittee’s pro cedures for flaring due to the occurrence of malfunctions, as c aused by process upsets, equipment failures or other reas ons, including the provisions in these procedures that a ct to minimize flaring.

iv. A detailed description of the Permittee’s proc edures to minimize flaring in conjunction with the startup an d shutdown of equipment.

v. A general description of the Permittee’s proced ures for preventative maintenance of equipment in the ammoni a plant, including the provisions in these procedures that should act to minimize flaring.

vi. A description of the established responsibilit ies of different personnel at the ammonia plant for the operation and maintenance of the plant.

vii. A detailed description of the Permittee’s pro cedures for periodic evaluation of flaring activity generally a nd specific evaluation of flaring incidents, including identification of the causes of flaring, assessment of measures to eliminate or reduce such flaring, and implementation of feasible measures to reduce flari ng.

viii. An evaluation of preventative measures to re duce the occurrence and magnitude of flaring for the ammonia plant, including a schedule for the expeditious implementation of all feasible prevention measures to address the following, including consideration of p ast flaring activity as information for actual operatio n of the plant becomes available:

A. Flaring that could reasonably be expected to occ ur or has occurred during startup or shutdown.

B. Flaring that could reasonably be expected to occ ur or has occurred due to issues of ammonia quality.

C. Flaring caused by the recurrent failure of equip ment or a process to operate in a normal or usual manner

. The evaluation shall consider the adequacy of existing maintenance schedules and protocols for such equipment.

b. After the shakedown of the ammonia plant is comp lete, the Plan shall also include a description of additional proc edures or19 other measures that are installed or implemented to reduce flaring from the ammonia plant, which addresses the following:

i. Measures taken within the last five years to red uce flaring which shall specify the year of installatio n or implementation of each measure.

ii. Measures that are planned, which shall specify the year in which operation or implementation of each planne d
measure is scheduled.

c. i. The Permittee shall submit a copy of the init ial Plan to

the Illinois EPA for review and comments at least 9 0 days prior to initial startup of the ammonia plant.

ii. The Permittee shall review the Plan on at least an annual basis and revise the Plan so that it is kept curren t and reflects any changes in the operation of the ammoni a plant.

iii. The Permittee shall make changes to the Plan i f required by the Illinois EPA or USEPA to address an apparent deficiency identified in the Plan or as otherwise n eeded to address apparent or possible deficiencies in the Plan identified by the Permittee.

iv. This Plan is a record required by this permit, which the
Permittee must retain and make available in accorda nce with the general requirements for retention and availability of records. In addition, when the Per mittee revises the Plan, the Permittee must also retain an d make available the previous versions of the Plan for a p eriod of at least 5 years after such revision.

d. After the shakedown of the ammonia plant is comp lete, the Permittee shall also conduct an event-specific inve stigation or “Root-Cause Analysis” into each “Flaring Incident” (incident) at the ammonia plant to determine the causes of the incident, to take reasonable steps to correct the conditions that caused or contributed to such incident, and to further min imize emissions from flaring, as follows. For this purpo se, a “Flaring Incident” is defined as a flaring event (i .e., the flaring of process gas from the ammonia plant) that results in an unscheduled shutdown of the plant or flaring for more than
six hours.

i. A Root Cause Analysis for a Flaring Incident sha ll consist of a systematic investigation of the incide nt by identifying and assessing corrective measures that are available to prevent or reduce the likelihood of recurrence of a similar incident (including design, operation and maintenance changes), and developing a program of interim and long-term corrective actions , if any, as are consistent with good engineering practi ce, to
minimize the likelihood of a recurrence of the root cause20 and all contributing causes to the incident, with a schedule for implementation of such measures if not already completed.

ii. The Permittee shall submit a report to the Illi nois EPA for each Root Cause Analysis, which report shall in clude the following information:

A. Date, time and duration of the incident, and a description of the incident. To the extent that th e incident involved multiple releases within a 24-hou rperiod or within subsequent, contiguous nonoverlapping periods, the report shall set forth the date, start time and duration of each release.

B. The amount of process gas flared during the inci dent and the estimated actual emissions of NOx, CO, VOM,
PM, PM 10 /PM 2.5 , methane and CO 2 from the incident, with supporting data and calculations.

C. A detailed analysis that sets forth the root cau se and all contributing causes to the incident, to the
extent determinable.

D. An analysis of the measures, if any, that are
available to reduce the likelihood of a recurrence of an incident resulting from the same root cause o r contributing causes in the future, which analysis discusses and evaluates the alternatives, if any, that are available, including possible operation an d maintenance changes, the probable effectiveness of various alternatives, and the cost of the various
alternatives.

E. If the analysis concludes that corrective action s are required, a description of those actions and, i f not already completed, a schedule for their implementation, with planned commencement and completion dates of various actions.

F. If the analysis concludes that corrective action is not needed, an explanation of the basis for that
conclusion.

iii. A report for each such incident and investiga tion shall be submitted to the Illinois EPA within 45 days of the date of the incident. If the investigation is stil l underway on this date, the report shall include information for the investigation to that point and a statement of the anticipated date by which a comple te follow-up report will be submitted, with explanatio n why it is not yet practical to submit a complete report for the incident. Thereafter, the Permittee shall subm it follow-up report(s) for the incident at least every 4521 days until a complete final report is submitted for the
incident.

e. Planning and other activities conducted by the P ermittee pursuant to this Condition 2.1.5-3 may be combined with planning and activities conducted by the Permittee as part of the preparation and implementation of SSM Plan purs uant to Condition 2.1.5-2 provided that the requirements of this
condition are also met.

2.1.6 Emission Limits

a. The emissions from the ammonia plant shall not e xceed the following limits:

Pollutant Limit (tons/year)

CO 2 Vents Flares Total

NOx --- 15.1 15.1

CO 3.40 82.3 85.7

VOM 14.3 11.6 25.9

PM --- 0.15 0.15

PM 10 /PM 2.5 --- 0.15 0.15

SO 2 --- 0.13 0.13

Individual HAP* 2.40 --- 2.40

Total HAPs 2.43 --- 2.43 GHG 343,105 25,971 369,076

* The individual HAP that is anticipated to be emit ted in the greatest amount is methanol.

b. Notwithstanding the above, until the commissioni ng of the ammonia plant is complete or one year after initial startup of the ammonia plant, whichever occurs first, the GHG emissions of the ammonia plant, including both the CO 2 vents and the flares
shall not exceed the limit for total GHG emissions of the ammonia plant and the separate limits for GHG emiss ions of the

CO 2 vents and the flares shall not apply and the limit s for the flares for emissions of other pollutants shall appl y on a bimonthly basis rather than on an annual basis.

2.1.7 Operational Testing for the Affected Flares

a. Within 30 days of initial startup of the ammonia plant, the
Permittee shall:

i. Conduct observations for visible emissions from the flares in accordance with 40 CFR 60.18(f)(1) to ver ify compliance with 40 CFR 60.18(c)(1).

ii. Perform sampling and analysis of the heat conte nt of the process gas streams that are sent to each flare in accordance with 40 CFR 60.18(f)(3) to verify compli ance with 40 CFR 60.18(c)(3).22 b. Test notifications and test reports shall be sub mitted to the Illinois EPA in accordance with the Condition 3.1(b ) and (c).

2.1.8-1 Monitoring and Instrumentation for the Ammo nia Plant

a. The Permittee shall install, calibrate, maintain , and operate continuous monitoring systems to measure the gas fl ow through

each affected CO 2 vent (scf/hour). These monitoring systems shall be operated as specified by the relevant prov isions of the NSPS, 40 CFR 60.107a(f).

b. The Permittee shall install, operate and maintai n continuous monitoring systems for the ammonia plant to measure production of the ammonia plant (tons/hour), as follows:

i. Total production.

ii. Production sent to storage.

c. The Permittee shall operate instrumentation for key operating parameters of the ammonia plant, including:

i. Temperatures in the ammonia conversion reactor a nd the
methanation reactor.

ii. Flow of off-gas to the reformer furnace for use as fuel.

2.1.8-2 Operational Monitoring for the Affected Fla res

a. The Permittee shall install, operate and maintai n continuous monitoring systems on each affected flare for the t otal flow of process gas to the flare (scfm). These monitoring systems shall be operated as specified by the relevant prov isions of the NSPS, 40 CFR 60.107a(f).

b. The Permittee shall continuously monitor each af fected flare for the presence of a flare pilot flame using a the rmocouple or any other equivalent device to detect the presence of a flame, which monitoring shall be conducted as specified by 40 CFR 60.18(f)(2).

c. The Permittee shall install, operate and maintai n instrumentation on each affected flare for the usag e of pilot gas, in scfm. If this instrumentation is equipped with an automatic data recorder, measured data shall be rec orded on a daily average basis, as well on an hourly average b asis.

d. The Permittee shall monitor the liquid level and pressure of

the knockout or seal drum that serves each affected flare.

e. The Permittee shall develop and maintain written monitoring procedures for each affected flare addressing the r equired operational monitoring systems for each flare and a ssociated equipment, which shall include the following inform ation. A23 copy of these procedures shall be submitted to the Illinois EPA for review prior to the initial startup of the ammo nia plant.

i. A process flow diagram of the affected flare and associated equipment as related to flaring, identif ying major components, such as the header, stack, burner (s), purge gas system, pilot gas system, ignition system
, assist system, and liquid seal for the flare and th e process gas lines.

ii. Drawing(s), with dimensions, showing the sampli ng location(s) at which sampling or monitoring is cond ucted, accompanied by an explanation of the methods used t o select these sampling locations for sampling of fla re process gas, flow of flare process gas and pilot ga s; on/off flow indicators; operating parameters of the liquid seal; and operating parameters of the ammoni a plant that could provide credible information on th e occurrence or nature of flaring.

iii. The type, make, and model of each monitoring d evice or instrument used for required monitoring, with a description of manufacturer’s specifications for th e device, including but not limited to range, precisi on, accuracy, calibration, and recommended procedures f or quality control, quality assurance and maintenance.

iv. A description of the data collection and record ing device(s) used to store data collected by required monitoring systems.

v. A description of the periods when visual observa tion(s) would be conducted to verify flame stability, as pr ovided for by Condition 2.1.2-2(b)(ii), and the Permittee’ s protocols and procedures for these observations.

vi. A description of the low flow operating conditi ons for the flare during which flow rates of process gas wo uld be determined by engineering analysis, rather than by monitoring, if any, including an explanation why mo nitors would not provide reliable data during such conditi ons and the types of engineering analysis that would be used in place of monitoring.

2.1.8-3 Sampling and Analysis of Process Gas Stream s in the Ammonia Plant

a. The Permittee shall take representative samples of the CO 2 stream from the regenerator that is emitted through the

affected CO 2 vents and other gas streams in the ammonia plant

that are or could be vented to the affected flares during startup, shutdown or malfunctions. The Permittee s hall have these samples analyzed using applicable ASTM method s for CO, VOM, methane, CO 2 and HAP content. The process gas streams shall also be analyzed for heating value, in accord ance with 40 CFR 60.18(f)(3).24 b. This activity shall be conducted:

i. Within 15 days after achieving the maximum produ ction rate at which the ammonia plant will be operated bu t not later than 30 days after initial startup of the amm onia plant.

ii. On a periodic basis thereafter, as follows:

A. For the CO 2 stream from the regenerator, on at least a monthly basis.

B. For gas streams in the ammonia plant that are o r could be vented to the flares, on at least a monthly basi s during the first year (12 months) of operation of the ammonia plant and on a quarterly basis thereafter.

iii. Within 90 days of a written request from the I llinois EPA, for process streams as specified in the request.

c. The Permittee shall maintain records for this sa mpling and analysis activity.

2.1.9-1 Recordkeeping Requirements for the Affected CO 2 Vents

a. The Permittee shall keep records related to the GHG emissions

of the affected CO 2 vents as would be required by 40 CFR 98 Subpart PP, including records for emissions in tons /day, tons/month and tons/year.

b. The Permittee shall keep the following records r elated to the
emissions of HAPs from each affected CO 2 vent:

i. A file containing the emission factors that the Permittee uses to calculate emissions, with supporting
documentation.

ii. Total monthly and annual emissions, based on op erating data and applicable emission factors, with supporti ng calculations.

2.1.9-2 Recordkeeping Requirements for the Affected Flares

a. The Permittee shall maintain a file or other rec ord for each affected flare containing the design destruction ef ficiencies of the flare for CO, VOM, and methane and the desig n emission rates of the pilot burners for NOx and CO, with sup porting
documentation.

b. The Permittee shall maintain an operating log or other similar records for the ammonia plant that includes the inf ormation specified in Condition 3.2(a) and the following det ailed
information:25 i. For each startup, the nature of the startup, the timing of major steps in the startup, any unusual occurren ces during the startup, and any deviations from the established startup procedures, with explanation.

ii. For each shutdown, the nature and reason for th e shutdown, the timing of major steps in the shutdown , any unusual occurrences during the shutdown, and any deviations from the established shutdown procedures , with explanation.

c. The Permittee shall keep the following operating records for each event when process gas was flared:

i. Date, time and duration of flaring.

ii. Description of the event, including the flare(s ) involved in the event and a discussion of the cause(s) and probable cause(s) of the event.

iii. Confirmation that established operating proced ures were followed.

iv. Confirmation that the flare(s) functioned prope rly, i.e., a flame was present and any visible emissions that occurred were as specified in 40 CFR 60.18(f)(1).

v. The amount and nature of the process gas sent to the flare(s).

vi. The amount of CO and VOM contained in the gas s ent to the flare(s) and the amount of CO and VOM emitted, pounds/event, with supporting calculations.

vii. Actions taken during the event to minimize emi ssions.

viii. A description of any actions taken to prevent or reduce
the likelihood of similar future occurrences.

d. The Permittee shall keep the following records r elated to emissions of NOx, CO, VOM, PM, PM 10 /PM 2.5 , SO 2 , HAPs and GHG from

each affected flare:

i. A file containing the emission factors that the Permittee uses to calculate emissions of each pollutant, with supporting documentation.

ii. Total daily, monthly and annual emissions of ea ch pollutant from the flare, based on operating data a nd applicable emission factors, with supporting
calculations.

e. The Permittee shall keep records for any deviati ons from applicable requirements involving the affected flar es, which records shall include the information specified by Condition26 3.3. These records may be combined with other reco rds required for the ammonia plant by this permit.

f. The Permittee shall maintain inspection, mainten ance and repair log(s) or other similar records for the affected fl ares that, at a minimum, include the information specified in Condition 3.2(b) and identify any occasion when the Permittee was unable to carry out its established maintenance procedures , with explanation.

2.1.9-3 Recordkeeping Requirements for the Ammonia Manufacturing Process

a. Beginning 12 months after the initial startup of the ammonia plant, the Permittee shall keep the following recor ds to show compliance with the limit in Condition 2.1.2-3 for the ammonia manufacturing process (i.e., the combination of the affected

CO 2 vents, the reformer furnace (Section 2.2) and the boiler (Section 2.3)) for GHG emissions, for each 12 conse cutive months of operation in which ammonia is produced:

i. Total emissions (tons).

ii. Average emission rate (tons per ton of ammonia produced).

iii. The applicable BACT limit for GHG, calculated in accordance with Condition 2.1.2-3 (tons per ton of ammonia produced), with supporting calculations.

2.1.10 Reporting Requirements

a. The Permittee shall promptly notify the Illinois EPA of deviations of unit(s) in the ammonia plant with per mit requirements as follows. Reports shall include the information specified by Condition 3.4:

i. Failure of an affected flare, e.g., loss of comb ustion, when operation continues for more than 1 hour (60 minutes) shall be reported to the Illinois EPA’s re gional office by telephone as soon as possible during norm al working hours, but no later than three days.

ii. The deviations addressed above and all other de viations shall be reported in the quarterly compliance repor ts required by Condition 2.1.10(b).

b. The Permittee shall submit quarterly compliance reports for the ammonia plant. The reports shall be submitted no l ater than 30 days after the end of each quarterly reporting peri od.

i. Information related to excess emissions and devi ations during the reporting period, if any. When no exces s emissions or deviations have occurred or the contin uous emissions monitoring system(s) have not been inoper ative, repaired, or adjusted, such information shall be st ated in the report.27 ii. A summary of operation and emissions of the amm onia plant during the reporting period, including the total nu mber of startups of the plant, the amount of ammonia pro duced by the plant, the amount of ammonia sent to storage , and the emissions of NOx, CO, PM, PM 10 /PM 2.5 , VOM, and GHG during the reporting period (tons).

iii. A listing of each flaring event during the rep orting period, i.e., each period when process gas was flar ed, with date and duration, a description of the event, incl uding cause(s), and whether an event-specific Root Cause Analysis was performed for the event pursuant to Condition 2 .1.5- 3(d).

c. With its Annual Emission Report, the Permittee s hall submit a report to the Illinois EPA for flaring during the p revious year, which report shall:

i. Provide the information specified in Condition 2.1.10(b)(iii) for flaring events during the previo us

year.

ii. Summarize flaring activity and emissions during the previous year, including an assessment of the cause (s) for such flaring as related to the number of events and share of emissions, a summary of each event-specifi c Root Cause Analysis was performed, and emissions of the flares as compared to the limits in Condition 2.1.6(a).

iii. Include copies of the summaries for flaring ac tivity for the preceding two years as required by Condition 2.1.10(c)(ii), as reported in earlier reports, as t hese
summaries become available.

iv. Summarize actions or measures implemented durin g the previous year to reduce flaring pursuant to the Roo t Cause Analyses required by Condition 2.1.5-3(d), an d the observed effect of these actions, and the actions o r measures planned for implementation during the curr ent year to reduce flaring pursuant to Root Cause Analy ses, and the expected effect of these actions.

v. Summarize other actions or measures implemented during the previous year to reduce flaring, not related to the required Root Cause Analyses, and the reason for an d observed effect of these actions, and other actions or measures planned for implementation during the curr ent year to reduce flaring, and the reason for and expe cted
effect of these actions.

vi. Include a listing of changes, if any, made to t he Flare Minimization Plan, as provided for by Conditions 2. 1.5- 3(c)(ii) and (iii), with a brief description.28 vii. Include a listing of significant changes, if a ny, made to the monitoring procedures required by Condition 2.1 .8- 2(e), with brief description.

viii. Provide confirmation that the required annual verification of the accuracy of the flow monitoring system was conducted, with a summary of results.

d. The Permittee shall submit the following additio nal reports for the ammonia plant during the shakedown period and t he year following the shakedown period:

i. The Permittee shall provide the Illinois EPA wit h notice at least 15 days prior to initial startup of the am monia plant.

ii. During the shakedown period for the ammonia pla nt , the Permittee shall promptly notify the Illinois EPA of any event(s) that disrupts orderly shakedown of the fac ility.

iii. During the shakedown period for the ammonia pl ant, the periodic compliance reports required by Condition 2.1.10(b) shall also include the following informat ion:

A. Operating data for the ammonia plant, i.e., tota l operating hours and ammonia production during the reporting period.

B. Activities accomplished and significant events related to emissions of the ammonia plant.

C. Current schedule for emission testing.

D. A summary of any required emissions testing that was conducted or notice that all such testing has been completed.

E. When applicable, notice that shakedown of the ammonia plant is considered complete.

e. The Permittee shall notify the Illinois EPA with in 30 days of the date that commissioning of the ammonia plant is complete,
if this date is different than the date that shaked own of the ammonia plant is complete, with explanation for the different

date.

2.1.11 Revision of the BACT Limit for GHG Emissions Based on Actual

Performance of the Facility

a. i. The values for R

u and R
a used in the GHG emission limit

for the facility in Condition 2.1.2-3(a) shall be l owered based on actual operation and emissions of the faci lity
unless the Permittee demonstrates and the Illinois EPA concurs, based on an evaluation as provided pursuan t Condition 2.1.11(b), that the limit that would resu lt29 could not be reliably met without unacceptable consequences, i.e., inability to comply with other emission limits or requirements or significant risk to equipment or personnel, and without unreasonable consequences, i.e., a significant increase in maint enance and repair needed for the facility.

ii. This permit will be revised to set lower values for R
u and R
a that the Illinois EPA finds, after considering actual operation of the facility and the evaluation performed by the Permittee, that the facility can a nd should be able to consistently comply with a limit that uses such values without unreasonable consequences.

b. i. The Permittee shall perform an evaluation for GHG

emissions in accordance with a plan submitted to th e Illinois EPA for review and comment. The initial p lan
shall be submitted to the Illinois EPA no later tha n one year after initial start-up of the facility.

ii. Beginning one year after submittal of this plan
, continuing until the final report for this evaluati on is submitted, the Permittee shall submit an annual pro gress report for this evaluation. This report shall incl ude information describing the status of the ammonia manufacturing process, including actions that have been carried out or are still planned to improve the ene rgy efficiency of the process and reduce GHG emissions and any circumstances that acted to result in higher th an normal GHG emissions, with description and explanat ion. This report shall also include data for the GHG emi ssion rate of the ammonia manufacturing process (tons per ton of ammonia) and the values of Ru and Ra that were achieved on a monthly basis and on an annual basis (running total of 12 months of data).

iii. A. This evaluation shall be completed and a de tailed report submitted to the Illinois EPA within three y ears after the date that commissioning of the facility i s complete or four years after initial startup, which ever occurs first. This report shall include proposed
alternative values for Ru and Ra.

B. The Illinois EPA may extend this deadline for up to an additional two years if the Permittee submits a progress report demonstrating the need for additional data to effectively set revised values

for R
u and R
a .

iv. The submittal by the Permittee of the final rep ort for
this evaluation shall constitute submittal of an application to the Illinois EPA for a revised permi t for the purpose of implementation of Condition 2.1.11(a ).30

SECTION 2.2: UNIT-SPECIFIC CONDITIONS FOR THE REFO RMER FURNACE

2.2.1 Description

The reformer furnace (the affected reformer) is a p rocess heater used in the production of hydrogen for the manufact ure of ammonia. In the reformer furnace, steam from the boiler (see Section 2.3) and pre-treated natural gas are catalytically converted to an intermediate stream that is composed primarily of h ydrogen and
carbon monoxide. The fuel fired in the reformer fu rnace is a combination of natural gas and process off-gases fr om the ammonia plant. The reformer will be equipped with a select ive catalytic reduction (SCR) system for control of its emissions of nitrogen oxide (NOx).

2.2.2 Control Technology Determination – BACT

a. i. The affected reformer shall be operated and m aintained in

conformance with the manufacturer’s design, which s hall include the following features:

A. Low-NOx burners and selective catalytic reductio n.

B. Automated combustion management, with an oxygen trim
system.

ii. The affected reformer shall be operated and mai ntained in accordance with good combustion practices.

b. The emissions of the affected reformer shall not exceed the following limits, in lbs/mmBtu:

Pollutant Limit NOx 0.0109, 30-day average, rolled daily CO 0.020, 30-day average, rolled daily

PM 0.0019, 3-hour average

PM 10 /PM 2.5 0.0024, 3-hour average VOM 0.0054, 3-hour average

Note: The GHG emissions of the affected reformer a re addressed by the BACT limit for GHG in Condition 2.1.2-3.

2.2.3 Applicable Emission Standards

The affected reformer is subject to the following s tate standards:

a. The emission of smoke or other particulate matte r shall not have an opacity greater than 20 percent, 6 minute a verage, except as allowed by 35 IAC 212.122(b) or 212.124. [35 IAC 212.109 and 212.122(a)]

b. CO emissions shall not exceed 200 ppm, corrected to 50 percent excess air. [35 IAC 216.121]31 Note: There are no federal emission standards unde r 40 CFR Parts 60 or 63 that apply to the affected reformer.

2.2.4 Non-Applicability Provisions

a. The affected reformer is not subject to the NSPS , 40 CFR 60 Subpart Db, because it is a “process heater” and no t a “steam generating unit” as defined by 40 CFR 60.41b.

b. The affected reformer is not subject to the NESH AP for Industrial, Commercial and Institutional Boilers at Area Sources, 40 CFR 63 Subpart JJJJJJ, because it is a process heater.

2.2.5 Operational Requirements, Work Practices and Production Limits

a. The nominal rated heat input capacity of the aff ected reformer shall not exceed 955 mmBtu/hour.

b. The only fuels combusted in the affected reforme r shall be natural gas and process off-gas from the ammonia pl ant.

c. For purposes of Condition 1.6, which generally r equires implementation of good air pollution control practi ce, the Permittee shall operate and maintain the affected r eformer and associated SCR system in accordance with written pr ocedures developed and maintained by the Permittee. These p rocedures may incorporate the manufacturer’s recommendations for operation and maintenance of the SCR system.

2.2.6 Emission Limits

a. The emissions of the affected reformer shall not exceed the following limits.

Pollutant Limit Pounds/Hour Tons/Year

NOx 10.4 45.6

CO 41.0 83.6

PM 1.81 7.9

PM 10 /PM 2.5 2.3 10.0

VOM 5.2 22.6

SO 2 --- 2.5

Hexane 0.10 0.44

Other Individual HAP* 0.7 3.0

Total HAP 1.0 4.3 GHG --- 488,159

* The individual HAP that is anticipated to be emit ted in the greatest amount is formaldehyde.32

2.2.7 Emission Testing Requirements

a. The Permittee shall have emissions testing perfo rmed for the affected reformer as follows at its expense by a qu alified testing service while the affected reformer is oper ating at maximum rates and under other representative operat ing
conditions:

i. Emissions testing shall be conducted for emissio ns of filterable PM, filterable PM 10 and PM 2.5 , condensable PM, VOM, hexane, methane, N 2 O and HAP as specified below, provided, however, that if the Permittee considers all
filterable PM 10 emissions to be emissions of filterable

PM 2.5 , testing for emissions of filterable PM 2.5 need not be performed unless specifically requested by the
Illinois EPA.

Note: Specific requirements for periodic emission testing may be established in the CAAPP permit for the facility.

ii. This testing shall be conducted as follows:

A. Within one year after initial startup of the reformer or 120 days after achieving the maximum production rate at which the reformer will be operated, whichever occurs first.

B. On a periodic basis thereafter, with testing conducted within at least five years from the date of the previous test.

C. In addition, the Permittee shall perform emissio n tests as provided below as requested by the Illinoi s EPA within 90 days of a written request by the Illinois EPA or such later date agreed to by the
Illinois EPA.

iii. Appropriate USEPA test methods, including the following methods, shall be used for testing, unless other me thods adopted by or being developed by USEPA or other alternative test methods are approved by the Illino is

EPA.

Filterable PM Method 5 or 5I
Filterable PM 10 & PM 2.5 Method 5I or 201A
Condensable PM Method 202
VOM Method 25A

N 2 O and Methane Method 320
Hexane Method 320
HAPs Method 320

c. i. Test plans, test notifications, and test repo rts shall be

submitted to the Illinois EPA in accordance with th e Condition 3.1.33 ii. In addition to other information required in a test report, test reports shall include detailed informa tion on the operating conditions of the affected reforme r during testing, including:

A. Firing rates, total and for natural gas, (mmBtu/ hour).

B. Oxygen content in the flue gas and other signifi cant operating parameters of the reformer.

C. Opacity of the exhaust, 6-minute averages, as determined by Method 9, if visible emissions, as determined by Method 22, are typically present during the operation of the reformer.

2.2.8-1 Emission Monitoring Requirements

a. For the affected reformer, the Permittee shall i nstall, calibrate, operate and maintain CEMS for NOx and CO emissions
and the concentration of CO 2 or O 2 in the exhaust.

i. The procedures under 40 CFR 60.13 shall be follo wed for installation, evaluation, and operation of these CE MS. This CEMS shall be operated during all periods of operation of the affected units except for CEMS breakdowns and repairs.

ii. The relevant provisions for monitoring NOx emis sions in the NSPS, 40 CFR 60.48b shall be followed for the N Ox CEMS. The relevant provisions of 40 CFR 60.48b(j)(4 )
shall be followed for the CO CEMS until and unless USEPA adopts procedures that would be directly applicable for continuous monitoring of CO emissions from this uni t.

iii. The 1-hour average NOx and CO emission rates m easured by the CEMS shall be expressed in lbs/mmBtu heat input and shall be used to calculate average emission rates. The 1-hour averages shall be calculated using data poin ts as provided for by 40 CFR 60.13(h)(2), except as provi ded by 40 CFR 60.48b(b)(2).

iv. These CEMS shall also be used to determine comp liance with the NOx and CO limits in Conditions 2.2.2(b), 2.2.3(b) and 2.2.6.

b. For the affected reformer, the Permittee shall i nstall, certify, operate and maintain a CEMS for CO 2 emissions. This CEMS shall be operated in accordance with applicabl e requirements of 40 CFR 75, including 40 CFR 75.10(a )(3).34

2.2.8-2 Operational Monitoring and Instrumentation Requirements

a. The Permittee shall install, calibrate, operate and maintain a continuous operational monitoring system for the af fected reformer for fuel consumption (scf/hour).

b. i. The Permittee shall equip, operate, and maint ain

instrumentation on the SCR system for the affected reformer for the SCR reagent injection rate, flue g as temperature at the inlet of the SCR catalyst and ot her operating parameters of the SCR system that are rel evant
to effective control of emissions.

ii. The Permittee shall maintain the records of the data from this instrumentation at least once per shift.

2.2.8-3 Opacity Observations

The Permittee shall perform opacity observations fo r the affected
reformer in accordance with Method 9 on at least an annual basis if visible emissions are normally present, as determin ed by Method 22.

2.2.9 Recordkeeping Requirements

a. The Permittee shall maintain a file that contain s the following
information for the affected reformer:

i. A record of the maximum design heat input capaci ty of the reformer, in mmBtu/hour, with supporting documentat ion.

ii. The Permittee’s established operating and maint enance procedures for the reformer.

iii. Records for all opacity measurements made in a ccordance
with USEPA Method 9 for the affected reformer that it conducts or that are conducted on its behest by individuals who are qualified to make such observat ions.
For each occasion on which such measurements are ma de, these records shall include the formal report for t he measurements if conducted pursuant to Condition 2.2 .8-3, or otherwise the identity of the observer, a descri ption of the measurements that were made, the operating condition of the affected reformer, the observed op acity, and copies of the raw data sheets for the measureme nts.

b. The Permittee shall maintain records for the amo unt of off-gas fired in the affected reformer (scf/month).

c. The Permittee shall maintain an operating log or other similar
records for the affected reformer that include the information specified in Condition 3.2(a) and the following inf ormation:

i. For each startup of the reformer, identification or any deviations from the normal startup procedures, as s et35 forth in the Permittee’s written operating procedur es, with explanation.

ii. For each shutdown of the reformer, the nature a nd reason for the shutdown, any unusual occurrences during th e shutdown, and any deviations from the normal shutdo wn procedures, as set forth in the Permittee’s written operating procedures, with explanation.

d. The Permittee shall keep the following records f or the SCR system:

i. A file containing the design NOx emission rates of the SCR system with supporting documentation, and manufacturer, vendor or source-specific operating a nd maintenance procedures, including a catalyst manage ment plan.

ii. Usage of SCR reagent on a monthly basis.

e. The Permittee shall maintain records of the foll owing
information for NOx and CO emissions from the affec ted reformer for each operating day:

i. Calendar date.

ii. The measured average hourly emission rates (exp ressed in lbs/mmBtu and lbs/hour).

iii. The 30-day average emission rates (lbs/mmBtu a nd lbs/hour) calculated at the end of each operating d ay from the measured hourly emission rates for the pre ceding 30 unit operating days.

iv. Identification of the operating days when the c alculated 30-day average emission rates are in excess of an applicable standard or limit, with the reasons for such excess emissions as well as a description of correc tive
actions taken.

v. Identification of the operating days in which NO x or CO emission data have not been obtained, including a description of corrective actions taken.

vi. Identification of the times when NOx or CO emis sion data have been excluded from the calculation of average emission rates and the reasons for excluding data.

vii. Identification of “F” factor used for calculat ions and
the method of determination.

viii. Identification of the times when the concentr ation of NOx or CO exceeded full span of the CEMS.36 ix. Description of any modifications to the CEMS th at could affect the ability of the CEMS to comply with Perfo rmance Specification 2 or 3.

x. Results of daily CEMS drift tests and quarterly accuracy assessments as required by 40 CFR Part 60 Appendix F,
Procedure 1.

f. The Permittee shall keep inspection, maintenance and repair logs or other similar records for the affected refo rmer and associated SCR system that contain the information specified in Condition 3.2(b), including information related to management of catalyst in the SCR system (e.g., replacement of catalyst).

g. The Permittee shall keep the following records r elated to the emissions of NOx, CO, PM, PM 10 /PM 2.5 , VOM, SO 2 , GHG, hexane, other individual HAP, and total HAPs from the affec ted

reformer:

i. If continuous monitoring is performed for a poll utant, the emissions of the pollutant from the affected re former based on continuous emissions monitoring data, in tons/month and tons/year.

ii. If continuous monitoring is not performed for a pollutant:

A. A file containing the emission factors that it u ses to calculate emissions, with supporting documentation; and

B. The emissions of the affected reformer based on operating data and applicable emission factors (tons/month and tons/year), with supporting

calculations.

2.2.10 Notification and Reporting Requirements

a. The Permittee shall promptly notify the Illinois EPA of any deviations from the requirements of this permit for the
affected reformer as follows. These notifications shall include the information specified by Condition 3.4.

i. Deviations from the NOx and CO limits in Conditi ons 2.2.2, 2.2.3 and 2.2.6 shall be reported with the r eports required by Condition 2.2.10(b).

ii. Other deviations shall be reported within 30 da ys and include a description of the incident, a discussion of the probable cause of such deviation, a description of the corrective actions taken, and a description of the preventative measures taken.

b. The Permittee shall submit periodic compliance r eports to the Illinois EPA for the affected reformer, which repor ts shall37 include the following information. These reports s hall be submitted on a semi-annual basis, with each report submitted no later than 30 days following the end of the reporti ng period:

i. Information related to excess emissions and devi ations:

A. As related to the limits for NO

x and CO emission, the information required for reporting of exceedances under 40 CFR 60.7(c) or (d) and 60.49b(h) and (j). If there are no such exceedances during the reporting period, the report shall state that no exceedances occurred during the reporting period.

B. Information for other deviations during the reporting period, if any.

C. When no excess emissions or deviations have occu rred or the CEMS have not been inoperative, repaired, or adjusted, such information shall be stated in the
report.38

SECTION 2.3: UNIT-SPECIFIC CONDITIONS FOR THE BOIL ER

2.3.1 Description

The boiler (the affected boiler) will supply steam to the reformer for production of hydrogen. The boiler will fire n atural gas.

2.3.2 Control Technology Determination - BACT

a. i. The affected boiler shall be operated and mai ntained in

conformance with the manufacturer’s design, which s hall include the following features:

A. Low-NOx burners and selective catalytic reductio n (SCR) or equivalent (see Condition 2.3.10(d)).

B. An automated combustion management system, with oxygen trim system.

C. Air preheater and automated blowdown management control system.

ii. The affected boiler shall be operated and maint ained in accordance with good combustion practices.

b. The emissions of the affected boiler shall not e xceed the following limits, in lbs/mmBtu:

Pollutant Limit NOx 0.0120, 30-day, rolled daily CO 0.020, 30-day, rolled daily

PM 0.0019, 3-hour

PM 10 0.0024, 3-hour

PM 2.5 0.0010, 3-hour VOM 0.0054, 3-hour

Note: The BACT limit for GHG in Condition 2.1.2-3 addresses
the GHG emissions of the affected boiler.

2.3.3-1 Applicable Federal Emission Standards

a. The affected boiler is an affected facility unde r the federal
NSPS for Industrial-Commercial-Institutional Steam Generating Units, 40 CFR 60 Subpart Db. For the affected boil er, the Permittee must comply with applicable requirements of this NSPS and applicable requirements of 40 CFR 60 Subpart A, General
Provisions.

b. The NOx emissions of the affected boiler shall n ot exceed 86 ng/J (0.20 lb/million Btu) on a 30-day rolling aver age, pursuant to 40 CFR 60.44b(a),on and after the date on which the initial performance test is completed or is require d to be completed under 40 CFR 60.8, whichever date comes f irst.39 c. Pursuant to the NSPS, 40 CFR 60.11(d), at all ti mes the Permittee shall, to the extent practicable, maintai n and operate the affected boiler in a manner consistent with good air pollution control practice for minimizing emiss ions.

2.3.3-2 Applicable State Emission Standards

The affected boiler is subject to the following sta te standards:

a. The emission of smoke or other particulate matte r shall not have an opacity greater than 20 percent, 6-minute a verage, except as allowed by 35 IAC 212.122(b) or 212.124. [35 IAC 212.109 and 212.122(a)]

b. CO emissions shall not exceed 200 ppm, corrected to 50 percent excess air. [35 IAC 216.121]

2.3.4 Non-Applicability Provisions

a. The affected boiler is not subject to the Title IV (i.e., Acid Rain) provisions of the federal Clean Air Act since it does not qualify as a utility unit or an electrical generati ng unit for the purpose of the Acid Rain program.

b. The affected boiler is not subject to the NSPS, 40 CFR 60 Subpart Da, because it does not meet the definition of an “electric utility steam generating unit” in 40 CFR 60.41Da.

c. This permit is issued based on certain provision s of the NSPS, 40 CFR 60 Subpart Db, as follows, not being applica ble to the
affected boiler:

i. The limits of this NSPS for PM and opacity, beca use this boiler only burns natural gas.

ii. The SO 2 standards of this NSPS because this boiler only fires fuel with a potential SO2 emission rate of 0. 32 lb/mmBtu heat input or less. [40 CFR 60.42b(k)(2), 60.47b(f) and 60.49b(r)]

iii. The opacity monitoring requirements of this NS PS, 40 CFR 60.48b, because this boiler only burns gaseous fuel s, without post-combustion technology to reduce SO2 or PM emissions. [40 CFR 60.48b(j)(2)]

d. The affected boiler is not subject to any requir ements of the NSPS, 40 CFR 60 Subpart D, because it is subject to the NSPS, 40 CFR 60 Subpart Db. [40 CFR 60.40b(j)]

e. The affected boiler is not subject to the NESHAP for Industrial, Commercial, and Institutional Boilers a t Area Sources, 40 CFR 63 Subpart JJJJJJ, because the affe cted boiler meets the definition of a gas-fired unit. [40 CFR 63.11195(e)]40

2.3.5 Operational Requirements, Work Practices and Production Limits

a. The nominal rated heat input capacity of the aff ected boiler shall not exceed 864 mmBtu/hour.

b. The only fuel fired in the affected boiler shall be natural

gas.

c. The steam from the affected boiler shall not be used to produce electricity for commercial sale to the grid.

d. For purposes of Condition 1.6, which generally r equires implementation of good air pollution control practi ce, if the affected boiler is equipped with an SCR system, the Permittee shall operate and maintain the affected boiler and associated SCR system in accordance with written procedures de veloped and maintained by the Permittee. These procedures may incorporate the manufacturer’s recommendations for operation an d maintenance of the SCR system.

2.3.6 Emission Limits

a. The emissions of the affected boiler shall not e xceed the following limits.

Pollutant Limits Pounds/Hour Tons/Year

NOx 17.28 45.4

CO 31.1 75.7

PM 1.64 7.20

PM 10 2.11 9.10

PM 2.5 0.88 3.90

VOM 4.67 20.4

SO 2 --- 2.23

Individual HAP* 1.52 6.70

Total HAP 1.60 7.00

GHG --- 442,339

* The individual HAP that is anticipated to be emit ted in the greatest amount is n-hexane.

2.3.7 Emission Testing Requirements

a. The Permittee shall conduct performance testing for the affected boiler for emissions of NOx as required un der the NSPS, including 40 CFR 60.8 and 60.46b(e).

b. The Permittee shall have emissions testing condu cted for the affected boiler as follows, at its expense by a qua lified testing service under representative operating cond itions, for emissions of PM, filterable PM 10 and PM 2.5 , condensable PM, VOM, formaldehyde, hexane, methane and N 2 0 provided, however, that
if the Permittee considers all filterable PM 10 emissions to be
emissions of filterable PM 2.5 , testing for emissions of41 filterable PM 2.5 need not be performed unless specifically requested by the Illinois EPA.

i. The timing of testing shall be as follows:

A. Testing shall initially be conducted within 60 d ays after achieving the maximum rate at which the boile r will be operated but not later than 365 days after initial startup of the boiler.

B. On a periodic basis thereafter, with testing conducted within at least five years from the date of the previous test.

C. In addition, the Permittee shall have testing performed as requested by the Illinois EPA for the affected boiler within 45 days of a written request by the Illinois EPA or such later date agreed to by
the Illinois EPA.

ii. Appropriate USEPA test methods, including the f ollowing methods, shall be used for testing, unless other me thods adopted by or being developed by USEPA or other alternative test methods are approved by the Illino is

EPA.

Filterable PM Method 5 or 5I or 201A
Filterable PM 10 /PM 2.5 Method 5I or 201A
Condensable PM Method 202
VOM Method 18 or 25A

N 2 O and methane Method 320
Hexane Method 320
HAPs Method 320

c. i. Test plans, test notifications, and test repo rts shall be

submitted to the Illinois EPA in accordance with th e Condition 3.1.

ii. In addition to other information required in a test report, test reports shall include detailed informa tion on the operating conditions of the affected boiler during testing, including:

A. Fuel consumption (scf);

B. Firing rate (mmBtu/hour) and other significant operating parameters of the affected boiler;

C. Opacity of the exhaust, 6-minute averages, as determined by USEPA Method 9, if visible emissions are normally present, as determined by Method 22.42

2.3.8-1 Emissions Monitoring Requirements

a. Pursuant to 40 CFR 60.48b, for the affected boil er, the Permittee shall install, calibrate, operate and mai ntain a CEMS for NOx emissions discharged from the affected boil er and the
concentration of CO 2 or O 2 in the exhaust.

i. The procedures under 40 CFR 60.13 shall be follo wed for installation, evaluation, and operation of these CE MS. This CEMS shall be operated during all periods of operation of the affected boiler except for CEMS breakdowns and repairs. This CEMS shall obtain emi ssion data for at least 75 percent of the operating hours in at least 22 out of 30 successive units operating days as specified and pursuant to 40 CFR 60.48b(f). Data i s to be obtained in the scheduling and course of perform ing calibration checks, and zero and span adjustments a s specified in the NSPS.*

* Fulfillment of the above criteria for availabilit y of emission data from the CEMS does not shield the Permittee from potential enforcement for failure to properly maintain and operate the CEMS.

ii. The 1-hour average NOx emission rates measured by the CEMS shall be expressed in lbs/mmBtu heat input and shall be used to calculate average emission rates pursuan t to the NSPS. The 1-hour averages shall be calculated using the data points required under 40 CFR 60.13(h)(2), except as allowed under 60.48b(b)(2).

iii. This CEMS shall also be used to determine comp liance with the NOx limits in Conditions 2.3.3-1(b), 2.3.2(b) a nd 2.3.6(a).

b. The Permittee shall install, calibrate, operate and maintain CEMS for measuring CO emissions from the affected b oiler.

i. The relevant monitoring procedures in 40 CFR 60. 48b(j)(4)
shall be followed for these CEMS until and unless U SEPA adopts procedures that would be directly applicable for continuous monitoring of CO emissions from the boil er.

ii. This CEMS shall be used to determine compliance with the CO limitations in Conditions in 2.3.2(b), 2.3.3-2(b ) and 2.3.6(a).

2.3.8-2 Operational Monitoring and Instrumentation Requirements

a. The Permittee shall install, calibrate, operate and maintain continuous operational monitoring systems for the a ffected boiler for fuel usage, scf/hour.

b. i. If the boiler is equipped with an SCR system, the

Permittee shall equip, operate, and maintain43 instrumentation on the SCR system for the affected reformer for the SCR reagent injection rate, flue g as temperature at the inlet of the SCR catalyst and ot her operating parameters of the SCR system that are rel evant
to effective control of emissions.

ii. The Permittee shall maintain the records of the data from this instrumentation at least once per shift.

2.3.8-3 Opacity Observations

a. The Permittee shall perform opacity observations for the affected
boiler in accordance with Method 9 on at least an a nnual basis if visible emissions are normally present, as determin ed by Method
22.

2.3.9 Recordkeeping Requirements

a. The Permittee shall maintain a file or other rec ord containing the following information for the affected boiler:

i. The maximum design heat input capacity of the af fected boiler, mmBtu/hour, with supporting documentation.

ii. The Permittee’s established operating and maint enance procedures for the affected boiler.

b. An operating log or other records for the affect ed boiler that, at a minimum, shall include the information specifi ed in Condition 3.2 and the following information:

i. Information for each startup and shutdown, inclu ding date, time and duration, as required by 40 CFR 60.7 (b).

ii. Information for any incident in which the opera tion of the affected boiler continued during malfunction or breakdown, including: date, time, and duration; a description of the incident; whether emissions exce eded or may have exceeded any applicable standard; a description of the corrective actions taken to redu ce emissions and the duration of the incident; and a description of the preventative actions taken, as addressed by 40 CFR 60.7(b).

c. The Permittee shall maintain the following opera ting records
for the affected boiler:

i. Daily records of fuel use, which records shall b e prepared and maintained following the procedures of 40 CFR 60.49b(d);

ii. Amount of fuel consumed, (scf/month and scf/yea r) and the annual capacity factor, determined on a 12-month ro lling basis with a new annual capacity factor calculated for each month pursuant to 40 CFR 60.49b(d);44 iii. For the affected boiler, pursuant to 40 CFR 60 .49b(r), the fuel receipts from the fuel supplier that certi fy that the gaseous fuel meets the definition of natur al gas as defined in 40 CFR 60.41b and the applicable sulf ur limit.

d. The Permittee shall maintain records of the foll owing
information for the NOx emissions of the affected b oiler for each operating day, pursuant to 40 CFR 60.49b(g) un less alternative recordkeeping requirements are approved for the boiler in conjunction with USEPA approval of altern ative monitoring procedures under the NSPS:

i. Calendar date.

ii. The measured average hourly emission rates (exp ressed in lbs/mmBtu heat input).

iii. The 30-day average emission rate (lbs/mmBtu he at input and lbs/hour) calculated at the end of each operati ng day from the measured hourly emission rates for the pre ceding 30 unit operating days.

iv. Identification of the operating days when the c alculated 30-day average emission rates are in excess of an applicable standard or limit, with the reasons for such excess emissions as well as a description of correc tive
actions taken.

v. Identification of the operating days for which e mission data have not been obtained, including a descriptio n of
corrective actions taken.

vi. Identification of the times when emission data have been excluded from the calculation of average emission r ates and the reasons for excluding data.

vii. Identification of “F” factor used for calculat ions, method of determination, and type of fuel combusted

.

viii. Identification of the times when the pollutan t concentration exceeded the full span of the CEMS.

ix. Description of any modifications to the CEMS th at could affect the ability of the CEMS to comply with Perfo rmance Specification 2 or 3.

x. Results of daily CEMS drift tests and quarterly accuracy assessments as required by 40 CFR Part 60 Appendix F,
Procedure 1.

e. The Permittee shall keep the following records f or the CO
emissions of the affected boiler:45 i. All measurements needed to demonstrate complianc e with the applicable standards and limits for CO includin g, but not limited to, 15-minute averages of CEMS data and raw performance evaluation measurements that support da ta that the Permittee is required to report.

ii. Records of CO emissions as compared to applicab le limits and standards and the date, start time and duration of any deviation from an applicable standard or limita tion, and whether the deviation occurred during startup,
shutdown or malfunction.

iii. Each period during which the CEMS is malfuncti oning or inoperative.

iv. All results of CEMS performance evaluations.

v. All CEMS calibration checks and all adjustments and maintenance performed on the CEMS.

vi. All measurements as may be necessary to determi ne the conditions of performance tests and performance
evaluations.

f. The Permittee shall keep inspection, maintenance and repair logs or other similar records for the affected boil er that contain the information specified in Condition 3.2( b).

g. The Permittee shall keep the following records r elated to the emissions of NOx, CO, VOM, SO 2 , PM, PM 10 /PM 2.5 , GHG, hexane,
other individual HAP and total HAPs from the affect ed boiler:

i. If continuous monitoring is performed for a poll utant, the emissions of the pollutant from the affected bo iler based on continuous emissions monitoring data, in tons/month and tons/year.

ii. If continuous monitoring is not performed for a pollutant:

A. A file containing the emission factors that are used to calculate emissions, with supporting documentation; and

B. The emissions of the affected boiler based on operating data and applicable emission factors, in tons/month and tons/year, with supporting

calculations.

2.3.10 Notification and Reporting Requirements

a. The Permittee shall fulfill applicable notificat ion and reporting requirements of the NSPS, 40 CFR 60.7 and 60.49b, for the affected boiler by sending required notificatio ns and reports to the Illinois EPA, including the followin g reports:46 i. Reports containing the information recorded unde r 40 CFR 60.49b(g) and (j).

ii. Periodic reports for excess emissions, as furth er addressed by Condition 2.3.10(c).

iii. With the periodic compliance reports, reports certifying that only natural gas that is known to contain insignificant amounts of sulfur were combusted in t he affected boiler during the reporting period, pursua nt to 40 CFR 60.49b(r).

b. The Permittee shall promptly notify the Illinois EPA of any deviations from the requirements of this permit for the
affected boiler as follows. These notifications sh all include the information specified by Condition 3.4.

i. Deviations from the NOx limits in Conditions 2.3 .2(b), 2.3.3-1(b) and 2.3.6(a) shall be reported with the periodic compliance reports required by the NSPS.

ii. Deviations from the CO limits in Conditions 2.3 .2(b), 2.3.3-2(b) and 2.3.6(a) shall also be reported with the periodic compliance reports required by the NSPS.

iii. Other deviations shall be reported within 30 d ays and include a description of the incident, a discussion of the probable cause of such deviation, a description of the corrective actions taken, and a description of the preventative measures taken.

c. The Permittee shall submit periodic compliance r eports to the Illinois EPA for the affected boiler, which reports shall include the following information related to excess emissions and deviations. These reports shall be submitted o n a semiannual basis, with each report submitted no later t han 30 days following the end of the reporting period:

i. As related to the NSPS standard for NOx (Conditi on 2.3.3- 1(b)) or the NOx limits in Conditions 2.3.2(b) and 2.3.6(a), the information required for reporting of exceedances under 40 CFR 60.7(c) or (d) and 60.49b( h) and (j). If there are no such exceedances during the reporting period, the report shall state that no exceedances occurred during the reporting period.

ii. Information for other deviations during the rep orting period, if any, which shall include the information specified by Condition 3.4.

iii. When no excess emissions or deviations have oc curred or the CEMS have not been inoperative, repaired, or adjusted, such information shall be stated in the r eport.47 d. If the Permittee proposes to use an add-on contr ol technology other than SCR for the affected boiler, at least 30 days before commencing construction of the affected boiler, the Permittee shall submit a copy of a performance guarantee from the
manufacturer of the boiler that shows the combinati on of lowNOx burners and the proposed equivalent add-on cont rol technology will comply with the NOx emission limit in Condition 2.3.2(b), i.e., 0.0120 lb/mmBtu, 30-day average, ro lled daily.48

SECTION 2.4: UNIT-SPECIFIC CONDITIONS FOR THE STAR TUP HEATER

2.4.1 Description

The startup heater (the “affected unit”) is a natur al gas-fired process heater for the ammonia plant. This heater is used during startup of the ammonia plant to heat a process stre am (i.e., a recycle stream going to the catalyst beds in the am monia converter) until the temperature is high enough that this reac tion is selfsustaining.

2.4.2 Control Technology Determination - BACT

a. i. The affected unit shall be operated and maint ained in

accordance with the manufacturer’s design, which sh all
include low-NOx burners.

ii. The affected unit shall be operated and maintai ned in accordance with good combustion practices.

b. i. The design emission rates of the affected uni t shall not

exceed 0.08, 0.037, 0.0054, 0.0019 and 0.0075 lb/mm Btu for NOx, CO, VOM, PM and PM 10 /PM 2.5 , respectively.

ii. The annual emissions of GHG from the affected u nit shall
not exceed the limit in Condition 2.4.6.

2.4.3 Applicable Emission Standards

The affected unit is subject to the following state standards:

a. The emission of smoke or other particulate matte r shall not have an opacity greater than 30 percent, 6-minute a verage, except as allowed by 35 IAC 212.123(b) or 212.124. [35 IAC 212.109 and 212.122(a)]

b. CO emissions shall not exceed 200 ppm, corrected to 50 percent excess air. [35 IAC 216.121]

2.4.4 Non-Applicability Provisions

a. The affected unit is not subject to the NSPS for IndustrialCommercial-Institutional Steam Generating Units, 40 CFR 60 Subpart Db, because the affected unit is a process heater.

b. The affected unit is not subject to the NESHAP, 40 CFR 63 Subpart JJJJJJ, Industrial, Commercial, and Institu tional
Boilers at Area Sources because the affected unit i s a process heater, as defined by 40 CFR 63.11237.

2.4.5 Operational Production Limits and Work Practi ces

a. The rated heat input capacity of the affected un it shall not exceed 104 mmBtu/hour.49 b. The only fuel fired in the affected unit shall b e natural gas.

c. After the completion of commissioning of the amm onia plant or one year after the initial startup of the ammonia p lant, whichever occurs first, the fuel usage of the affec ted unit shall not exceed 14.61 million scf per year.

2.4.6 Emission Limits

a. The emissions of the affected unit shall not exc eed the following limits:

Pollutant Hourly Limits (Pounds/Hour) Annual Limits (Tons/Year)

NOx 18.6 0.60

CO 3.80 0.27

PM 0.20 0.02

PM 10 /PM 2.5 0.80 0.06

VOM 0.60 0.04

SO 2 --- 0.01

Total HAPs --- 0.01

GHG --- 871

b. Notwithstanding the above, until the commissioni ng of the ammonia plant is complete or one year after initial startup of the ammonia plant, whichever occurs first, the abov e limits for annual emissions of the Startup Heater shall apply on a bimonthly basis rather than on an annual basis.

2.4.7 Recordkeeping Requirements

a. For the affected unit, the Permittee shall maint ain a file containing information for the heat input capacity and design emission rates, with supporting documentation as pr ovided by

manufacturer of the burner.

b. The Permittee shall maintain records of the fuel usage of the affected unit (scf/month and scf/year).

c. The Permittee shall maintain an operating log or other similar
records for the affected unit that include the info rmation specified in Condition 3.2(a).

d. The Permittee shall keep inspection, maintenance and repair logs or other similar records for the affected unit that contain the information specified in Condition 3.2( b).

e. The Permittee shall keep records for any deviati ons from applicable requirements involving the affected unit , which records shall include the information specified by Condition 3.3. These records may be combined with other recor ds required
for the affected unit.

f. The Permittee shall maintain records of the emis sions of NOx,
CO, PM, PM 10 /PM 2.5 , VOM, SO 2 , GHG and total HAPs from the50 affected unit (tons/month and tons/year), with supp orting
documentation and calculations.

2.4.8 Reporting Requirements

a. The Permittee shall notify the Illinois EPA of d eviations of the affected unit with the permit requirements with the periodic compliance reports required by Condition 2 .1.10(b).
These notifications shall include the information s pecified in
Condition 3.4.51

SECTION 2.5: UNIT-SPECIFIC CONDITIONS FOR THE AMMO NIA STORAGE FLARE

2.5.1 Description

The ammonia storage flare (the “affected flare”) co mbusts ammonia at times when the amount of ammonia in the refrigerate d pressure tanks
in which it is stored must be lowered. This is nec essary in certain circumstances to keep the pressure in the tanks wit hin safe levels.
The ammonia that is released is ducted to the ammon ia storage flare, where it is combusted, resulting in emissions of NO x. The events that commonly lead to increased pressure in the tan ks, with the need to flare ammonia, include loss of electrical power or mechanical failures of the refrigeration system for the storag e tanks and sudden drops in atmospheric pressure.

2.5.2 Control Technology Determination – BACT

a. i. As the operation of the ammonia storage plant affects the

occurrence of flaring and emissions from flaring, t he ammonia storage plant, including the affected flare
, shall be operated and maintained in conformance wit h its physical and process design.

ii. The operating practices for the ammonia storage plant shall include implementation of practices to minimi ze flaring, as further addressed in Condition 2.5.4(c)

b. The design emission rates of the pilot burner in the affected flare shall not exceed 0.07 and 0.37 lb/mmBtu for N Ox and CO, respectively.

c. The emissions of NOx, CO, PM, PM 10 /PM 2.5 , VOM and GHG of the
affected flare shall not exceed the limits in Condi tion 2.5.5(a).

2.5.3 Applicable State Emission Standards

a. The emission of smoke or other particulate matte r from the affected flare shall not have an opacity greater th an 30 percent, 6 minute average, except as allowed by 35 IAC 212.122(b) or 212.124. [35 IAC 212.109 and 212.122 (a)]

2.5.4 Operational Work Practices

a. Ammonia releases from the primary pressure relie f valves on the ammonia storage tanks shall be ducted through a clo sed vent system to the affected flare.

b. The flare shall be operated with a flame present when ammonia is being vented to it.

c. i. The work practices to minimize flaring conduc ted by the

Permittee for the affected flare pursuant to Condit ion 2.5.2(a) shall include the preparation and maintena nce of52 a Flare Minimization Plan (Plan) for the ammonia pl ant that includes the following:

A. A general description of the Permittee’s written procedures for the storage of ammonia.

B. A general description of the Permittee’s procedu res for preventative maintenance of equipment for ammonia storage, including the provisions in these procedures that should act to minimize flaring.

C. A description of the established responsibilitie s of different personnel at the facility for the operation and maintenance of ammonia storage equipment.

ii. After the shakedown of the ammonia plant is com plete, the Plan shall also include a description of additional procedures or other measures that are installed or implemented to reduce flaring from the affected fla re.

iii. A. The Permittee shall review the Plan on at l east an

annual basis and revise the Plan so that it is kept current and reflects any changes in the operation o f the ammonia plant.

B. The Permittee shall submit a copy of the Plan to the Illinois EPA for review and comments upon written request.

C. This Plan is a record required by this permit, w hich
the Permittee must retain and make available to the
Illinois EPA and USEPA in accordance with the general requirements for retention and availability of records. In addition, when the Permittee revise s the Plan, the Permittee must also retain and make available the previous version of the Plan for a period of at least 5 years after such revision.

d. After the shakedown of the ammonia plant is comp lete, the Permittee shall also conduct an event-specific inve stigation or “Root-Cause Analysis” into each “Flaring Incident” associated with ammonia storage to determine the causes of the incident, to take reasonable steps to correct the conditions that caused or contributed to such incident, and to further min imize emissions from flaring, consistent with the require ments of Condition 2.1.5-3(d). For this purpose, a “Flaring Incident” is defined as a flaring event that results in flari ng of more than 500 pounds of ammonia.

e. The Permittee shall operate and maintain the aff ected flare in accordance with written procedures developed and ma intained by the Permittee. These procedures may incorporate pr ocedures provided by the supplier of equipment.53

2.5.5 Emission Limits

a. The emissions of the affected flare shall not ex ceed the following limits:

Pollutant Limit

(tons/year)

NOx 12.8

CO 1.52

VOM 0.21

PM 0.10

PM 10 /PM 2.5 0.25

SO 2 0.02

GHG 479

2.5.6 Operational Monitoring and Instrumentation Re quirements

a. The Permittee shall install, calibrate, maintain , and operate a continuous monitoring system to measure the flow of ammonia to the affected flare (scfm).

b. The Permittee shall install, maintain, and opera te
instrumentation on the affected flare for:

i. The presence of a pilot flame, as identified by a thermocouple, ultra-violet beam sensor, infrared se nsor or other device capable of continuously detecting a

flame.

ii. The usage of fuel by the pilot burner (scf).

2.5.7 Recordkeeping Requirements

a. The Permittee shall maintain a file or other rec ord for the affected flare containing the design destruction ef ficiency of the flare for ammonia and the design emission rates of the pilot burner for NOx and CO, with supporting docume ntation.

b. The Permittee shall keep an inspection, maintena nce and repair log for the affected flare, which lists activities that are performed, with date and responsible individual(s).

c. The Permittee shall keep a log or other records that includes
information that confirms that the affected flare f unctions properly, i.e., a flame was present.

d. The Permittee shall keep the following records r elated to emissions of NOx, CO, PM, PM 10 /PM 2.5 , VOM, SO 2 and GHG from the

affected flare:

i. A file containing the factors used by the Permit tee to determine emissions of the affected flare (lbs/hour ), with supporting documentation, including:54 A. The emissions of each pollutant from combustion of fuel (lbs/million scf).

B. The emissions of NOx and GHG from flaring of amm onia (lbs/lb ammonia flared).

ii. Records of the emissions of each pollutant (ton s/month and tons/year), with supporting calculations.

2.5.8 Reporting Requirements

a. The Permittee shall notify the Illinois EPA of d eviations of the affected flare with the permit requirements wit h the periodic compliance reports required by Condition 2 .1.10(b).
These notifications shall include the information s pecified in
Condition 3.4.55

SECTION 2.6: UNIT-SPECIFIC CONDITIONS FOR THE UREA PLANT

2.6.1 Description

In the urea plant, a water urea solution is produce d from the reaction of liquid ammonia and gaseous CO 2 under pressure in a closed process. The ammonia plant supplies both the ammon ia and CO 2 for the process. As the amount of CO 2 is slightly greater than the amount that is needed to make urea, the excess CO 2 is vented from a pressure

control CO 2 vent that is located at the urea plant.

A portion of the urea solution initially produced i n the urea plant may be used for making diesel exhaust fluid by addi ng more water. This fluid would be stored in tanks pending shipmen t from the facility.

The urea solution that is not made into diesel exha ust fluid is further processed in the urea plant to make solid u rea. First, water is removed from the urea solution in evaporat ors to produce a
concentrated urea solution. The concentrated solut ion is then processed in a drier or granulator. The hot solutio n provides the heat for the drying process. A small amount of an anti-caking additive, a urea-formaldehyde resin solution, is ad ded to the urea solution fed to the granulator. This additive reac ts with the urea granules to reduce caking and dust formation during subsequent handling of the granular urea product, both at the facility and by customers. The granulator emits particulate and fo rmaldehyde, which are controlled by a two-stage control system consis ting of an acid scrubber (first-stage scrubber) followed by a ventu ri scrubber (second-stage scrubber). The acid scrubber also se rves to control traces of ammonia in the exhaust. The flows of spe nt scrubbant are recycled back into the urea solution to recover the urea and
ammonia.

The hot urea from the granulator is processed in a screen and a final cooler. The particulate emissions of these u nits are also controlled by the two-stage scrubber system for the granulator.

The particulate emissions from the evaporators are also controlled by the first-stage scrubber on the granulator. As such, the emissions of all the emission units in the urea pla nt that are involved in the production of solid urea, including the evaporators, the granulator, the coolers and associated material transfer systems all occur through a single stack, the stack on the second-stage

scrubber.

For purposes of these unit-specific conditions, the “affected urea units” are the emission units in the urea plant inv olved in the production of granular urea. The handling, storage and loadout of
finished urea are addressed in Section 2.9 of this permit. The pressure control CO 2 vent at the urea plant is addressed with the CO 2 vents at the ammonia plant in Section 2.1 of this p ermit.56

2.6.2 Control Technology Determination – BACT

a. The emissions of the affected urea units shall b e controlled by a high-efficiency scrubber whose PM emissions shall not exceed 0.005 grains per dry standard cubic foot (gr/dscf).

b. The emissions of the affected urea units, in tot al, shall not exceed the following limits:

i. PM and PM 10 /PM 2.5 : 0.140 and 0.121 lbs/ton of urea, respectively, 3-hour average.

ii. VOM: 0.36 lbs/hour, 3-hour average.

Note: The BACT limit for GHG in Condition 2.1.2-3 addresses
the GHG emissions of the CO 2 vent located at the Urea Plant.

2.6.3 Applicable Emission Standards

a. The emission of smoke or other PM from the affec ted urea units shall not have an opacity greater than 30 percent, 6 minute average, except as allowed by 35 IAC 212.124. [35 IAC 212.109 and 212.123(a)]

b. The PM emissions from the affected urea units sh all comply with the applicable limit pursuant to 35 IAC 212.321, wh ich rule limits emissions based on the process weight rate o f the units.

Note: There are no federal emission standards unde r 40 CFR Parts 60 or 63 that apply to the affected urea plan t.

2.6.4 Operational Requirements

a. The Permittee shall operate and maintain the scr ubbers
associated with the affected urea units in accordan ce with written procedures developed and maintained by the Permittee.

b. i. The key operating parameters of the second-st age

scrubber, as specified below, shall be maintained a t
levels that are consistent with levels at which emi ssion testing demonstrated compliance with applicable requirements, on a 3-hour average basis, rolled hou rly:

A. Minimum scrubbant flow rate.

B. Minimum differential pressure across the scrubbe r.

ii. Notwithstanding the above, for the purpose of e valuation of this scrubber and further emission testing, the Permittee may operate this scrubber at different op erating parameters in accordance with a detailed plan descr ibing the evaluation and testing program submitted to and approved by the Illinois EPA.57

2.6.5 Emission Limits

a. The emissions of the affected urea units shall n ot exceed the following limits:

Pollutant Limits Pounds/hour Tons/year

PM 28.5 124.7

PM 10 /PM 2.5 24.7 108.1

VOM 0.36 1.60

Total HAPs --- 1.60

2.6.6-1 Testing Requirements

a. The Permittee shall have the emissions of PM, fi lterable PM 10 and PM 2.5 , condensable PM, VOM and formaldehyde of the affec ted urea units (i.e., the second-stage scrubber) conduc ted by a qualified testing service as follows:

i. Within 60 days after achieving the maximum produ ction rate at which the affected urea units will be opera ted, but not later than 180 days after initial startup o f
these units.

ii. Within 12 months and 18 months after the initia l testing required above.

iii. Within 90 days of a written request from the Illinois EPA, for such pollutants as specified in the reques t.

b. i. Testing for particulate shall be conducted us ing

appropriate USEPA Test Methods, for measurement of PM,
filterable PM 10 and PM 2.5 , and condensable PM, provided, however, that if the moisture level in the stack ma kes
measurements of filterable PM 10 and PM 2.5 infeasible or if
the Permittee considers all PM emissions to be emis sions
of filterable PM 10 and PM 2.5 , testing for emissions of
filterable PM 10 and PM 2.5 need not be performed. In such case, compliance with the PM limit shall be determi ned based on the emissions of filterable particulate an d compliance with the PM 10 /PM 2.5 limit shall be determined
based on the total of filterable and condensable particulate.

ii. The following methods shall be used for testing VOM and formaldehyde unless other methods adopted by or bei ng developed by USEPA or other alternative test method s are approved by the Illinois EPA.

VOM Method 25A Formaldehyde Method 320

c. Test plan(s) and test notifications shall be sub mitted to the Illinois EPA in accordance with Conditions 3.1(a) a nd (b).58 d. The Permittee shall expeditiously submit Final R eport(s) for required emission testing to the Illinois EPA, no l ater than 60 days after the date of testing. These reports shal l include the information specified in Condition 3.1(c) and t he following
information:

i. The data measured by the continuous monitoring s ystems and instrumentation required by Condition 2.6.7 dur ing each test run and the levels of operating parameter s within which the Permittee plans to operate pursuan t to Condition 2.6.4(b), with explanation.

ii. Representative opacity data (6-minute average) during testing as determined by USEPA Method 9.

2.6.6-2 Opacity Observations

a. Within 45 days of a written request by the Illin ois EPA or such later date agreed to by the Illinois EPA, the Permi ttee shall have opacity observations conducted for the affecte d urea units by Method 9 while units are operating at conditions that are representative of maximum emissions, as follows:

i. The duration of opacity observations for each te st shall be at least 60 minutes (ten 6-minute averages) unle ss the average opacities for the first 18 minutes of observations (three six-minute averages) are all le ss than 5 percent.

ii. A. The Permittee shall notify the Illinois EPA at least

7 days in advance of the date and time of these observations, in order to allow the Illinois EPA to
witness observations. This notification shall include the name and employer of the qualified observer(s).

B. The Permittee shall promptly notify the Illinois EPA of any changes in the time or date for observations

.

iii. The Permittee shall provide a copy of its obse rver’s readings to the Illinois EPA at the time of observa tions, if Illinois EPA personnel are present.

iv. The Permittee shall submit a written report for these observations within 15 days of the date of observat ions. This report shall include:

A. Date and time of observations.

B. Name and employer of qualified observer and a co py of the current Method 9 certification.

C. Description of the operating conditions of the
affected units.59 D. Raw data.

E. Opacity determinations.

F. Conclusion.

2.6.7 Operational Monitoring and Instrumentation

a. i. The Permittee shall operate a continuous moni toring

system on the granulator for the rate of urea solut ion into the unit (volume or weight).

ii. The Permittee shall operate continuous monitori ng systems
on all scrubbers for the affected urea units for th e following operating parameters.

A. Pressure drop across the scrubber.

B. Scrubbant flow rate.

C. Scrubbant recirculation rate, if scrubbant is
recirculated.

D. Acid content or pH of scrubbant (first-stage scrubber only).

iii. Data measured by these monitoring systems shal l be recorded on an hourly average basis and on a 3-hour average basis, rolled hourly.

b. The Permittee shall operate instrumentation for the rates at which urea solution and the anti-caking additive ar e fed to the granulator.

2.6.8 Inspection Requirements

a. The Permittee shall perform detailed inspections of the
scrubbers for the affected urea units while the uni ts are out of service, with an initial inspection performed be fore any maintenance and repair activities are conducted dur ing the period the units are out of service and a follow-up inspection performed after any such activities are completed. These inspections shall be conducted at least every 18 mo nths.

b. The Permittee shall keep records for these inspe ctions, which may be combined with the records required by Condit ion 2.6.9(c).

2.6.9 Recordkeeping Requirements

a. The Permittee shall maintain a file or other rec ords for the affected urea units that contain the following info rmation, with supporting material, which records shall be ke pt current:60 i. The maximum production capacity of the affected units (tons urea/hour).

ii. The standard emission factors used by the Permi ttee to determine emissions of the affected units, with sup porting
documentation.

iii. The maximum hourly rates of emissions of PM, P M 10 /PM 2.5 , VOM and formaldehyde of the affected units (pounds/hour ).

iv. The maximum process weight rate of the affected units, with supporting analysis, and a demonstration that the m aximum hourly PM emissions of the affected units will comp ly with the limit set by 35 IAC 212.321.

b. The Permittee shall maintain records for the amo unt of urea produced by the affected urea units (tons/month and tons/year).

c. The Permittee shall keep inspection and maintena nce log(s) or
other records for the affected units and associated scrubbers that, at a minimum, include:

i. Type of activity.

ii. Date and time and name(s) of personnel involved

.

iii. For inspections, a description of the observed condition of equipment.

iv. For maintenance or repair, a description of the actions taken, with reason, e.g., routine maintenance or replacement of failed components.

d. The Permittee shall maintain records of the foll owing for each incident when any affected unit operated without th e control as required by Condition 2.6.4(b)(i):

i. The date of the incident and identification of t he unit(s) that were involved.

ii. A description of the incident, including: the e stablished control measures that were not present or implement ed; the established control measures that were present, if any; and other control measures or mitigation measu res that were implemented, if any.

iii. The time at and means by which the incident wa s identified, e.g., scheduled inspection or observati on by operating personnel.

iv. Operational data for the incident.

v. The corrective action(s) taken and the length of time after the incident was identified that the unit(s) continued to operate before established control mea sures61 were in place or the operations were shutdown (to r esume operation only after established control measures w ere in place) and, if this time was more than one hour, an explanation why this time was not shorter, includin g a detailed description of any mitigation measures tha t were implemented during the incident.

vi. The estimated total duration of the incident, i .e., the total length of time that the unit(s) ran without
established control measures and the estimated amou nt of material processed during the incident.

vii. A discussion of the probable cause of the inci dent and any preventative measures taken.

viii. An estimate of any additional emissions of pa rticulate, VOM, formaldehyde, methanol and any other HAPs (pou nds) above the emissions associated with normal operatio n that resulted from the incident, if any, with supporting
calculations.

e. The Permittee shall maintain records for the emi ssions of PM,

PM 10 /PM 2.5 , VOM, formaldehyde, methanol and any other HAPs of the affected urea units (tons/month and tons/year), wit h supporting
documentation and calculations.

2.6.10 Reporting Requirements

a. The Permittee shall promptly notify the Illinois EPA of deviations of the affected units from applicable re quirements,
as follows. These notifications shall also include the information specified by Condition 3.4.

i. Notification within 30 days for deviations from the operational requirements in Condition 2.6.4(b)(i) t hat
continue for more than 24 hours.

ii. Notification for other deviations with the quar terly reports required by Condition 2.1.10(b).62

SECTION 2.7: UNIT-SPECIFIC CONDITIONS FOR THE COOL ING TOWER

2.7.1 Description

A multi-cell cooling tower will supply the cooling water needed by various units in the urea and ammonia plants. The cooling tower (the affected unit) emits particulate from mineral material present in the water supply. This material is emitted with water droplets that escape from the cooling tower or completely ev aporate. These particulate emissions are controlled by drift elimi nators, which collect water droplets entrained in the air in the tower.

2.7.2 Control Technology Determination - BACT

a. The affected unit shall be equipped, operated, a nd maintained with drift eliminators designed to limit the loss o f water droplets from the unit to no more than 0.0005 perce nt of the circulating water flow.

b. The Total Dissolved Solids content of the water used in the affected unit shall not exceed 2000 mg/l, daily ave rage.

c. The particulate emissions of the affected unit s hall not exceed
the limits in Condition 2.7.6.

2.7.3 Applicable Emission Standards

a. The emission of particulate matter from the affe cted unit shall not have opacity greater than 30 percent, 6-minute average. [35 IAC 212.109 and 212.123(a)]

b. The affected unit shall comply with 35 IAC 212.3 01 and 212.314, which provide that emissions of fugitive PM shall n ot be visible from any process, including any material ha ndling or storage activity, when looking generally toward the zenith at a point beyond the property line of the source, excep t when the wind speed exceeds 25 miles per hour.

c. The PM emissions from the affected unit shall co mply with the applicable limit pursuant to 35 IAC 212.321.

2.7.4 Non-Applicability Provisions

This permit is issued based on the affected unit no t being subject to the NESHAP for Industrial Process Cooling Towers (40 CFR 63, Subpart Q) because chromium-based water treatment c hemicals will not

be used.

2.7.5 Operating Requirements

a. Chromium-based water treatment chemicals, as def ined in 40 CFR 63.401, shall not be used in the affected unit.

b. i. Only non-VOM additives shall be used in the a ffected

unit.63 ii. Plant process wastewater shall not be introduce d into cooling water, other than through unintentional lea ks, which shall promptly be repaired.

c. The Permittee shall operate and maintain the aff ected unit, including the drift eliminators, in accordance with written procedures. These procedures shall address the pra ctices that will be followed as good air pollution control prac tice and the actions that will be implemented if needed to preve nt a significant contribution to icing and fogging on of fsite roadways.

2.7.6 Emission Limits

a. The emissions of the affected unit for PM and PM 10 /PM 2.5 , respectively, shall not exceed the following limits . Compliance
with these limits shall be determined from relevant operating data for the cooling tower and the efficiency of th e drift eliminators, using engineering calculations for emi ssions.

i. 1.0 and 0.6 pounds/hour, 24-hour average basis.

ii. 4.42 and 2.47 tons/year.

2.7.7 Operational Measurements

a. Within one year after initial startup of the amm onia plant, the Permittee shall test the drift lost (percent) from the affected unit in accordance with the Cooling Technology Inst itute’s Acceptance Test Code No. 140. This test shall be p erformed by a licensed performance testing service.

2.7.8 Sampling and Analysis of Cooling Water

a. The Permittee shall sample and analyze the water being
circulated in the affected unit on at least a month ly basis for
the total dissolved solids content. Measurements o f the total dissolved solids content in the wastewater discharg e associated with the affected unit, as required by a National P ollution Discharge Elimination System permit, may be used to satisfy this requirement if the effluent has not been dilut ed or otherwise treated in a manner that would significan tly reduce
its total dissolved solids content.

b. Upon written request by the Illinois EPA, the Pe rmittee shall promptly have the water circulating in the affected unit sampled and analyzed for the presence of hexavalent chromium in accordance with the procedures of 40 CFR 63.404(a) and (b).

c. The Permittee shall keep records for this sampli ng and analysis activity, including documentation for sampling and analysis as well as the resulting data that is collected.64

2.7.9 Recordkeeping Requirements

a. The Permittee shall keep a file that contains th e following
information for the affected unit:

i. The design loss specification for the drift elim inators
installed in the affected unit.

ii. The supplier’s recommended procedures for inspe ction and
maintenance of the drift eliminators.

iii. The operating factors, if any, used to determi ne the amount of water circulated in the unit or the PM, P M 10 , PM 2.5 from the unit, with supporting documentation.

iv. Copies of the Material Safety Data Sheets or ot her comparable information from the suppliers of the va rious
water treatment chemicals that are added to the wat er circulated in the unit.

v. Calculations for the maximum PM, PM 10 and PM 2.5 emissions from the affected unit (pounds/hour on a 24-hour av erage basis for PM, PM 10 and PM 2.5 ), based on the maximum operating rate of the affected unit and other facto rs that result in greatest emissions.

b. The Permittee shall keep the records for the amo unt of water circulated in the affected unit, gallons/month. As an alternative to direct data for water flow, these re cords may contain other relevant operating data for the affec ted unit (e.g., water flow to the affected unit) from which the amount of water circulated in the affected unit may be rea sonably
determined.

c. The Permittee shall maintain an operating log or other similar
records for the affected unit that include the info rmation specified in Condition 3.2(a).

d. The Permittee shall keep inspection and maintena nce logs for the affected unit, including the drift eliminators installed in the affected unit, which shall include the informat ion specified in Condition 3.2(b).

e. The Permittee shall maintain records for the PM, PM 10 and PM 2.5 emissions of the affected unit based on the above r ecords, the measurements required by Conditions 2.7.7 and 2.7.8 , and appropriate USEPA emission estimation methodology a nd emission factors, with supporting calculations.

2.7.10 Reporting Requirements

a. The Permittee shall promptly notify the Illinois EPA of deviations of the affected unit with permit require ments.
These notifications shall include the information s pecified by
Condition 3.4.65 i. If the affected unit is damaged so there is a de viation from an applicable requirement that is not repaired or otherwise corrected within 24 hours, the Permittee shall notify the Illinois EPA as soon as possible during normal working hours, but no later than three days after t he

event occurred.

ii. All other deviations shall be reported with the periodic compliance reports required by Condition 2.7.10(b).

b. The Permittee shall submit periodic compliance r eports to the Illinois EPA for the affected units, which reports shall include information for deviations during the repor ting period, if any. These reports shall be submitted with the periodic reports required by Condition 2.1.10(b).66

SECTION 2.8: UNIT-SPECIFIC CONDITIONS FOR EQUIPMEN T COMPONENTS

2.8.1 Description

Certain equipment, piping and ductwork at the facil ity have components, including valves, flanges and other con nectors, pump seals, compressor seals, and pressure relief valves , that handle fluid streams containing VOM and/or methane and hav e the potential to emit VOM or methane when they leak. Three strea ms are present at this facility that contain or potentially contain V OM and/or methane: 1) Natural gas streams, either as natural gas is being
used as fuel or is handled as the feedstock for ste am reforming; 2) The off-gases from the ammonia plant that are ducte d to the reformer for use as fuel, and 3) The process vent gases from the ammonia plant that are flared. Two other streams are prese nt that contain or potentially contain only VOM: 1) The CO 2 absorption solvent used in the ammonia plant, and 2) The urea-formaldehyde resin solution used in the urea plant. As appropriate, the emissi ons of VOM and methane from these components are addressed through timely identification and repair of any leaks that occur o r, in the case of the pumps and valves handling urea-formaldehyde res in solution, by use of “leakless components”.

The piping that transports CO 2 from the regenerator to the urea plant also has components that have the potential to emit CO 2 when they
leak. The emissions of CO 2 from these components are also addressed by provisions for timely identification and repair of any leaks that

occur.

For purposes of these unit-specific conditions, the “affected components” are all components that contain fluids containing VOM and/or methane. The “affected natural gas componen ts” are the components that handle natural gas. The “affected off-gas components” are the components that handle off-gase s from the ammonia plant that are used as fuel. The “affected process-gas components” are the components in the ammonia plant that handle gas streams that are flared. The “affected absorption solvent components” are the components that handle the CO 2 absorption solvent. The “affected resin components” are the c omponents that handle the urea-formaldehyde resin for the urea pla nt. The
“affected CO 2 components” are the components that handle the CO 2 stream from the regenerator to the urea plant.

2.8.2 Control Technology Determination - BACT

a. i. For affected natural gas, off-gas and process -gas

components, emissions from leaks shall be controlle d by compliance with the provisions of the NSPS for Equi pment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry for Which Construction, Reconstruction, or Modification Commenced After Nov ember 7, 2006, 40 CFR 60 Subpart VVa, that apply to “fuel gas system” or “closed vent systems,” including 40 CFR 60.482-10a(a) and other relevant provisions of this NSPS for work practices, testing, recordkeeping and repo rting.67 ii. For this purpose, a component shall be “in VOM service” if it contains a gas stream that contains more than 1 percent VOM and a leak shall be a VOM concentration of 500 ppm or more. A component shall be in “methane service” if it contains a gas stream that contains more than 5 percent methane and a leak shall be a methan e concentration of 2000 ppm or more.

b. For affected absorption solvent components, emis sions from leaks shall be controlled by compliance with the pr ovisions of the NSPS, 40 CFR 60 Subpart VVa, that apply to comp onents ”in heavy liquid service,” including 40 CFR 60.482-8a(a ) and other relevant provisions of this NSPS for work practices , testing, recordkeeping and reporting.

c. For affected resin components, emissions from le aks shall be controlled by:

i. For components other than connectors and pressur e relief valves, by use of components that are of “leakless” design.

ii. For connectors and pressure relief valves, by c ompliance with the provisions of the National Emission Standa rds for Organic Hazardous Air Pollutants for Equipment Leaks, 40 CFR 63 Subpart H, that apply to components ”in h eavy liquid service,” including 40 CFR 63.169(a) and oth er relevant provisions of these standards for work practices, testing, recordkeeping and reporting.

d. For affected CO 2 components, emissions from leaks shall be controlled by implementing the following practices:

i. If evidence of a potential leak is found by soun d or any other detection method, the Permittee shall make a first attempt at repair within 5 calendar days, which sha ll include best practices such as tightening of flange bolts, as practicable, and eliminating the sound or other indication of a potential leak within 15 calendar d ays of detection unless repair is technically infeasible w ithout a process unit shutdown, in which case repair shall occur before the end of the next scheduled process unit

shutdown.

ii. Notwithstanding Condition 2.8.2(d)(i), if a met hod for monitoring the concentration of CO 2 from a leak is specified by the Illinois EPA in the Clean Air Act Permit Program (CAAPP) permit for the source, if evidence of a potential leak is found by sound or any other detec tion method, either one of the following procedures shal l be

followed:68 A. The Permittee shall eliminate the sound or other indication of a potential leak within 5 calendar days of detection.

B. The Permittee shall monitor the equipment within 5 days to determine whether a leak is present and shall then comply with the following requirements: 1) If an instrument reading of 25,000 ppm or greate r is measured, a leak is detected; 2) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, unless repair is technically infeasible without a process unit shutdown, in whic h case repair shall occur before the end of the next scheduled process unit shutdown; and 3) The first attempt at repair shall be made no later than 5 calendar days after each leak is detected and include best practices such as tightening of flange bolts, as practicable.

2.8.3 Applicable Emission Standards

a. For the affected resin components, the Permittee is subject to and shall comply with all applicable requirements o f the NSPS, 40 CFR 60 Subpart VVa.

2.8.4 Non-Applicability Provisions

a. i. This permit is issued based on affected compo nents in the

urea plant other than the affected resin components not being subject to NSPS, 40 CFR 60 Subpart VVa. This is because these components are not in VOC service sin ce urea is not a VOC and components that handle urea a re not “in VOC service” as defined by 40 CFR 60.481a.

ii. This permit is issued based on the other affect ed components at the facility (i.e., components at the facility other than components at the urea plant) n ot being subject to the requirements of the NSPS, 40 C FR 60 Subpart VVa. This is because they are not located at a synthetic chemical manufacturing facility for purpo ses of this NSPS because they do not produce as an interme diate or final product any chemical listed in 40 CFR 60.4 89.

b. This permit is issued based on affected componen ts in the urea plant not being subject to 35 IAC Part 215 Subpart Q, Leaks for Synthetic Organic Chemical and Polymer Manufacturin g Equipment, because this plant does have any VOM components tha t are in “gas service” or “light liquid service,” as defined by 35 IAC 211.2530 or 211.3410, respectively.

c. This permit is issued based on affected pumps an d compressors not being subject to the control requirement of 35 IAC 215.142 because none of these components will handle a vola tile organic liquid with a vapor pressure of 2.5 psia or greater at 70°F.69

2.8.5 Work Practice Requirements

a. The CO 2 absorption solvent used in the ammonia plant shall be such that the affected absorption solvent component s (i.e., the components that handle this material) are “in heavy liquid service” as defined by 40 CFR 60.481a.

b. For the affected resin components, the Permittee shall comply with the relevant work practice requirements set fo rth in 40 CFR 60 Subpart VVa.

2.8.6 Emission Limits

a. Emissions of VOM, methane and HAPS from the affe cted components shall not exceed 9.92, 28.1 and 0.44 tons/year, res pectively, as determined by use of appropriate USEPA methodolo gy for estimating emissions from leaking components.

b. GHG emissions from the affected CO 2 components shall be
addressed with the GHG emissions of the CO 2 vents. (See Condition 2.1.6.)

2.8.7 Recordkeeping Requirements

a. For the affected resin components, the Permittee shall maintain relevant records as specified by the NSPS, 40 CFR 6 0 Subpart VVa.

b. For affected components other than the affected resin components, the Permittee shall maintain a log or o ther records that identify leaking components and a compilation of leaking components by month by type of component, the natur e of the
leaks and the duration of the leaks.

c. For the affected components, the Permittee shall maintain the following records related to emissions of VOM, meth ane and

HAPs:

i. A file containing the emission factors used by t he
Permittee to determine the emissions from leaks in different types of components, with supporting
documentation and calculations.

ii. Records of the actual emissions of each polluta nt (tons/month and tons/year), with supporting data an d
calculations.

d. For affected CO 2 components, the Permittee shall maintain records to address compliance with Condition 2.8.2( d), including:

i. Records for the identification of potential leak s from an

affected CO 2 component, including date, identification of the component and the method by which the potential leak
was identified.70 ii. The actions taken in response to a potential le ak from an

affected CO 2 component, including data, description and further explanation if repair was not feasible unti l the next scheduled process unit shutdown.

2.8.8 Reporting Requirements

a. The Permittee shall promptly notify the Illinois EPA of deviations from the requirements of this permit for affected components, as follows. Reports shall include the information specified in Condition 3.4.

i. Deviations from requirements that must be report ed in reports pursuant to the NSPS, as required by Condit ion 2.8.2(a) and (b), shall be reported in such reports

.

ii. Other deviations shall be reported with the per iodic compliance reports required by Condition 2.1.10(b).71

SECTION 2.9: UNIT-SPECIFIC CONDITIONS FOR HANDLING OF UREA PRODUCT

2.9.1 Description

The finished urea product from the urea plant is tr ansferred to storage, reclaimed from storage and then loaded out from the facility by truck or rail. Emissions of particulat e from these operations are controlled by work practices and by a fabric filter or baghouse.

For purposes of these unit-specific conditions, the “affected units” are the units involved in the handling of finished urea product, including transfer, storage and loadout.

2.9.2 Control Technology Determination - BACT

a. Particulate matter emissions from the affected u nits shall be controlled by enclosure and baghouse(s).

b. There shall be no visible emissions from the aff ected units.

c. The PM emissions from the baghouse(s) for the af fected units shall each not exceed 0.005 gr/dscf, 3-hour average

.

2.9.3 Applicable State Emission Standards

a. The emission of smoke or other PM from the affec ted units shall not have an opacity greater than 30 percent, 6 minu te average, except as allowed by 35 IAC 212.124. [35 IAC 212.1 09 and 212.123(a)]

b. The PM emissions of the affected units shall com ply with the applicable limit pursuant to 35 IAC 212.321, which rule limits emissions based on the process weight rate of emiss ion units.

c. With respect to emissions of fugitive PM, the af fected units shall comply with 35 IAC 212.301, which provides th at emissions of fugitive PM shall not be visible from any proces s, including any material handling or storage activity, when loo king generally toward the zenith at a point beyond the p roperty line of the source, except when the wind speed exceeds 2 5 miles per hour, as provided by 35 IAC 212.314.

2.9.4 Operational Requirements and Limits

a. The Permittee shall implement and maintain pract ices for the loadout of urea and other work practices for the af fected units that provide assurance of compliance with the appli cable standards and limits in Conditions 2.9.2, 2.9.3 and 2.9.5.

b. For the affected units, the Permittee shall also operate and maintain the affected units with a written Operatin g Plan setting forth the work practices used to reduce the generation of particulate emissions by the affected units.72

2.9.5 Emission Limits

a. Emissions of PM/PM 10 /PM 2.5 from the affected units shall not exceed 0.21 pounds/hour and 0.94 tons/year.

2.9.6-1 Emission Testing Requirements

a. The Permittee shall have the emissions of PM, fi lterable PM 10 and PM 2.5 and condensable PM of the affected units (i.e., th e baghouse) conducted by a qualified testing service as follows:

i. Within 60 days after achieving the maximum produ ction rate at which the affected units will be operated, but not later than 180 days after initial startup of th ese units.

ii. Within 90 days of a written request from the Il linois

EPA.

b. Testing shall be conducted using appropriate USE PA Test Methods, for measurement of PM, filterable PM 10 and PM 2.5 and condensable PM, provided, however, if the Permittee considers
all PM emissions to be emissions of filterable PM 10 and PM 2.5 , testing for emissions of filterable PM 10 and PM 2.5 need not be performed.

c. Test plan(s), test notifications and test report s shall be
submitted to the Illinois EPA in accordance with Co nditions 3.1(a) and (b).

d. The Permittee shall expeditiously submit Final R eport(s) for required emission testing to the Illinois EPA, no l ater than 60 days after the date of testing. These reports shal l include the information specified in Condition 3.1(c) and t he following
information:

Opacity data (6-minute average) for each test run b y Method 9.

2.9.6-2 Observations for Opacity

a. Within 45 days of a written request by the Illin ois EPA or such later date agreed to by the Illinois EPA, the Permi ttee shall have opacity observations conducted for the affecte d units by Method 9 while units are operating consistent with conditions that are representative of maximum emissions, with such observations conducted in accordance with the requi rements of Conditions 2.6.6-2(a)(i), (ii), (iii) and (iv).

2.9.7 Inspections

a. The Permittee shall conduct inspections of affec ted units on at least a monthly basis with personnel who are not di rectly responsible for the day-to-day operation of these u nits.73 i. These inspections shall verify that the work pra ctices used to prevent emissions from affected units are b eing properly implemented.

ii. These inspections shall also include observatio n for the presence of visible emissions, performed in accorda nce with Method 22.

b. The Permittee shall perform detailed inspections of the baghouse for the affected units while these units a re out of service, with an initial inspection performed befor e any maintenance and repair activities are conducted dur ing the period the affected unit is out of service and a fo llow-up inspection performed after any such activities are completed. These inspections shall be conducted at least every 18 months.

2.9.8 Recordkeeping Requirements

a. The Permittee shall keep file(s) or other record s for the affected units containing the following information , with supporting material, which records shall be kept cu rrent:

i. The maximum operating rates of the different aff ected units (tons/hour).

ii. The standard emission factors used by the Permi ttee to
determine emissions of the affected units.

iii. The maximum hourly rates of PM, PM 10 and PM 2.5 emissions of the affected units (pounds/hour), with supporting information, which records shall be kept current.

iv. The maximum process weight rate of the affected units, with supporting analysis, and a demonstration that the maximum hourly PM emissions of the units will compl y with the limit set by 35 IAC 212.321.

b. The Permittee shall maintain operating records o f the amount of urea shipped from the facility (tons/month and tons /year, by truck and by rail).

c. The Permittee shall maintain records of the foll owing for each incident when any affected unit operates without th e work practices used to reduce emissions of particulate.

i. A description of the incident, including the req uired work practices that were not present or implemented ; the work practices that were present, if any; other con trol measures or mitigation measures that were implement ed, if any; and the magnitude of the PM emissions during t he
incident.

ii. The length of time after the incident was ident ified that the affected unit(s) continued to operate before th e work practices were in place or the affected unit(s) wer e74 shutdown (to resume operation only after work pract ices were in place) and, if this time was more than one hour, an explanation why this time was not shorter, inclu ding a description of any mitigation measures that were implemented during the incident.

iii. The estimated total duration of the incident, i.e., the total length of time that the affected unit(s) ran without work practices and the estimated amount of material handled during the incident.

iv. A discussion whether any applicable emission st andards or limits in Conditions 2.9.2, 2.9.3, and 2.9.5, may h ave been violated during the incident, with supporting explanation.

d. The Permittee shall keep records of the emission s of PM, PM 10 and PM 2.5 of the affected units (tons/month and tons/year), with supporting documentation and calculations.

2.9.9 Reporting Requirements

a. The Permittee shall report deviations from requi rements set by this permit for the affected units with the quarter ly reports required by Condition 2.1.10(b). These reports sha ll include the information specified in Condition 3.4.75

SECTION 2.10: UNIT-SPECIFIC CONDITIONS FOR ROADWAY S

2.10.1 Description

The “affected units” are roadways and parking areas at the facility, which may be sources of fugitive particulate matter due to vehicle
traffic or windblown dust. These emissions are con trolled by paving and implementation of work practices to prevent the generation and emissions of particulate matter.

2.10.2 Control Technology Determination - BACT

a. The opacity of fugitive particulate matter emiss ions from affected units shall not exceed 10 percent. For th is purpose, opacity shall be determined in accordance with 35 I AC 212.109.

b. i. Best management practices shall be implemente d to reduce

dust emissions from affected units in accordance wi th a written operating program, as further addressed by Condition 2.10.4. After construction activity is complete, these practices shall provide for pavemen t on all regularly traveled roads and treatment of roadw ays that are routinely subject to vehicle traffic.

ii. For this purpose, roads that serve any office b uilding, employee parking areas or are normally used by truc ks transporting urea or ammonia shall be considered to be subject to regular travel and are required to be pa ved.

c. The handling of material collected from affected units by sweeping or vacuuming trucks shall be enclosed or s hall utilize spraying, pelletizing, screw conveying or other equ ivalent
methods to control PM emissions.

2.10.3 Applicable State Emission Standards

a. The affected units shall comply with 35 IAC 212. 301 and 212.314, which provides that emissions of fugitive particulate matter shall not be visible from any process, inclu ding material handling and storage activities, when look ing generally toward the zenith at a point beyond the p roperty line of the source, except when the wind speed is greate r than 25 miles per hour.

2.10.4 Operating Program for Control of Fugitive Pa rticulate Emissions

a. The Permittee shall carry out control of fugitiv e particulate
emissions from affected units in accordance with a written operating program describing the measures being imp lemented in accordance with Condition 2.10.2(b) to control emis sions from these units, which program shall be kept current.

i. The written operating program shall include:76 A. Maps or diagrams indicating the location of affe cted units, with description of the unit (length, width, surface material, etc.) and volume and nature of expected vehicle traffic, or other activity on such unit, and an identification of any roadways that ar e not considered routinely traveled, with justification.

B. A detailed description of the emissions control technique(s) (e.g., sweeping) for the affected unit
, including: typical application rate; type and concentration of additives; normal frequency with which measures would be implemented; circumstances in which the measure would not be implemented, e.g.
, recent precipitation; triggers for additional control (e.g., observation of 8 percent opacity); and calculated control efficiency for PM emissions.

ii. The Permittee shall submit copies of the writte n operating program to the Illinois EPA for review as

follows:

A. A program addressing affected units during the construction of the facility shall be submitted within 30 days of beginning actual construction of the facility.

B. A program addressing affected units with the operation of the facility shall be submitted within 90 days of initial startup of the ammonia plant.

C. Significant amendments to the program by the Permittee shall be submitted within 30 days of the
date that the amendment is made.

iii. A revised operating program shall be submitted to the Illinois EPA for review within 90 days of a request from
the Illinois EPA for revision to address observed deficiencies in control of fugitive particulate
emissions.

2.10.5 Emission Limits

Emissions of PM, PM 10 , and PM 2.5 from the affected units shall not exceed 11.71, 2.34, and 0.57 tons/year, respectivel y. Compliance
with these limits shall be determined from the amou nt and nature of vehicle traffic associated with the operation of th e plant, specific operating information for affected units, and appro priate emission factors published by USEPA.

2.10.6-1 Opacity Observations

a. The Permittee shall conduct observations, which include a series of observations of the opacity of fugitive e missions from the affected units as follows, to determine th e range of77 opacity from affected units and the change in opaci ty as
related to the amount and nature of vehicle traffic and implementation of the operating program.

b. “Performance observations” for the opacity of em issions shall be conducted as follow. For performance observatio ns, the Permittee shall submit test plans, test notificatio ns and test reports, as specified by Condition 3.1.

i. In conjunction with the measurements of silt loa ding on the affected units required by Condition 2.10.7, performance observations shall first be completed n o later than 30 days after the date that construction of process units in the ammonia or urea plant are comp leted, provided, however, that observation may be deferred as long as heavy construction equipment is on site preventing paving of roadways.

ii. Performance observations shall be repeated with in 30 days in the event of changes involving affected units th at would act to increase opacity (so that observations that are representative of the current circumstances of the affected units have not been conducted), including changes in the amount or type of traffic on affecte d units, changes in the standard operating practices for affected units, such as application of salt or trac tion material during cold weather, and changes in the operating program for affected units.

c. “Compliance observations” shall be conducted for affected units on at least a quarterly basis to verify opacity lev els and confirm the effectiveness of the operating program in controlling emissions.

d. Upon written request by the Illinois EPA, the Pe rmittee shall conduct performance or compliance observations, as specified in the request. Unless another date is agreed to by t he Illinois EPA, performance observations shall be completed wi thin 30 days and compliance observations shall be completed with in 5 days of the Illinois EPA’s request.

2.10.6-2 Inspections

a. i. The Permittee shall conduct inspections of af fected units

for the specific purpose of verifying that the oper ating program required by Condition 2.10.4 for the affect ed units is being implemented. These inspections shal l be conducted by supervisory or management personnel or shall be overseen by such personnel.

ii. The Permittee shall conduct these inspections o f affected units on at least a weekly basis during constructio n of the facility and on a monthly basis thereafter with personnel not directly responsible for the day-to-d ay implementation of the operating program.78 b. The Permittee shall keep records for these inspe ctions, which shall include the following information, at a minim um:

i. Date and time the inspection was performed and t he name(s) and position(s) of inspection personnel.

ii. The observed condition of the control practices for the
affected units.

iii. A description of any changes to control practi ces that are recommended as a result of the inspection.

iv. A summary of the observed implementation or sta tus of the operating program.

v. If the inspection was not performed by superviso ry or management personnel, the name(s) and position(s) o f the supervisory or management personnel who oversaw the inspection.

vi. The condition of the pavement on principal road ways.

2.10.7 Operational Measurements

a. The Permittee shall conduct measurements of the silt loading on various affected roadway segments as follows. This sampling and analysis shall be conducted using the “Procedur es for Sampling Surface/Bulk Dust Loading,” Appendix C.1 i n Compilation of Air Pollutant Emission Factors, USEP A, AP-42. A series of samples shall be taken to determine the a verage silt loading and address the change in silt loadings as related to the amount and nature of vehicle traffic and implem entation of the operating program.

b. Measurements shall be performed by the following dates:

i. Measurements shall first be completed no later t han 30 days after construction is completed.

ii. Measurements shall be repeated within 30 days i n the event of changes involving affected units that woul d act to increase silt loading (so that data that is representative of the current circumstances of the affected units has not been collected), including c hanges in the amount or type of traffic on affected units, changes in the standard operating practices for aff ected units, such as application of salt or traction mate rial during cold weather, and changes in the operating p rogram for affected units.

iii. Upon written request by the Illinois EPA, the Permittee shall conduct measurements, as specified in the req uest, which shall be completed within 75 days of the Illi nois EPA’s request.79 c. The Permittee shall submit test plans, test noti fications and test reports for these measurements as specified by Condition 3.1, provided, however, that once a test plan has b een accepted by the Illinois EPA, a new test plan need not be su bmitted if the accepted plan will be followed unless a new tes t plan is requested by the Illinois EPA.

d. The Permittee shall keep records for the measure ments conducted for affected units pursuant to Condition 2.10.7, in cluding records for the sampling and analysis activities an d results.

2.10.8 Recordkeeping Requirements

a. The Permittee shall keep a file that contains:

i. The operating factors used to determine the amou nt of activity associated with the affected units or the particulate emissions from the affected units, with supporting documentation.

ii. The maximum PM, PM 10 and PM 2.5 emission of the facility, in tons/year, considering the maximum amounts of vehic le traffic needed for the operation of the facility, w ith supporting calculations and documentation, and confirmation that the control measures in the opera ting program are sufficient to ensure compliance with th e emission limits in Condition 2.10.5.

b. The Permittee shall maintain records documenting implementation of the operating program required by Condition 2.10 .4(a), including:

i. Records for each treatment of an affected unit o r units:

A. The identity of the affected unit(s), the date a nd time, and the identification of the truck(s) or treatment equipment used;

B. For application of dust suppressant by truck: Target application rate or truck speed during application, total quantity of water or chemical used and, for application of a chemical or chemical solution, the identity of the chemical and concentration, if applicable;

C. For sweeping or cleaning: Identity of equipment used and identification of any deficiencies in the condition of equipment; and

D. For other type of treatment: A description of t he
action that was taken.

ii. Records for each incident when control measures were not implemented and each incident when additional contr ol80 measures were implemented due to particular activit ies, including description, date, a statement of explana tion, and expected duration of such circumstances.

c. The Permittee shall keep records for any periods during which affected unit(s) were not properly controlled as re quired by this permit, which records shall include the inform ation specified by Condition 3.3, including the following , and an estimate of the additional emissions of PM, PM 10 and PM 2.5 that resulted, if any, with supporting calculations.

i. The dates that control measures were not impleme nted with a listing of those control measures.

ii. The reasons that the control measures were not implemented.

iii. The dates when controls measures were not impl emented based on a belief that implementation of such contr ol measures would have been unreasonable given prevail ing
weather conditions.

d. The Permittee shall maintain records for the PM, PM 10 , and PM 2.5 emissions of the affected units, based on data for shipments of ammonia and urea and other activities at the plant, the above records for the affected units including data for implementation of the operating program, and approp riate USEPA emission estimation methodology and emission factor s, with supporting calculations.

2.10.9 Reporting Requirements

a. The Permittee shall notify the Illinois EPA of d eviations of affected units with permit requirements with the pe riodic reports required by Condition 2.1.10(b). These not ifications shall include the information specified by Conditio n 3.4.81

SECTION 2.11: UNIT-SPECIFIC CONDITIONS FOR ENGINES

2.11.1 Description

The facility has three diesel-fueled emergency engi ne generators and one smaller diesel-fueled firewater pump engine (th e affected emergency engine generator engines and affected fir ewater pump engine, respectively). The emergency generators wi ll supply electricity to critical equipment during power outa ges. The firewater pump would be used in the event of fire. Other than during power outages or fires, these engines (the a ffected engines) will each normally be operated for less than one ho ur per week for purposes of operational testing.

2.11.2 Control Technology Determination - BACT

a. i. The emergency generator engines shall be desi gned and

operated to comply with the following limits, in grams/kW-hour, power output:

Pollutant Limit

NOx 0.67

CO 3.5 PM/PM 10 /PM 2.5 0.10 VOM (as NMHC) 0.40

Note: These limits reflect the USEPA’s Tier IV sta ndards for nonroad engines in 40 CFR Part 1039, Control ofEmissions from New and In-Use Nonroad CompressionIgnition Engines, for engines with a maximum power greater than 900 kW that power electrical generator s (40 CFR 1039.102, Table 7).

ii. The GHG emissions of the emergency generator en gines shall not exceed 432 tons/year, combined.

b. i. The firewater pump engine shall be designed a nd operated

to comply with the following limits, grams/kW-hr po wer output:

Pollutant Limit

NOx 3.5

CO 3.5 PM/PM 10 /PM 2.5 0.10 VOM (as NMHC) 0.40

Note: These limits reflect the USEPA’s Tier IV sta ndards for nonroad engines in 40 CFR Part 1039, Control ofEmissions from New and In-Use Nonroad CompressionIgnition Engines, for engines with a maximum power that is no than 900 kW (40 CFR 1039.102, Table 7).

ii. The GHG emissions of the firewater pump engine shall not exceed 72 tons/year.82

2.11.3-1 Applicable Federal Emission Standards

a. i. The affected engines are subject to the NSPS for

Stationary Compression Ignition Internal Combustion Engines, 40 CFR 60 Subpart IIII, and related provis ions in the General Provisions of the NSPS, 40 CFR 60 Su bpart

A.

ii. The emergency generator engines, as new emergen cy stationary compression ignition internal combustion engines with a displacement of less than 10 liters per cylinder that are not fire pump engines, must compl y with the NSPS standards for new emergency stationary int ernal combustion engines with rated power output greater than 560 kW, as follows. The Permittee shall comply wit h these standards by purchasing an engine certified t o these standards for the same model year and maximum engine power. The engine must be installed and configured according to the manufacturer’s specifications. [40 CFR 60.4205(b), 60.4202(b) and 60.4211(c) and 40 CFR 89.112(a) and 89.113(a)]

A. NOx + NMHC: 6.7 g/kW-hour.

B. CO: 3.5 g/kW-hour.

C. PM: 0.20 g/kW-hour.

iii. The firewater pump engine, as a new firewater pump engine with a displacement of less than 30 liters per cyli nder, must comply with the emission standards in Table 4 of 40 CFR 60 Subpart IIII applicable to units with a maxi mum engine power greater than 225 kW but less than 450 kW, as follows. The Permittee shall comply with these sta ndards by purchasing an engine certified to these standard s for the same model year and maximum (i.e., NFPA namepla te) engine power. The engine must be installed and configured according to the manufacturer’s specifications. [40 CFR 60.4205(c) and 60.4211(c)]

A. NOx + NMHC: 4.0 g/kW-hour.

B. CO: 3.5 g/kW-hour.

C. PM: 0.20 g/kW-hour.

iv. The diesel fuel used in the affected engines sh all meet the requirements of 40 CFR 80.510(b) for nonroad di esel fuel. [40 CFR 60.4207(b)].

b. As new stationary engines located at an area sou rce for HAPs, the affected engines must meet the requirements of the National Emission Standards for Hazardous Air Pollutants (NE SHAP) for Stationary Reciprocating Internal Combustion Engine s, 40 CFR 63 Subpart ZZZZ, by meeting the requirements of the NS PS, 40 CFR83 60 Subpart IIII, for compression ignition engines. No further requirements apply for the affected engines under 4 0 CFR 63 Subpart ZZZZ. [63.6590(c)]

2.11.3-2 Applicable State Emission Standards

a. The affected engines are subject to 35 IAC 212.1 23(a), which provides that no person shall cause or allow the em ission of smoke or other particulate matter, with an opacity greater than 30 percent, 6-minute average, from any emission uni t, except as allowed by 35 IAC 212.123(b) and 212.124.

b. The affected engines are subject to 35 IAC 214.3 01, which
limits emissions of SO 2 to no more than 2000 ppm.

2.11.4 Operational Limits and Work Practices

a. Except as provided by 40 CFR 60.4211(g), the Per mittee shall operate and maintain the affected engines according to the
manufacturer’s written instructions related to emis sions. In addition, the Permittee may only change those emiss ion-related settings that are permitted by the manufacturer. T he Permittee must also meet the requirements of 40 CFR Parts 89, 94 and/or 1068, as applicable. [40 CFR 60.4211(a)]

b. Pursuant to the NSPS and this permit, the affect ed engines may be operated for the purpose of maintenance checks a nd readiness testing, provided that the tests are recommended by Federal, State or local government, the manufacturer, the ve ndor, or the insurance company associated with the affected engi ne. Maintenance checks and readiness testing of the eac h engine are limited to 100 hours per year. There is no time li mit on the use of an affected engine in emergency situations. The Permittee may petition the USEPA Administrator for approval of
additional hours to be used for maintenance checks and readiness testing, but a petition is not required i f the Permittee maintains records indicating that Federal , State, or local standards require maintenance and testing of emergency engines beyond 100 hours per year. Emergency engin es may operate up to 50 hours per year in nonemergency sit uations, but those 50 hours are counted towards the 100 hours pe r year provided for maintenance and testing. The 50 hours per year for non-emergency situations cannot be used for pea k shaving or to generate income for a facility to supply power t o an electric grid or otherwise supply non-emergency pow er as part of a financial arrangement with another entity. An y operation other than emergency operation, maintenance and tes ting, and operation in non-emergency situations for 50 hours per year, as provided herein, is prohibited. [40 CFR 60.4211(f) ]

2.11.5 Emission Limits

a. The emissions of the affected emergency generato r engines shall not the following limits:84 Pollutant Limit (Each Engine) Combined
Limit Pounds/Hour Tons/Year Tons/Year

NOx 4.14 0.41 1.20

CO 21.6 2.16 6.48

PM 0.62 0.06 0.19

PM 10 /PM 2.5 0.62 0.06 0.19

VOM 2.47 0.25 0.75

GHG --- --- 430

SO 2 --- --- 0.10

Total HAPs --- --- 0.10

b. The emissions of the affected firewater pump eng ine shall not exceed the following limits:

Pollutant Limit Pounds/Hour Tons/Year

NOx 2.15 0.11

CO 2.15 0.11

PM 0.06 0.003

PM 10 /PM 2.5 0.06 0.003

VOM --- 0.10

GHG --- 72.0

SO 2 --- 0.04

Total HAPs --- 0.02

2.11.6 Operational Monitoring

a. The Permittee shall operate and maintain a non-r esettable hour meter on each affected engine.

2.11.7 Recordkeeping Requirements

a. If an affected engine does not also meet the sta ndards of the NSPS, 40 CFR 60 Subpart IIII, applicable to non-eme rgency engines in the applicable model year, the Permittee must keep records of the operation of the engine in emergency and nonemergency service that are recorded through the non -resettable
hour meter. The Permittee must record the time of operation of the engine and the reason the engine was in operati on during that time. [40 CFR 60.4214(b)]

b. The Permittee shall keep a file for the affected engines containing copies of the certifications from the ma nufacturers for the emission rates of the engines and their fue l consumption rates, in gallons per kW-hour.

c. The Permittee shall maintain records of consumpt ion of fuel by the affected engines (gallons/month, separately for the affected emergency generator engines and the affect ed firewater pump engine).

d. For the affected emergency generator engines and the affected firewater pump engine, the Permittee shall maintain the85 following records related to emissions of NOx, CO, SO 2 , VOM,
PM, PM 10 /PM 2.5 , GHG and total HAPs:

i. A file containing the maximum emission rates of each pollutant from the affected engines in pounds per g allon of fuel, pounds per hour and in the terms used in Conditions 2.11.2(a)(i) and (b)(i) and 2.11.3-1(a)( ii) and (iii), with supporting documentation and
calculations.

ii. Records of the actual emissions of each polluta nt separately for the affected emergency generator eng ines and the affected firewater pump engine (tons/month and tons/year), with supporting calculations.

2.11.8 Reporting Requirements

a. The Permittee shall notify the Illinois EPA of d eviations of the affected engines with the permit requirements w ith the periodic compliance reports required by Condition 2 .1.10(b).
These notifications shall include the information s pecified in
Condition 3.4.86

PART 3: GENERAL PERMIT CONDITIONS

CONDITION 3.1: GENERAL REQUIREMENTS FOR EMISSION T ESTING

a. i. At least 60 days prior to the actual date of initial emission

testing required by this permit, a written test pla n shall be submitted to the Illinois EPA for review. This pla n shall describe the specific procedures for testing and sh all include
at a minimum:

A. The person(s) who will be performing sampling an d analysis and their experience with similar tests.

B. The specific conditions, e.g., operating rate an d control device operating conditions, under which testing sh all be performed including a discussion of why these condi tions will be representative and the means by which the operating parameters will be determined.

C. The specific determinations of emissions that ar e intended to be made, including sampling and monitor ing
locations.

D. The test method(s) that will be used, with the s pecific analysis method if the method can be used with diff erent analysis methods.

ii. As provided by 35 IAC 283.220(d), the Permittee need not submit a test plan for subsequent emissions testing that w ill be conducted in accordance with the procedures used fo r previous tests accepted by the Illinois EPA or the previous test plan submitted to and approved by the Illinois EPA, prov ided that the Permittee’s notification for testing, as requir ed below, contains the information specified by 35 IAC 283.22 0(d)(1)(A), (B) and (C).

b. i. The Permittee shall notify the Illinois EPA p rior to performing

emissions testing required by this permit to enable the
Illinois EPA to observe the tests. Notification fo r the expected date of testing shall be submitted a minim um of 30 days* prior to the expected date, and identify the testing that will be performed. Notification of the actual date and expected time of testing shall be submitted a minimum of 5 w orking days* prior to the actual date of testing. Notwithstandi ng 40 CFR 60.8(d), the Illinois EPA may at its discretion acc ept notifications with shorter advance notice provided that the Illinois EPA will not accept such notifications if it interferes with the Illinois EPA’s ability to obser ve testing.

ii. This notification shall also identify the parti es that will be performing testing and the set or sets of operating conditions under which testing will be performed.

c. Three copies of the Final Reports for emission t ests shall be

forwarded to the Illinois EPA within 30 days after the test results87 are compiled and finalized but not later than 90 da ys after the date of testing. At a minimum, the Final Report for tes ting shall contain the following. Copies of emission test rep orts shall be retained for at least five years after the date tha t an emission test is superseded by a more recent test.

i. A tabular summary of results which includes:

- Process rates (e.g., feedstock usage rate or firi ng rate).

- Measured emission rates for different pollutants tested.

- Emission factor, calculated using the average tes t results in the terms of the applicable limits, for example, in units of lbs/mmBtu.

- Compliance demonstrated - Yes/No.

ii. Description of test method(s) and procedures, i ncluding a description of sampling points, sampling train, ana lysis equipment, and test schedule

iii. Detailed description of test conditions, inclu ding:

- Pertinent process information (e.g., usage of raw material or fuel and composition).

- Control equipment information (i.e., monitored da ta and other relevant operating parameters during testing)

.

iv. Data and calculations, including copies of all raw data sheets and records of laboratory analysis, sample calculat ions, and data on equipment calibration.

CONDITION 3.2: GENERAL REQUIREMENTS FOR “LOGS” OR SIMILAR RECORDS

a. Operating logs or other similar records required by this permit

shall, at a minimum, include the following informat ion related to the emission units and associated control system:

i. Information identifying periods when an emission unit or group
of related emission units was not in service.

ii. For periods when a unit or group of related uni ts is in service and operating normally, relevant process and contro l system information to generally confirm normal operation.

iii. For periods when a unit or group of related un its is in service and is not operating normally, identification of ea ch such period, with detailed information describing the op eration of the unit(s), the potential consequences for additio nal emissions from the unit(s), the potential of any ex cess emissions from the affected unit(s), the actions ta ken to restore normal operation, and any actions taken to prevent
similar events in the future.88 iv. Other information as may be appropriate to show that the emission unit or group of related emission units is operated in accordance with good air pollution control practice

.

b. Inspection, maintenance and repair logs or other similar information

required by this permit shall, at a minimum, includ e the following
information related to the emission units and assoc iated control system:

i. Identification of equipment, with date, time, re sponsible employee and type of activity.

ii. For inspections, a description of the inspectio n, findings, and any recommended actions, with reason.

iii. For maintenance and repair activity, a descrip tion of actions taken, reason for action (e.g., preventative measur e or corrective action as a result of inspection), proba ble cause for requiring maintenance or repair if not routine or preventative, and the condition of equipment follow ing completion of the activity.

iv. Other information as may be appropriate to show that the emission unit or group of related emission units is maintained in accordance with good air pollution control pract ices, including prompt repair of defects that interfere w ith
effective control of emissions.

c. The logs required by this permit may be kept in manual or electronic

form, and may be part of a larger information datab ase maintained by the Permittee provided that the information require d to be kept in a log is readily accessible.

CONDITION 3.3: GENERAL REQUIREMENTS FOR RECORDKEEP ING FOR DEVIATIONS

a. Except as specified in a particular provision of this permit or in a

subsequent CAAPP Permit for the plant, records for deviations from applicable requirements shall include at least the following information: the date, time and estimated duration of the deviation; a description of the deviation; the mann er in which the deviation was identified, if not readily apparent; the probable cause for deviation, if known, including a descript ion of any equipment malfunction or breakdown associated with the deviation; information on the magnitude of the deviation, incl uding actual emissions or performance in terms of the applicable standard if measured or readily estimated; confirmation that st andard procedures were followed or a description of any event-specifi c corrective actions taken; and a description of any preventativ e measures taken to prevent future occurrences, if appropriate.

CONDITION 3.4: GENERAL REQUIREMENTS FOR REPORTING OF DEVIATIONS

a. The Permittee shall include the following inform ation in records and

reports for deviations:89 i. Identity of the deviation, with date, time, dura tion and description.

ii. Describe the effect of the deviation on complia nce, with an estimate of the excess emissions that accompanied t he deviation, if any.

iii. Describe the probable cause of the deviation a nd any corrective actions or preventive measures taken.

b. i. Unless otherwise specified in a particular co ndition of this

permit, if deviation(s) from requirements of this p ermit occurs during a reporting period, a compliance report shal l be submitted no later than 45 days after the end of th e reporting period. This report shall also provide a listing o f all deviations for which immediate or 30-day reporting was required, but need not include copies of the previo usly
submitted information.

ii. If there are no deviations during a reporting p eriod, the Permittee shall still submit a compliance report, w hich report shall state that no deviations occurred during the reporting period.

c. Upon issuance of a Clean Air Act Permit Program (CAAPP) permit for

the plant, the provisions of the CAAPP permit with respect to reporting of deviations will supersede the requirem ents of this permit.90ATTACHMENTSATTACHMENT 1: SUMMARY OF THE PERMITTED EMISSIONS OF THE FACILITYaTable 1: Emissions of the Facility (tons/year)PollutantAmmonia PlantReformerFurnace Boiler Urea Plant“OtherUnits”(See Table 2) TotalFlares CO2VentsbNOx 15.1 --- 45.6 45.4 --- 14.71 120.8CO 82.3 3.4 83.6 75.7 --- 8.36 253.4VOM 11.6 14.3 22.6 20.4 1.60 11.21 81.7PM 0.15 --- 7.90 7.20 124.7 17.38 157.3PM100.15 --- 10.0 9.10 108.1 6.25 133.6PM2.50.15 --- 10.0 3.90 108.1 4.48 126.6SO20.13 --- 2.46 2.23 --- 0.17 5.0GHG 25,971 343,105 488,159 442,339 --- 2,591 1,302,165Notes:a. This summary addresses operation of the facilityafter the commissioning of the facility iscomplete. In the period prior to commissioning, operation and emissions of the flares in theAmmonia Plant and the Startup Heater would potentially be greater but operation and emissions ofother units would be lower.b. Emissions from the CO2Vent in the Urea Plant are addressed with the CO2Vent in the Ammonia Plant.91Table 2: Emissions of “Other Units” (tons/year)PollutantStartupHeaterCoolingTower EnginesaEquipmentComponentsRoadwaysProductUreaHandlingAmmoniaStorageFlare TanksbSubTotalNOx 0.60 --- 1.31 --- --- --- 12.8 --- 14.71CO 0.27 --- 6.59 --- --- --- 1.52 --- 8.36VOM 0.04 --- 0.85 9.92 --- --- 0.20 0.20 11.21PM 0.02 4.42 0.19 --- 11.71 0.94 0.10 --- 17.38PM100.06 2.47 0.19 --- 2.34 0.94 0.25 --- 6.25PM2.50.06 2.47 0.19 --- 0.57 0.94 0.25 --- 4.48SO20.01 --- 0.14 --- --- --- 0.02 --- 0.17GHG 871 --- 502 739 --- --- 479 --- 2,591Notes:a. The engines are the three emergency generator engines and the firewater pump engine.b. The tanks are the storage tanks at the facilityfor organic liquids, e.g., amine absorption solvent.92ATTACHMENT 2: SUMMARY OF THE PERMITTED HAP EMISSIONS OF THE FACILITYa, bTable 1: Emissions of the Facility (tons/year)PollutantAmmonia PlantReformerFurnaceBoilerUreaPlant"OtherUnits"(See Table2)TotalFlares CO2VentscTotal HAPs2.43 4.30 6.74 1.60 0.90 15.97Any Individual HAPd0.04 0.04Hexane--- 0.01 0.01 6.7 --- 0.01 6.73Formaldehyde--- 0.01 3.0 0.01 1.38 0.13 4.53Methanol--- 2.40 0.01 0.02 0.22 0.44 3.09Other Individual HAP (i.e., a HAPother than hexane, formaldehyde ormethanol)--- 0.01 1.28 0.01 --- 0.04 1.34Notes:a. This summary addresses operation of the facilityafter the commissioning of the facility iscomplete. In the period prior to commissioning, operation and emissions of the flares in theAmmonia Plant and the Startup Heater would potentially be greater but operation and emissions ofother units would be lower.b. Emissions of at most negligible amounts of HAPs(i.e., at most 0.001 tons/year) are shown by “---“.c. Emissions from the CO2Vent in the Urea Plant are addressed with the CO2Vent in the AmmoniaPlant.d. The limits for individual HAPs from the variousemission units are either: 1) “Generic,” withonly an emission limit set for any individual HAP,or 2) “Speciated,” with emission limits setfor hexane, formaldehyde and methanol and for “other individual HAPs,” i.e., any individual HAPother than hexane, formaldehyde and methanol.93Table 2: Emissions of the “Other Units” (tons/year)PollutantStartupHeaterAmmoniaStorageFlareCoolingTowerEquipmentComponentsProductUreaHandling RoadwaysGeneratorEnginesFirePumpEngineResinTankSubTotalTotal HAPs 0.03 0.01 0.01 0.47 0.01 0.01 0.13 0.130.10 0.90Any Indiv. HAP 0.01 0.01 0.01 0.01 0.04Hexane ---0.01 --- --- --- 0.01Formaldehyde 0.020.01 --- --- 0.10 0.13Methanol ---0.44 --- --- --- 0.44Other Indiv. HAP 0.010.01 0.01 0.01 --- 0.0494 ATTACHMENT 3: STANDARD PERMIT CONDITIONS

STANDARD CONDITIONS FOR CONSTRUCTION/DEVELOPMENT PE RMITS

ISSUED BY THE ILLINOIS ENVIRONMENTAL PROTECTION AGE NCY

The Illinois Environmental Protection Act (Illinois Revised Statutes, Chapter 111-1/2, Section 1039) authorizes the Environmental Protection Agency to impose conditions on permits, which it issues.

The following conditions are applicable unless supe rseded by special condition(s).

1. Unless this permit has been extended or it has b een voided by a newly issued permit, this permit will expire one year fro m the date of issuance, unless a continuous program of constructi on or development on this project has started by such time.

2. The construction or development covered by this permit shall be done in compliance with applicable provisions of the Illino is Environmental Protection Act and Regulations adopted by the Illin ois Pollution

Control Board.

3. There shall be no deviations from the approved p lans and specifications unless a written request for modification, along wi th plans and specifications as required, shall have been submitt ed to the Illinois EPA and a supplemental written permit issued.

4. The Permittee shall allow any duly authorized ag ent of the Illinois EPA upon the presentation of credentials, at reasonable times:

a. To enter the Permittee’s property where actual o r potential effluent, emission or noise sources are located or where any activity is to be conducted pursuant to this permit
,

b. To have access to and to copy any records requir ed to be kept under the terms and conditions of this permit,

c. To inspect, including during any hours of operat ion of equipment constructed or operated under this permit, such equ ipment and any equipment required to be kept, used, operated, cali brated and maintained under this permit,

d. To obtain and remove samples of any discharge or emissions of pollutants, and

e. To enter and utilize any photographic, recording , testing, monitoring or other equipment for the purpose of pr eserving, testing, monitoring, or recording any activity, dis charge, or emission authorized by this permit.95

5. The issuance of this permit:

a. Shall not be considered as in any manner affecti ng the title of the premises upon which the permitted facilities ar e to be located;

b. Does not release the Permittee from any liabilit y for damage to person or property caused by or resulting from the construction, maintenance, or operation of the proposed facilitie s;

c. Does not release the Permittee from compliance w ith other applicable statutes and regulations of the United S tates, of the State of Illinois, or with applicable local laws, o rdinances and regulations;

d. Does not take into consideration or attest to th e structural stability of any units or parts of the project; and

e. In no manner implies or suggests that the Illino is EPA (or its officers, agents or employees) assumes any liabilit y, directly or indirectly, for any loss due to damage, installatio n, maintenance, or operation of the proposed equipment or facility.

6a. Unless a joint construction/operation permit ha s been issued, a permit for operation shall be obtained from the Illinois E PA before the equipment covered by this permit is placed into ope ration.

b. For purposes of shakedown and testing, unless o therwise specified by a special permit condition, the equipment covered und er this permit may be operated for a period not to exceed thirty (30) days.

7. The Illinois EPA may file a complaint with the B oard for modification, suspension or revocation of a permit.

a. Upon discovery that the permit application conta ined misrepresentations, misinformation or false stateme nt or that all relevant facts were not disclosed, or

b. Upon finding that any standard or special condit ions have been violated, or

c. Upon any violations of the Environmental Protect ion Act or any regulation effective thereunder as a result of the construction or development authorized by this permit.