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: September 5, 2014 

Subject: Urea and Ammonia Production Facility 

Location: 785 East Highway 36, Tuscola 

Permit is hereby granted to the above-designated Permittee to CONSTRUCT 

emission units and air pollution control equipment consisting of a urea and 

ammonia production facility, as described in the above 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 Deterioration of Air 

Quality (PSD) for the facility, as described in the application, in that the 

Illinois EPA finds that the application fulfills all 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 Delegation of Authority 

agreement between the USEPA and the Illinois EPA for the administration of 

the PSD Program. This approval becomes effective in 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 conditions. This approval is also 

subject to the general requirement that the facility be developed and 

operated consistent with the specifications and data included in the 

application and any significant departure from the terms expressed in the 

application, if not otherwise authorized by this permit, must receive prior 

written authorization from the Illinois EPA. 

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

Raymond E. Pilapil Date Signed: ___________________ 

Acting Manager, Permit Section 

Division of Air Pollution Control 

REP:RPS:psj 
2 

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 Construction 

 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 Emission Limits 

 1.8 Records for Monitoring Systems and Instrumentation 

 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 EMISSION 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 Records 

 3.3 General Requirements for Records for Deviations 

 3.4 General Requirements for Reporting of Deviations 

90 

ATTACHMENTS 84 

 1. Summary of Permitted Emissions 

 2. Summary of the Permitted HAP Emissions of the Facility 

 3. Standard Permit Conditions 
3 

Findings 

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

that would produce urea and ammonia. Natural gas would 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 would be an 

intermediate material used in the production of urea. The facility 

would also be able to make ammonia for direct sale but this would be 

limited to 25 percent of the annual ammonia production capacity of 

the facility. This mode of operation would most likely occur in the 

spring and fall to supply the seasonal demand for ammonia. 

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 the PSD rules. This 

is because the facility will have potential emissions of nitrogen 

oxides (NOx), particulate matter (as PM, PM10 and PM2.5), and carbon 

monoxide (CO) that are more than 100 tons per year. The facility 

will also be subject to PSD for volatile organic material (VOM) 

greenhouse gases (GHG) because the facility’s potential 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 by this permit, 

the potential emissions from the facility will be less 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 (NESHAP), adopted by 

USEPA under 40 CFR 63 that apply to major sources of HAPs. A caseby-case determination of Maximum Achievable Control Technology 

(MACT) is also not required for the proposed facility pursuant to 

Section 112(g) of the federal Clean Air Act. 

4. After reviewing the materials submitted by Cronus, the Illinois EPA 

determined that the facility will be designed to: (i) comply with 

applicable state emission standards, (ii) comply with 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 Illinois 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 Control Board Air 

Pollution Control Regulations, the applicable federal New Source 

Performance Standards (NSPS), and the federal PSD rules, 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 not cause or 

contribute to violations of the National Ambient Air Quality 

Standards for NO2, PM10/PM2.5 and CO. The air quality analysis also 

shows compliance with the applicable allowable increment levels 

established under the PSD rules. 

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

the PSD rules, to address other potential impacts from the emissions 

of the proposed facility. 

8. A copy of the application, the project summary prepared by the 

Illinois EPA, and a draft of this construction permit were placed in 

a nearby public repository, and the public was given notice and an 

opportunity to examine this material and to participate 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 the responsibility to 

comply with all local, state and federal regulations that are part 

of the applicable Illinois’ State Implementation Plan, as well as 

all other applicable federal, state and local requirements. 

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

responsibility to carry out practices during the construction and 

operation of the facility, such as application of water or dust 

suppressant sprays to unpaved traffic areas, as necessary 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 effective, if 

construction is discontinued for a period of 18 months or more, or 

if construction is not completed within a reasonable period of time, 

pursuant to 40 CFR 52.21(r)(2). The Illinois EPA may extend the 18-

month period upon a satisfactory showing that an extension is 

justified. This condition supersedes Standard Condition 1. 

b. For purposes of the above provisions, the definitions 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 actual 

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 units at the facility 

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

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

of natural gas to the facility or other documentation for the 

natural gas fired in the emission units at the facility that 

confirms that it meets the criteria in the definition 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 organic liquids at the 

facility, including the tanks for CO2 absorption solvent, ureaformaldehyde additive and diesel fuel, combined, shall 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 POLLUTANTS (HAPs) 

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

source of hazardous air pollutants (HAPs), i.e., the 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 per 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 units at the facility 

and the facility as a whole shall not exceed the limits in 

Attachment 2. Compliance with these limits for various emission 

units shall be determined based on activity and operating data for 

those units and emission factors that do not understate actual 

emissions of those units, as developed from representative sourcespecific testing or analysis, USEPA methodology, or other 

authoritative source. 

c. The Permittee shall keep records of the HAP emissions of the various 

units at the facility and the facility as a whole to verify that the 

facility is not a major source of emissions of HAPs. For this 

purpose, in addition to other records required by other provisions 

of this permit, the Permittee shall keep a file containing the 

emission factors that it uses to calculate emissions 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 emission units at this facility, 

including associated air pollution control equipment, in a manner consistent 

with good air pollution control practice, as follows: 

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

breakdown, operate as practicable to minimize emissions. 

b. Conduct routine inspections and perform appropriate maintenance and 

repairs to facilitate proper functioning of equipment and minimize 

or prevent malfunctions and breakdowns. 

c. Install, calibrate and maintain required monitoring devices and 

instrumentation in accordance with good monitoring practices, 

following the manufacturer’s recommended operating and maintenance 

procedures or such other procedures as otherwise necessary 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, including BACT limits and 

other permit limits for emissions, apply at all times unless 

otherwise specified in a particular provision. 

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

standards for particulate matter under applicable regulations 

that are referenced in the conditions of this permit address 

only filterable particulate, as would be measured by USEPA 

Method 5 or 5I or other appropriate USEPA Test Methods. 

ii. Emissions limits for particulate matter10 (PM10) and particulate 

matter2.5 (PM2.5) set by this permit address both filterable and 

condensable particulate. 

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

address GHG as carbon dioxide equivalents (CO2e). 

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

are in terms of the higher heating value of the fuel burned in an 

emission unit. 

e. When emission testing is conducted, compliance with hourly limits 

set by this permit shall be determined from the average of the test 

results, commonly three runs, each nominally one hour in duration. 

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

a particular provision of this permit, compliance shall be 

determined as follows: 

i. Compliance with annual emission limits for emission units and 

pollutants for which continuous emissions monitoring is 

required by the permit shall be determined from emission data 

collected by such monitoring systems, including use of 

substitute data for periods of missing data. Compliance with 

annual emission limits for emission units and pollutants for 

which continuous emission monitoring is not required shall be 

determined from emission data calculated as the product of 

activity or operating data and emission factors that do not 

understate emissions, as developed from representative sourcespecific testing or analysis, USEPA methodology or other 

authoritative source. 

ii. Compliance with annual limits established by this 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 consider all 

emissions, including emissions during startup, shutdown, and 

malfunction and breakdown, provided however, that for 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 preceding 

months. 
8 

CONDITION 1.8: RECORDS FOR MONITORING SYSTEMS AND INSTRUMENTATION 

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

monitoring systems and instrumentation. Unless otherwise provided 

in a particular condition of this permit, the following requirements 

shall apply to such recordkeeping: 

i. For required monitoring systems, data shall be automatically 

recorded by a central data system, dedicated data logging 

system, chart recorder or other data recording device. If an 

electronic data logging system is used, the recorded data shall 

be the hourly average value of the particular parameter for 

each hour. During periods when the automatic recording 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 otherwise 

specified, with data and time both recorded, for periods when 

the associated emission unit(s) are in service, provided 

however that if data from an instrument is recorded

automatically, the above provisions for recording of data from 

monitoring systems shall apply and manual recording of data is 

not required. 

b. The Permittee shall keep records for the operation, calibration 

maintenance and repair of required monitoring systems and 

instrumentation. These operating records shall, at a minimum, 

identify the date and duration of any time when a required 

monitoring instrument or device was not in operation, with 

explanation; the performance of manual quality control and quality 

assurance procedures for the system; and maintenance 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 procedures 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 units at the facility 

that it conducts or that are conducted on its behest by individuals 

who are qualified to make such observations. For each occasion on 

which such measurements are made, these records shall include the 

formal report for the measurements if conducted pursuant to this 

permit or a request from the Illinois EPA, or otherwise 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 RECORDS 

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

permit for at least five years from the date of entry (unless a 

longer retention period is specified by a particular 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 USEPA upon 

request. 

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

facility office hours any records retained in an electronic format 

(e.g., computer) in response to an Illinois EPA or USEPA request for 

records during the course of a 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 indicated: 

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 following 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 operated 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 additional 365 

days upon request of the Permittee if additional time is needed 

to complete shakedown or perform emission testing. 

ii. The remainder of the facility, excluding the ammonia plant, may 

be operated under this construction permit for a period of 365 

days after initial startup of the ammonia plant. This period 

of time may be extended by the Illinois EPA upon written 

request by the Permittee as needed to reasonably accommodate 

unforeseen difficulties experienced during shakedown 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 permits, attached hereto and 

incorporated herein by reference, shall apply to this project, unless 

superseded by other conditions in the permit. (Refer to Attachment 3.) 
11 

PART 2: UNIT-SPECIFIC CONDITIONS FOR PARTICULAR EMISSION UNITS 

SECTION 2.1: UNIT-SPECIFIC CONDITIONS FOR THE AMMONIA PLANT 

2.1.1 Description 

The ammonia plant produces ammonia (NH3) from nitrogen and hydrogen. 

The nitrogen comes from the atmosphere. The hydrogen is made in the 

first part of the ammonia plant from natural gas by “steam 

reforming”. In steam reforming for production of ammonia, a 

hydrogen-rich stream of synthesis gas is made from natural gas and 

steam in a reformer furnace. The amount of hydrogen in this stream 

is increased in a secondary reformer where air is added to the 

stream. This is followed by shift-conversion to further increase 

the hydrogen content of the stream. 

The majority of the carbon dioxide (CO2) in the stream of synthesis 

gas is then removed using an amine absorbent solution. This 

absorbent solution is then processed in a regenerator system that 

drives the CO2 out of the solution. This process also removes 

organic compounds from the gas stream, which are sent back to the 

reformer furnace for use as fuel. 

The remaining carbon monoxide (CO) and CO2 in the stream of synthesis 

gas are then reacted with some of the hydrogen in this stream to 

convert the CO and CO2 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, which is now 

essentially only hydrogen and nitrogen, is then converted into 

ammonia in a catalytic converter. 

When urea is being produced by the facility, most of the CO2 from the 

regenerator system is fed to the urea plant where it is used in 

making urea and is not emitted. Only a small amount of CO2 is 

emitted to regulate operational pressure, either through the CO2 vent 

in the ammonia plant or another CO2 vent that is physically located 

in the urea plant. The full CO2 stream from the regenerator system 

is only emitted when ammonia is produced for direct sale, when the 

CO2 stream is vented through the CO2 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 production capacity 

of the facility. 

During startup, shutdown and upsets or “malfunctions” of the ammonia 

plant, process gases from various units in the plant, 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” handles releases 

from the later process steps, including regeneration, methanation 

and ammonia synthesis. The flares have emissions from combustion of 

both process gases and from the fuel needed for operation of the 

flares. 

For purposes of these unit-specific conditions, the “affected 

process gas vents” are the vents that release process gases from the 
12 

ammonia plant during startup, shutdown and malfunction, which are to 

be ducted to the Front End and Back End Flares, i.e., “the affected 

flares”. The “affected CO2 vents” are the main CO2 vent at the 

ammonia plant and the pressure control CO2 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: Affected CO2 Vents 

a. As the operation of the ammonia plant affects the emissions of 

CO, VOM, methane and GHG from the CO2 vents, the ammonia plant 

shall be operated and maintained in conformance with its 

physical and process design. 

b. The emissions of CO, VOM and methane from the affected CO2

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 the occurrence of 

flaring and emissions from flaring, the ammonia plant, 

including the affected flares, shall be operated and 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 CO2 vents and the vents for 

off-gas streams that are ducted to the reformer furnace: 

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 shall 

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 equipment 

in the plant, as may be needed to prepare for 

maintenance or startup. 

ii. The operating practices for the ammonia plant shall 

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 flares 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 visual 

observations to show compliance with 40 CFR 60.18(c)(1), 

which addresses the presence of visible emissions from a 

flare. 

iii. The only fuel used in the pilot burners of the flares 

shall be natural gas. These burners shall be equipped 

with automatic igniter devices for the pilot flame.

iv. The only purge gas used in the flare system when the 

ammonia plant is operating shall be nitrogen. 

c. The design emission rates of the pilot burners in 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, PM10/PM2.5 and GHG from the 

affected flares shall not exceed the limits in Condition 2.1.6. 

that apply to the flares. For the purpose of determining 

compliance with these limits for CO and VOM, emissions shall be 

determined from the CO and VOM content of the flared process 

gas using destruction efficiencies for a properly operating 

flare of no more than 98 percent. For the purpose of 

determining compliance with the limits for GHG, methane 

emissions shall be determined from the methane content of the 

flared process gas using a destruction efficiency for a 

properly operating flare of no more than 99 percent. 

2.1.2-3 Control Technology Determination – BACT: 

Limit for GHG from the CO2 Vent in the Ammonia Plant and from the CO2

Vent in the Urea Plant, the Reformer Furnace and the Boiler 

a. The GHG emissions, as carbon dioxide equivalents (CO2e), of the 

combination of the affected CO2 vents in the ammonia plant and 

the urea plant, the reformer furnace and the boiler, on an 
14 

annual average basis, rolled monthly, shall not exceed a limit 

determined as follows: 

E = {(Pu x Ru) + (Pa x Ra)} ÷ (Pu + Pa) 

Where 

E = Limit on GHG emissions, as CO2e, tons/ton ammonia produced, 

annual average, rolled monthly. 

Pu = Ammonia production sent to the urea plant (tons/year, 

rolled monthly). 

Pa = Ammonia production for direct sale (tons/year, rolled 

monthly), determined as ammonia sent to storage. 

Ru = 0.92 tons per ton of ammonia sent to the urea plant. 

Ra = 2.22 tons per ton of ammonia sent to storage. 

b. i. Notwithstanding the above, alternative values for Ru and 

Ra shall be used in the above equation, as follows, to 

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 of 

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 as 

provided for by Condition 2.1.11, which provides for 

a reduction in these values based on the 

demonstrated performance of the facility. 

ii. For this purpose, if different values of Ru and Ra apply 

in a year, the data for ammonia production for each

portion of the year shall be multiplied by the 

appropriate values of Ru and Ra for that portion of the 

year and the sum of these results shall serve as the 

numerator in the above equation. 

c. For the purpose of determining compliance with this limit and 

other limits for GHG emissions set by this permit for the CO2

vents, the reformer and the boiler, the Permittee shall 

determine GHG emissions as follows: 

i. For the reformer furnace and boiler, emissions shall be 

determined in accordance with 40 CFR Part 98 Subpart C, 

except that emissions of CH4 and N2O shall be determined 

using emission factors developed from testing of these 

units, if such testing indicates that emissions are

higher than the default factors in 40 CFR Part 98 Subpart 

C. 

ii. For the CO2 vents, CO2 emissions shall be determined in 

accordance with 40 CFR Part 98 Subpart PP and emissions 

of methane shall be determined using data from sampling 
15 

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 affected 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 affected units are subject to 35 IAC 212.321(a), which 

provides that no person shall cause or allow the emission of 

particulate matter into the atmosphere in any one hour period 

from any new process emission unit which, either alone or in 

combination with the emissions of particulate matter from all 

other similar new process emission units at a source or 

premises, exceeds the allowable emission rates specified 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 ammonia plant as any 

direct emissions of organic material from such units are to be 

flared or otherwise combusted, which will assure compliance with the 

alternative standard of 35 IAC 215.302, providing at 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 tons/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 average. 

2.1.5-2 Startup, Shutdown and Malfunction Plan 

a. i. The Permittee shall develop, implement, and maintain a 

written Startup, Shutdown, and Malfunction Plan (SSM 

Plan) that describes, in detail, procedures for operating 

and maintaining the various emission units in the ammonia 

plant during periods of startup, shutdown, and 

malfunction and a program of corrective action for 

malfunctioning equipment used to comply with the relevant 

emission standards and emission control requirements. 

This SSM Plan shall be developed to satisfy the purposes 

set forth in 40 CFR 63.6(e)(3)(i)(A), (B) and (C). In 

this regard, with respect to startups, this SSM Plan 

shall address readily foreseeable startup scenarios. 

With respect to malfunction, this SSM Plan shall identify 
16 

and address likely malfunction events with specific

programs of corrective actions, and provide that upon 

occurrence of a malfunction that will result in a 

deviation, that the Permittee shall, as soon as 

practicable, repair the affected equipment or reduce the 

operating rate of the plant so that the deviation ceases. 

ii. For the purpose of this condition, the definitions of the 

terms “startup,” “shutdown” and “malfunction” under the 

NESHAP, at 40 CFR 63.2, shall apply and be used. In 

addition, as related to the scope of the SSM Plan with 

respect to malfunctions, the plan shall also address and 

apply to failures of equipment that could reasonably 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, notification 

and reporting related to malfunctions shall be applicable 

for failures of equipment irrespective of the cause of 

such failure. 

Note: Although the ammonia plant is not a major source 

of HAPs for purposes of Section 112 of the Clean Air Act, 

this permit refers to provisions of the federal NESHAP to 

establish appropriate work practices for the startup, 

shutdown and malfunction of the ammonia plant. 

b. The Permittee shall at all times, including periods of startup, 

shutdown, and malfunction as defined at 40 CFR 63.2, operate 

and maintain the ammonia plant, in a manner consistent 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 information 

available to the Illinois EPA and USEPA, which may include, but 

is not limited to, monitoring results, review of operation and 

maintenance procedures (including the SSM Plan), review of 

operation and maintenance records, and inspection of units. 

[Reflects 40 CFR 63.6(e)(1)(i)] 

i. During periods of startup, shutdown, and malfunction of 

unit(s) in the ammonia plant, the Permittee shall operate 

and maintain such unit(s), in accordance with the 

procedures specified in the SSM Plan. The Permittee 

shall correct malfunctions as soon as practicable after 

their occurrence in accordance with the SSM Plan. To the 

extent that an unexpected event arises during a startup, 

shutdown, or malfunction, the Permittee shall comply by 

minimizing emissions during such event consistent with 

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 startup, 

shutdown, or malfunction (including actions taken to 
17 

correct a malfunction) are consistent with the procedures 

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 records 

of the occurrence and duration of each startup, shutdown, 

or malfunction of operation. Furthermore, the Permittee 

shall confirm in the periodic compliance report (refer to 

Condition 2.1.10(b)) that actions taken during periods 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 startup, 

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 taken 

for that event and must promptly report such actions as 

specified by 40 CFR 63.6(d)(5), unless otherwise 

specified elsewhere in this permit or when superseded 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 Plan prior to 

the initial startup of the ammonia plant. The Permittee 

shall make changes to the SSM Plan if required by the 

Illinois EPA or as necessary to satisfy the requirements 

of this permit or address other changes to procedures for 

the ammonia plant. [Reflects 40 CFR 63.6(e)(3)(vii) and 

(viii)] 

ii. This SSM Plan is a record required by this permit, which 

the Permittee must retain in accordance with the general 

requirements for retention and availability of records. 

In addition, when the Permittee revises the SSM Plan, the 

Permittee must also retain and make available the 

previous (i.e., superseded) versions of the SSM Plan 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 Condition 2.1.2-

2(a)(ii)(B) shall include the preparation and maintenance of a 

Flare Minimization Plan (Plan) for the ammonia plant that 

include the following: 

 i. Technical information for the ammonia plant, including a 

general description of the ammonia plant, including

process flow diagram(s) depicting all process units, 

detailed process flow diagram(s) for the affected flares, 

including process gas lines, knockout pots, surge drums, 
18 

seal drums, and other significant components of the

flares. 

 ii. A general description of the Permittee’s written 

procedures for the operation of the ammonia plant. 

 iii. A detailed description of the Permittee’s procedures for 

flaring due to the occurrence of malfunctions, as caused 

by process upsets, equipment failures or other reasons, 

including the provisions in these procedures that act to 

minimize flaring. 

 iv. A detailed description of the Permittee’s procedures to 

minimize flaring in conjunction with the startup and 

shutdown of equipment. 

 v. A general description of the Permittee’s procedures for 

preventative maintenance of equipment in the ammonia 

plant, including the provisions in these procedures that 

should act to minimize flaring. 

 vi. A description of the established responsibilities of 

different personnel at the ammonia plant for the 

operation and maintenance of the plant. 

 vii. A detailed description of the Permittee’s procedures for 

periodic evaluation of flaring activity generally and 

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 flaring. 

 viii. An evaluation of preventative measures to reduce 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 past 

flaring activity as information for actual operation of 

the plant becomes available: 

A. Flaring that could reasonably be expected to occur 

or has occurred during startup or shutdown. 

B. Flaring that could reasonably be expected to occur 

or has occurred due to issues of ammonia quality. 

C. Flaring caused by the recurrent failure of equipment 

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 complete, the Plan 

shall also include a description of additional procedures or 
19 

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 reduce 

flaring which shall specify the year of installation or 

implementation of each measure. 

ii. Measures that are planned, which shall specify the year 

in which operation or implementation of each planned 

measure is scheduled. 

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

the Illinois EPA for review and comments at least 90 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 current and 

reflects any changes in the operation of the ammonia 

plant. 

iii. The Permittee shall make changes to the Plan if required 

by the Illinois EPA or USEPA to address an apparent

deficiency identified in the Plan or as otherwise needed 

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 accordance 

with the general requirements for retention and 

availability of records. In addition, when the Permittee 

revises the Plan, the Permittee must also retain and make 

available the previous versions of the Plan for a period 

of at least 5 years after such revision. 

d. After the shakedown of the ammonia plant is complete, the 

Permittee shall also conduct an event-specific investigation 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 minimize 

emissions from flaring, as follows. For this purpose, 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 shall 

consist of a systematic investigation of the incident 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 practice, to 

minimize the likelihood of a recurrence of the root cause 
20 

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 Illinois EPA 

for each Root Cause Analysis, which report shall include 

the following information: 

A. Date, time and duration of the incident, and a 

description of the incident. To the extent that the 

incident involved multiple releases within a 24-hour 

period 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 incident 

and the estimated actual emissions of NOx, CO, VOM,

PM, PM10/PM2.5, methane and CO2 from the incident, 

with supporting data and calculations. 

C. A detailed analysis that sets forth the root cause 

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 or 

contributing causes in the future, which analysis 

discusses and evaluates the alternatives, if any, 

that are available, including possible operation and 

maintenance changes, the probable effectiveness of 

various alternatives, and the cost of the various 

alternatives. 

E. If the analysis concludes that corrective actions 

are required, a description of those actions and, if 

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 investigation shall 

be submitted to the Illinois EPA within 45 days of the 

date of the incident. If the investigation is still 

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 complete 

follow-up report will be submitted, with explanation why 

it is not yet practical to submit a complete report for 

the incident. Thereafter, the Permittee shall submit 

follow-up report(s) for the incident at least every 45 
21 

days until a complete final report is submitted for the 

incident. 

e. Planning and other activities conducted by the Permittee 

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 pursuant 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 exceed the 

following limits: 

Pollutant 

Limit (tons/year) 

CO2

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 

PM10/PM2.5 --- 0.15 0.15 

SO2 --- 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 emitted in 

the greatest amount is methanol. 

b. Notwithstanding the above, until the commissioning 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 CO2 vents and the flares 

shall not exceed the limit for total GHG emissions of the 

ammonia plant and the separate limits for GHG emissions of the 

CO2 vents and the flares shall not apply and the limits for the 

flares for emissions of other pollutants shall apply 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 verify 

compliance with 40 CFR 60.18(c)(1). 

ii. Perform sampling and analysis of the heat content of the 

process gas streams that are sent to each flare in 

accordance with 40 CFR 60.18(f)(3) to verify compliance 

with 40 CFR 60.18(c)(3). 
22 

b. Test notifications and test reports shall be submitted to the 

Illinois EPA in accordance with the Condition 3.1(b) and (c). 

2.1.8-1 Monitoring and Instrumentation for the Ammonia Plant 

a. The Permittee shall install, calibrate, maintain, and operate 

continuous monitoring systems to measure the gas flow through 

each affected CO2 vent (scf/hour). These monitoring systems 

shall be operated as specified by the relevant provisions of 

the NSPS, 40 CFR 60.107a(f). 

b. The Permittee shall install, operate and maintain 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 and 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 Flares 

a. The Permittee shall install, operate and maintain continuous 

monitoring systems on each affected flare for the total flow of 

process gas to the flare (scfm). These monitoring systems 

shall be operated as specified by the relevant provisions of 

the NSPS, 40 CFR 60.107a(f). 

b. The Permittee shall continuously monitor each affected flare 

for the presence of a flare pilot flame using a thermocouple 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 maintain 

instrumentation on each affected flare for the usage of pilot 

gas, in scfm. If this instrumentation is equipped with an 

automatic data recorder, measured data shall be recorded on a 

daily average basis, as well on an hourly average basis. 

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 required 

operational monitoring systems for each flare and associated 

equipment, which shall include the following information. A 
23 

copy of these procedures shall be submitted to the Illinois EPA 

for review prior to the initial startup of the ammonia plant. 

i. A process flow diagram of the affected flare and

associated equipment as related to flaring, identifying 

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 the 

process gas lines. 

ii. Drawing(s), with dimensions, showing the sampling 

location(s) at which sampling or monitoring is conducted, 

accompanied by an explanation of the methods used to 

select these sampling locations for sampling of flare 

process gas, flow of flare process gas and pilot gas; 

on/off flow indicators; operating parameters of the

liquid seal; and operating parameters of the ammonia 

plant that could provide credible information on the 

occurrence or nature of flaring. 

iii. The type, make, and model of each monitoring device or 

instrument used for required monitoring, with a 

description of manufacturer’s specifications for the 

device, including but not limited to range, precision, 

accuracy, calibration, and recommended procedures for 

quality control, quality assurance and maintenance.

iv. A description of the data collection and recording 

device(s) used to store data collected by required 

monitoring systems. 

v. A description of the periods when visual observation(s) 

would be conducted to verify flame stability, as provided 

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 conditions for 

the flare during which flow rates of process gas would be 

determined by engineering analysis, rather than by 

monitoring, if any, including an explanation why monitors 

would not provide reliable data during such conditions 

and the types of engineering analysis that would be used 

in place of monitoring. 

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

a. The Permittee shall take representative samples of the CO2

stream from the regenerator that is emitted through the 

affected CO2 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 shall have 

these samples analyzed using applicable ASTM methods for CO, 

VOM, methane, CO2 and HAP content. The process gas streams 

shall also be analyzed for heating value, in accordance with 40 

CFR 60.18(f)(3). 
24 

b. This activity shall be conducted: 

i. Within 15 days after achieving the maximum production 

rate at which the ammonia plant will be operated but not 

later than 30 days after initial startup of the ammonia 

plant. 

ii. On a periodic basis thereafter, as follows: 

A. For the CO2 stream from the regenerator, on at least a 

monthly basis. 

B. For gas streams in the ammonia plant that are or could 

be vented to the flares, on at least a monthly basis 

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 Illinois EPA, 

for process streams as specified in the request. 

c. The Permittee shall maintain records for this sampling and 

analysis activity. 

2.1.9-1 Recordkeeping Requirements for the Affected CO2 Vents 

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

of the affected CO2 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 related to the 

emissions of HAPs from each affected CO2 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 operating 

data and applicable emission factors, with supporting 

calculations. 

2.1.9-2 Recordkeeping Requirements for the Affected Flares 

a. The Permittee shall maintain a file or other record for each 

affected flare containing the design destruction efficiencies 

of the flare for CO, VOM, and methane and the design emission 

rates of the pilot burners for NOx and CO, with supporting 

documentation. 

b. The Permittee shall maintain an operating log or other similar 

records for the ammonia plant that includes the information 

specified in Condition 3.2(a) and the following detailed 

information: 
25 

i. For each startup, the nature of the startup, the timing 

of major steps in the startup, any unusual occurrences 

during the startup, and any deviations from the 

established startup procedures, with explanation. 

ii. For each shutdown, the nature and reason for the 

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 procedures were 

followed. 

iv. Confirmation that the flare(s) functioned properly, 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 sent 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 emissions. 

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 related to 

emissions of NOx, CO, VOM, PM, PM10/PM2.5, SO2, 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 each 

pollutant from the flare, based on operating data and 

applicable emission factors, with supporting 

calculations. 

e. The Permittee shall keep records for any deviations from 

applicable requirements involving the affected flares, which 

records shall include the information specified by Condition 
26 

3.3. These records may be combined with other records required 

for the ammonia plant by this permit. 

f. The Permittee shall maintain inspection, maintenance and repair 

log(s) or other similar records for the affected flares 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 records to show 

compliance with the limit in Condition 2.1.2-3 for the ammonia 

manufacturing process (i.e., the combination of the affected 

CO2 vents, the reformer furnace (Section 2.2) and the boiler 

(Section 2.3)) for GHG emissions, for each 12 consecutive 

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 permit 

requirements as follows. Reports shall include the information 

specified by Condition 3.4: 

i. Failure of an affected flare, e.g., loss of combustion, 

when operation continues for more than 1 hour (60 

minutes) shall be reported to the Illinois EPA’s regional 

office by telephone as soon as possible during normal 

working hours, but no later than three days. 

ii. The deviations addressed above and all other deviations 

shall be reported in the quarterly compliance reports 

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 later than 30 

days after the end of each quarterly reporting period. 

i. Information related to excess emissions and deviations 

during the reporting period, if any. When no excess 

emissions or deviations have occurred or the continuous 

emissions monitoring system(s) have not been inoperative, 

repaired, or adjusted, such information shall be stated 

in the report. 
27 

ii. A summary of operation and emissions of the ammonia plant 

during the reporting period, including the total number 

of startups of the plant, the amount of ammonia produced 

by the plant, the amount of ammonia sent to storage, and 

the emissions of NOx, CO, PM, PM10/PM2.5, VOM, and GHG 

during the reporting period (tons). 

iii. A listing of each flaring event during the reporting 

period, i.e., each period when process gas was flared, with 

date and duration, a description of the event, including 

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 shall submit a 

report to the Illinois EPA for flaring during the previous 

year, which report shall: 

i. Provide the information specified in Condition 

2.1.10(b)(iii) for flaring events during the previous 

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-specific 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 activity for 

the preceding two years as required by Condition 

2.1.10(c)(ii), as reported in earlier reports, as these 

summaries become available. 

iv. Summarize actions or measures implemented during the 

previous year to reduce flaring pursuant to the Root 

Cause Analyses required by Condition 2.1.5-3(d), and the 

observed effect of these actions, and the actions or 

measures planned for implementation during the current 

year to reduce flaring pursuant to Root Cause Analyses, 

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 and 

observed effect of these actions, and other actions or 

measures planned for implementation during the current 

year to reduce flaring, and the reason for and expected 

effect of these actions. 

vi. Include a listing of changes, if any, made to the 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 any, 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 additional reports for 

the ammonia plant during the shakedown period and the year 

following the shakedown period: 

i. The Permittee shall provide the Illinois EPA with notice 

at least 15 days prior to initial startup of the ammonia 

plant. 

ii. During the shakedown period for the ammonia plant, the 

Permittee shall promptly notify the Illinois EPA of any 

event(s) that disrupts orderly shakedown of the facility. 

iii. During the shakedown period for the ammonia plant, the 

periodic compliance reports required by Condition 

2.1.10(b) shall also include the following information: 

A. Operating data for the ammonia plant, i.e., total 

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 within 30 days of 

the date that commissioning of the ammonia plant is complete, 

if this date is different than the date that shakedown 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 Ru and Ra used in the GHG emission limit 

for the facility in Condition 2.1.2-3(a) shall be lowered 

based on actual operation and emissions of the facility 

unless the Permittee demonstrates and the Illinois EPA 

concurs, based on an evaluation as provided pursuant 

Condition 2.1.11(b), that the limit that would result 
29 

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 maintenance 

and repair needed for the facility. 

ii. This permit will be revised to set lower values for Ru

and Ra that the Illinois EPA finds, after considering 

actual operation of the facility and the evaluation

performed by the Permittee, that the facility can and 

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 the 

Illinois EPA for review and comment. The initial plan 

shall be submitted to the Illinois EPA no later than 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 evaluation is 

submitted, the Permittee shall submit an annual progress 

report for this evaluation. This report shall include 

information describing the status of the ammonia 

manufacturing process, including actions that have been 

carried out or are still planned to improve the energy 

efficiency of the process and reduce GHG emissions and 

any circumstances that acted to result in higher than 

normal GHG emissions, with description and explanation. 

This report shall also include data for the GHG emission 

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 detailed 

report submitted to the Illinois EPA within three years 

after the date that commissioning of the facility is 

complete or four years after initial startup, whichever 

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 Ru and Ra. 

iv. The submittal by the Permittee of the final report for 

this evaluation shall constitute submittal of an 

application to the Illinois EPA for a revised permit for 

the purpose of implementation of Condition 2.1.11(a). 
30 

SECTION 2.2: UNIT-SPECIFIC CONDITIONS FOR THE REFORMER FURNACE 

2.2.1 Description 

The reformer furnace (the affected reformer) is a process heater 

used in the production of hydrogen for the manufacture 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 hydrogen and 

carbon monoxide. The fuel fired in the reformer furnace is a 

combination of natural gas and process off-gases from the ammonia 

plant. The reformer will be equipped with a selective 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 maintained in 

conformance with the manufacturer’s design, which shall 

include the following features: 

A. Low-NOx burners and selective catalytic reduction. 

B. Automated combustion management, with an oxygen trim 

system. 

ii. The affected reformer shall be operated and maintained 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 

PM10/PM2.5 0.0024, 3-hour average 

VOM 0.0054, 3-hour average 

Note: The GHG emissions of the affected reformer are 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 state standards: 

a. The emission of smoke or other particulate matter shall not 

have an opacity greater than 20 percent, 6 minute average, 

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 under 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 not a “steam 

generating unit” as defined by 40 CFR 60.41b. 

b. The affected reformer is not subject to the NESHAP 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 affected reformer 

shall not exceed 955 mmBtu/hour. 

b. The only fuels combusted in the affected reformer shall be 

natural gas and process off-gas from the ammonia plant. 

c. For purposes of Condition 1.6, which generally requires 

implementation of good air pollution control practice, the 

Permittee shall operate and maintain the affected reformer and 

associated SCR system in accordance with written procedures 

developed and maintained by the Permittee. These procedures 

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 

PM10/PM2.5 2.3 10.0 

VOM 5.2 22.6 

SO2 --- 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 emitted in 

the greatest amount is formaldehyde. 
32 

2.2.7 Emission Testing Requirements 

a. The Permittee shall have emissions testing performed for the 

affected reformer as follows at its expense by a qualified 

testing service while the affected reformer is operating at 

maximum rates and under other representative operating 

conditions: 

i. Emissions testing shall be conducted for emissions of 

filterable PM, filterable PM10 and PM2.5, condensable PM, 

VOM, hexane, methane, N2O and HAP as specified below, 

provided, however, that if the Permittee considers all 

filterable PM10 emissions to be emissions of filterable 

PM2.5, testing for emissions of filterable PM2.5 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 emission 

tests as provided below as requested by the Illinois 

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 methods 

adopted by or being developed by USEPA or other 

alternative test methods are approved by the Illinois 

EPA. 

Filterable PM Method 5 or 5I 

Filterable PM10 & PM2.5 Method 5I or 201A 

Condensable PM Method 202 

VOM Method 25A 

N2O and Methane Method 320 

Hexane Method 320 

HAPs Method 320 

c. i. Test plans, test notifications, and test reports shall be 

submitted to the Illinois EPA in accordance with the 

Condition 3.1. 
33 

ii. In addition to other information required in a test 

report, test reports shall include detailed information 

on the operating conditions of the affected reformer 

during testing, including: 

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

B. Oxygen content in the flue gas and other significant 

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 install, 

calibrate, operate and maintain CEMS for NOx and CO emissions 

and the concentration of CO2 or O2 in the exhaust. 

i. The procedures under 40 CFR 60.13 shall be followed for 

installation, evaluation, and operation of these CEMS. 

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 emissions in 

the NSPS, 40 CFR 60.48b shall be followed for the NOx 

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 unit. 

iii. The 1-hour average NOx and CO emission rates measured 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 points as 

provided for by 40 CFR 60.13(h)(2), except as provided by 

40 CFR 60.48b(b)(2). 

iv. These CEMS shall also be used to determine compliance 

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 install, 

certify, operate and maintain a CEMS for CO2 emissions. This 

CEMS shall be operated in accordance with applicable 

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 affected 

reformer for fuel consumption (scf/hour). 

b. i. The Permittee shall equip, operate, and maintain 

instrumentation on the SCR system for the affected 

reformer for the SCR reagent injection rate, flue gas 

temperature at the inlet of the SCR catalyst and other 

operating parameters of the SCR system that are relevant 

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 for the affected 

reformer in accordance with Method 9 on at least an annual basis if 

visible emissions are normally present, as determined by Method 22. 

2.2.9 Recordkeeping Requirements 

a. The Permittee shall maintain a file that contains the following 

information for the affected reformer: 

i. A record of the maximum design heat input capacity of the 

reformer, in mmBtu/hour, with supporting documentation. 

ii. The Permittee’s established operating and maintenance 

procedures for the reformer. 

iii. Records for all opacity measurements made in accordance 

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 observations. 

For each occasion on which such measurements are made, 

these records shall include the formal report for the 

measurements if conducted pursuant to Condition 2.2.8-3, 

or otherwise the identity of the observer, a description 

of the measurements that were made, the operating 

condition of the affected reformer, the observed opacity, 

and copies of the raw data sheets for the measurements. 

b. The Permittee shall maintain records for the amount 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 information: 

i. For each startup of the reformer, identification or any 

deviations from the normal startup procedures, as set 
35 

forth in the Permittee’s written operating procedures, 

with explanation. 

ii. For each shutdown of the reformer, the nature and reason 

for the shutdown, any unusual occurrences during the 

shutdown, and any deviations from the normal shutdown 

procedures, as set forth in the Permittee’s written

operating procedures, with explanation. 

d. The Permittee shall keep the following records for 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 and 

maintenance procedures, including a catalyst management 

plan. 

ii. Usage of SCR reagent on a monthly basis. 

e. The Permittee shall maintain records of the following 

information for NOx and CO emissions from the affected reformer 

for each operating day: 

i. Calendar date. 

ii. The measured average hourly emission rates (expressed in 

lbs/mmBtu and lbs/hour). 

iii. The 30-day average emission rates (lbs/mmBtu and 

lbs/hour) calculated at the end of each operating day 

from the measured hourly emission rates for the preceding 

30 unit operating days. 

iv. Identification of the operating days when the calculated 

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 corrective 

actions taken. 

v. Identification of the operating days in which NOx or CO 

emission data have not been obtained, including a 

description of corrective actions taken. 

vi. Identification of the times when NOx or CO emission data 

have been excluded from the calculation of average 

emission rates and the reasons for excluding data. 

vii. Identification of “F” factor used for calculations and 

the method of determination. 

viii. Identification of the times when the concentration of NOx 

or CO exceeded full span of the CEMS. 
36 

ix. Description of any modifications to the CEMS that could 

affect the ability of the CEMS to comply with Performance 

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 reformer 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 related to the 

emissions of NOx, CO, PM, PM10/PM2.5, VOM, SO2, GHG, hexane, 

other individual HAP, and total HAPs from the affected 

reformer: 

i. If continuous monitoring is performed for a pollutant, 

the emissions of the pollutant from the affected reformer 

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 uses 

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 Conditions 

2.2.2, 2.2.3 and 2.2.6 shall be reported with the reports 

required by Condition 2.2.10(b). 

ii. Other deviations shall be reported within 30 days 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 reports to the 

Illinois EPA for the affected reformer, which reports shall 
37 

include the following information. These reports shall be 

submitted on a semi-annual basis, with each report submitted no 

later than 30 days following the end of the reporting period: 

i. Information related to excess emissions and deviations: 

A. As related to the limits for NOx 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 occurred 

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 BOILER 

2.3.1 Description 

The boiler (the affected boiler) will supply steam to the reformer 

for production of hydrogen. The boiler will fire natural gas. 

2.3.2 Control Technology Determination - BACT 

a. i. The affected boiler shall be operated and maintained in 

conformance with the manufacturer’s design, which shall 

include the following features: 

A. Low-NOx burners and selective catalytic reduction 

(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 maintained in 

accordance with good combustion practices. 

b. The emissions of the affected boiler shall not exceed 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 

PM10 0.0024, 3-hour 

PM2.5 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 under the federal 

NSPS for Industrial-Commercial-Institutional Steam Generating 

Units, 40 CFR 60 Subpart Db. For the affected boiler, 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 not exceed 86 

ng/J (0.20 lb/million Btu) on a 30-day rolling average, 

pursuant to 40 CFR 60.44b(a),on and after the date on which the 

initial performance test is completed or is required to be 

completed under 40 CFR 60.8, whichever date comes first. 
39 

c. Pursuant to the NSPS, 40 CFR 60.11(d), at all times the 

Permittee shall, to the extent practicable, maintain and 

operate the affected boiler in a manner consistent with good 

air pollution control practice for minimizing emissions. 

2.3.3-2 Applicable State Emission Standards 

The affected boiler is subject to the following state standards: 

a. The emission of smoke or other particulate matter shall not 

have an opacity greater than 20 percent, 6-minute average, 

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 generating 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 provisions of the NSPS, 

40 CFR 60 Subpart Db, as follows, not being applicable to the 

affected boiler: 

i. The limits of this NSPS for PM and opacity, because this 

boiler only burns natural gas. 

ii. The SO2 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 NSPS, 40 CFR 

60.48b, because this boiler only burns gaseous fuels, 

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 requirements 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 at Area 

Sources, 40 CFR 63 Subpart JJJJJJ, because the affected 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 affected 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 requires 

implementation of good air pollution control practice, 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 developed and 

maintained by the Permittee. These procedures may incorporate 

the manufacturer’s recommendations for operation and 

maintenance of the SCR system. 

2.3.6 Emission Limits 

a. The emissions of the affected boiler shall not exceed the 

following limits. 

Pollutant 

Limits 

Pounds/Hour Tons/Year 

NOx 17.28 45.4 

CO 31.1 75.7 

PM 1.64 7.20 

PM10 2.11 9.10 

PM2.5 0.88 3.90 

VOM 4.67 20.4 

SO2 --- 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 emitted 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 under the 

NSPS, including 40 CFR 60.8 and 60.46b(e). 

b. The Permittee shall have emissions testing conducted for the 

affected boiler as follows, at its expense by a qualified 

testing service under representative operating conditions, for 

emissions of PM, filterable PM10 and PM2.5, condensable PM, VOM, 

formaldehyde, hexane, methane and N20 provided, however, that 

if the Permittee considers all filterable PM10 emissions to be 

emissions of filterable PM2.5, testing for emissions of 
41 

filterable PM2.5 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 days 

after achieving the maximum rate at which the boiler 

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 following 

methods, shall be used for testing, unless other methods 

adopted by or being developed by USEPA or other 

alternative test methods are approved by the Illinois 

EPA. 

Filterable PM Method 5 or 5I or 201A 

Filterable PM10/PM2.5 Method 5I or 201A 

Condensable PM Method 202 

VOM Method 18 or 25A 

N2O and methane Method 320 

Hexane Method 320 

HAPs Method 320 

c. i. Test plans, test notifications, and test reports shall be 

submitted to the Illinois EPA in accordance with the 

Condition 3.1. 

ii. In addition to other information required in a test 

report, test reports shall include detailed information 

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 boiler, the 

Permittee shall install, calibrate, operate and maintain a CEMS 

for NOx emissions discharged from the affected boiler and the 

concentration of CO2 or O2 in the exhaust. 

i. The procedures under 40 CFR 60.13 shall be followed for 

installation, evaluation, and operation of these CEMS. 

This CEMS shall be operated during all periods of 

operation of the affected boiler except for CEMS 

breakdowns and repairs. This CEMS shall obtain emission 

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 is to 

be obtained in the scheduling and course of performing 

calibration checks, and zero and span adjustments as 

specified in the NSPS.* 

* Fulfillment of the above criteria for availability 

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 pursuant 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 compliance with 

the NOx limits in Conditions 2.3.3-1(b), 2.3.2(b) and 

2.3.6(a). 

b. The Permittee shall install, calibrate, operate and maintain 

CEMS for measuring CO emissions from the affected boiler. 

i. The relevant monitoring procedures in 40 CFR 60.48b(j)(4) 

shall be followed for these CEMS until and unless USEPA 

adopts procedures that would be directly applicable for 

continuous monitoring of CO emissions from the boiler. 

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 affected 

boiler for fuel usage, scf/hour. 

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

Permittee shall equip, operate, and maintain 
43 

instrumentation on the SCR system for the affected 

reformer for the SCR reagent injection rate, flue gas 

temperature at the inlet of the SCR catalyst and other 

operating parameters of the SCR system that are relevant 

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 annual basis if 

visible emissions are normally present, as determined by Method 

22. 

2.3.9 Recordkeeping Requirements 

a. The Permittee shall maintain a file or other record containing 

the following information for the affected boiler: 

i. The maximum design heat input capacity of the affected 

boiler, mmBtu/hour, with supporting documentation. 

ii. The Permittee’s established operating and maintenance 

procedures for the affected boiler. 

b. An operating log or other records for the affected boiler that, 

at a minimum, shall include the information specified in 

Condition 3.2 and the following information: 

i. Information for each startup and shutdown, including 

date, time and duration, as required by 40 CFR 60.7(b). 

ii. Information for any incident in which the operation of 

the affected boiler continued during malfunction or

breakdown, including: date, time, and duration; a 

description of the incident; whether emissions exceeded 

or may have exceeded any applicable standard; a 

description of the corrective actions taken to reduce 

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 operating records 

for the affected boiler: 

i. Daily records of fuel use, which records shall be prepared 

and maintained following the procedures of 40 CFR 

60.49b(d); 

ii. Amount of fuel consumed, (scf/month and scf/year) and the 

annual capacity factor, determined on a 12-month rolling 

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 certify 

that the gaseous fuel meets the definition of natural gas 

as defined in 40 CFR 60.41b and the applicable sulfur 

limit. 

d. The Permittee shall maintain records of the following 

information for the NOx emissions of the affected boiler for 

each operating day, pursuant to 40 CFR 60.49b(g) unless 

alternative recordkeeping requirements are approved for the 

boiler in conjunction with USEPA approval of alternative 

monitoring procedures under the NSPS: 

i. Calendar date. 

ii. The measured average hourly emission rates (expressed in 

lbs/mmBtu heat input). 

iii. The 30-day average emission rate (lbs/mmBtu heat input 

and lbs/hour) calculated at the end of each operating day 

from the measured hourly emission rates for the preceding 

30 unit operating days. 

iv. Identification of the operating days when the calculated 

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 corrective 

actions taken. 

v. Identification of the operating days for which emission 

data have not been obtained, including a description of 

corrective actions taken. 

vi. Identification of the times when emission data have been 

excluded from the calculation of average emission rates 

and the reasons for excluding data. 

vii. Identification of “F” factor used for calculations, 

method of determination, and type of fuel combusted. 

viii. Identification of the times when the pollutant 

concentration exceeded the full span of the CEMS. 

ix. Description of any modifications to the CEMS that could 

affect the ability of the CEMS to comply with Performance 

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 for the CO 

emissions of the affected boiler: 
45 

i. All measurements needed to demonstrate compliance with 

the applicable standards and limits for CO including, but 

not limited to, 15-minute averages of CEMS data and raw 

performance evaluation measurements that support data 

that the Permittee is required to report. 

ii. Records of CO emissions as compared to applicable limits 

and standards and the date, start time and duration of 

any deviation from an applicable standard or limitation, 

and whether the deviation occurred during startup, 

shutdown or malfunction. 

iii. Each period during which the CEMS is malfunctioning 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 determine 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 boiler that 

contain the information specified in Condition 3.2(b). 

g. The Permittee shall keep the following records related to the 

emissions of NOx, CO, VOM, SO2, PM, PM10/PM2.5, GHG, hexane, 

other individual HAP and total HAPs from the affected boiler: 

i. If continuous monitoring is performed for a pollutant, 

the emissions of the pollutant from the affected boiler 

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 notification and 

reporting requirements of the NSPS, 40 CFR 60.7 and 60.49b, for 

the affected boiler by sending required notifications and 

reports to the Illinois EPA, including the following reports: 
46 

i. Reports containing the information recorded under 40 CFR 

60.49b(g) and (j). 

ii. Periodic reports for excess emissions, as further 

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 the 

affected boiler during the reporting period, pursuant 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 shall 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 days 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 reports 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 on a semiannual basis, with each report submitted no later than 30 days 

following the end of the reporting period: 

i. As related to the NSPS standard for NOx (Condition 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 reporting 

period, if any, which shall include the information

specified by Condition 3.4. 

iii. When no excess emissions or deviations have occurred or 

the CEMS have not been inoperative, repaired, or 

adjusted, such information shall be stated in the report. 
47 

d. If the Permittee proposes to use an add-on control 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 combination of lowNOx burners and the proposed equivalent add-on control 

technology will comply with the NOx emission limit in Condition 

2.3.2(b), i.e., 0.0120 lb/mmBtu, 30-day average, rolled daily. 
48 

SECTION 2.4: UNIT-SPECIFIC CONDITIONS FOR THE STARTUP HEATER 

2.4.1 Description 

The startup heater (the “affected unit”) is a natural gas-fired 

process heater for the ammonia plant. This heater is used during 

startup of the ammonia plant to heat a process stream (i.e., a 

recycle stream going to the catalyst beds in the ammonia converter) 

until the temperature is high enough that this reaction is selfsustaining. 

2.4.2 Control Technology Determination - BACT 

a. i. The affected unit shall be operated and maintained in 

accordance with the manufacturer’s design, which shall 

include low-NOx burners. 

ii. The affected unit shall be operated and maintained in 

accordance with good combustion practices. 

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

exceed 0.08, 0.037, 0.0054, 0.0019 and 0.0075 lb/mmBtu 

for NOx, CO, VOM, PM and PM10/PM2.5, respectively. 

ii. The annual emissions of GHG from the affected unit 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 matter shall not 

have an opacity greater than 30 percent, 6-minute average, 

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 Institutional 

Boilers at Area Sources because the affected unit is a process 

heater, as defined by 40 CFR 63.11237. 

2.4.5 Operational Production Limits and Work Practices 

a. The rated heat input capacity of the affected unit shall not 

exceed 104 mmBtu/hour. 
49 

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

c. After the completion of commissioning of the ammonia plant or 

one year after the initial startup of the ammonia plant, 

whichever occurs first, the fuel usage of the affected unit 

shall not exceed 14.61 million scf per year. 

2.4.6 Emission Limits 

a. The emissions of the affected unit shall not exceed 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 

PM10/PM2.5 0.80 0.06 

VOM 0.60 0.04 

SO2 --- 0.01 

Total HAPs --- 0.01 

GHG --- 871 

b. Notwithstanding the above, until the commissioning of the 

ammonia plant is complete or one year after initial startup of 

the ammonia plant, whichever occurs first, the above 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 maintain a file 

containing information for the heat input capacity and design 

emission rates, with supporting documentation as provided 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 information 

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 deviations 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 records required 

for the affected unit. 

f. The Permittee shall maintain records of the emissions of NOx, 

CO, PM, PM10/PM2.5, VOM, SO2, GHG and total HAPs from the 
50 

affected unit (tons/month and tons/year), with supporting 

documentation and calculations. 

2.4.8 Reporting Requirements 

a. The Permittee shall notify the Illinois EPA of deviations 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 specified in 

Condition 3.4. 
51 

SECTION 2.5: UNIT-SPECIFIC CONDITIONS FOR THE AMMONIA STORAGE FLARE 

2.5.1 Description 

The ammonia storage flare (the “affected flare”) combusts ammonia at 

times when the amount of ammonia in the refrigerated pressure tanks 

in which it is stored must be lowered. This is necessary in certain 

circumstances to keep the pressure in the tanks within safe levels. 

The ammonia that is released is ducted to the ammonia storage flare, 

where it is combusted, resulting in emissions of NOx. The events 

that commonly lead to increased pressure in the tanks, with the need 

to flare ammonia, include loss of electrical power or mechanical 

failures of the refrigeration system for the storage 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, the 

ammonia storage plant, including the affected flare, 

shall be operated and maintained in conformance with its 

physical and process design. 

ii. The operating practices for the ammonia storage plant 

shall include implementation of practices to minimize 

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 NOx and CO, 

respectively. 

c. The emissions of NOx, CO, PM, PM10/PM2.5, VOM and GHG of the 

affected flare shall not exceed the limits in Condition 

2.5.5(a). 

2.5.3 Applicable State Emission Standards 

a. The emission of smoke or other particulate matter from the 

affected flare shall not have an opacity greater than 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 relief valves on the 

ammonia storage tanks shall be ducted through a closed 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 conducted by the 

Permittee for the affected flare pursuant to Condition 

2.5.2(a) shall include the preparation and maintenance of 
52 

a Flare Minimization Plan (Plan) for the ammonia plant 

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 procedures 

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 responsibilities of 

different personnel at the facility for the 

operation and maintenance of ammonia storage 

equipment. 

ii. After the shakedown of the ammonia plant is complete, the 

Plan shall also include a description of additional

procedures or other measures that are installed or 

implemented to reduce flaring from the affected flare. 

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

annual basis and revise the Plan so that it is kept

current and reflects any changes in the operation of 

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, which 

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 revises 

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 complete, the 

Permittee shall also conduct an event-specific investigation 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 minimize 

emissions from flaring, consistent with the requirements of 

Condition 2.1.5-3(d). For this purpose, a “Flaring Incident” 

is defined as a flaring event that results in flaring of more 

than 500 pounds of ammonia. 

e. The Permittee shall operate and maintain the affected flare in 

accordance with written procedures developed and maintained by 

the Permittee. These procedures may incorporate procedures 

provided by the supplier of equipment. 
53 

2.5.5 Emission Limits 

a. The emissions of the affected flare shall not exceed the 

following limits: 

Pollutant 

Limit 

(tons/year) 

NOx 12.8 

CO 1.52 

VOM 0.21 

PM 0.10 

PM10/PM2.5 0.25 

SO2 0.02 

GHG 479 

2.5.6 Operational Monitoring and Instrumentation Requirements 

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 operate 

instrumentation on the affected flare for: 

i. The presence of a pilot flame, as identified by a 

thermocouple, ultra-violet beam sensor, infrared sensor 

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 record for the 

affected flare containing the design destruction efficiency of 

the flare for ammonia and the design emission rates of the 

pilot burner for NOx and CO, with supporting documentation. 

b. The Permittee shall keep an inspection, maintenance 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 functions 

properly, i.e., a flame was present. 

d. The Permittee shall keep the following records related to 

emissions of NOx, CO, PM, PM10/PM2.5, VOM, SO2 and GHG from the 

affected flare: 

i. A file containing the factors used by the Permittee 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 ammonia 

(lbs/lb ammonia flared). 

ii. Records of the emissions of each pollutant (tons/month 

and tons/year), with supporting calculations. 

2.5.8 Reporting Requirements 

a. The Permittee shall notify the Illinois EPA of deviations of 

the affected flare with the permit requirements with the 

periodic compliance reports required by Condition 2.1.10(b). 

These notifications shall include the information specified 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 produced from the 

reaction of liquid ammonia and gaseous CO2 under pressure in a closed 

process. The ammonia plant supplies both the ammonia and CO2 for the 

process. As the amount of CO2 is slightly greater than the amount 

that is needed to make urea, the excess CO2 is vented from a pressure 

control CO2 vent that is located at the urea plant. 

A portion of the urea solution initially produced in the urea plant 

may be used for making diesel exhaust fluid by adding more water. 

This fluid would be stored in tanks pending shipment from the 

facility. 

The urea solution that is not made into diesel exhaust fluid is 

further processed in the urea plant to make solid urea. First, 

water is removed from the urea solution in evaporators to produce a 

concentrated urea solution. The concentrated solution is then 

processed in a drier or granulator. The hot solution provides the 

heat for the drying process. A small amount of an anti-caking 

additive, a urea-formaldehyde resin solution, is added to the urea 

solution fed to the granulator. This additive reacts 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 formaldehyde, which 

are controlled by a two-stage control system consisting of an acid 

scrubber (first-stage scrubber) followed by a venturi scrubber 

(second-stage scrubber). The acid scrubber also serves to control 

traces of ammonia in the exhaust. The flows of spent 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 units 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 plant 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 involved 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 CO2 vent at the urea plant is addressed with the CO2

vents at the ammonia plant in Section 2.1 of this permit. 
56 

2.6.2 Control Technology Determination – BACT 

a. The emissions of the affected urea units shall be 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 total, shall not 

exceed the following limits: 

i. PM and PM10/PM2.5: 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 CO2 vent located at the Urea Plant. 

2.6.3 Applicable Emission Standards 

a. The emission of smoke or other PM from the affected 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 shall comply with 

the applicable limit pursuant to 35 IAC 212.321, which rule 

limits emissions based on the process weight rate of the units. 

Note: There are no federal emission standards under 40 CFR 

Parts 60 or 63 that apply to the affected urea plant. 

2.6.4 Operational Requirements 

a. The Permittee shall operate and maintain the scrubbers 

associated with the affected urea units in accordance with 

written procedures developed and maintained by the Permittee. 

b. i. The key operating parameters of the second-stage 

scrubber, as specified below, shall be maintained at 

levels that are consistent with levels at which emission 

testing demonstrated compliance with applicable 

requirements, on a 3-hour average basis, rolled hourly: 

A. Minimum scrubbant flow rate. 

B. Minimum differential pressure across the scrubber. 

ii. Notwithstanding the above, for the purpose of evaluation 

of this scrubber and further emission testing, the 

Permittee may operate this scrubber at different operating 

parameters in accordance with a detailed plan describing 

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 not exceed the 

following limits: 

Pollutant 

Limits 

Pounds/hour Tons/year 

PM 28.5 124.7 

PM10/PM2.5 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, filterable PM10

and PM2.5, condensable PM, VOM and formaldehyde of the affected 

urea units (i.e., the second-stage scrubber) conducted by a 

qualified testing service as follows: 

i. Within 60 days after achieving the maximum production 

rate at which the affected urea units will be operated, 

but not later than 180 days after initial startup of 

these units. 

ii. Within 12 months and 18 months after the initial testing 

required above. 

 iii. Within 90 days of a written request from the Illinois 

EPA, for such pollutants as specified in the request. 

b. i. Testing for particulate shall be conducted using 

appropriate USEPA Test Methods, for measurement of PM, 

filterable PM10 and PM2.5, and condensable PM, provided, 

however, that if the moisture level in the stack makes 

measurements of filterable PM10 and PM2.5 infeasible or if 

the Permittee considers all PM emissions to be emissions 

of filterable PM10 and PM2.5, testing for emissions of 

filterable PM10 and PM2.5 need not be performed. In such 

case, compliance with the PM limit shall be determined 

based on the emissions of filterable particulate and 

compliance with the PM10/PM2.5 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 being 

developed by USEPA or other alternative test methods are 

approved by the Illinois EPA. 

VOM Method 25A 

Formaldehyde Method 320 

c. Test plan(s) and test notifications shall be submitted to the 

Illinois EPA in accordance with Conditions 3.1(a) and (b). 
58 

d. The Permittee shall expeditiously submit Final Report(s) for 

required emission testing to the Illinois EPA, no later than 60 

days after the date of testing. These reports shall include 

the information specified in Condition 3.1(c) and the following 

information: 

i. The data measured by the continuous monitoring systems 

and instrumentation required by Condition 2.6.7 during 

each test run and the levels of operating parameters 

within which the Permittee plans to operate pursuant 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 Illinois EPA or such 

later date agreed to by the Illinois EPA, the Permittee shall 

have opacity observations conducted for the affected 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 test shall 

be at least 60 minutes (ten 6-minute averages) unless the 

average opacities for the first 18 minutes of 

observations (three six-minute averages) are all less 

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 observer’s 

readings to the Illinois EPA at the time of observations, 

if Illinois EPA personnel are present. 

iv. The Permittee shall submit a written report for these 

observations within 15 days of the date of observations. 

This report shall include: 

A. Date and time of observations. 

B. Name and employer of qualified observer and a copy 

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 monitoring 

system on the granulator for the rate of urea solution 

into the unit (volume or weight). 

ii. The Permittee shall operate continuous monitoring systems 

on all scrubbers for the affected urea units for the 

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 shall 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 are 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 units are out 

of service, with an initial inspection performed before any 

maintenance and repair activities are conducted during 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 months. 

b. The Permittee shall keep records for these inspections, which 

may be combined with the records required by Condition 

2.6.9(c). 

2.6.9 Recordkeeping Requirements 

a. The Permittee shall maintain a file or other records for the 

affected urea units that contain the following information, 

with supporting material, which records shall be kept current: 
60 

i. The maximum production capacity of the affected units (tons 

urea/hour). 

ii. The standard emission factors used by the Permittee to 

determine emissions of the affected units, with supporting 

documentation. 

iii. The maximum hourly rates of emissions of PM, PM10/PM2.5, 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 maximum 

hourly PM emissions of the affected units will comply with 

the limit set by 35 IAC 212.321. 

b. The Permittee shall maintain records for the amount of urea 

produced by the affected urea units (tons/month and tons/year). 

c. The Permittee shall keep inspection and maintenance 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 following for each 

incident when any affected unit operated without the control as 

required by Condition 2.6.4(b)(i): 

i. The date of the incident and identification of the 

unit(s) that were involved. 

ii. A description of the incident, including: the established 

control measures that were not present or implemented; 

the established control measures that were present, if 

any; and other control measures or mitigation measures 

that were implemented, if any. 

iii. The time at and means by which the incident was 

identified, e.g., scheduled inspection or observation 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 measures 
61 

were in place or the operations were shutdown (to resume 

operation only after established control measures were in 

place) and, if this time was more than one hour, an

explanation why this time was not shorter, including a 

detailed description of any mitigation measures that 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 amount of 

material processed during the incident. 

vii. A discussion of the probable cause of the incident and 

any preventative measures taken. 

viii. An estimate of any additional emissions of particulate, 

VOM, formaldehyde, methanol and any other HAPs (pounds) 

above the emissions associated with normal operation that 

resulted from the incident, if any, with supporting

calculations. 

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

PM10/PM2.5, VOM, formaldehyde, methanol and any other HAPs of the 

affected urea units (tons/month and tons/year), with 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 requirements, 

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) that 

continue for more than 24 hours. 

ii. Notification for other deviations with the quarterly 

reports required by Condition 2.1.10(b). 
62 

SECTION 2.7: UNIT-SPECIFIC CONDITIONS FOR THE COOLING 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 evaporate. These 

particulate emissions are controlled by drift eliminators, 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, and maintained 

with drift eliminators designed to limit the loss of water 

droplets from the unit to no more than 0.0005 percent 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 average. 

c. The particulate emissions of the affected unit shall not exceed 

the limits in Condition 2.7.6. 

2.7.3 Applicable Emission Standards 

a. The emission of particulate matter from the affected 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 212.301 and 212.314, 

which provide that emissions of fugitive PM shall not be 

visible from any process, including any material handling or 

storage activity, when looking generally toward the zenith at a 

point beyond the property line of the source, except when the 

wind speed exceeds 25 miles per hour. 

c. The PM emissions from the affected unit shall comply 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 not being subject 

to the NESHAP for Industrial Process Cooling Towers (40 CFR 63, 

Subpart Q) because chromium-based water treatment chemicals will not 

be used. 

2.7.5 Operating Requirements 

a. Chromium-based water treatment chemicals, as defined in 40 CFR 

63.401, shall not be used in the affected unit. 

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

unit. 
63 

ii. Plant process wastewater shall not be introduced into 

cooling water, other than through unintentional leaks, 

which shall promptly be repaired. 

c. The Permittee shall operate and maintain the affected unit, 

including the drift eliminators, in accordance with written 

procedures. These procedures shall address the practices that 

will be followed as good air pollution control practice and the 

actions that will be implemented if needed to prevent a 

significant contribution to icing and fogging on offsite 

roadways. 

2.7.6 Emission Limits 

a. The emissions of the affected unit for PM and PM10/PM2.5, 

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 the drift 

eliminators, using engineering calculations for emissions. 

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 ammonia plant, the 

Permittee shall test the drift lost (percent) from the affected 

unit in accordance with the Cooling Technology Institute’s 

Acceptance Test Code No. 140. This test shall be performed 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 monthly basis for 

the total dissolved solids content. Measurements of the total 

dissolved solids content in the wastewater discharge associated 

with the affected unit, as required by a National Pollution 

Discharge Elimination System permit, may be used to satisfy 

this requirement if the effluent has not been diluted or 

otherwise treated in a manner that would significantly reduce 

its total dissolved solids content. 

b. Upon written request by the Illinois EPA, the Permittee 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 sampling 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 the following 

information for the affected unit: 

i. The design loss specification for the drift eliminators 

installed in the affected unit. 

ii. The supplier’s recommended procedures for inspection and 

maintenance of the drift eliminators. 

iii. The operating factors, if any, used to determine the 

amount of water circulated in the unit or the PM, PM10, 

PM2.5 from the unit, with supporting documentation. 

iv. Copies of the Material Safety Data Sheets or other 

comparable information from the suppliers of the various 

water treatment chemicals that are added to the water 

circulated in the unit. 

v. Calculations for the maximum PM, PM10 and PM2.5 emissions 

from the affected unit (pounds/hour on a 24-hour average 

basis for PM, PM10 and PM2.5), based on the maximum 

operating rate of the affected unit and other factors 

that result in greatest emissions. 

b. The Permittee shall keep the records for the amount of water 

circulated in the affected unit, gallons/month. As an 

alternative to direct data for water flow, these records may 

contain other relevant operating data for the affected unit 

(e.g., water flow to the affected unit) from which the amount 

of water circulated in the affected unit may be reasonably 

determined. 

c. The Permittee shall maintain an operating log or other similar 

records for the affected unit that include the information 

specified in Condition 3.2(a). 

d. The Permittee shall keep inspection and maintenance logs for 

the affected unit, including the drift eliminators installed in 

the affected unit, which shall include the information 

specified in Condition 3.2(b). 

e. The Permittee shall maintain records for the PM, PM10 and PM2.5

emissions of the affected unit based on the above records, the 

measurements required by Conditions 2.7.7 and 2.7.8, and 

appropriate USEPA emission estimation methodology and 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 requirements. 

These notifications shall include the information specified by 

Condition 3.4. 
65 

i. If the affected unit is damaged so there is a deviation 

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 the 

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 reports to the 

Illinois EPA for the affected units, which reports shall 

include information for deviations during the reporting 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 EQUIPMENT COMPONENTS 

2.8.1 Description 

Certain equipment, piping and ductwork at the facility have 

components, including valves, flanges and other connectors, pump 

seals, compressor seals, and pressure relief valves, that handle 

fluid streams containing VOM and/or methane and have the potential 

to emit VOM or methane when they leak. Three streams are present at 

this facility that contain or potentially contain VOM and/or 

methane: 1) Natural gas streams, either as natural gas is being 

used as fuel or is handled as the feedstock for steam reforming; 2) 

The off-gases from the ammonia plant that are ducted to the reformer 

for use as fuel, and 3) The process vent gases from the ammonia 

plant that are flared. Two other streams are present that contain 

or potentially contain only VOM: 1) The CO2 absorption solvent used 

in the ammonia plant, and 2) The urea-formaldehyde resin solution 

used in the urea plant. As appropriate, the emissions of VOM and 

methane from these components are addressed through timely 

identification and repair of any leaks that occur or, in the case of 

the pumps and valves handling urea-formaldehyde resin solution, by 

use of “leakless components”. 

The piping that transports CO2 from the regenerator to the urea plant 

also has components that have the potential to emit CO2 when they 

leak. The emissions of CO2 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 components” are the 

components that handle natural gas. The “affected off-gas 

components” are the components that handle off-gases 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 CO2 absorption 

solvent. The “affected resin components” are the components that 

handle the urea-formaldehyde resin for the urea plant. The 

“affected CO2 components” are the components that handle the CO2

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 controlled by 

compliance with the provisions of the NSPS for Equipment 

Leaks of VOC in the Synthetic Organic Chemicals 

Manufacturing Industry for Which Construction, 

Reconstruction, or Modification Commenced After November 

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 reporting. 
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 methane 

concentration of 2000 ppm or more. 

b. For affected absorption solvent components, emissions from 

leaks shall be controlled by compliance with the provisions of 

the NSPS, 40 CFR 60 Subpart VVa, that apply to components ”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 leaks shall be 

controlled by: 

i. For components other than connectors and pressure relief 

valves, by use of components that are of “leakless”

design. 

ii. For connectors and pressure relief valves, by compliance 

with the provisions of the National Emission Standards 

for Organic Hazardous Air Pollutants for Equipment Leaks, 

40 CFR 63 Subpart H, that apply to components ”in heavy 

liquid service,” including 40 CFR 63.169(a) and other 

relevant provisions of these standards for work 

practices, testing, recordkeeping and reporting. 

d. For affected CO2 components, emissions from leaks shall be 

controlled by implementing the following practices:

i. If evidence of a potential leak is found by sound or any 

other detection method, the Permittee shall make a first 

attempt at repair within 5 calendar days, which shall 

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 days of 

detection unless repair is technically infeasible without 

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 method for 

monitoring the concentration of CO2 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 detection 

method, either one of the following procedures shall 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 greater 

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 which 

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 of the NSPS, 

40 CFR 60 Subpart VVa. 

2.8.4 Non-Applicability Provisions 

a. i. This permit is issued based on affected components 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 since 

urea is not a VOC and components that handle urea are not 

“in VOC service” as defined by 40 CFR 60.481a. 

ii. This permit is issued based on the other affected 

components at the facility (i.e., components at the

facility other than components at the urea plant) not 

being subject to the requirements of the NSPS, 40 CFR 60 

Subpart VVa. This is because they are not located at a 

synthetic chemical manufacturing facility for purposes of 

this NSPS because they do not produce as an intermediate 

or final product any chemical listed in 40 CFR 60.489. 

b. This permit is issued based on affected components in the urea 

plant not being subject to 35 IAC Part 215 Subpart Q, Leaks for 

Synthetic Organic Chemical and Polymer Manufacturing Equipment, 

because this plant does have any VOM components that 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 and compressors 

not being subject to the control requirement of 35 IAC 215.142 

because none of these components will handle a volatile organic 

liquid with a vapor pressure of 2.5 psia or greater at 70°F. 
69 

2.8.5 Work Practice Requirements 

a. The CO2 absorption solvent used in the ammonia plant shall be 

such that the affected absorption solvent components (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 forth in 40 

CFR 60 Subpart VVa. 

2.8.6 Emission Limits 

a. Emissions of VOM, methane and HAPS from the affected components 

shall not exceed 9.92, 28.1 and 0.44 tons/year, respectively, 

as determined by use of appropriate USEPA methodology for 

estimating emissions from leaking components. 

b. GHG emissions from the affected CO2 components shall be 

addressed with the GHG emissions of the CO2 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 60 Subpart VVa. 

b. For affected components other than the affected resin 

components, the Permittee shall maintain a log or other records 

that identify leaking components and a compilation of leaking 

components by month by type of component, the nature 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, methane and 

HAPs: 

i. A file containing the emission factors used by the 

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 pollutant 

(tons/month and tons/year), with supporting data and 

calculations. 

d. For affected CO2 components, the Permittee shall maintain 

records to address compliance with Condition 2.8.2(d), 

including: 

i. Records for the identification of potential leaks from an 

affected CO2 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 leak from an 

affected CO2 component, including data, description and 

further explanation if repair was not feasible until 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 reported in 

reports pursuant to the NSPS, as required by Condition 

2.8.2(a) and (b), shall be reported in such reports. 

ii. Other deviations shall be reported with the periodic 

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 transferred to 

storage, reclaimed from storage and then loaded out from the 

facility by truck or rail. Emissions of particulate 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 units shall be 

controlled by enclosure and baghouse(s). 

b. There shall be no visible emissions from the affected units. 

c. The PM emissions from the baghouse(s) for the affected 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 affected 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 of the affected units shall comply with the 

applicable limit pursuant to 35 IAC 212.321, which rule limits 

emissions based on the process weight rate of emission units. 

c. With respect to emissions of fugitive PM, the affected units 

shall comply with 35 IAC 212.301, which provides that emissions 

of fugitive PM shall not be visible from any process, including 

any material handling or storage activity, when looking 

generally toward the zenith at a point beyond the property line 

of the source, except when the wind speed exceeds 25 miles per 

hour, as provided by 35 IAC 212.314. 

2.9.4 Operational Requirements and Limits 

a. The Permittee shall implement and maintain practices for the 

loadout of urea and other work practices for the affected units 

that provide assurance of compliance with the applicable 

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 Operating 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/PM10/PM2.5 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, filterable PM10

and PM2.5 and condensable PM of the affected units (i.e., the 

baghouse) conducted by a qualified testing service as follows: 

i. Within 60 days after achieving the maximum production 

rate at which the affected units will be operated, but 

not later than 180 days after initial startup of these 

units. 

ii. Within 90 days of a written request from the Illinois 

EPA. 

b. Testing shall be conducted using appropriate USEPA Test 

Methods, for measurement of PM, filterable PM10 and PM2.5 and 

condensable PM, provided, however, if the Permittee considers 

all PM emissions to be emissions of filterable PM10 and PM2.5, 

testing for emissions of filterable PM10 and PM2.5 need not be 

performed. 

c. Test plan(s), test notifications and test reports shall be 

submitted to the Illinois EPA in accordance with Conditions 

3.1(a) and (b). 

d. The Permittee shall expeditiously submit Final Report(s) for 

required emission testing to the Illinois EPA, no later than 60 

days after the date of testing. These reports shall include 

the information specified in Condition 3.1(c) and the following 

information: 

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

2.9.6-2 Observations for Opacity 

a. Within 45 days of a written request by the Illinois EPA or such 

later date agreed to by the Illinois EPA, the Permittee shall 

have opacity observations conducted for the affected 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 requirements of 

Conditions 2.6.6-2(a)(i), (ii), (iii) and (iv). 

2.9.7 Inspections 

a. The Permittee shall conduct inspections of affected units on at 

least a monthly basis with personnel who are not directly 

responsible for the day-to-day operation of these units. 
73 

i. These inspections shall verify that the work practices 

used to prevent emissions from affected units are being 

properly implemented. 

ii. These inspections shall also include observation for the 

presence of visible emissions, performed in accordance 

with Method 22. 

b. The Permittee shall perform detailed inspections of the 

baghouse for the affected units while these units are out of 

service, with an initial inspection performed before any 

maintenance and repair activities are conducted during the 

period the affected unit is out of service and a follow-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 records for the 

affected units containing the following information, with 

supporting material, which records shall be kept current: 

i. The maximum operating rates of the different affected 

units (tons/hour). 

ii. The standard emission factors used by the Permittee to 

determine emissions of the affected units. 

iii. The maximum hourly rates of PM, PM10 and PM2.5 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 comply with 

the limit set by 35 IAC 212.321. 

b. The Permittee shall maintain operating records of 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 following for each 

incident when any affected unit operates without the work 

practices used to reduce emissions of particulate. 

i. A description of the incident, including the required 

work practices that were not present or implemented; the 

work practices that were present, if any; other control 

measures or mitigation measures that were implemented, if 

any; and the magnitude of the PM emissions during the 

incident. 

ii. The length of time after the incident was identified that 

the affected unit(s) continued to operate before the work 

practices were in place or the affected unit(s) were 
74 

shutdown (to resume operation only after work practices 

were in place) and, if this time was more than one hour, 

an explanation why this time was not shorter, including 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 standards or 

limits in Conditions 2.9.2, 2.9.3, and 2.9.5, may have 

been violated during the incident, with supporting 

explanation. 

d. The Permittee shall keep records of the emissions of PM, PM10

and PM2.5 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 requirements set by 

this permit for the affected units with the quarterly reports 

required by Condition 2.1.10(b). These reports shall include 

the information specified in Condition 3.4. 
75 

SECTION 2.10: UNIT-SPECIFIC CONDITIONS FOR ROADWAYS 

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 controlled 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 emissions from 

affected units shall not exceed 10 percent. For this purpose, 

opacity shall be determined in accordance with 35 IAC 212.109. 

b. i. Best management practices shall be implemented to reduce 

dust emissions from affected units in accordance with a 

written operating program, as further addressed by 

Condition 2.10.4. After construction activity is 

complete, these practices shall provide for pavement on 

all regularly traveled roads and treatment of roadways 

that are routinely subject to vehicle traffic. 

ii. For this purpose, roads that serve any office building, 

employee parking areas or are normally used by trucks 

transporting urea or ammonia shall be considered to be 

subject to regular travel and are required to be paved. 

c. The handling of material collected from affected units by 

sweeping or vacuuming trucks shall be enclosed or shall utilize 

spraying, pelletizing, screw conveying or other equivalent 

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, including 

material handling and storage activities, when looking 

generally toward the zenith at a point beyond the property line 

of the source, except when the wind speed is greater than 25 

miles per hour. 

2.10.4 Operating Program for Control of Fugitive Particulate Emissions 

a. The Permittee shall carry out control of fugitive particulate 

emissions from affected units in accordance with a written 

operating program describing the measures being implemented in 

accordance with Condition 2.10.2(b) to control emissions 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 affected 

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 are 

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 written 

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, PM10, and PM2.5 from the affected units shall not 

exceed 11.71, 2.34, and 0.57 tons/year, respectively. Compliance 

with these limits shall be determined from the amount and nature of 

vehicle traffic associated with the operation of the plant, specific 

operating information for affected units, and appropriate 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 emissions 

from the affected units as follows, to determine the range of 
77 

opacity from affected units and the change in opacity as 

related to the amount and nature of vehicle traffic and 

implementation of the operating program. 

b. “Performance observations” for the opacity of emissions shall 

be conducted as follow. For performance observations, the 

Permittee shall submit test plans, test notifications and test 

reports, as specified by Condition 3.1. 

i. In conjunction with the measurements of silt loading on 

the affected units required by Condition 2.10.7, 

performance observations shall first be completed no 

later than 30 days after the date that construction of 

process units in the ammonia or urea plant are completed, 

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 within 30 days 

in the event of changes involving affected units that 

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 affected 

units, changes in the standard operating practices for 

affected units, such as application of salt or traction 

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 levels and 

confirm the effectiveness of the operating program in 

controlling emissions. 

d. Upon written request by the Illinois EPA, the Permittee shall 

conduct performance or compliance observations, as specified in 

the request. Unless another date is agreed to by the Illinois 

EPA, performance observations shall be completed within 30 days 

and compliance observations shall be completed within 5 days of 

the Illinois EPA’s request. 

2.10.6-2 Inspections 

a. i. The Permittee shall conduct inspections of affected units 

for the specific purpose of verifying that the operating 

program required by Condition 2.10.4 for the affected 

units is being implemented. These inspections shall be 

conducted by supervisory or management personnel or shall 

be overseen by such personnel. 

ii. The Permittee shall conduct these inspections of affected 

units on at least a weekly basis during construction of 

the facility and on a monthly basis thereafter with

personnel not directly responsible for the day-to-day 

implementation of the operating program. 
78 

b. The Permittee shall keep records for these inspections, which 

shall include the following information, at a minimum: 

i. Date and time the inspection was performed and the 

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 practices that 

are recommended as a result of the inspection. 

iv. A summary of the observed implementation or status of the 

operating program. 

v. If the inspection was not performed by supervisory or 

management personnel, the name(s) and position(s) of the 

supervisory or management personnel who oversaw the

inspection. 

vi. The condition of the pavement on principal roadways. 

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 “Procedures for 

Sampling Surface/Bulk Dust Loading,” Appendix C.1 in 

Compilation of Air Pollutant Emission Factors, USEPA, AP-42. A 

series of samples shall be taken to determine the average silt 

loading and address the change in silt loadings as related to 

the amount and nature of vehicle traffic and implementation of 

the operating program. 

b. Measurements shall be performed by the following dates: 

i. Measurements shall first be completed no later than 30 

days after construction is completed. 

ii. Measurements shall be repeated within 30 days in the 

event of changes involving affected units that would act 

to increase silt loading (so that data that is 

representative of the current circumstances of the 

affected units has not been collected), including changes 

in the amount or type of traffic on affected units,

changes in the standard operating practices for affected 

units, such as application of salt or traction material 

during cold weather, and changes in the operating program 

for affected units. 

iii. Upon written request by the Illinois EPA, the Permittee 

shall conduct measurements, as specified in the request, 

which shall be completed within 75 days of the Illinois 

EPA’s request. 
79 

c. The Permittee shall submit test plans, test notifications and 

test reports for these measurements as specified by Condition 

3.1, provided, however, that once a test plan has been accepted 

by the Illinois EPA, a new test plan need not be submitted if 

the accepted plan will be followed unless a new test plan is 

requested by the Illinois EPA. 

d. The Permittee shall keep records for the measurements conducted 

for affected units pursuant to Condition 2.10.7, including 

records for the sampling and analysis activities and results. 

2.10.8 Recordkeeping Requirements 

a. The Permittee shall keep a file that contains: 

i. The operating factors used to determine the amount of 

activity associated with the affected units or the 

particulate emissions from the affected units, with

supporting documentation. 

ii. The maximum PM, PM10 and PM2.5 emission of the facility, in 

tons/year, considering the maximum amounts of vehicle 

traffic needed for the operation of the facility, with 

supporting calculations and documentation, and 

confirmation that the control measures in the operating 

program are sufficient to ensure compliance with the 

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 or units: 

A. The identity of the affected unit(s), the date and 

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 the 

action that was taken. 

ii. Records for each incident when control measures were not 

implemented and each incident when additional control 
80 

measures were implemented due to particular activities, 

including description, date, a statement of explanation, 

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 required by 

this permit, which records shall include the information 

specified by Condition 3.3, including the following, and an 

estimate of the additional emissions of PM, PM10 and PM2.5 that 

resulted, if any, with supporting calculations. 

i. The dates that control measures were not implemented 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 implemented 

based on a belief that implementation of such control 

measures would have been unreasonable given prevailing 

weather conditions. 

d. The Permittee shall maintain records for the PM, PM10, and PM2.5

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 appropriate USEPA 

emission estimation methodology and emission factors, with 

supporting calculations. 

2.10.9 Reporting Requirements 

a. The Permittee shall notify the Illinois EPA of deviations of 

affected units with permit requirements with the periodic 

reports required by Condition 2.1.10(b). These notifications 

shall include the information specified by Condition 3.4. 
81 

SECTION 2.11: UNIT-SPECIFIC CONDITIONS FOR ENGINES

2.11.1 Description 

The facility has three diesel-fueled emergency engine generators and 

one smaller diesel-fueled firewater pump engine (the affected 

emergency engine generator engines and affected firewater pump 

engine, respectively). The emergency generators will supply 

electricity to critical equipment during power outages. The 

firewater pump would be used in the event of fire. Other than 

during power outages or fires, these engines (the affected engines) 

will each normally be operated for less than one hour per week for 

purposes of operational testing. 

2.11.2 Control Technology Determination - BACT 

a. i. The emergency generator engines shall be designed and 

operated to comply with the following limits, in 

grams/kW-hour, power output: 

Pollutant Limit 

NOx 0.67 

CO 3.5 

PM/PM10/PM2.5 0.10 

VOM (as NMHC) 0.40 

Note: These limits reflect the USEPA’s Tier IV standards 

for nonroad engines in 40 CFR Part 1039, Control of

Emissions from New and In-Use Nonroad CompressionIgnition Engines, for engines with a maximum power 

greater than 900 kW that power electrical generators (40 

CFR 1039.102, Table 7). 

ii. The GHG emissions of the emergency generator engines 

shall not exceed 432 tons/year, combined. 

b. i. The firewater pump engine shall be designed and operated 

to comply with the following limits, grams/kW-hr power 

output: 

Pollutant Limit 

NOx 3.5 

CO 3.5 

PM/PM10/PM2.5 0.10 

VOM (as NMHC) 0.40 

Note: These limits reflect the USEPA’s Tier IV standards 

for nonroad engines in 40 CFR Part 1039, Control of

Emissions 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 provisions 

in the General Provisions of the NSPS, 40 CFR 60 Subpart 

A. 

ii. The emergency generator engines, as new emergency 

stationary compression ignition internal combustion

engines with a displacement of less than 10 liters per 

cylinder that are not fire pump engines, must comply with 

the NSPS standards for new emergency stationary internal 

combustion engines with rated power output greater than 

560 kW, as follows. The Permittee shall comply with 

these standards by purchasing an engine certified to 

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 cylinder, 

must comply with the emission standards in Table 4 of 40 

CFR 60 Subpart IIII applicable to units with a maximum 

engine power greater than 225 kW but less than 450 kW, as 

follows. The Permittee shall comply with these standards 

by purchasing an engine certified to these standards for 

the same model year and maximum (i.e., NFPA nameplate) 

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 shall meet 

the requirements of 40 CFR 80.510(b) for nonroad diesel 

fuel. [40 CFR 60.4207(b)]. 

b. As new stationary engines located at an area source for HAPs, 

the affected engines must meet the requirements of the National 

Emission Standards for Hazardous Air Pollutants (NESHAP) for 

Stationary Reciprocating Internal Combustion Engines, 40 CFR 63 

Subpart ZZZZ, by meeting the requirements of the NSPS, 40 CFR 
83 

60 Subpart IIII, for compression ignition engines. No further 

requirements apply for the affected engines under 40 CFR 63 

Subpart ZZZZ. [63.6590(c)] 

2.11.3-2 Applicable State Emission Standards 

a. The affected engines are subject to 35 IAC 212.123(a), which 

provides that no person shall cause or allow the emission of 

smoke or other particulate matter, with an opacity greater than 

30 percent, 6-minute average, from any emission unit, except as 

allowed by 35 IAC 212.123(b) and 212.124. 

b. The affected engines are subject to 35 IAC 214.301, which 

limits emissions of SO2 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 Permittee shall 

operate and maintain the affected engines according to the 

manufacturer’s written instructions related to emissions. In 

addition, the Permittee may only change those emission-related 

settings that are permitted by the manufacturer. The 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 affected engines may 

be operated for the purpose of maintenance checks and readiness 

testing, provided that the tests are recommended by Federal, 

State or local government, the manufacturer, the vendor, or the 

insurance company associated with the affected engine. 

Maintenance checks and readiness testing of the each engine are 

limited to 100 hours per year. There is no time limit 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 if the 

Permittee maintains records indicating that Federal, State, or 

local standards require maintenance and testing of emergency 

engines beyond 100 hours per year. Emergency engines may 

operate up to 50 hours per year in nonemergency situations, but 

those 50 hours are counted towards the 100 hours per year 

provided for maintenance and testing. The 50 hours per year 

for non-emergency situations cannot be used for peak shaving or 

to generate income for a facility to supply power to an 

electric grid or otherwise supply non-emergency power as part 

of a financial arrangement with another entity. Any operation 

other than emergency operation, maintenance and testing, 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 generator 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 

PM10/PM2.5 0.62 0.06 0.19 

VOM 2.47 0.25 0.75 

GHG --- --- 430 

SO2 --- --- 0.10 

Total HAPs --- --- 0.10 

b. The emissions of the affected firewater pump engine 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 

PM10/PM2.5 0.06 0.003 

VOM --- 0.10 

GHG --- 72.0 

SO2 --- 0.04 

Total HAPs --- 0.02 

2.11.6 Operational Monitoring 

a. The Permittee shall operate and maintain a non-resettable hour 

meter on each affected engine. 

2.11.7 Recordkeeping Requirements 

a. If an affected engine does not also meet the standards of the 

NSPS, 40 CFR 60 Subpart IIII, applicable to non-emergency 

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 operation 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 manufacturers 

for the emission rates of the engines and their fuel 

consumption rates, in gallons per kW-hour. 

c. The Permittee shall maintain records of consumption of fuel by 

the affected engines (gallons/month, separately for the 

affected emergency generator engines and the affected firewater 

pump engine). 

d. For the affected emergency generator engines and the affected 

firewater pump engine, the Permittee shall maintain the 
85 

following records related to emissions of NOx, CO, SO2, VOM, 

PM, PM10/PM2.5, GHG and total HAPs: 

i. A file containing the maximum emission rates of each 

pollutant from the affected engines in pounds per gallon 

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 pollutant 

separately for the affected emergency generator engines 

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 deviations of 

the affected engines with the permit requirements with the 

periodic compliance reports required by Condition 2.1.10(b). 

These notifications shall include the information specified in 

Condition 3.4. 
86 

PART 3: GENERAL PERMIT CONDITIONS 

CONDITION 3.1: GENERAL REQUIREMENTS FOR EMISSION TESTING 

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

testing required by this permit, a written test plan shall be 

submitted to the Illinois EPA for review. This plan shall 

describe the specific procedures for testing and shall include 

at a minimum: 

A. The person(s) who will be performing sampling and 

analysis and their experience with similar tests. 

B. The specific conditions, e.g., operating rate and control 

device operating conditions, under which testing shall be 

performed including a discussion of why these conditions 

will be representative and the means by which the 

operating parameters will be determined. 

C. The specific determinations of emissions that are 

intended to be made, including sampling and monitoring 

locations. 

D. The test method(s) that will be used, with the specific 

analysis method if the method can be used with different 

analysis methods. 

ii. As provided by 35 IAC 283.220(d), the Permittee need not submit 

a test plan for subsequent emissions testing that will be 

conducted in accordance with the procedures used for previous 

tests accepted by the Illinois EPA or the previous test plan 

submitted to and approved by the Illinois EPA, provided that 

the Permittee’s notification for testing, as required below, 

contains the information specified by 35 IAC 283.220(d)(1)(A), 

(B) and (C). 

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

emissions testing required by this permit to enable the 

Illinois EPA to observe the tests. Notification for the 

expected date of testing shall be submitted a minimum 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 working days* 

prior to the actual date of testing. Notwithstanding 40 CFR 

60.8(d), the Illinois EPA may at its discretion accept 

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 observe testing. 

ii. This notification shall also identify the parties 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 tests shall be 

forwarded to the Illinois EPA within 30 days after the test results 
87 

are compiled and finalized but not later than 90 days after the date 

of testing. At a minimum, the Final Report for testing shall 

contain the following. Copies of emission test reports shall be 

retained for at least five years after the date that 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 firing rate). 

- Measured emission rates for different pollutants tested. 

- Emission factor, calculated using the average test 

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, including a 

description of sampling points, sampling train, analysis 

equipment, and test schedule 

iii. Detailed description of test conditions, including: 

- Pertinent process information (e.g., usage of raw

material or fuel and composition). 

- Control equipment information (i.e., monitored data and 

other relevant operating parameters during testing). 

iv. Data and calculations, including copies of all raw data sheets 

and records of laboratory analysis, sample calculations, 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 information 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 units is in service 

and operating normally, relevant process and control system 

information to generally confirm normal operation. 

iii. For periods when a unit or group of related units is in service 

and is not operating normally, identification of each such 

period, with detailed information describing the operation of 

the unit(s), the potential consequences for additional 

emissions from the unit(s), the potential of any excess 

emissions from the affected unit(s), the actions taken 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, include the following 

information related to the emission units and associated control 

system: 

i. Identification of equipment, with date, time, responsible 

employee and type of activity. 

ii. For inspections, a description of the inspection, findings, and 

any recommended actions, with reason. 

iii. For maintenance and repair activity, a description of actions 

taken, reason for action (e.g., preventative measure or 

corrective action as a result of inspection), probable cause 

for requiring maintenance or repair if not routine or 

preventative, and the condition of equipment following 

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 practices, 

including prompt repair of defects that interfere with 

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 database maintained by 

the Permittee provided that the information required to be kept in a 

log is readily accessible. 

CONDITION 3.3: GENERAL REQUIREMENTS FOR RECORDKEEPING 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 manner in which the 

deviation was identified, if not readily apparent; the probable 

cause for deviation, if known, including a description of any 

equipment malfunction or breakdown associated with the deviation; 

information on the magnitude of the deviation, including actual 

emissions or performance in terms of the applicable standard if 

measured or readily estimated; confirmation that standard procedures 

were followed or a description of any event-specific corrective 

actions taken; and a description of any preventative measures taken 

to prevent future occurrences, if appropriate. 

CONDITION 3.4: GENERAL REQUIREMENTS FOR REPORTING OF DEVIATIONS 

a. The Permittee shall include the following information in records and 

reports for deviations: 
89 

i. Identity of the deviation, with date, time, duration and 

description. 

ii. Describe the effect of the deviation on compliance, with an 

estimate of the excess emissions that accompanied the 

deviation, if any. 

iii. Describe the probable cause of the deviation and any corrective 

actions or preventive measures taken. 

b. i. Unless otherwise specified in a particular condition of this 

permit, if deviation(s) from requirements of this permit occurs 

during a reporting period, a compliance report shall be 

submitted no later than 45 days after the end of the reporting 

period. This report shall also provide a listing of all 

deviations for which immediate or 30-day reporting was 

required, but need not include copies of the previously 

submitted information. 

ii. If there are no deviations during a reporting period, the 

Permittee shall still submit a compliance report, which 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 requirements of this 

permit. 
90 

ATTACHMENTS 

ATTACHMENT 1: SUMMARY OF THE PERMITTED EMISSIONS OF THE FACILITYa

Table 1: Emissions of the Facility (tons/year) 

Pollutant 

Ammonia Plant 

Reformer 

Furnace Boiler Urea Plant 

“Other Units” 

(See Table 2) 

Flares CO2 Ventsb

NOx 15.1 --- 45.6 45.4 --- 14.71 CO 82.3 3.4 83.6 75.7 --- 8.36 VOM 11.6 14.3 22.6 20.4 1.60 11.21 PM 0.15 --- 7.90 7.20 124.7 17.38 PM10 0.15 --- 10.0 9.10 108.1 6.25 PM2.5 0.15 --- 10.0 3.90 108.1 4.48 SO2 0.13 --- 2.46 2.23 --- 0.17 GHG 25,971 343,105 488,159 442,339 --- 2,591 

Notes: a. This summary addresses operation of the facility after the commissioning of the f

complete. In the period prior to commissioning, operation and emissions of the fAmmonia Plant and the Startup Heater would potentially be greater but operation aother units would be lower. 

b. Emissions from the CO2 Vent in the Urea Plant are addressed with the CO2 Vent in t
91 

Table 2: Emissions of “Other Units” (tons/year) 

Pollutant 

Startup 

Heater 

Cooling 

Tower Enginesa

Equipment 

Components Roadways 

Product 

Urea 

Handling 

Ammonia Storage 

Flare T

NOx 0.60 --- 1.31 --- --- --- 12.8 CO 0.27 --- 6.59 --- --- --- 1.52 VOM 0.04 --- 0.85 9.92 --- --- 0.20 PM 0.02 4.42 0.19 --- 11.71 0.94 0.10 PM10 0.06 2.47 0.19 --- 2.34 0.94 0.25 PM2.5 0.06 2.47 0.19 --- 0.57 0.94 0.25 SO2 0.01 --- 0.14 --- --- --- 0.02 GHG 871 --- 502 739 --- --- 479 Notes: a. The engines are the three emergency generator engines and the firewater pump engib. The tanks are the storage tanks at the facility for organic liquids, e.g., amine 
92 

ATTACHMENT 2: SUMMARY OF THE PERMITTED HAP EMISSIONS OF THE FACILI

Table 1: Emissions of the Facility (tons/year) 

Pollutant 

Ammonia Plant 

Reformer

Furnace Boiler Urea Plant 

"OtUn

(See 

Flares CO2 Ventsc

Total HAPs 2.43 4.30 6.74 1.60 0Any Individual HAPd 0Hexane --- 0.01 0.01 6.7 --- 0Formaldehyde --- 0.01 3.0 0.01 1.38 0Methanol --- 2.40 0.01 0.02 0.22 0Other Individual HAP (i.e., a HAP other than hexane, formaldehyde or methanol) 

--- 0.01 1.28 0.01 --- 0

Notes: a. This summary addresses operation of the facility after the commissioning of the f

complete. In the period prior to commissioning, operation and emissions of the fAmmonia Plant and the Startup Heater would potentially be greater but operation aother units would be lower. 

b. Emissions of at most negligible amounts of HAPs (i.e., at most 0.001 tons/year) a

c. Emissions from the CO2 Vent in the Urea Plant are addressed with the CO2 Vent in t

Plant. 

d. The limits for individual HAPs from the various emission units are either: 1) “G

only an emission limit set for any individual HAP, or 2) “Speciated,” with emissifor hexane, formaldehyde and methanol and for “other individual HAPs,” i.e., any other than hexane, formaldehyde and methanol. 
93 

Table 2: Emissions of the “Other Units” (tons/year) 

Pollutant 

Startup

Heater 

Ammonia Storage 

Flare 

Cooling

Tower 

Equipment 

Components

Product 

Urea 

Handling Roadways

Generator

Engines 

FirPum

Engi

Total HAPs 0.03 0.01 0.01 0.47 0.01 0.01 0.13 0.1Any Indiv. HAP 0.01 0.01 0.01 0.01 Hexane --- 0.01 --- --- Formaldehyde 0.02 0.01 --- --- Methanol --- 0.44 --- --- Other Indiv. HAP 0.01 0.01 0.01 0.0
94 

ATTACHMENT 3: STANDARD PERMIT CONDITIONS 

STANDARD CONDITIONS FOR CONSTRUCTION/DEVELOPMENT PERMITS 

ISSUED BY THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 

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 superseded by special 

condition(s). 

1. Unless this permit has been extended or it has been voided by a newly 

issued permit, this permit will expire one year from the date of 

issuance, unless a continuous program of construction 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 Illinois Environmental 

Protection Act and Regulations adopted by the Illinois Pollution 

Control Board. 

3. There shall be no deviations from the approved plans and specifications 

unless a written request for modification, along with plans and 

specifications as required, shall have been submitted to the Illinois 

EPA and a supplemental written permit issued. 

4. The Permittee shall allow any duly authorized agent of the Illinois EPA 

upon the presentation of credentials, at reasonable times: 

a. To enter the Permittee’s property where actual or 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 required to be kept 

under the terms and conditions of this permit, 

c. To inspect, including during any hours of operation of equipment 

constructed or operated under this permit, such equipment and any 

equipment required to be kept, used, operated, calibrated 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 preserving, 

testing, monitoring, or recording any activity, discharge, or 

emission authorized by this permit. 
95 

5. The issuance of this permit: 

a. Shall not be considered as in any manner affecting the title of 

the premises upon which the permitted facilities are to be 

located; 

b. Does not release the Permittee from any liability for damage to 

person or property caused by or resulting from the construction, 

maintenance, or operation of the proposed facilities; 

c. Does not release the Permittee from compliance with other 

applicable statutes and regulations of the United States, of the 

State of Illinois, or with applicable local laws, ordinances and 

regulations; 

d. Does not take into consideration or attest to the structural 

stability of any units or parts of the project; and

e. In no manner implies or suggests that the Illinois EPA (or its 

officers, agents or employees) assumes any liability, directly or 

indirectly, for any loss due to damage, installation, 

maintenance, or operation of the proposed equipment or facility. 

6a. Unless a joint construction/operation permit has been issued, a permit 

for operation shall be obtained from the Illinois EPA before the 

equipment covered by this permit is placed into operation. 

 b. For purposes of shakedown and testing, unless otherwise specified by a 

special permit condition, the equipment covered under this permit may 

be operated for a period not to exceed thirty (30) days. 

7. The Illinois EPA may file a complaint with the Board for modification, 

suspension or revocation of a permit. 

a. Upon discovery that the permit application contained 

misrepresentations, misinformation or false statement or that all 

relevant facts were not disclosed, or 

b. Upon finding that any standard or special conditions have been 

violated, or 

c. Upon any violations of the Environmental Protection Act or any 

regulation effective thereunder as a result of the construction 

or development authorized by this permit.