217/782-2113 

CONSTRUCTION PERMIT - PSD APPROVAL 

NSPS EMISSION UNITS 

PERMITTEE

Power Holdings of Illinois, LLC 

Attn: Joseph Darguzas 

2112 West Galena Boulevard 

Aurora, Illinois 60506 

Application No.: 07100063 I.D. No.: 081801AAF 

Applicant’s Designation: SNG PLANT Date Received: October 18, 2007 

Subject: Synthetic Natural Gas Plant 

Date Issued: October 26, 2009 

Location: Tomahawk Lane, 5 miles south of Illinois Route 15, west of Waltonville 

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

source and air pollution control equipment consisting of a plant to produce 

synthetic natural gas (SNG) by gasification of coal, including six gasifiers, 

two gas processing trains (including synthesis gas cleanup units and methanation 

units), two sulfuric acid plants, two steam superheaters, a cooling tower, an 

auxiliary boiler, feedstock storage and handling, and other ancillary 

operations, 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 plant, as described in the application, in that the Illinois Environmental 

Protection Agency (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 regulations promulgated thereunder at 40 CFR 52.21 for 

Prevention of Significant Deterioration of Air Quality (PSD), and a Delegation of 

Authority agreement between the United States Environmental Protection Agency 

(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 

plant 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 217/782-2113. 

ORIGINAL SIGNED BY EDWIN C. BAKOWSKI OCTOBER 26, 2009 

Edwin C. Bakowski, P.E. Date Signed: ___________________ 

Manager, Permit Section 

Division of Air Pollution Control 

ECB:RPS:psj 

cc: Region 3 

USEPA Region V 
2 

TABLE OF CONTENTS 

 Page

 

SECTION 1 FINDINGS 3 

 

SECTION 2 IDENTIFICATION OF SIGNIFICANT EMISSION UNITS 5 

 

SECTION 3 SOURCE-WIDE CONDITIONS 6 

 

 3.1 Effect of Permit 

 3.2 Validity of Permit and Commencement of Construction 

 3.3 Emissions of Hazardous Air Pollutants (HAPs) 

 3.4 Miscellaneous Ancillary Equipment 

 3.5 Good Air Pollution Control Practices 

 3.6 Compliance with Emission Limitations 

 3.7 Records for Monitoring Systems and Instrumentation 

 3.8 Records for Opacity Measurements 

 3.9 Retention and Availability of Records 

 3.10 Addresses for the Illinois EPA 

 3.11 Authorization to Operate Emission Units 

 

SECTION 4 UNIT-SPECIFIC CONDITIONS FOR PARTICULAR EMISSION UNITS 12 

 

4.1 Gasification Block 12 

4.2 Steam Superheaters and Auxiliary Boiler 34 

4.3 Startup Burners 47 

4.4 Sulfuric Acid Plants 49 

4.5 Cooling Tower 57 

4.6 Alcohol Storage Tanks 61 

4.7 Feedstock and Bulk Material Handling and Storage 67 

4.8 Roadways and Other Open Areas 77 

4.9 Leaking Components 83 

 

SECTION 5 GENERAL PERMIT CONDITIONS 86 

 

 5.1 General Requirements for Emission Testing 

 5.2 General Requirements for “Logs” or Similar Records 

 5.3 General Requirements for Records for Deviations 

 5.4 General Requirements for Reporting of Deviations 

 

ATTACHMENTS 

 

 1. Summary of Permitted Emissions 1-1 

 2. Standard Permit Conditions 2-1 
3 

SECTION 1: FINDINGS

1a. Power Holdings of Illinois, LLC (Power Holdings) has requested a 

permit for a plant that would produce synthetic natural gas (SNG) by 

gasification of coal. The proposed plant would have six gasifiers 

and two gas processing trains with heat recovery and gas cleaning 

systems and associated emission control devices. Other emission 

units would include two sulfuric acid plants, two steam 

superheaters, an auxiliary boiler, a cooling tower, feedstock 

handling and storage and ancillary operations. 

 b. Each of the gasifiers would have a nominal design capacity of about 

2,630 tons of coal per day. The design coal supply for the plant 

would be Illinois No. 6 coal from mines in Illinois containing 3.25 

percent sulfur by weight and 11,090 Btu per pound higher heating 

value, on an as-received basis. Alcohol would be used as the 

startup feedstock for the gasifiers. 

2. The plant would be located in rural Jefferson County, between 

Waltonville and Ashly. The site is in an area that is designated 

attainment for all criteria pollutants. 

3. The proposed plant is a major source under the PSD rules. This is 

because the potential annual emissions of sulfur dioxide (SO2), 

nitrogen oxides (NOx) and carbon monoxide (CO) will each be in excess 

of 100 tons. In addition, emissions of particulate matter 

(PM/PM10/PM2.5) and sulfuric acid mist will be in excess of their 

significant emission thresholds of 25/15/10 and 7 tons per year, 

respectively. (Refer to Attachment I for the potential emissions of 

the plant.) 

4. The proposed plant is not a major source for emissions of hazardous 

air pollutants (HAPs), i.e., as limited by this permit, the 

potential emissions from the plant will be less than 10 tons of an 

individual HAP (e.g., methanol), and will be less than 25 tons in 

aggregate for all HAPs. Therefore, the plant is not subject to 

National Emission Standards for Hazardous Air Pollutants (NESHAP), 

adopted by USEPA under 40 CFR Part 63 or to review under Section 

112(g) of the federal Clean Air Act. 

5a. After reviewing the materials submitted by Power Holdings, the 

Illinois EPA has determined that the project will (i) comply with 

applicable Board emission standards, (ii) comply with applicable 

federal emission standards, and (iii) utilize Best Available Control 

Technology (BACT) on emissions as required by PSD. 

 b. The determinations of BACT made by the Illinois EPA for the proposed 

plant are the control technology determinations contained in the 

permit conditions for specific emission units. 

6a. The air quality analysis submitted by Power Holdings and reviewed by 

the Illinois EPA shows that the proposed project will not cause or 

contribute to violations of the national ambient air quality 

standard (NAAQS) for NOx, SO2, PM10 and CO or the allowable air 
4 

quality increments established under the PSD rules. This analysis 

also enables the Illinois EPA to conclude that this project will not 

cause or contribute to violations of the NAAQS for PM2.5. 

 b. Power Holdings also submitted a screening analysis addressing the 

impacts of the project on air quality in Mammoth Cave National Park 

and the Wilderness Area at the Mingo Wildlife Refuge, which are 

located approximately 160 kilometers southwest and 270 kilometers 

southeast, respectively, of the site of the proposed plant. This 

analysis indicated that the plant will not violate the Class I air 

quality increments applicable in the areas. The Illinois EPA has 

determined, based on the assessment submitted by Power Holdings, 

that the proposed plant would not have an adverse impact on air 

quality values in these areas. 

7. The Illinois EPA has determined that the application for the 

proposed plant complies with all applicable Illinois Air Pollution 

Regulations and the federal rules for Prevention of Significant 

Deterioration of Air Quality (PSD), 40 CFR 52.21. 

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

Illinois EPA, a draft of this construction permit was placed in a 

nearby public repository, and the public was given notice and 

opportunity to examine this material and to participate in a public 

hearing and to submit comments on these matters. 
5 

SECTION 2: IDENTIFICATION OF SIGNIFICANT EMISSIONS UNITS 

Section Emission Units Emission Controls 

4.1 Gasification Block – 

Normal Operation 

Syngas cleanup (particulate, mercury 

and sulfur removal) and Oxidizers 

Gasification Block - 

Startup/Shutdown/Malfunction 

Good operating practices 

Flare minimization and proper flaring 

4.2 Steam Superheaters Fuel Selection 

Good combustion practices 

Selective catalytic reduction systems 

Auxiliary Boiler Fuel Selection 

Low–NOx burners and flue gas recirculation 

Good combustion practices

4.3 Startup Burners Good combustion practices 

4.4 Sulfuric Acid Plants Selective catalytic reduction system 

Hydrogen peroxide scrubber 

Sulfuric Acid Storage Tanks Vent control system 

4.5 Cooling Tower High-efficiency drift eliminators 

4.6 Alcohol Storage Tanks Internal floating roof 

4.7 Material Handling Equipment design, enclosure and 

filters 

4.8 Roadways Paving and fugitive dust control 

program 

4.9 Leaking Components Leak detection and repair program 
6 

SECTION 3: SOURCE-WIDE PERMIT CONDITIONS

CONDITION 3.1: 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 plant, 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 3.2: 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) and 40 CFR 63.43(g)(41). 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 54.21 (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 54.21 (b)(11).) 

CONDITION 3.3: EMISIONS OF HAZARDOUS AIR POLLUTANTS (HAPs) 

a. This permit is issued based on this plant 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 provisions of 40 CFR Part 63, and Section 112(g) of the Clean 

Air Act do not apply to this source. (Refer to the unit-specific 

conditions of this permit for further limits on HAP emissions.) 

b. The emissions of lead and mercury from the plant shall not exceed 

0.050 and 0.0005 tons/year, respectively. 

c. The Permittee shall keep records of the annual emissions of HAPs 

from the plant to demonstrate that the plant is not a major source 

or emissions of HAPs. These records shall be compiled on at least 

an annual basis and the results reported to the Illinois EPA with 

the Annual Emission Reports that the Permittee must submit for the 

plant pursuant to 35 IAC Part 254. 
7 

CONDITION 3.4: MISCELLANEOUS ANCILLARY EQUIPMENT 

a. i. A. The fuel fired in emergency engines and 

engines/generators shall be natural gas or very low 

sulfur diesel fuel. 

B. Engines firing fuels other than natural gas shall only be 

used as emergency equipment, as defined at 35 IAC 

211.1920. 

C. The power output of engines firing fuels other than 

natural gas shall be no more than 1,500 horsepower. 

D. The operation of engines firing fuels other than natural 

gas shall not exceed 500 hours per year, provided, 

however, that the Illinois EPA may authorize temporary 

operation of engines in excess of 500 hours per year to 

address extraordinary circumstances that require 

operation of this device, by issuance of a separate state 

construction permit addressing such circumstances. 

E. Emission from the engines shall not exceed the limits in 

Attachment I. 

ii. This permit is issued based on negligible emissions of VOM and 

PM from storage tanks not addressed in Section 4.6 of this 

permit, including diesel fuel and ammonia storage tanks. For 

this purpose, VOM emissions from each tank shall not exceed 

nominal emission rates of 0.1 lb/hour and 0.44 ton/year. 

iii. This permit is issued based on negligible emissions of each 

criteria pollutant from the wastewater treatment plant. For 

this purpose, emissions shall not exceed nominal emission rates 

of 0.1 lb/hour and 0.44 ton/year. 

iv. All ancillary equipment shall be operated and maintained in 

accordance with good air pollution control practice to minimize 

emissions (See also Condition 3.5.) 

Note: These requirements constitute the determination of Best 

Available Control Technology (BACT) for ancillary equipment, as 

required under the PSD rules. 

b. i. Ancillary equipment shall comply with all applicable emission 

standards and control requirements of applicable federal New 

Source Performance Standards (NSPS), 40 CFR Part 60, including 

the NSPS for Stationary Compression Ignition Internal 

Combustion Engines, 40 CFR 60, Subpart IIII, for the engines at 

the plant. 

ii. Ancillary equipment shall comply with all applicable emission 

standards and control of requirements of applicable state 

emission regulations at Title 35, Subtitle B, Chapter I, 

Subchapter c. 
8 

iii. The Permittee shall fulfill applicable requirements of 

applicable regulations, including provisions for testing, 

monitoring, recordkeeping, notification and reporting, for 

ancillary equipment 

CONDITION 3.5: GOOD AIR POLLUTION CONTROL PRACTICES 

The Permittee shall operate and maintain all emission units at this plant, 

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. 

CONDITION 3.6: COMPLIANCE WITH EMISSION LIMITATIONS 

a. In this permit, except as otherwise specified in a particular 

provision, the emission limitations for “particulate matter” or “PM” 

shall apply to particulate matter as would be measured by USEPA 

Reference Method 5, rather than to PM10 or PM2.5. The limitations for 

PM emissions also serve to limit emissions of PM10 and PM2.5, as 

measured by applicable USEPA methods for measurement of filterable 

emissions, since filterable PM10 and filterable PM2.5 are a subset of 

PM. Emissions of condensable particulate matter are addressed by 

limitations that are set for emissions of sulfuric acid mist. 

b. i. Except as provided below or unless otherwise specified in a 

particular provision, compliance with annual limitations 

established by this permit shall be determined 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). 

ii. For the first year (12 months) of operation, compliance shall 

be determined 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. 

CONDITION 3.7: 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 
9 

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 for an affected flare 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 3.8: 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 plant 

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. 

CONDITION 3.9: 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), 
10 

keep the records at a location at the plant 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 plant 

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 plant inspection. 

CONDITION 3.10: 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 3.11: AUTHORIZATION TO OPERATE EMISSION UNITS 

a. i. Under this permit, each gasifier, gas processing train, and 

sulfuric acid plant may be operated for a period that ends 365 

days after initial startup to allow for equipment shakedown and 

required emissions testing. This period may be extended by 

Illinois EPA upon request of the Permittee if additional time 

is needed to complete shakedown or perform emission testing. 

ii. The remainder of the plant, excluding the above units, may be 

operated under this construction permit for a period of 365 

days after initial startup of the first gasifier. This period 

of time may be extended by the Illinois EPA for up to an 

additional 365 days upon written request by the Permittee as 

needed to reasonably accommodate unforeseen difficulties 

experienced during shakedown of the plant. 

iii. In addition, the auxiliary boiler may be operated at up to 10 

percent of capacity annual average (i.e., 127.4 mmBtu/hour, 

annual average), during construction of the plant, when it 
11 

would be used to protect equipment from freezing and provide 

comfort heating. 

b. Upon successful completion of required emission testing, the 

Permittee may continue to operate emission units as allowed by 

Section 39.5(5) of the Environmental Protection Act. 

c. These conditions supersede Standard Condition 6. 

CONDITION 3.12: 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 2.) 
12 

SECTION 4: UNIT-SPECIFIC CONDITIONS FOR PARTICULAR EMISSION UNITS

CONDITION 4.1: UNIT-SPECIFIC CONDITIONS FOR THE GASIFICATION BLOCK 

4.1.1 Description of Emission Units 

The affected emissions units for the purpose of these unit-specific 

permit conditions are the units in the gasification block. 

The gasification block would have six identical gasifiers to convert 

coal into a synthesis gas or “syngas”. The raw syngas from the 

gasifiers would then undergo a series of processes to remove 

contaminants from the gas and prepare it for conversion into 

synthetic natural gas (SNG). These cleanup processes would remove: 

1) particulate matter; 2) mercury; and 3) sulfur compounds, 

primarily hydrogen sulfide (H2S) from the raw syngas. The 

gasification block would also include the methanation units in which 

cleaned syngas would be converted into methane, which is the 

principal constituent of natural gas. 

The first step in the cleanup of raw syngas would be the particulate 

removal system for each gasifier. Further cleanup of the raw syngas 

would take place in separate gas processing or gas cleanup trains. 

The gasification block would have two parallel gas processing 

trains, each designed to handle the raw syngas output from three 

gasifiers. During maintenance or other outage of one gas processing 

train, the plant would continue to operate at half capacity with the 

other train. In each gas processing train, a carbon bed would 

remove mercury from the raw syngas. Sulfur compounds would be 

removed in Acid Gas Removal (AGR) units. These sulfur compounds 

would be converted to sulfuric acid, which would be a secondary 

product from the plant. The sulfuric acid plants are addressed in 

Section 4.4 of this permit. 

The main emission points from the gasification block during normal 

operation, if carbon dioxide (CO2) from the gasification block is not 

otherwise utilized, would be the atmospheric vents from the AGR 

units. In addition to removing sulfur compounds from the raw 

syngas, which are sent to the sulfuric acid plants, the AGR units 

also remove CO2 from the raw syngas. The CO2 streams from the AGR 

units would pass through regenerative thermal oxidizers to control 

the carbon monoxide (CO) and volatile organic material (VOM) present 

in these streams, before they are vented. These oxidizers would 

also convert the remaining sulfur compounds present in these streams 

to sulfur dioxide (SO2). 

During startup, shutdown and certain upsets of a gasifier or a gas 

processing train, the gasification block would also have emissions 

from one or more of the flare systems serving the gasification 

block. Each gas train would have two flare systems, one for flaring 

any releases of syngas from the train and the other for flaring any 

releases of H2S laden acid gas from the AGR unit. Emissions from 

flaring associated with startup of gasifiers would be minimized as 

alcohol would be used as the startup feedstock to bring the gasifier 
13 

up to normal operating pressure before coal is fed into the 

gasifier. The emissions from flaring would also be minimized 

through appropriate planning and remedial action to prevent and 

minimize events that would otherwise necessitate flaring. In 

addition, flared syngas should typically have undergone cleaning 

prior to flaring. During normal operation of the gasification 

block, the only emissions from the flares would be from the pilot 

burners and flow of purge gas to the flares, which are needed to 

safely maintain flares in readiness to ignite and combust any syngas 

or acid gas (i.e., process gases) that are sent to the flares. 

The gasification block would also have emissions from the natural 

gas fired burners that are used during the preheat step for each 

gasifier and certain units in the gas processing trains. The 

refractory lining in a gasifier must be preheated to operating 

temperature prior to introduction of alcohol startup feedstock. The 

catalyst beds in the CO shift and methanation units must also be 

preheated to operating temperature before syngas is introduced into 

these units. The natural gas-fired preheat burners would be vented 

through separate preheat vents that would only be open during 

preheating. Because the emissions of these preheat burners would be 

those associated with normal combustion of natural gas, these 

burners are addressed in Section 4.3 of this permit, rather than 

here in Section 4.1 with the gasification block. 

4.1.2 Control Technology Determination 

a. The gasification block shall be designed, equipped and 

maintained with the following features to minimize and control 

emissions. 

i. Gas cleanup systems for the raw syngas for removal of: 

A. Particulate Matter (PM); and 

B. Sulfur compounds, which shall be conducted with an 

absorption solvent such as Rectisol solvent or other 

comparable absorption solvent; 

ii. Vent systems so that any discharge of process gas (i.e., 

syngas or acid gas streams) from the gasifiers or gas 

cleanup units that is not sent to a methanation unit, 

sulfuric acid plant, or otherwise used can be vented to a 

combustion device (flare, oxidizer, or other combustion 

unit) for disposal. This requirement does not apply to 

exhaust from the preheating of gasifiers and process 

units (as addressed in Section 4.3 of this permit) or to 

air or nitrogen introduced into a unit during periods 

when a unit is shut down, as might be needed to purge the 

unit in preparation for maintenance or startup. 

iii. Oxidizers or other combustion units to control carbon 

monoxide and organic compounds in the CO2 vent streams 

from the acid gas removal (AGR) units. 
14 

iv. Flares shall be fitted with an automatic igniter device 

for the pilot flame, which device shall be maintained in 

good working order. 

b. The gasification block shall be operated to comply with the 

following work practices: 

i. All discharges of process gas to the atmosphere shall be 

vented to a flare, oxidizer, or other combustion device 

through a closed vent system, except during preheat 

operations (as addressed in Section 4.3 of this permit) 

or when a failure of equipment or planning preclude the 

safe disposal of a gas stream in this manner. 

ii. The operating level of gasifiers at any time shall not 

exceed the actual working capacity of the gas processing 

trains at the time. 

iii. Process gas shall not be flared except during startup, 

shutdown, or malfunction due to either failure of 

equipment or planning, which precludes the safe handling 

of the raw gas by the gas processing trains. 

iv. All acid gas streams produced by cleanup of syngas shall 

be processed by a sulfuric acid plant (See Section 4.4) 

except in the event of startup, shutdown or malfunction, 

when acid gas streams shall be flared. 

v. Emissions from startup of gasifiers shall be minimized by 

use of natural gas to preheat a gasifier prior to 

introduction of feedstock into the gasifier, use of 

alcohol during startup of a gasifier prior to 

introduction of solid feedstock into the gasifier, and 

coordination with the startup and operation of the gas 

processing trains. 

vi. Flares shall be operated to comply with all relevant 

requirements of 40 CFR 60.18. 

vii. Only natural gas or SNG shall be used as fuel for the 

pilot burners for the flares. 

c. The good air pollution control practices used for the 

gasification block to minimize emissions, including flaring and 

its associated emissions, shall include the following: 

i. Operation of emission units in accordance with written 

operating procedures that include startup, shutdown and 

malfunction plan(s), as further addressed in Condition 

4.1.5-2. 
15 

ii. Inspection, maintenance and repair of units in accordance 

with written maintenance procedures, as further addressed 

in Condition 4.1.5-2. 

iii. Implementation of flare minimization planning, as further 

addressed in Condition 4.1.5-3. 

d. i. The emissions of SO2, NOx, CO, PM and sulfuric acid mist 

from the flares in the gasification block shall not 

exceed the annual limitations in Condition 4.1.6(a), 

effective one year after the shakedown of the 

gasification block is complete. For the purpose of 

determining compliance with the limitation for CO, 

emissions shall be determined from the CO content of 

flared process gas using a destruction efficiency of no 

more that 99 percent for a properly operating flare. 

ii. The emissions of SO2, NOx, CO, PM and sulfuric acid mist 

from the AGR units in the gasification block (i.e., the 

exhaust from the oxidizers on the CO2 vents from the AGR 

units) shall not exceed the hourly limitations in 

Condition 4.1.6(b). 

Note: These conditions set “secondary” BACT limits for the 

units in the gasification block to accompany the equipment and 

work practice requirements established as BACT in Condition 

4.1.2(a), (b) and (c). 

4.1.3 Applicable State Emission Standards 

Affected units are subject to the following state emission standards. 

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

emission unit shall not have opacity greater than 30 percent, 

pursuant to 35 IAC 212.123(a), except as authorized 35 IAC Part 

201 Subpart I. 

b. The emissions of SO2 into the atmosphere shall not exceed 2000 

ppm, pursuant to 35 IAC 214.301. 

c. Notwithstanding Conditions 4.1.3(a) and (b), the Permittee is 

authorized pursuant to 35 IAC 201.149, 201.161 and 201.262 to 

operate the affected flares in violation of the applicable 

standards in 35 IAC 212.123(a) and 214.301 (Condition 4.1.3(a) 

and (b)) during malfunction or breakdown. This authorization 

is subject to the following terms and conditions. 

i. This authorization only allows such continued operation 

as necessary to prevent risk of injury to personnel or 

severe damage to equipment, provided however, that 

operation shall not continue solely for the economic 

benefit of the owner or operator of the plant. As 

provided by 35 IAC 201.265, this authorization does not 

shield the source from enforcement for any such violation 
16 

and shall only constitute a prima facie defense to such 

an enforcement action, provided that the Permittee has 

fully complied with all terms and conditions connected 

with such authorization. 

ii. The Permittee shall operate and maintain the affected 

flares in accordance with a Startup, Shutdown and 

Malfunction Plan, as further addressed by Condition 

4.1.5-2. 

iii. Upon occurrence of excess emissions due to malfunction or 

breakdown, the Permittee shall as soon as practicable, 

repair the unit(s) that are responsible or remove unit(s) 

from service, so that excess emissions cease. For this 

purpose, if the Permittee has operated and maintained the 

equipment and associated air pollution control equipment 

so that malfunctions and breakdowns are infrequent, 

sudden, and not caused by poor maintenance or careless 

operation, and in general are not preventable, the 

Permittee shall begin shutdown of equipment within 4 

hours unless the malfunction is expected to be repaired 

within 6 hours. In such case, the shutdown of the 

affected plant shall be undertaken when it is apparent 

that the repair will not be accomplished within 6 hours. 

iv. The Permittee shall fulfill applicable recordkeeping and 

reporting requirements of Conditions 4.1.10(c) and (d) 

and 4.1.11(c). 

4.1.4 Non-applicability Provisions 

a. This permit is issued based on affected units not being subject 

to state emission standards for fuel combustion emission units 

because the units are chemical process units and any recovery 

of heat from the units is incidental to this function. 

b. This permit does not address the control requirements of 35 IAC 

215.301, Use of Organic Material, for affected units, as any 

emissions of organic material directly from such units are to 

be flared, which will assure compliance with the alternative 

standard of 35 IAC 215.302, providing at least 85 percent 

control of emissions of organic material. 

4.1.5-1 Operating Requirements 

a. The amount of solid feedstock fed to the gasification block 

shall not exceed 15,800 tons per day, weekly average and 

5,000,000 tons/year. 

b. The total flow of pilot gas to each flare in the gasification 

block shall not exceed 6,240 scf per day, 30-day rolling 

average. 
17 

c. Each gas processing train shall be designed, equipped and 

maintained with an activated carbon bed for removal of mercury 

from the raw syngas. 

4.1.5-2 Startup, Shutdown and Malfunction Plans 

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

written Startup, Shutdown, and Malfunction Plans (Plans) 

that describe, in detail, procedures for operating and 

maintaining the various emission units in the 

gasification block, including associated emission control 

systems, during periods of startup, shutdown, and 

malfunction and a program of corrective action for 

malfunctioning process, air pollution control and 

monitoring equipment used to comply with the relevant 

emission standards and emission control requirements. 

These Plans shall be developed to satisfy the purposes 

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

amended April 20, 2006. In this regard, with respect to 

startups, these Plans shall address readily foreseeable 

startup scenarios, including so called “hot startups” 

when the operation of a gasifier or gas train, is only 

temporarily interrupted. With respect to malfunction, 

these Plans shall identify 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, reduce the 

operating rate of the gasifiers or remove gasifiers from 

service to so that the deviation ceases. 

ii. For the purpose of this condition and other conditions of 

this permit for which the regulatory definitions of the 

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

NSPS are not applicable, the definitions of the terms 

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

at 40 CFR 63.2 (as amended April 20, 2006), shall apply 

and be used. In addition, as related to the scope of the 

Startup Shutdown and Malfunction Plan, the term 

“malfunction” 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 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 emission units in the gasification block. 
18 

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

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

and maintain units in the gasification block, including 

associated air pollution control equipment and monitoring 

equipment, in a manner consistent with safety and good air 

pollution control practices for minimizing emissions to the 

levels required by the applicable standards and limits or 

comply with the applicable 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 Plan), review of 

operation and maintenance records, and inspection of units. 

[Reflects 40 CFR 63.6(e)(1)(i) as amended April 20, 2006] 

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

unit(s) in the gasification block, the Permittee shall 

operate and maintain such unit(s), including associated 

air pollution control and monitoring equipment, in 

accordance with the procedures specified in the 

applicable Plan. The Permittee shall correct 

malfunctions as soon as practicable after their 

occurrence in accordance with the 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 practices. 

[Reflects 40 CFR 63.6(e)(1)(ii) and (3)(ii) as amended 

April 20, 2006] 

ii. When actions taken by the Permittee during a startup, 

shutdown, or malfunction (including actions taken to 

correct a malfunction) are consistent with the procedures 

specified in the applicable 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 and each malfunction of the 

air pollution control and monitoring equipment. 

Furthermore, the Permittee shall confirm in the periodic 

compliance report (refer to Condition 4.1.11(b) that 

actions taken during periods of startup, shutdown, and 

malfunction were consistent with the Plan. [Reflects 40 

CFR 63.6(e)(3)(iii) as amended April 20, 2006] 

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 Plan, and the 

unit(s) exceeds a relevant emission standard or limit, 

then the Permittee must record the actions taken for that 
19 

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 CAAPP 

Permit for the plant. [Reflects 40 CFR 63.6(e)(3)(iv) as 

amended April 20, 2006] 

c. i. The Permittee shall develop its initial Plans prior to 

the initial startup of the gasification block. The 

Permittee shall make changes to the Plan if required by 

the Illinois EPA or necessary to satisfy the requirements 

of this permit or address other changes to procedures for 

the gasification block. [Reflects 40 CFR 63.6(e)(3)(vii) 

and (viii) as amended April 20, 2006] 

ii. This 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 Plan, the 

Permittee must also retain and make available the 

previous (i.e., superseded) version of the Plan for a 

period of at least 5 years after such revision. 

[Reflects 40 CFR 63.6(e)(v) and 40 CFR 63.10(b)(1) as 

amended April 20, 2006] 

d. Consistent with the above, if the Permittee has maintained and 

operated the gasification block so that malfunctions are 

infrequent, sudden, not caused by poor maintenance or careless 

operation, and in general are not reasonably preventable, the 

Permittee shall begin shutdown of gasifiers within 4 hours, 

unless the malfunction is expected to be repaired within 6 

hours. In such case, shutdown shall be undertaken when it is 

apparent that repair will not be accomplished within 6 hours or 

at a later time if shutdown will endanger the safety of plant 

personnel or cause severe damage to equipment. In no case 

shall shutdown of gasifiers be delayed solely for the economic 

benefit of the Permittee. 

4.1.5-3 Flaring Minimization Planning 

a. The flaring minimization planning conducted by the Permittee 

for the gasification block pursuant to Condition 4.1.2(c)(iii) 

shall include the preparation and maintenance of Flare 

Minimization Plans (Plans) for the gasification block that 

include the following: 

i. Technical information for the gasification block, 

including a general description of the gasification 

block, 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, seal drums, and other significant 

components of the flares. 
20 

ii. A general description of the Permittee’s written 

procedures for the operation of the gasification block. 

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

flaring due to occurrence of process upsets or 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 gasification 

block, including the provisions in these procedures that 

should act to minimize flaring. 

vi. A description of the established responsibilities of 

different personnel at the plant for the operation and 

maintenance of the gasification block. 

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 gasification 

block, 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 syngas 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 gasification block 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 gasification block, which addresses the 

following: 
21 

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 

measured 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 gasification block. 

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 gasification 

block. 

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. These Plans are records 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 gasification block is complete, the 

Permittee shall also conduct an event-specific investigation or 

“Root-Cause Analysis” into each “Flaring Incident” at the 

gasification block 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 gasification block) that accompanies the unscheduled 

shutdown of a gas processing train. 

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 

and all contributing causes to the incident, with a 
22 

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 CO, VOM and SO2

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 
23 

days until a complete final report is submitted for the 

incident. 

e. Planning and other activities conducted by the Permittee as 

part of flaring minimization planning pursuant to this 

Condition 4.1.5-3 may be combined with planning and activities 

conducted by the Permittee as part of the preparation and 

implementation of Startup, Shutdown and Malfunction Plans 

pursuant to Condition 4.1.5-2 provided that the requirements of 

this condition are also met. 

4.1.5-4 Other Work Practice Requirements 

The Permittee shall handle the feedstock for the gasification block 

in accordance with a written Feedstock Management Plan that shall be 

designed to provide the gasifiers with a consistent feedstock that 

meets relevant criteria needed for proper operation of the gasifiers 

and production of a syngas that can be reliably processed by the gas 

trains. The Permittee shall review this plan on a regular basis and 

revise it if needed consistent with good air pollution control 

practice based on actual operating experience and equipment 

performance. This review shall occur at least every two years if 

not otherwise initiated by events that are not adequately addressed 

by the existing plan or a specific request by the Illinois EPA for 

such review. 

4.1.6 Emission Limitations 

a. The emissions of the affected AGR units (i.e., the exhausts 

from the oxidizers on the CO2 vents from the AGR units) shall 

not exceed the following limits. The hourly limits shall apply 

on a 24-hour block average for pollutants for which continuous 

emissions monitoring is performed or otherwise on a 3-hour 

average. The annual limits shall take effect one year after 

the shakedown of the gasification block is complete. 

Pollutant 

Individual Limits Total Annual 

Limit 

(Tons/Year) 

Hourly 

(Lbs/Hour) 

Annual 

(Tons/Year) 

SO2 11.0 48.3 96.6 

NOx 2.7 11.7 23.4 

CO 61.0 266.2 532.5 

VOM 0.09 0.4 8.01 

PM 0.5 1.9 3.8 

Sulfuric Acid Mist 0.005 0.023 0.05 

Total Reduced Sulfur 0.048 0.21 0.43 

Fluorides 0.011 0.050 0.1 

Methanol 0.82 3.6 7.2 

Other Individual HAP 0.13 0.57 1.14 

Total HAPs 0.95 4.17 8.34 

b. The emissions from the affected units controlled by flares 

shall not exceed the following limits. The hourly limits shall 
24 

apply on a 24-hour block average for pollutants for which 

continuous emissions monitoring is performed or otherwise on a 

3-hour average. The annual limits shall take effect one year 

after the shakedown of the gasification block is complete. 

Pollutant 

Hourly Limits (Lbs/Hour) Annual 

Limits 

(Tons/Year,

totala

) 

Syngas Flares 

(combined) 

Acid Gas Flares 

(combined) 

Normal Otherb Normal Otherb

SO2 0.10 9,510.0 0.10 9,510.00 73.10 

NOx 0.16 513.0 0.10 3.70 5.30 

CO 0.20 1,279.0 0.10 0.10 18.80 

VOM 0.02 105.0 0.01 0.74 1.20 

PM 0.10 15.4 0.10 0.11 0.52 

Sulfuric Acid 

Mist 

0.02 71.0 0.02 95.0 1.46 

Total Reduced 

Sulfurd

---- 1.94 ---- 1.94 1.90 

Methanol ---- 6.30 ---- 1.60 0.10 

Other 

Individual HAPc

0.01 0.01 0.01 0.01 0.06 

Total HAPs 0.01 6.31 0.01 1.61 0.19 

Notes

a. Total emission of all flares, including periods of 

startup, shutdown and malfunction or breakdown. 

b. Operation during startup, shutdown and malfunction. 

c. Individual HAP other than methanol. 

d. Total Reduced Sulfur is the combination of hydrogen 

sulfide, carbonyl sulfide and carbon disulfide. 

4.1.7-1 Operational Testing for the Flares 

a. Within 90 days of initial startup of each affected flare, the 

Permittee shall conduct observations for visible emissions from 

the flare in accordance with 40 CFR 60.18(f)(1) to verify 

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

b. Within 90 days of initial startup of the first syngas flare and 

the first acid gas flare, the Permittee and shall perform 

sampling and analysis of the heat content of the process 

gas(es) that would be that flare in accordance with 40 CFR 

60.18(f)(3) to verify compliance with 40 CFR 60.18(c)(3). 

4.1.7-2 Emission Testing for the AGR Units 

a. The Permittee shall have emissions tests conducted for the 

atmospheric vent from each AGR Unit (oxidizer exhaust) as 

follows at its expense by an approved testing service while the 
25 

unit is operating in the maximum range and other representative 

operating conditions. 

i. Within 60 days after achieving the maximum rate at which 

the unit will be operated but not later than 365 days 

after initial startup of the unit, the Permittee shall 

have tests conducted for emissions of CO. 

ii. A. Within 60 days after achieving the maximum rate at 

which the unit will be operated but not later than 

365 days after initial startup of the unit, the 

Permittee shall have tests conducted for emissions 

of NOx, total reduced sulfur, sulfuric acid mist, VOM 

and methanol. 

B. This period of time may be extended by the Illinois 

EPA for up to an additional 365 days upon written 

request by the Permittee as needed to reasonably 

accommodate unforeseen difficulties in the startup 

and testing of the associated gas train, provided 

that preliminary emissions measurements are 

conducted and reported to the Illinois EPA. 

iii. In addition to the emission testing required above, the 

Permittee shall perform emission tests as provided below 

as specified by the Illinois EPA within 45 days of a 

written request by the Illinois EPA or such later date 

agreed to by the Illinois EPA. 

Note: Specific requirements for periodic emission 

testing may be established in the CAAPP Permit for the 

plant. 

b. The following methods and procedures shall be used for testing, 

unless other methods adopted or endorsed by USEPA or being 

developed by USEPA are approved by the Illinois EPA. 

Location of Sample Points Method 1 

Gas Flow and Velocity Method 2 

Flue Gas Weight Method 3 or 3A 

Moisture Method 4 

Nitrogen Oxides Method 19 

Carbon Monoxide Method 10 

Total Reduced Sulfur Method 15A 

Sulfuric Acid Mist Method 8 

Volatile Organic Material Method 18 

Methanol Method 308 

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

submitted to the Illinois EPA in accordance with the 

Condition 5.1. 

ii. In addition to other information required to be included 

in a test report, test reports shall include detailed 
26 

information on the operating conditions of the 

gasification block during testing, including: 

A. Feedstock consumption (tons/day); 

B. Composition of the feedstock (Refer to Condition 

4.1.9), including the metals (e.g., mercury), 

chlorine and fluorine content, expressed in weight 

percent; 

C. Significant operating parameters of the gasifiers; 

D. Amount of syngas processed by each AGR unit; 

E. Composition of the gas routed to the oxidizer for 

chlorine, fluorine and metals by elemental analysis; 

F. Combustion chamber temperature of the oxidizer; and 

G. Opacity of the exhaust, 6-minute averages, as 

determined by USEPA Method 9. 

4.1.8-1 Operational Instrumentation and Monitoring for the Gasification Block 

a. The Permittee shall install, operate, and maintain 

instrumentation for consumption of coal (solid) feedstock and 

alcohol by the gasifiers. 

b. The Permittee shall install, operate and maintain continuous 

monitoring systems for key operating parameters of the cleanup 

systems in each gas processing train, including: 

i. Temperature at and pressure drop across the cleanup 

system for mercury; and 

ii. Flow rate of the adsorption solvent in the AGR unit. 

4.1.8-2 Operational Instrumentation and Monitoring for the Affected Flares 

a. The Permittee shall install, operate and maintain continuous 

monitoring systems on each affected flare related to the 

discharge of process gas (i.e., syngas or acid gas streams but 

not fuel for the pilot flame or purge gas) to a flare for the 

following parameters. These monitoring systems shall be 

operated in accordance with relevant provisions of the NSPS, 40 

CFR 60.107(a): 

i. The total flow of process gas sent to the flare (SCFM). 

ii. The H2S and CO content of the process gas sent to the 

flare (ppm). 

b. The Permittee shall continuously monitor each affected flare 

for the presence of a flare pilot flame using a thermocouple or 
27 

any other equivalent device to detect the presence of a flame, 

which monitoring shall be conducted in accordance with 40 CFR 

60.18(f)(2). 

c. The Permittee shall install, operate and maintain continuous 

monitoring systems on each affected flare for the usage of 

pilot gas and purge gas (other than nitrogen or other inert 

gas) by the flare, in scfm. Readings shall be taken at least 

once every 5 minutes and the average hourly values shall be 

recorded on an hourly and daily basis. 

d. The Permittee shall continuously monitor the liquid level and 

pressure of the seal drum that serves each affected flare, 

which monitoring devices shall be operated according to the 

manufacturer’s specifications and requirements. 

e. The Permittee shall develop and maintain written Monitoring 

Procedures for each affected flare addressing the required 

monitoring systems and the operational monitoring systems for 

each flare and associated equipment in the gasification block, 

which shall include the following information. A copy of these 

procedures shall be submitted to the Illinois EPA for review 

prior to the initial startup of the gasification block. 

i. A process flow diagram of the affected flare and 

equipment in the gasification block 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 for the 

gasification block. 

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 location, for sampling of flare 

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

purge gas; on/off flow indicators, HHV analyzer, total 

sulfur analyzer, operating parameters of the liquid seal, 

and operating parameters of the gasification block 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. 
28 

4.1.8-3 Operational Instrumentation and Monitoring for the AGR Units 

a. The Permittee shall install, operate and maintain continuous 

monitoring systems on the oxidizer associated with each AGR 

unit for the following parameters: 

i. The H2S content of gas entering the oxidizer, which 

monitoring systems shall be operated in accordance with 

relevant provisions of the NSPS, CFR 60.107a. 

ii. The temperature in the combustion chamber of the 

oxidizer. 

4.1.9 Sampling and Analysis of Feedstock and Syngas 

a. The Permittee shall sample and analyze the solid feedstock 

supplied to the gasification block for sulfur and heat content 

in accordance with USEPA Method 19 and for mercury and other 

metals, chlorine and fluorine content using applicable ASTM 

methods. This activity shall be conducted: 

i. In conjunction with emissions testing of the superheaters 

(see Condition 4.2.7). 

ii. Within 90 days of acceptance of a feedstock from a new 

source. 

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

iv. At least once every two calendar years, if a more frequent 

analysis is not otherwise needed pursuant to the above. 

b. The Permittee shall sample and analyze the gas stream from each 

AGR Unit that is sent to the oxidizer for its sulfur content 

using USEPA Method 19 and its VOM (hydrocarbons), methanol, 

H2S, COS and CS2 content using applicable ASTM methods. This 

activity shall be conducted: 

i. In conjunction with emissions testing of an AGR Unit (see 

Condition 4.1.7-2). 

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

iii. At least once every two calendar years, if a more frequent 

analysis is not otherwise needed pursuant to the above. 

c. The Permittee shall take representative samples at least every 

three calendar years of the various gas streams that could be 

vented to the flare(s) and analyze them using applicable ASTM 

methods for sulfur, VOM, methanol, chlorine, fluorine, and 

mercury and other metals content and for heat content. 

d. The Permittee shall maintain records for this sampling and 

analysis activity. 
29 

4.1.10 Recordkeeping Requirements 

a. The Permittee shall maintain records of the production of 

synthetic natural gas (SNG) by the plant, million SCF per 

month, determined as SNG transferred offsite from the plant. 

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

records for the affected units in the gasification block that 

include the information specified in Condition 5.2(a) and the 

following detailed information: 

i. For each startup of unit(s), 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 of unit(s), 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 in compliance with 40 CFR 60.18(f)(1). 

v. The amount and nature of the process gas sent to the 

flare(s), with detailed explanation if partially cleaned 

syngas was flared. 

vi. The amount of CO, H2S and VOM contained in the gas sent 

to the flare(s) and the amount of CO, SO2 and VOM 

emitted, pounds/event, with supporting calculations. 

vii. Whether SO2 emissions of the flare(s) may have exceeded 

the standard of 35 IAC 214.301, i.e., 2000 ppm, on an 

hourly average. 

viii. Corrective actions taken during the event. 
30 

ix. A description of any actions taken to prevent or reduce 

the likelihood of similar future occurrences. 

d. The Permittee shall maintain inspection, maintenance and repair 

log(s) or other similar records for the affected units in the 

gasification block that at a minimum include the information 

specified in Condition 5.2(b) and identify any occasion when 

the Permittee was unable to carry out its established 

maintenance procedures, with explanation. 

e. The Permittee shall keep records for any deviations from 

applicable requirements involving the gasification block, which 

records shall include the information specified by Condition 

5.3. These records may be combined with other records required 

for the gasification block by this permit. 

f. The Permittee shall keep the following records related to 

emissions of SO2, NOx, VOM, CO, PM, methanol, mercury, hydrogen 

chloride, hydrogen fluoride and other HAPs from the emission 

units in the gasification block (each flare and each AGR 

unit/oxidizer): 

i. A file containing the emission factors that the Permittee 

uses to calculate emissions of each pollutant, with 

supporting documentation. 

ii. Emissions of each pollutant from the unit, based on 

operating data and applicable emission factors, with 

supporting calculations. 

4.1.11 Reporting for Units in the Gasification Block 

a. The Permittee shall promptly notify the Illinois EPA of 

deviations of unit(s) in the gasification block with permit 

requirements as follows. Reports shall include the information 

specified by Condition 5.4: 

i. Failure of an affected flare or an oxidizer on an AGR 

unit, 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. For certain deviations by the affected flares, as 

specified by Condition 4.1.11(b). 

iii. The deviations addressed above and all other deviations 

shall be reported in the periodic compliance reports 

required by Condition 4.1.11(c). 

b. The Permittee shall provide the following notifications and 

reports to the Illinois EPA, concerning each incident when 

operation of affected flare(s) continued during a malfunction 
31 

or breakdown with SO2 emissions or opacity in excess of that 

allowed by 35 IAC 214.301 or 212.123(a), respectively. 

i. The Permittee shall notify the Illinois EPA’s regional 

office by telephone as soon as possible during normal 

working hours, but no later than three days, for each 

incident. 

ii. Upon completion of the incident, the Permittee shall give 

a written follow-up notice to the Illinois EPA, 

Compliance Section and Regional Field Office, within 15 

days providing a detailed explanation of the event, an 

explanation why continued operation was necessary, the 

length of time during which operation continued under 

such conditions, the measures taken by the Permittee to 

minimize and correct deficiencies with chronology, and 

when the repairs were completed or units were shutdown. 

c. The Permittee shall submit periodic compliance reports for the 

gasification block. The reports shall be submitted no later 

than 30 days after the end of the calendar six month 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. 

ii. A summary of operation and emissions of the gasification 

block during the reporting period, including the total 

number of startups of gasifiers, the total number of 

startups of gas processing trains, the amount of SNG 

produced by the plant, and the emissions of SO2, NOx and 

CO 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 a event-specific Root 

Cause Analysis was performed for the event pursuant to 

Condition 4.1.5-3(d). 

d. 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 

4.1.11(c)(iii) for flaring events during the 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 
32 

share of emissions, a summary of each event-specific Root 

Cause Analysis was performed, and calculated CO emissions 

of the flares as compared to the limit in Condition 

4.1.5-3(d). 

iii. Include copies of the summaries for flaring activity for 

the preceding three years as required by Condition 

4.1.11(d)(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 4.1.5-3(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 

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 4.1.5-

3(c)(ii) and (iii), with brief description. 

vii. Include a listing of significant changes, if any, made to 

the Monitoring Procedures required by Condition 4.1.8-

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. 

4.1.12 Additional Reporting for the Shakedown Period and the Following Year 

a. The Permittee shall provide the Illinois EPA with notice at 

least 15 days advance prior to initial feeding of alcohol to a 

gasifier and initial feeding of coal to a gasifier. 

b. During the shakedown period for the gasification block, the 

Permittee shall promptly notify the Illinois EPA of any 

event(s) that disrupts orderly shakedown. 

c. During the shakedown period for the gasification block and a 

period that extends for one year (12 months) after the 

conclusion of the shakedown period, the Permittee shall submit 

the periodic compliance reports required by Condition 4.1.11(c) 

on a monthly basis, with reports submitted no later than 25 

days after the end of each calendar month, beginning with the 
33 

first month in which any fuel is fired in the unit. During the 

shakedown period, these reports shall also include the 

following information: 

i. Operating data for the gasification block, i.e., total 

operating hours and feedstock usage and SNG production 

during the reporting period); 

ii. Activities accomplished and significant events related to 

emissions of the gasification block; 

iii. Current schedule for emission testing; 

iv. A summary of any emission measurements conducted; and 

v. When applicable, notice that all emission testing has 

been completed and shakedown of the gasification block is 

considered complete. 
34 

CONDITION 4.2: UNIT-SPECIFIC CONDITIONS FOR THE STEAM SUPERHEATERS AND 

AUXILIARY BOILER 

4.2.1 Description 

The affected units for the purpose of these unit-specific conditions 

are the two natural gas-fired steam superheaters and the natural 

gas-fired auxiliary boiler at the plant. 

The superheaters will “superheat” or further heat low temperature 

steam generated from various heat exchangers in the gasification 

block that are recover the thermal energy of high-temperature gas 

streams. This “low quality” process steam must be further heated to 

raise its temperature to a level that meets the specifications for 

steam sent to the steam turbine generators at the plant that supply 

the electricity for the operation of the plant. The superheaters 

would be fired on natural gas which may include both natural and 

synthetic natural gas. The emissions of NOx from the superheaters 

will be controlled by a Selective Catalytic Reduction (SCR) system 

installed on each unit. The flue gas from each unit will then merge 

and be vented through a common stack. 

The auxiliary boiler will be used to supply steam to the plant when 

the gasification block is not operating and to assist in the startup 

of units in the gasification block. Given its functions, the 

auxiliary boiler would not operate continuously. The auxiliary 

boiler will fire commercial natural gas that is piped to the plant. 

The boiler’s emissions of NOx from will be controlled by low-NOx

burners and flue gas recirculation. 

4.2.2 Control Technology Determination 

a. Each affected superheater shall be equipped and operated with 

the following to control emissions: 

i. Use of natural gas. 

ii. A Selective Catalytic Reduction (SCR) system. 

iii. Good Combustion Practices. 

b. The affected auxiliary boiler shall be equipped and operated 

with the following to control emissions: 

i. Use of natural gas. 

ii. Low-NOx Burners. 

iii. Flue Gas Recirculation 

iv. Good Combustion Practices. 

c. The emissions of the affected units shall not exceed the 

following limits, in lbs/mmBtu: 
35 

Pollutant Superheaters (combined) Auxiliary Boiler 

NOx 0.035, 30-day rolling 0.035, 24-hour block 

CO 0.040, 30-day rolling 0.040, 24-hour block 

SO2 0.0013, 24-hour block 0.0013, 24-hour block 

PM 0.01, 24-hour block 0.01, 24-hour block 

4.2.3-1 Applicable Federal Emission Standards 

a. The affected units are subject to the NSPS for IndustrialCommercial-Institutional Steam Generating Units, 40 CFR 60, 

Subpart Db and related provisions in 40 CFR 60, Subpart A, 

General Provisions. 

b. i. The affected superheaters shall comply with the 

applicable NSPS standard for NOx emissions, as follows, 

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: 

A. 86 ng/J (0.20 lb/million Btu) on a 30-day rolling 

average, pursuant to 40 CFR 60.44b(l); or 

alternatively. 

B. A limit set by USEPA pursuant to 40 CFR 60.44b(f). 

ii. The affected auxiliary boiler shall also comply with the 

above NSPS standard for NOx emissions, provided, however, 

that, compliance shall be determined on a 24-hour average 

basis for the initial performance test and on a 3-hour 

average basis thereafter until initial startup of the 

gasification block, as provided by 40 CFR 60.44b(j) for 

natural gas-fired units whose annual capacity factor is 

limited to no more than 10 percent. 

c. The affected superheaters shall comply with the applicable NSPS 

standards for PM and opacity, as follows, 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: 

i. Opacity shall not exceed 20 percent (6-minute average), 

except for one 6-minute period per hour of not more than 

27 percent opacity pursuant to 40 CFR 60.43b(f). This 

standard shall apply at all times, except during periods 

of startup, shutdown or malfunction as provided by 40 CFR 

60.2 and 60.11(c). 

ii. PM emissions shall not exceed 13 ng/J per actual heat 

input in any one hour period (0.030 lb/million Btu), 

pursuant to 40 CFR 60.43b(h)(1), except during periods of 

startup, shutdown or malfunction as provided by 40 CFR 

60.2 and 60.11(c). 
36 

d. At all times, the Permittee shall maintain and operate the 

affected units, including associated air pollution control 

equipment, in a manner consistent with good air pollution 

control practice for minimizing emissions, pursuant to 40 CFR 

60.11(d). 

4.2.3-2 Applicable State Emission Standards 

The affected units are subject to the following state emission 

standards: 

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

the affected auxiliary boiler shall not have an opacity 

greater than 20 percent, except as allowed by 35 IAC 

212.122(b) or 212.124. [35 IAC 212.122(a)] 

ii. The emission of smoke or other particulate matter from 

the affected superheaters shall not have an opacity 

greater than 30 percent, except as allowed by 35 IAC 

212.123(b) or 212.124. [35 IAC 212.123(a)] 

iii. Compliance with these limits shall be determined by 6-

minute averages of opacity measurements in accordance 

with USEPA Reference Method 9. [35 IAC 212.109 and 

212.122(a)] 

b. The CO emissions into the atmosphere from the affected units 

shall not exceed 200 ppm, corrected to 50 percent excess air. 

[35 IAC 216.121] 

c. The NOx emissions from the affected units shall not exceed 0.2 

lb/mmBtu in any one-hour period. [35 IAC 217.121(a)] 

4.2.4 Non-Applicability Provisions 

a. The affected units are not subject to the Title IV (i.e., Acid 

Rain) provisions of the federal Clean Air Act since they do not 

qualify as electrical generating units for the purpose of the 

Acid Rain program. 

b. This permit is issued based on certain provisions of the NSPS, 

as follows, not being applicable for the affected units: 

i. The affected auxiliary boiler is not subject to the 

limits of the NSPS for PM or opacity because it only 

burns natural gas. 

ii. The affected units are not subject to the SO2 standards 

of the NSPS, 40 CFR 60, Subpart Db, because the units 

only fire fuels 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 60.48b(j)(5)] 
37 

iii. The affected units are not eligible for the optional 

output-based NOx standard of the NSPS, 40 CFR 

60.44b(1)(3). This is because combustion of fuel in the 

superheaters and in the auxiliary boiler only contributes 

a portion of the energy in the steam that is recovered as 

electricity by the steam turbine generators. 

iv. The affected units are not subject to the opacity 

monitoring requirements of the NSPS, 40 CFR 60.48b, 

because they only burn gaseous fuels, without postcombustion technology to reduce SO2 or PM emissions. [40 

CFR 60.48b(j)(2)] 

v. The affected auxiliary boiler is not subject to the NOx

monitoring requirements of the NSPS, 40 CFR 60.48b, 

during the period before the initial startup of the 

gasification block because it will meet the criteria of 

40 CFR 60.44b(j) during this period, i.e., the annual 

capacity factor of the boiler will be limited no more 

than 10 percent. [40 CFR 60.48b(i)] 

vi. The affected units are not subject to any requirements of 

the NSPS, 40 CFR 60, Subpart D, because they are subject 

to the NSPS, 40 CFR 60, Subpart Db. [40 CFR 60.40(e)] 

4.2.5 Operational and Production Limits and Work Practice 

a. Natural gas shall be the only fuel combusted in the affected 

units. 

b. i. The annual capacity factor, as defined by 40 CFR 60.41b, of 

the affected auxiliary boiler shall not exceed 46 percent. 

ii. Notwithstanding the above, during the period before the 

initial startup of the gasification block, the annual 

capacity factor of the affected auxiliary boiler shall 

not exceed 10 percent (127.4 mmBtu/hour, annual average). 

4.2.6 Emission Limitations 

a. The emissions of the affected superheaters, combined, shall not 

exceed the following limits. The hourly limits shall apply on 

a monthly average for pollutants for which continuous emissions 

monitoring is performed or otherwise on a 24-hour block 

average. The annual limits address all emissions from the 

units, including emissions during startup, shutdown and 

malfunction and breakdown. 

Pollutant 

Hourly Limit (Lbs/Hour) Annual Limit 

Normal Other (Tons/Year) a

SO2 0.17 0.3 0.5 

NOx 4.60 9.5 17.5 

CO 5.25 10.5 20.0 

VOM 1.30 3.0 2.6 
38 

Pollutant 

Hourly Limit (Lbs/Hour) Annual Limit 

Normal Other (Tons/Year) a

PMb 1.50 3.0 5.8 

Individual HAP 0.33 1.7 1.2 

Total HAPs 0.33 1.7 1.2 

Notes: 

a. “Other” addresses periods of startup, shutdown, and 

malfunction or breakdown. 

b. Limits for PM address total emissions of particulate 

matter, including both filterable and condensable 

particulate. 

b. The emissions of the affected auxiliary boiler shall not exceed 

the following limits. The hourly limits shall apply on a 24-

hour block average basis for pollutants for which continuous 

emissions monitoring is performed or otherwise on a 3-hour 

block average. The annual limits address all emissions from 

the units, including emissions during startup, shutdown, 

malfunction and breakdown. 

Pollutant 

Hourly Limits 

(Lbs/Hour) 

Annual Limits 

(Tons/Year) 

SO2 1.7 3.3 

NOx 44.6/89.2a 89.2 

CO 51.0 101.9 

VOM 6.4 12.8 

PMb 12.8 25.6 

Individual HAP 1.6 3.2 

Total HAPs 1.6 3.2 

a. The alternate limitation applies during periods of 

startup, shutdown, and malfunction or breakdown. 

b. Limits for PM address total emissions of particulate 

matter, including both filterable and condensable 

particulate. 

4.2.7 Emission Testing Requirements 

a. The Permittee shall have emissions testing performed for the 

affected units as follows at its expense by an approved testing 

service while the affected units are operating at maximum 

operating load and other representative operating conditions: 

i. For the affected auxiliary boiler, initial performance 

testing for emissions of NOx required under the NSPS 

shall be conducted in accordance with 40 CFR 60.8 and 

60.46b. 
39 

ii. For each affected superheater, initial performance 

testing for emissions of PM, PM(condensable) and NOx and 

opacity required under the NSPS shall be conducted in 

accordance with 40 CFR 60.8 and 60.46b. 

iii. For the affected superheaters, 

A. Emissions tests shall be performed for CO, PM 

(filterable and condensable), and VOM within one 

year (365 days) after completing the shakedown of 

the gasification block. 

B. This period of time may be extended by the Illinois 

EPA for up to an additional 365 days upon written 

request by the Permittee as needed to reasonably 

accommodate unforeseen difficulties in the startup 

and testing of the gasification block or enable 

testing while both superheaters are operating 

provided that applicable initial performance testing 

required by the NSPS has been completed and the test 

report submitted to the Illinois EPA. 

iv. In addition to the emission testing required above, the 

Permittee shall perform emission tests as requested by 

the Illinois EPA for affected unit(s) within 45 days of a 

written request by the Illinois EPA or such later date 

agreed to by the Illinois EPA. 

Note: Specific requirements for periodic emission 

testing may be established in the CAAPP Permit for the 

plant. 

b. i. The methods and procedures for testing emissions of PM 

and NOx and opacity shall be in accordance with 40 CFR 

60.46b. 

ii. The following methods and procedures shall be used for 

testing, unless use of other methods adopted or endorsed 

by USEPA or being developed by USEPA are approved by the 

Illinois EPA. 

Location of Sample Points Method 1 

Gas Flow and Velocity Method 2 

Flue Gas Weight Method 3 or 3A 

Moisture Method 4 

PM (Condensable) Method 202 

COa Method 10 

VOM Methods 18 and 25A 

Note: 

a. CO emission testing shall be conducted for the 

purpose of certification of the continuous emission 

monitors required by Condition 4.2.8-1(b). 
40 

Thereafter, CO emission data from certified monitors 

may be provided in lieu of conducting emissions 

tests. 

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

submitted to the Illinois EPA in accordance with the 

Condition 5.1. 

ii. In addition to other information required in a test 

report, test reports shall include detailed information 

on the operating conditions of an affected unit during 

testing, including: 

A. Fuel consumption, by type (in million scf); 

B. Firing rate (mmBtu/hour) and other significant 

operating parameters of the affected unit; 

C. For the affected superheaters, results of the 

analyses of the fuel gas for heat content (Btu/scf) 

and ash, chlorine, fluorine and individual heavy 

metals (pound per million Btu); 

D. Opacity of the exhaust, 6-minute averages. 

4.2.8-1 Emissions Monitoring Requirements 

a. Pursuant to 40 CFR 60.48b, for the affected superheaters, the 

Permittee shall install, calibrate, operate and maintain a 

continuous emission monitoring system (CEMS) for measuring the 

NOx emissions from the superheaters. 

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. 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. Pursuant to 40 CFR 60.48b, for the affected auxiliary 

boiler, after the initial startup of the gasification 

block, the Permittee shall also install, calibrate, 

operate and maintain a CEMS for measuring the NOx

emissions from the boiler as provided above. 
41 

iii. The 1-hour average NOx emission rates measured by each 

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), except as 

allowed under 60.48b(b)(2). 

iv. These CEMS shall also be used to determine compliance 

with the NOx limits in Condition 4.2.6. 

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

CEMS for measuring CO emissions from the affected superheaters 

and 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 these units. 

ii. These CEMS shall be used to determine compliance with the 

CO limitations in Conditions in 4.2.2, 4.2.3-2 and 4.2.6. 

4.2.8-2 Opacity Observations 

The Permittee shall perform opacity observations for the affected 

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

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

4.2.9 Recordkeeping Requirements 

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

information: 

i. The rated heat input capacity of each affected unit, with 

supporting documentation. 

ii. The Permittee’s established operating and maintenance 

procedures for the affected units. 

b. The Permittee shall maintain records of the following 

information for NOx emissions from the affected superheaters 

and the affected boiler for each operating day, pursuant to 40 

CFR 60.49b(g) if monitoring is being conducted for NOx

emissions, unless alternative recordkeeping requirements are 

approved for affected unit(s) in conjunction with USEPA 

approval of alternative monitoring procedures under the NSPS: 

i. Calendar date; 

ii. The average hourly emission rates (expressed in 

lbs/million Btu heat input) measured or predicted; 
42 

iii. The 30-day average emission rate (lbs/million Btu 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 full span of the continuous 

monitoring system; 

ix. Description of any modifications to the continuous 

monitoring system that could affect the ability of the 

continuous monitoring system to comply with Performance 

Specification 2 or 3; and 

x. Results of daily CEMS drift tests and quarterly accuracy 

assessments as required under Appendix F, Procedure 1 of 

40 CFR 60. 

c. The Permittee shall keep the following records for the CO CEMS 

required by Condition 4.2.8(b) for the affected superheaters 

and the affected boiler: 

i. All measurements needed to demonstrate compliance with 

the applicable standards and limitations 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 period of 

startup, shutdown, or malfunction. 

iii. Each period during which a CEMS is malfunctioning or 

inoperative. 
43 

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. 

d. The Permittee shall maintain the following operating records 

for the affected superheaters and 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); 

iii. For the affected superheaters, pursuant to 40 CFR 

60.49b(r)(2), analysis reports for the sulfur content of 

fuel combusted in these units that shall contain, at a 

minimum, the following information. A site-specific fuel 

analysis plan shall be submitted to the Illinois EPA for 

review and approval no later than 60 days before the date 

of the Permittee’s intended initial compliance 

determination. Such plan shall include a minimum initial 

requirement of weekly testing. Monthly or quarterly 

sampling may be approved in place of weekly sampling. 

A. The potential sulfur emissions rate of the 

representative fuel mixture in ng/J heat input; and 

B. The method used to determine the potential sulfur 

emissions rate. 

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

records for the affected units that include the information 

specified in Condition 5.2(a) and the following information: 

i. For each startup of an affected unit, the information 

specified by 40 CFR 60.7(b) and identification of any 

deviations from normal startup procedures, as set forth 

in the Permittee’s written operating procedures, with 

explanation. 

ii. For each shutdown of an affected unit, 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. 
44 

iii. For malfunctions or breakdowns, the information required 

by 40 CFR 60.7(b) and, if excess emissions occurred: 

A. An explanation why continued operation of the 

affected unit was necessary. 

B. The rates or magnitude of excess emissions during 

the event. 

f. The Permittee shall keep inspection, maintenance and repair 

logs or other similar records for the affected units that 

contain the information specified in Condition 5.2(b). 

g. The Permittee shall keep records for any deviations from 

applicable requirements involving the affected acid plants, 

which records shall include the information specified by 

Condition 5.3. These records may be combined with other 

records required by this section of this permit. 

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

emissions of NOx, CO, VOM, SO2, PM of the affected superheaters 

and the affected boiler: 

i. If continuous monitoring is performed for a pollutant, 

the emissions of the pollutant from the affected unit(s) 

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 unit(s) based on 

operating data and applicable emission factors, in 

tons/month and tons/year, with supporting 

calculations. 

4.2.10 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 units by sending required notifications and 

reports to the Illinois EPA, including the following reports: 

i. Notification of the date of initial startup of each unit, 

as provided by 40 CFR 60.7. This notification shall 

include: (1) the design heat input of the unit, and (2) 

the annual capacity factor at which the Permittee 

anticipates operating the unit. 
45 

ii. Reports containing the information recorded under 40 CFR 

60.49b(g) and (j). 

iii. Periodic reports for excess emissions, as further 

addressed by Condition 4.2.10(d). 

b. The Permittee shall promptly notify the Illinois EPA of any 

deviations from the requirements of this permit for the 

affected units as follows. These notifications shall include 

the information specified by Condition 5.4. 

i. If there is an exceedance of a state emission or opacity 

standard other than during startup or shutdown, e.g., due 

to a malfunction or breakdown event, the Permittee shall 

immediately notify the Illinois EPA in accordance with 

Condition 4.2.10(c). 

ii. If there is a deviation from other applicable 

requirements for PM emissions or opacity that is not 

repaired or otherwise corrected within two hours (120 

minutes), the Permittee shall notify the Illinois EPA 

within 30 days. 

iii. The deviations addressed above and all other deviations 

shall be reported in the periodic compliance reports 

required by Condition 4.2.10(d). 

c. i. Pursuant to 35 IAC 201.263, the Permittee shall 

immediately report to the Illinois EPA, Regional Office, 

by telephone or fax upon continued operation of an 

affected unit during a malfunction or breakdown of the 

unit or associated control equipment when such continued 

operation would cause an exceedance or violation of the 

applicable state emission standard. 

ii. The Permittee shall submit a written follow-up report to 

the Illinois EPA within five business days providing a 

detailed explanation of the event and explanation why 

continued operation of the unit was necessary, the length 

of time during which operation continued under such 

conditions, the measures by the Permittee to minimize and 

correct deficiencies with chronology, and when the 

repairs were completed or the unit was taken out of 

service. 

d. The Permittee shall submit periodic compliance reports to the 

Illinois EPA for the affected units, which reports shall 

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: 
46 

A. As related to the NSPS standard for NOx emissions or 

the NOx limit in Condition 4.2.2, 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 continuous emissions monitoring system(s) 

have not been inoperative, repaired, or adjusted, 

such information shall be stated in the report. 

ii. A summary of operation and emissions of the affected 

superheaters and affected boiler during the reporting 

period, including the amounts of fuel used, total 

operating hours, number of startups by type, and average 

hourly emission rates for NOx, SO2 and CO. 

4.2.11 Additional Reporting for the Shakedown Period 

a. During the shakedown period for each affected unit, the 

Permittee shall promptly notify the Illinois EPA of any 

event(s) that disrupts the orderly shakedown of an affected 

unit. 

b. During the shakedown period for the affected units and a period 

that extends for one year (12 months) after the conclusion of 

the shakedown period, the Permittee shall submit the periodic 

compliance reports required by Condition 4.2.10(d) on a monthly 

basis, with reports submitted no later than 25 days after the 

end of each calendar month, beginning with the first month in 

which any fuel is fired in a unit. During the shakedown 

period, these reports shall also include the following 

information: 

i. Operating data for the unit, i.e., total operating hours 

and fuel usage and maximum heat input achieved during the 

reporting period); 

ii. Activities accomplished and significant events related to 

emissions of the unit; 

iii. Current schedule for emission testing; 

iv. A summary of any emission measurements conducted; and 

v. When applicable, notice that all emission testing has 

been completed and shakedown of the unit is considered 

complete. 
47 

CONDITION 4.3: UNIT-SPECIFIC CONDITIONS FOR STARTUP BURNERS 

4.3.1 Description of Emission Unit 

The affected units for the purpose of these unit-specific conditions 

are the natural gas-fired burners used to pre-heat certain units in 

the gasification block. The gasifier burners are used to preheat 

the refractory of the gasifier vessels to operating temperature 

before the introduction of the startup feedstock. The startup 

burners for the CO shift and methanation units are used to heat the 

catalyst beds in these units to operating temperature prior to 

beginning operation of the units. 

4.3.2 Control Technology Determination 

a. The affected units shall be operated and maintained with the 

following features to control emissions: 

i. Use of natural gas

ii. Good combustion practices 

b. Affected units shall be designed and operated to comply with 

the following limits, which are in lbs/mmBtu: 

Pollutant Burners for 

Gasifiers 

Burners for CO Shift 

& Methanation Units 

Averaging 

Time 

NOx 0.2 0.08 24-Hour 

CO 0.1 0.04 3-Hour 

SO2 0.0013 0.0013 24-Hour 

PM 0.01 0.01 3-Hour 

4.3.3 Applicable Emission Standards 

Each affected unit is subject to 35 IAC 212.123, which provides that 

no person shall cause or allow the emissions of smoke or other 

particulate matter, with an opacity greater than 30 percent, into 

the atmosphere from any emission unit. 

4.3.4 Non-Applicability Provisions 

a. The affected units are not subject to the NSPS for Small 

Industrial-Commercial-Institutional Steam Generating Units, 40 

CFR 60 Subpart Dc because they are not steam generating units 

as defined by the NSPS. 

b. This permit is issued based on the affected units not being 

subject to 35 IAC 212.206, 212.207, or 214.162 because the 

affected units are not fuel combustion emission units as 

defined by 35 IAC 211.2470. 

4.3.5 Operational Production Limits and Work Practices 

a. Natural gas shall be the only fuel fired in the affected units. 
48 

4.3.6 Emission Limitations 

a. The total annual emissions of the affected units shall not 

exceed the following limitations, beginning effective one year 

after the shakedown of the gasification block is complete: 

Pollutant 

Limit 

(tons/year) 

SO2 0.10 

NOx 9.9 

CO 5.0 

VOM 1.0 

PM 0.5 

Individual HAP 0.1 

Total HAPs 0.1 

4.3.7 Recordkeeping Requirements 

a. The Permittee shall maintain a file containing information for 

the heat input capacity of each unit and design emission rates 

of each unit, with supporting documentation as provided by 

manufacturer of the burner; 

b. The Permittee shall maintain records of the total fuel usage or 

total unit operating hours of the two classes of units (i.e., 

gasifier burners and process unit burners); and 

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

records for the affected units that include the information 

specified in Condition 5.2(a). 

d. The Permittee shall keep inspection, maintenance and repair 

logs or other similar records for the affected units that 

contain the information specified in Condition 5.2(b). 

e. The Permittee shall keep records for any deviations from 

applicable requirements involving the affected units, which 

records shall include the information specified by Condition 

5.3. These records may be combined with other records required 

by this section of this permit. 

f. The Permittee shall maintain records of the SO2, NOx, CO, VOM 

and PM emissions from the units (tons/month and tons/years), 

with supporting calculations. 

4.3.8 Reporting Requirements 

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

the affected units with the permit requirements with the 

periodic compliance reports required by Condition 4.1.12(c). 

These notifications shall include the information specified in 

Condition 5.4. 
49 

CONDITION 4.4: UNIT-SPECIFIC CONDITIONS FOR THE SULFURIC ACID PLANTS 

4.4.1 Description of Emission Unit 

The affected units for these unit-specific conditions are the two 

sulfuric acid plants. These plants produce sulfuric acid from the 

sulfur-laden acid gas streams from the acid gas removal (AGR) units 

in the gasification block. In these plants, the recovered sulfur 

compounds are first combusted to SO2 and then this SO2 is converted 

into sulfuric acid (H2SO4) by a catalytic process. The NOx emissions 

from each sulfuric acid plant would be controlled by a Selective 

Catalytic Reduction (SCR) system. Emissions of SO2 and sulfuric acid 

mist would be controlled by hydrogen peroxide scrubbers with high 

efficiency mist eliminators. The two sulfuric acid plants would 

then exhaust through a common stack. 

During a malfunction or breakdown of an acid plant, the acid gas 

stream feeding the plant could be diverted to the acid gas flare in 

the gasification block, as addressed in Section 4.1 of this permit. 

4.4.2 Control Technology Determination for the Affected Acid Plants 

a. Each affected acid plant shall be operated and maintained with 

the following measures to control emissions: 

i. An SCR system. 

ii. A hydrogen peroxide scrubber with high efficiency mist 

eliminator. 

iii. Good air pollution control practices, including the 

measures specified in Condition 4.4.5. 

b. The emissions from the affected acid plants, in pounds per ton 

of 100 percent acid produced, shall not exceed the following 

limits: 

Pollutant Short Term Annual 

SO2 1.41 (30-Day)a 1.40b

CO 0.32 (30-Day)a 0.40b

NOx 0.16 (30-Day)a 0.16b

PM 0.01 (24-Hour) --- 

Sulfuric Acid Mist 0.06 (24-Hour) --- 

Notes: 

a. Excluding periods of startup, shutdown and malfunction. 

b. Including periods of startup, shutdown and malfunction. 

c. The sulfuric acid storage tanks associated with the affected 

acid plants shall be controlled by vent control and 

recirculation. 
50 

4.4.3-1 Applicable Federal Emission Standards 

a. The affected acid plants are subject to the federal NSPS for 

Sulfuric Acid Plants, 40 CFR 60, Subpart H, and related 

provisions in 40 CFR 60, Subpart A, General Provisions. 

b. Pursuant to the NSPS, the emissions of the affected acid plants 

shall comply with the following standards except during 

startup, shutdown and malfunction, as provided by 40 CFR 

60.8(c): 

i. Emissions of SO2 shall not exceed 4.0 lbs/ton of sulfuric 

acid produced (expressed as 100 percent H2SO4). [40 CFR 

60.81(a)] 

ii. Emissions of sulfur acid mist shall not exceed 0.15 

lb/ton of sulfuric acid produced (expressed as 100 

percent H2SO4). [40CFR 60.83 (a)] 

iii. Opacity shall not be 10 percent or greater. [40 CFR 

60.83(b)] 

c. At all times, the Permittee shall operate and maintain the 

affected acid plants, including the associated control system, 

in a manner consistent with good air control practice, as 

required by the NSPS, 40 CFR 60.11(d). 

4.4.3-2 Applicable State Emission Standards 

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

affected acid plants shall not have opacity greater than 30 

percent, pursuant to 35 IAC 212.123(a). 

b. The emissions of SO2 and sulfuric acid mist from the affected 

acid plants shall not exceed the following limits: 

i. Emissions of SO2 shall not exceed 4.0 lbs/ton of acid 

produced, pursuant to 35 IAC 214.381(a). 

ii. Emissions of sulfuric acid mist shall not exceed 0.15 

lbs/ton of acid produced, pursuant to 35 IAC 214.381(b). 

c. The emissions of SO2 from the affected acid plants shall not 

exceed 2000 ppm, pursuant to 35 IAC 214.301. 

4.4.4 Non-Applicability Provisions 

None 

4.4.5 Operating Requirements 

a. The good air pollution control practices for the affected acid 

plants shall include operation and maintenance of the affected 
51 

plants in accordance with detailed written procedures, as it is 

safe to do so, which procedures shall: 

i. Fulfill relevant requirements of 40 CFR 63.6(e) for a 

Startup, Shutdown and Malfunction Plan. 

ii. With respect to startups, address readily foreseeable 

startup scenarios, including so called “hot startups” 

when the operation of an affected plant, is only 

temporarily interrupted. 

iii. A. With respect to malfunction, identify and address 

likely malfunction events with specific programs of 

corrective actions, and provide that upon occurrence 

of a malfunction that will result in emissions in 

excess of the applicable limits in Condition 4.4.2, 

4.4.3 or 4.4.6, the Permittee shall, as soon as 

practicable, repair equipment, reduce the operating 

rate of the affected plant or remove gasifiers from 

service so that excess emissions cease. 

B. Consistent with the above, if the Permittee has 

maintained and operated the gasification block and 

the affected acid plants so that malfunctions are 

infrequent, sudden, not caused by poor maintenance 

or careless operation, and in general are not 

reasonably preventable, the Permittee shall begin 

shutdown of gasifiers within 4 hours, unless the 

malfunction is expected to be repaired within 6 

hours. In such case, shutdown of gasifiers shall be 

undertaken when it is apparent that repair will not 

be accomplished within 6 hours or at a later time if 

shutdown will endanger the safety of plant personnel 

or cause severe damage to equipment. In no case 

shall shutdown of units be delayed solely for the 

economic benefit of the Permittee. 

4.4.6 Emission Limitations 

a. The total emissions from the affected acid plants, including 

emissions from the sulfuric acid storage tanks, shall not 

exceed the following limits. The hourly limits shall apply on 

a monthly average basis for pollutants in which continuous 

emissions monitoring is performed or otherwise on a 24-hour 

block average. 

Pollutant 

Short Term (Pounds/Hour) Annual 

Normal (Tons/Year) a Otherb

SO2 90.0 180.0 342.4 

NOx 11.0 22.0 38.6 

CO 20.0 40.0 75.7 

VOM 0.7 1.5 2.4 

PM 0.06 0.1 0.33 

Sulfuric Acid Mist 3.3 8.0 14.4 
52 

Pollutant 

Short Term (Pounds/Hour) Annual 

Normal (Tons/Year) a Otherb

Total Reduced Sulfur 0.55 0.55 2.4 

Individual HAP 0.01 0.01 0.044 

Total HAPs 0.10 0.10 0.44 

Notes

a. Applicable during periods other than startup, shutdown 

and malfunction. 

b. Applicable during periods of startup, shutdown and 

malfunction. 

4.4.7 Emission Testing Requirements 

a. The Permittee shall have emission tests conducted for the 

affected acid plants as follows at its expense by an approved 

testing service while the plants and the gasification block are 

operating at maximum operating load and other representative 

operating conditions. 

i. Initial performance testing for emissions of SO2 and 

sulfuric acid mist and opacity required under the NSPS 

shall be conducted in accordance with 40 CFR 60.8 and 

60.85. 

ii. A. Within 90 days after achieving the maximum 

production rate at which the acid plants will be 

operated but not later than 365 days after initial 

startup of the first acid plant, the Permittee shall 

have tests conducted for emissions of PM (filterable 

and condensable), CO, total reduced sulfur and 

sulfuric acid mist and, if the NOx CEMS has not yet 

been certified, NOx. 

B. This period of time may be extended by the Illinois 

EPA for up to an additional 365 days upon written 

request by the Permittee as needed to reasonably 

accommodate unforeseen difficulties in the startup 

and emission testing of the gasification block or 

enable testing to be conducted while both acid 

plants are operating, provided that preliminary 

emissions measurements are conducted and reported to 

the Illinois EPA. 

iii. In addition to the emission testing required above, the 

Permittee shall perform emission tests as requested by 

the Illinois EPA within 45 days of a written request by 

the Illinois EPA or such later date agreed to by the 

Illinois EPA. 
53 

Note: Specific requirements for periodic emission 

testing may be established in the CAAPP Permit for the 

plant. 

b. i. The methods and procedures for testing emissions of SO2

and sulfuric acid mist and opacity shall be in accordance 

with 40 CFR 60.85. 

ii. The following methods and procedures shall be used for 

testing of emissions of other pollutants, unless other 

methods adopted by or being developed by USEPA are 

approved by the Illinois EPA. 

Location of Sample Points Method 1 

Gas Flow and Velocity Method 2 

Flue Gas Weight Method 3 or 3A 

Moisture Method 4 

NOx Method 19 

CO Method 10 

PM Method 5 

PM (condensable) Method 202 

Total Reduced Sulfur Compounds Method 15A 

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

submitted to the Illinois EPA in accordance with the 

Condition 5.1. 

ii. In addition to other information required to be included 

in a test report, test reports shall include detailed 

information on the operating conditions of the 

gasification block during testing, including: 

A. Feedstock consumption (tons/day) and sulfur content 

of the feedstock (Refer to Condition 4.1.9); 

B. Amount of syngas processed by each AGR unit; 

C. Opacity of the exhaust, 6-minute averages, as 

determined by USEPA Method 9, if opacity is not 

otherwise tested. 

4.4.8 Emissions Monitoring 

a. The Permittee shall monitor SO2 emissions from the affected 

acid plants, as required by the NSPS, 40 CFR 60.84. 

b. The Permittee shall install, operate and maintain continuous 

emission monitoring systems (CEMS) for measuring emissions of 

NOx from the affected acid plants. 

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

the installation, evaluation, operation and maintenance 

of these CEMS. 
54 

ii. These CEMS shall be used to determine compliance with the 

NOx limitations in Conditions in 4.4.2 and 4.4.6. 

4.4.9 Operational Monitoring 

The Permittee shall install, maintain, and operate instrumentation 

for the following operating parameters for each affected acid plant: 

a. Reagent injection rate of the SCR system. 

b. Pressure drop across the scrubber. 

4.4.10 Recordkeeping Requirements 

a. The Permittee shall maintain the following records for the 

required emissions monitoring systems to verify compliance with 

applicable standards and limitations: 

i. Records of SO2 and NOx emissions from the affected acid 

plants, in pounds per hour, as derived from the data 

obtained by the monitors. 

ii. Records of SO2 and NOx emissions from the affected acid 

plants in the terms and averaging periods of the 

applicable standards and limitations, as derived from the 

data obtained by the monitors. 

iii. Records of any period when the SO2 or NOx emission rate 

exceeded an applicable standard or limitation, including 

whether the exceedance occurred during a startup, 

shutdown or malfunction event, with explanation. 

A. For the purposes of the NSPS, periods of excess SO2

emissions shall be all three-hour periods (or the 

arithmetic average of three consecutive one-hour 

periods) during which the integrated average SO2

emissions exceed the applicable standard under 40 

CFR 60.82. [40 CFR 60.84(e)] 

iv. Records of the conversion factors and values needed to 

convert or express monitored emission data in terms of 

pounds per ton of 100 percent acid. (For the NSPS 

standard for SO2, refer to 40 CFR 60.84(b) and (c).) 

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

acid produced by the affected acid plants (100 percent basis) 

on a daily, monthly and annual basis. 

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

records for the affected acid plants that include the 

information specified in Condition 5.2(a) and the following 

information: 
55 

i. For each startup of an acid plant, the information 

specified by 40 CFR 60.7(b) and identification of any 

deviations from normal startup procedures, as set forth 

in the Permittee’s written operating procedures, with 

explanation. 

ii. For each shutdown of an acid plant, 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. 

iii. For malfunctions or breakdowns, the information required 

by 40 CFR 60.7(b) and, if excess emissions occurred: 

A. An explanation why continued operation of the 

affected plant was necessary. 

B. The rates or magnitude of excess emissions during 

the event. 

d. The Permittee shall keep inspection, maintenance and repair 

logs or other similar records for the affected acid plants that 

contain the information specified in Condition 5.2(b). 

e. The Permittee shall keep records for any deviations from 

applicable requirements involving the affected acid plants, 

which records shall include the information specified by 

Condition 5.3. These records may be combined with other 

records required by this section of this permit. 

f. The Permittee shall maintain the following records related to 

the emissions of SO2, NOx, CO, VOM, PM, total reduced sulfur and 

sulfuric acid mist from the affected acid plants: 

i. For SO2 and NOx, the emissions of each pollutant 

(tons/month and tons/year), based on monitored data. 

ii. For pollutants for which continuous emissions monitoring 

is not performed: 

A. A file containing the emission factors that the 

Permittee uses to calculate emissions of the 

pollutant, with supporting documentation. 

B. The emissions of each pollutant based on operating 

data and applicable emission factors, in tons/month 

and tons/year, with supporting calculations. 

4.4.11 Reporting Requirements 

a. The Permittee shall fulfill applicable notification and 

reporting requirements of the NSPS, 40 CFR 60.7, for the 
56 

affected units by sending required notifications and reports to 

the Illinois EPA, including the following reports: 

i. Notification of the date of initial startup of each 

plant. [40 CFR 60.7(a)(3)] 

ii. Periodic reports for excess emissions. [40 CFR 60.7(c)] 

b. The Permittee shall promptly notify the Illinois EPA of 

deviations of the affected acid plants with permit requirements 

as follows. Reports shall include the information specified by 

Condition 5.4: 

i. Failure of the SCR system or scrubber on an acid plant, 

e.g., loss of reagent or scrubbant flow, when operation 

of the acid plant continues for more than 3 hours (180 

minutes) shall be 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, for 

each incident. 

ii. The deviations addressed above and all other deviations 

shall be reported in the periodic compliance reports 

required by Condition 4.4.11(c). 

c. The Permittee shall submit periodic compliance reports for the 

affected acid plants, which include the following information. 

The reports shall be submitted no later than 30 days after the 

end of the calendar six month reporting period. 

i. Information related to excess emissions and deviations: 

A. As related to the NSPS standard for SO2 emissions or 

the SO2 limit in Condition 4.4.2, the information 

required for reporting of exceedances under 40 CFR 

60.7(c) or (d), including the magnitude of excess 

emissions, any conversion factor(s) used, and the 

date and time of commencement and completion of each 

time period of excess emissions and whether it 

occurred during startup, shutdown, or malfunction. 

B. Information for other deviations during the 

reporting period, if any. 

C. 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. 

ii. A summary of operation and emissions of the affected acid 

plants during the reporting period, including the total 

amount of acid produced (100 percent basis) and their 

average hourly emission rates for NOx and SO2. 
57 

CONDITION 4.5: UNIT-SPECIFIC CONDITIONS FOR THE COOLING TOWER 

4.5.1 Description of Emission Unit 

The affected unit for the purpose of these unit-specific conditions 

is a multi-cell cooling tower. The cooling tower will supply the 

cooling water needed by various operation at the plant. 

The cooling tower is a source of particulate emissions because of 

mineral material present in the water supply for the tower. This 

material is emitted to the atmosphere 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 exhausted from the tower. 

4.5.2 Control Technology Determination 

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 not more than 0.0005 percent of the 

circulating water flow. 

b. The PM emissions of the affected unit, as PM10, shall not exceed 

1.4 pounds per hour, as determined from relevant operating data 

for the cooling tower and the efficiency of the drift 

eliminators, using engineering calculations for the emissions 

of PM10 due to the drift from the unit. 

4.5.3 Applicable Emission Standards 

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

not have opacity greater than 30 percent. Compliance with this 

limit shall be determined by 6-minute averages of opacity 

measurements in accordance with USEPA Reference Method 9. [35 

IAC 212.109 and 212.123(a)] 

b. The affected unit 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. 

c. The emissions of PM from the affected unit shall comply with 

the applicable limit pursuant to 35 IAC 212.321. 

4.5.4 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. 
58 

4.5.5 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. 

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 a manner consistent with 

good air pollution control practices for minimizing emissions. 

d. The Permittee shall operate and maintain the affected unit in 

accordance with written procedures, which procedures shall be 

kept current. These procedures shall address the practices 

that will be followed as good air pollution control practices 

and the actions that will be followed to prevent a significant 

contribution to icing and fogging on offsite roadways. 

4.5.6 Emission Limitations 

The total annual emissions of PM10 from the affected unit shall not 

exceed 6.2 tons/year, as determined by appropriate emission factors 

and engineering calculations. 

4.5.7 Operational Measurements 

Within one year (365 days) after initial startup of the gasification 

block, the Permittee shall test the percent drift achieved by the 

drift eliminator in accordance with the Cooling Technology 

Institute’s Acceptance Test Code No. 140. This test shall be 

performed by a licensed performance testing service. 

4.5.8 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). 
59 

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. 

4.5.9 Records 

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 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 PM10

emissions 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 PM10 emissions from the unit 

(pounds/hour, 24-hour average), based on the maximum 

operating rate of the 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 unit (e.g., water 

flow to the unit) from which the amount of water circulated in 

the unit may be reasonably determined. 

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

records for the affected units in the gasification block that 

include the information specified in Condition 5.2(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 5.2(b). 

e. The Permittee shall maintain records for the PM10 emissions of 

the affected unit based on the above records, the measurements 

required by Condition 4.5.9(a), and appropriate USEPA emission 

estimation methodology and emission factors, with supporting 

calculation. 
60 

4.5.10 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 5.4. 

i. If the cooling tower is damaged so there is a deviation 

from an applicable requirements 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. 

ii. All other deviations shall be reported with the periodic 

compliance reports required by Condition 4.5.10(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 4.1.11(c). 
61 

CONDITION 4.6: ALCOHOL STORAGE TANKS 

4.6.1 Description 

The affected units for the purpose of these unit-specific conditions 

are the large storage tanks at the plant for: (1) Rectisol solvent, 

which is primarily methanol and is used for acid gas cleanup of the 

raw syngas; and (2) Alcohol, most likely ethanol, used as the 

startup feedstock for the gasifiers. These storage tanks are 

equipped with internal floating roof tanks to minimize loss of 

material by evaporation and emissions of VOM. 

4.6.2 Applicable Federal Emission Standards 

a. Each affected tank is subject to the NSPS for Storage Vessels, 

40 CFR 60 Subpart Kb, and associated General Provisions, 40 CFR 

60 Subpart A. Specifically, the Permittee shall operate and 

maintain each affected tank with a fixed roof in combination 

with an internal floating roof meeting the following 

specifications of 40 CFR 60.112b: 

i. The internal floating roof shall rest or float on the 

liquid surface (but not necessarily in complete contact 

with it) inside a storage vessel that has a fixed roof. 

The internal floating roof shall be floating on the 

liquid surface at all times, except during initial fill 

and during those intervals when the storage vessel is 

completely emptied or subsequently emptied and refilled. 

When the roof is resting on the leg supports, the process 

of filling, emptying, or refilling shall be continuous 

and shall be accomplished as rapidly as possible. 

ii. Each internal floating roof shall be equipped with one of 

the following closure devices between the wall of the 

storage vessel and the edge of the floating roof: 

A. A foam-or liquid-filled seal mounted in contact with 

the liquid (liquid-mounted seal). A liquid-mounted 

seal means a foam or liquid-filled seal mounted in 

contact with the liquid between the wall of the 

storage vessel and the floating roof continuously 

around the circumference of the tank. 

B. Two seals mounted one above the other so that each 

forms a continuous closure that completely covers 

the space between the wall of the storage vessel and 

the edge of the floating roof. The lower seal may 

be vapor-mounted, but both must be continuous. 

C. A mechanical shoe seal. A mechanical shoe seal is a 

metal sheet held vertically against the wall of the 

storage vessel by springs or weighted levers and is 

connected by braces to the floating roof. A 
62 

flexible coated fabric (envelope) spans the annular 

space between the metal sheet and the floating roof. 

iii. Each opening in a noncontact internal floating roof 

except for automatic bleeder vents (vacuum breaker vents) 

and the rim space vents is to provide a projection below 

the liquid surface. 

iv. Each opening in the internal floating roof except for leg 

sleeves, automatic bleeder vents, rim space vents, column 

wells, ladder wells, sample wells, and stub drains is to 

be equipped with a cover or lid which is to be maintained 

in a closed position at all times (i.e., no visible gap) 

except when the device is in actual use. The cover or 

lid shall be equipped with a gasket. Covers on each 

access hatch and automatic gauge float well shall be 

bolted except when they are in use. 

v. Automatic bleeder vents shall be equipped with a gasket 

and are to be closed at all times when the roof is 

floating except when the roof is being floated off or is 

being landed on the roof leg supports. 

vi. Rim space vents shall be equipped with a gasket and are to 

be set to open only when the internal floating roof is not 

floating or at the manufacturer’s recommended setting. 

vii. Each penetration of the internal floating roof for the 

purpose of sampling shall be a sample well. The sample 

well shall have a slit fabric cover that covers at least 

90 percent of the opening. 

viii. Each penetration of the internal floating roof that 

allows for passage of a column supporting the fixed roof 

shall have a flexible fabric sleeve seal or a gasketed 

sliding cover. 

ix. Each penetration of the internal floating roof that allows 

for passage of a ladder shall have a gasketed sliding cover. 

4.6.3 Applicable State Emission Standards 

None 

4.6.4 Non-Applicability Provisions 

a. This permit is issued based on the affected tanks not being 

subject to 35 IAC 215.121(b) and 215.122(b) because the vapor 

pressure of stored material is less than 2.5 psia at 70°F. 

b. The affected tanks are not subject to the requirements of 35 

IAC 215.123(b) because they are subject to the NSPS, 40 CFR 60 

Subpart Kb. 
63 

4.6.5 Operating Limitations 

a. The affected tanks shall not store VOL with a maximum true 

vapor pressure of 2.5 psia or greater. 

b. The VOL throughput of the affected tanks (other than the 

Rectisol tank) shall not exceed 1,505,000 gallons/year, total. 

4.6.6 Emission Limitations 

The emissions of VOM and HAPs from the affected tanks shall not 

exceed 1.3 and 0.79 tons/year, total, respectively, as determined 

using the methodology in USEPA’s Compilation of Air Pollutant 

Emissions Factors, AP-42, the latest version of the TANKS program, 

or other methodology published by USEPA. 

4.6.7 Inspection Requirements 

a. For each affected tank, after installing the permanently 

affixed roof and internal floating roof (required to meet the 

NSPS), the Permittee shall visually inspect the internal 

floating roof, the primary seal, and the secondary seal (if one 

is in service), prior to filling the storage vessel with VOL. 

If there are holes, tears, or other openings in the primary 

seal, the secondary seal, or the seal fabric or defects in the 

internal floating roof, or both, the Permittee shall repair the 

items before filling the tank. [40 CFR 60.113b(a)] 

b. For tanks equipped with a liquid-mounted or mechanical shoe 

primary seal the Permittee shall, visually inspect the internal 

floating roof and the primary seal or the secondary seal (if 

one is in service) through manholes and roof hatches on the 

fixed roof at least once every 12 months after initial fill. 

If the internal floating roof is not resting on the surface of 

the VOL inside the tank, or there is liquid accumulated on the 

roof, or the seal is detached, or there are holes or tears in 

the seal fabric, the Permittee shall repair the items or empty 

and remove the tank from service within 45 days. If a failure 

that is detected during this inspection cannot be repaired 

within 45 days and if the tank cannot be emptied within 45 

days, a 30-day extension may be requested from the Illinois EPA 

in the required inspection report. Such a request for an 

extension must document that alternate storage capacity is 

unavailable and specify a schedule of actions the Permittee 

will take that will assure that the control equipment will be 

repaired or the vessel will be emptied as soon as possible. 

c. For tanks equipped with a double-seal system as specified in 

Condition 4.6.2(a)(ii)(B), the Permittee shall: 

i. Visually inspect the tank as specified in Condition 

4.6.7(d) at least every 5 years; or 
64 

ii. Visually inspect the tank as specified in Condition 

4.6.7(b). 

d. The Permittee shall visually inspect the internal floating 

roof, the primary seal, the secondary seal (if one is in 

service), gaskets, slotted membranes and sleeve seals (if any) 

each time the storage vessel is emptied and degassed. If the 

internal floating roof has defects, the primary seal has holes, 

tears, or other openings in the seal or the seal fabric, or the 

secondary seal has holes, tears, or other openings in the seal 

or the seal fabric, or the gaskets no longer close off the 

liquid surfaces from the atmosphere, or the slotted membrane 

has more than 10 percent open area, the Permittee shall repair 

the items as necessary so that none of the conditions specified 

in this paragraph exist before refilling the tank with VOL. In 

no event shall inspections conducted in accordance with this 

provision occur at intervals greater than 10 years in the case 

of tanks conducting the annual visual inspection as specified 

in Conditions 4.6.7(b) and (c)(ii) and at intervals no greater 

than 5 years in the case of tanks specified in Condition 

4.6.7(c)(i). 

4.6.8 Recordkeeping Requirements 

a. The Permittee shall maintain readily accessible records of the 

dimensions of each affected tank and an analysis of the 

capacity of the tank. These records shall be kept for the life 

of the tank. [40 CFR 60.116b(b) and 35 IAC 215.129(f)] 

b. i. The Permittee shall keep records of the VOL stored in 

each affected tank, the period of storage, and the 

maximum true vapor pressure of the VOL during the 

respective storage period based on the actual monthly 

storage temperature. [40 CFR 60.116b(c) and (e)] 

ii. The Permittee shall keep records of throughput 

(gallons/month and gallons/year) and physical properties 

(vapor pressure and molecular weight) of the VOL as 

stored in each affected tank. 

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

records for each affected tank that include the information 

specified in Condition 5.2(a) and the following information: 

i. A record of the date when a floating roof in the tank is 

set on its legs or other support devices and the date 

when the roof was refloated, with information indicating 

whether the process of refloating was continuous. 

f. The Permittee shall keep inspection, maintenance and repair 

logs or other similar records for each affected tank that 

contain the information specified in Condition 5.2(b) and the 

following information required by 40 CFR 60.115b(a)(2) 
65 

i. A record of each inspection performed as required by 

Condition 4.6.7, which shall contain the date the tank 

was inspected and the observed condition of each 

component of the control equipment (seals, internal 

floating roof, and fittings). 

e. The Permittee shall maintain records of VOM emissions from the 

affected tanks, tons/month and tons/year, with supporting 

calculations. 

4.6.9 Reporting Requirements 

a. The Permittee shall fulfill applicable notification and 

reporting requirements of the NSPS, 40 CFR 60.7 and 60.105b, 

for the affected tanks, including: 

i. Notifying the Illinois EPA in writing at least 30 days 

prior to the filling or refilling of each tank for which 

an inspection is required by the NSPS to afford the 

Illinois EPA the opportunity to have an observer present. 

If the inspection required by the NSPS is not planned and 

the Permittee could not have known about the inspection 

30 days in advance or refilling the tank, the Permittee 

shall notify the Illinois EPA at least 7 days prior to 

the refilling of the storage vessel. Notification shall 

be made by telephone immediately followed by written 

documentation demonstrating why the inspection was 

unplanned. Alternatively, this notification including 

the written documentation may be made in writing and sent 

by express mail so that it is received by the Illinois 

EPA at least 7 days prior to the refilling. [40 CFR 

60.113b(a)(5)] 

ii. Providing the following reports for inspection of the 

control equipment (internal floating roof) on each 

affected tank: 

A. Furnish the Illinois EPA with a report that 

describes the control equipment and certifies that 

the control equipment meets the specifications of 

the NSPS. [40 CFR 60.115b(a)(1)] 

B. If any of the conditions described in Condition 

4.6.7(b) are detected during a required annual 

visual inspection, a report shall be furnished to 

the Illinois EPA within 30 days of the inspection. 

Each report shall identify the storage vessel, the 

nature of the defects, and the date the storage 

vessel was emptied or the nature of and date the 

repair was made. [40 CFR 60.115b(a)(3)] 

C. After each inspection required by Condition 4.6.7(c) 

that finds holes or tears in the seal, or defects in 

the internal floating roof, or other control 
66 

equipment defects listed in Condition 4.6.7(c)(ii), 

a report shall be furnished to the Illinois EPA 

within 30 days of the inspection. The report shall 

identify the storage tank and the reason it did not 

meet the specifications of Condition 4.6.5(a) or 

4.6.7(c) and list each repair made. [40 CFR 

60.115b(a)(4)] 

b. The Permittee shall notify the Illinois EPA of deviations of an 

affected tank with the permit requirements. These reports 

shall include the information specified by Condition 5.4 and be 

submitted with the periodic reports required by Condition 

4.1.11(c), unless otherwise provided by Condition 4.6.9(b)(ii). 
67 

CONDITION 4.7: UNIT-SPECIFIC CONDITIONS FOR FEEDSTOCK AND BULK MATERIAL 

HANDLING AND STORAGE

4.7.1 Description of Emission Units 

The affected units for the purpose of these unit-specific conditions 

are equipment and facilities handling coal, slag and other bulk 

materials that are involved with the operation of the gasification 

block and that have the potential for particulate matter (PM) 

emissions. Affected units include receiving, transfer, and storage, 

as relevant for the various materials. 

Emissions of PM from affected units are controlled by appropriate 

measures given the nature of the material. In particular, units 

handling dry materials must be enclosed and aspirated to control 

equipment if it is practical to do so. 

4.7.2 Control Technology Determination 

a. PM emissions from an affected unit handling a wet material 

shall be controlled by the following measures. For this 

purpose, wet material is a material that has sufficient 

moisture during normal operation to minimize the potential for 

direct emissions. 

i. Maintaining the material with adequate moisture to 

prevent visible emissions directly from such unit during 

the handling, storage or load out of the material. 

ii. Collection of spilled material that could become airborne 

if it dried or were subject to vehicle traffic as part of 

the Program for Control of Fugitive Dust as required by 

Condition 4.8.5. 

b. PM emissions from an affected unit handling a dry material, 

other than a storage pile for dry material and handling 

operations associated with the pile, shall be controlled by: 

i. Enclosure of the unit so as to prevent visible fugitive 

emissions, as defined by 40 CFR 60.675, from the affected 

unit. 

ii. Aspiration to a control device designed to emit no more 

than 0.001 grains/dry standard cubic foot (gr/dscf), 

which device shall be operated in accordance with good 

air pollution control practice to minimize emissions. 

For this purpose, the control device shall be a baghouse 

or other filtration type device unless the Permittee 

demonstrates and the Illinois EPA concurs that another 

type of control device is preferable due to 

considerations of operational safety. 
68 

4.7.3-1 Applicable Federal Emission Standards 

a. Affected units engaged in handling and processing coal shall 

comply with applicable requirements of the NSPS for coal 

Preparation Plants, 40 CFR 60, Subpart Y, and related 

provisions of 40 CFR 60, Subpart A. 

b. Pursuant to the NSPS, the opacity of the exhaust from coal 

processing and conveying equipment, coal storage systems (other 

than open storage piles), and coal loading systems shall not 

exceed 20 percent. [40 CFR 60.254(b)] 

c. At all times, the Permittee shall maintain and operate affected 

units that are subject to NSPS, including associated air 

pollution control equipment, in a manner consistent with good 

air pollution control practices for minimizing emissions, 

pursuant to 40 CFR 60.11(d). 

4.7.3-2 Applicable State Emission Standards 

a. The emission of smoke or other PM from affected units shall not 

have an opacity greater than 30 percent, except as allowed by 

35 IAC 212.124. Compliance with this limit shall be determined 

by 6-minute averages of opacity measurements in accordance with 

USEPA Reference Method 9. [35 IAC 212.109 and 212.123(a)] 

b. With respect to emissions of fugitive PM, 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. 

c. The emissions of PM from affected units other than units 

excluded by 35 IAC 212.323 (refer to Condition 4.7.4(b)) 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 and allows a minimum emission rate of 0.55 

lb/hour for any individual unit. 

4.7.4 Non-Applicability Provisions 

a. This permit is issued based on the affected units not being 

subject to 40 CFR 60, Subpart OOO, as materials handled by 

affected units are nonmetallic minerals as defined by 40 CFR 

60.671. 

b. This permit is issued based on the coal handling operations not 

being subject to 35 IAC 212.321 pursuant to 35 IAC 212.323, 

which provides that 35 IAC 212.321 shall not apply to emission 

units, which, because of the disperse nature of such emission 

units, such rules cannot reasonably be applied. 
69 

4.7.5 Operating Requirements 

a. Coal and other bulk materials that have the potential for PM 

emissions shall be stored in silos, bins, and buildings, 

without storage of such materials in outdoor piles except on a 

temporary basis during breakdown or other disruption in the 

capabilities of the enclosed storage facilities. 

b. The Permittee shall implement and maintain control measures for 

the affected units that minimize visible emissions of PM and 

provide assurance of compliance with the applicable limits and 

standards in Conditions 4.7.2, 4.7.3-1 and 4.7.3-2. 

c. The affected units, including associated control equipment 

shall be operated and maintained in accordance with good air 

pollution control practice to minimize emissions. 

4.7.6 Emission Limitations 

Emissions of PM and PM10 from the affected units shall not exceed 

14.3 and 14.3 tons/year, total, respectively. Compliance with this 

limit shall be determined from the amount of material handled and 

other operating information for affected units, and appropriate 

emission factors. 

4.7.7-1 Initial Performance Observations 

a. Within 60 days after achieving the maximum production rate at 

which each affected unit subject to NSPS will be operated, but 

not later than 180 days after initial startup of each such 

unit, the Permittee shall have opacity observations conducted 

at its expense as follows below by an approved testing service 

under unit operating conditions that are representative of 

maximum emissions. 

b. The following USEPA methods and procedures shall be used for PM 

and opacity measurements as specified in 40 CFR 60.257: 

PM - Method 5, with the sampling time and sample volume for 

each run to be at least 60 minutes and 30 dscf and sampling to 

begin no less than 30 minutes after startup and to terminate 

before shutdown begins. 

Opacity - Method 9, with measurements performed by a certified 

observer. 

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

submitted to the Illinois EPA in accordance with Condition 5.1. 

4.7.7-2 Periodic Testing 

a. i. The Permittee shall have the opacity of the emissions of 

the affected units during representative weather and 

operating conditions determined by a qualified observer 
70 

in accordance with USEPA Test Method 9, as further 

specified below. 

A. If emissions are normally visible from a unit when 

it is in operation, as determined by USEPA Reference 

Method 22, opacity testing shall be conducted at 

least annually. 

B. Upon written request by the Illinois EPA, such 

testing shall be conducted for specific affected 

units within 45 calendar days of the request or on 

the date agreed upon by the Illinois EPA, whichever 

is later. 

ii. The duration of opacity observations for each test shall 

be at least 30 minutes (five 6-minute averages) unless 

the average opacities for the first 12 minutes of 

observations (two six-minute averages) are both less than 

5.0 percent. 

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

7 days in advance of the date and time of these 

tests, in order to allow the Illinois EPA to witness 

testing. 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 testing. 

iv. The Permittee shall provide a copy of its observer’s 

readings to the Illinois EPA at the time of testing, if 

Illinois EPA personnel are present. 

v. The Permittee shall submit a written report for this 

testing within 30 days of the date of testing. This 

report shall include: 

A. Date and time of testing. 

B. Name and employer of qualified observer. 

C. Copy of current certification. 

D. Description of observation conditions, including 

recent weather. 

E. Description of the operating conditions of the 

affected processes. 

F. Raw data. 

G. Opacity determinations. 

H. Conclusions. 
71 

b. Unless otherwise specified for the affected units by a CAAPP 

permit issued to the source: 

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

EPA, the Permittee shall have the PM emissions at the 

stacks or vents of affected units, as specified in such 

request, measured during representative operating 

conditions, as set forth below. 

ii. A. Testing shall be conducted using appropriate USEPA 

Test Methods, including Method 5 or 17 for PM 

emissions. 

B. Compliance may be determined from the average of 

three valid test runs, subject to the restrictions 

and conditions contained in 35 IAC Part 283. 

iii. A. Test plans, test notifications, and test reports 

shall be submitted to the Illinois EPA in accordance 

with the Condition 5.1. 

B. In addition to other information required in a test 

report, test reports shall include a detailed 

description of the operating conditions of the 

affected process during testing, including operating 

rate (tons/hour) and the control measures being 

used, and representative opacity data (6-minute 

average) measured during testing. 

4.7.8 Operational Instrumentation 

The Permittee shall install, operate and maintain systems to measure 

the pressure drop across each baghouse used to control affected 

units, other than bin vent filters and other similar filtration 

devices. 

4.7.9 Inspections 

a. i. 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, for the specific purpose of verifying that 

the measures identified in the operating program and 

other measures required to control emissions from 

affected units are being properly implemented. 

ii. These inspections shall include observation for the 

presence of visible emissions, performed in accordance 

with USEPA Method 22, from buildings in which affected 

units are located and from units from which the Permittee 

has elected to demonstrate no visible emissions. 
72 

b. The Permittee shall perform detailed inspections of the dust 

collection equipment for affected 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 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 15 months. 

4.7.10 Recordkeeping 

a. For affected units that are subject to NSPS, the Permittee 

shall fulfill applicable recordkeeping requirements of the 

NSPS, 40 CFR 60.7. 

b. The Permittee shall maintain file(s), which shall be kept 

current, that contain: 

i. The maximum operating capacity of each affected unit or 

group of related units (tons/hour). 

ii. A. For the baghouses and other filter devices 

associated with affected units, design 

specifications for each device (type of unit, 

maximum design exhaust flow (acfm and scfm), filter 

area, type of filter cleaning, performance guarantee 

for particulate exhaust loading in gr/scf, etc.), 

the manufacturer’s recommended operating and 

maintenance procedures for the device, and design 

specification for the filter material in each device 

(type of material, surface treatment(s) applied to 

material, weight, performance guarantee, warranty 

provisions, etc.). 

B. For each baghouse, the normal range of pressure drop 

across the device and the minimum and maximum safe 

pressure drop for the device, with supporting 

documentation. 

iii. For affected units that are not controlled with baghouses 

or other filter-type devices, a detailed description of 

the work practices used to control emissions of PM 

pursuant to Condition 4.7.5(b). 

iv. The designated PM emission rate, in pounds/hour and 

tons/year, from affected units, either individually or 

grouped by related units, with supporting calculations 

and documentation, including detailed documentation for 

the level of emissions control achieved through the work 

practices that are used to control PM emissions. The sum 

of these emission rates shall not exceed the total limit 

in Condition 4.7.6. 

v. A demonstration that confirms that the above established 

control measures are sufficient to assure compliance with 
73 

the above emissions rates and, for units to which it 

applies, Condition 4.7.3-2(c), at the maximum process 

weight rate at which each affected unit can be operated 

(tons/hour), with supporting emission calculations and 

documentation for the emission factors and the efficiency 

of the control measures being relied upon by the 

Permittee. Except as addressed by Condition 

4.7.10(b)(ii) or testing of PM emissions from an affected 

unit is conducted in accordance with Condition 4.7.7-

2(b), this demonstration shall be developed using 

emission factors for uncontrolled PM emissions, 

efficiency of control measures, and controlled PM 

emissions published by USEPA. 

c. The Permittee shall keep records for the amount of bulk 

materials received by or loaded out from the plant by category 

or type of material (tons/month). 

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

records for the affected units that include the information 

specified in Condition 5.2(a) and the following information for 

each incident when any unit operated without the control 

measures required by Condition 4.7.2 or 4.7.5(b) or (c): 

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 

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. 
74 

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

any preventative measures taken. 

viii. An estimate of any additional emissions of PM (pounds) 

above the PM emissions associated with normal operation 

that resulted from the incident, if any, with supporting 

calculations. 

ix. A discussion whether any applicable emission standard, as 

listed in Condition 4.7.2, 4.7.3-1, or 4.7.3-2 or any 

applicable emission rate, as identified in the records 

pursuant to Condition 4.7.10(b), may have been violated 

during the incident, with an estimate of the amount of 

any excess PM emissions (lbs) and supporting explanation. 

e. The Permittee shall keep inspection, maintenance and repair 

logs or other similar records for the affected units and the 

control measures associated with the affected units, including 

buildings and enclosures, dust suppression systems and control 

devices that contain the information specified in Condition 

5.2(b) and the following information. 

i. The following information for the inspections required by 

Condition 4.7.9(a): 

A. Date and time the inspection was performed and 

name(s) of inspection personnel. 

B. The observed condition of the control measures for 

each affected unit, including the presence of any 

visible emissions. 

C. A description of any maintenance or repair 

associated with established control measures that 

are recommended as a result of the inspection and a 

review of outstanding recommendations for 

maintenance or repair from previous inspection(s), 

i.e., whether recommended action has been taken, is 

yet to be performed or no longer appears to be 

required. 

D. A summary of the observed implementation or status 

of actual control measures, as compared to the 

established control measures. 

ii. The following information for the inspections required by 

Condition 4.7.9(b): 

A. Date and time the inspection was performed and 

name(s) of inspection personnel. 

B. The observed condition of the dust collection 

equipment. 
75 

C. A summary of the maintenance and repair that is to 

be or was conducted on the equipment. 

D. A description of any maintenance or repair that is 

recommended as a result of the inspection and a 

review of outstanding recommendations for 

maintenance or repair from previous inspection(s), 

i.e., whether recommended action has been taken, is 

yet to be performed or no longer appears to be 

required. 

E. A summary of the observed condition of the equipment 

as related to its ability to reliably and 

effectively control emissions. 

f. The Permittee shall maintain the following records for the 

emissions of the affected units: 

i. A file containing the standard emission factors used by 

the Permittee to determine PM emissions from the units, 

with supporting documentation. 

ii. Records of PM emissions based on operating data for the 

unit(s) and appropriate emission factors, with supporting 

documentation and calculations. 

4.7.11 Reporting Requirements 

The Permittee shall promptly notify the Illinois EPA of deviations 

from permit requirements for the affected units. These 

notifications shall include the information specified by Condition 

5.4. 

a. The Permittee shall notify the Illinois EPA within 30 days of 

deviations that continue for more than 24 hours. For this 

purpose, time shall be measured from the start of a particular 

event. The absence of a deviation for a short period shall not 

be considered to end the event if the deviation resumes. In 

such circumstances, the event shall be considered to continue 

until corrective actions are taken so that the deviation ceases 

or the Permittee takes the affected unit out of service for 

repairs. 

b. The Permittee shall notify the Illinois EPA of the above 

deviations and other deviations with the periodic reports 

required by Condition 4.1.11(c). 

4.7.12 Operational Flexibility 

The Permittee is authorized, as follows, to construct and operate 

affected units that differ from those described in the application 

in certain respects without obtaining further approval by the 

Illinois EPA. This condition does not affect the Permittee’s 
76 

obligation to comply with all applicable requirements for affected 

units: 

a. This authorization only extends to changes that result from the 

detailed design of the project and any refinements to that 

design of the affected units that occur during construction and 

the initial operation of the gasification block. 

b. With respect to air quality impacts, these changes shall 

generally act to improve dispersion and reduce impacts, as 

emissions from individual units are lowered, units are moved 

apart or away from the fence line, stack heights are increased, 

and heights of nearby structures are reduced. 

c. The Permittee shall notify the Illinois EPA prior to proceeding 

with any changes. In this notification, the Permittee shall 

describe the proposed changes and explain why the proposed 

changes will act to reduce impacts, with detailed supporting 

documentation. 

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

promptly have air quality dispersion modeling performed to 

demonstrate that the overall effect of the changes is to reduce 

air quality impacts, so that impacts from affected units remain 

at or below those predicted by the air quality analysis 

accompanying the application. 
77 

CONDITION 4.8: UNIT-SPECIFIC CONDITIONS FOR ROADWAYS AND OTHER OPEN AREAS 

4.8.1 Description of Emission Units 

The affected units for the purpose of these unit-specific conditions 

are roadways, parking areas, and other open areas at the plant, 

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. 

4.8.2 Control Technology Determination 

a. The opacity of fugitive particulate matter emissions from 

affected units, except during periods of high wind speeds, 

shall not exceed 15 percent opacity. For this purpose, opacity 

and the presence of high wind speeds shall be determined in 

accordance with 35 IAC 212.109 and 35 IAC 212.314, 

respectively. 

b. i. Good air pollution control practices shall be implemented 

to minimize dust emissions from affected units. After 

construction activity is complete, these practices shall 

provide for pavement on all regularly traveled roads and 

treatment (sweeping) of roadways and areas that are 

routinely subject to vehicle traffic for very effective 

and effective control of dust, respectively (nominal 90 

percent control for paved roads and areas and 85 percent 

control for unpaved roads and areas). 

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

employee parking areas or are used on a daily basis by 

operating and maintenance personnel for the plant in the 

course of their typical duties shall be considered to be 

subject to regular travel and are required to be paved. 

Regularly traveled roads shall be considered to be 

subject to routine vehicle traffic except as they are 

currently inactive or as traffic has been temporarily 

blocked off. Other roads shall be considered to be 

routinely traveled if activities are occurring such that 

they are experiencing significant vehicle traffic. 

c. The handling of material collected from any affected unit 

associated with the plant by sweeping or vacuuming trucks shall 

be enclosed or shall utilize spraying, pelletizing, screw 

conveying or other equivalent methods to control PM emissions. 

4.8.3 Applicable State Emission Standards 

a. All affected units shall comply with 35 IAC 212.301, 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, 
78 

except when the wind speed is greater than 25 miles per hour, 

as provided by 35 IAC 212.314. 

4.8.4 Non-Applicability Provisions 

None 

4.8.5 Operational and Production Limits and Work Practices 

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 Conditions 4.8.2 and 4.8.3 to control emissions 

at each unit with the potential to generate significant 

quantities of such emissions, which program shall be kept 

current. 

i. The written operating program shall include: 

A. Maps or diagrams indicating the location of affected 

units with the potential to generate significant 

quantities of fugitive particulate matter, 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 12 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 plant shall be submitted within 

30 days of beginning actual construction of the 

plant. 

B. A program addressing affected units with the 

operation of the affected plant shall be submitted 

within 90 days of initial start up of the plant. 

C. Significant amendments to the program by the 

Permittee shall be submitted within 30 days of the 

date that the amendment is made. 
79 

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 matter 

emissions. 

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

least a weekly basis during construction of the plant and on a 

monthly basis thereafter with personnel not directly 

responsible for the day-to-day implementation of the fugitive 

dust control program, for the specific purpose of verifying 

that the measures identified in the operating program and other 

measures required to control emissions from affected units are 

being properly implemented. 

4.8.6 Emission Limitations 

Emissions of PM and PM10 from the affected units shall not exceed 2.0 

and 0.4 tons/year, total, respectively. Compliance with these 

limitations 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. 

4.8.7 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 

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. For performance 

observations, the Permittee shall submit test plans, test 

notifications and test reports, as specified by General 

Condition 5.1. 

i. Performance observations shall first be completed no 

later than 30 days after the date that construction of 

process units in the gasification block are completed, 

provided, however, that observation may be deferred as 

long as heavy construction equipment is on the site, 

preventing paving of roadways, in conjunction with the 

measurements of silt loading on the affected units 

required by Condition 4.8.8. 

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 
80 

material during cold weather, and changes in the 

operating program for affected units. 

b. 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. 

c. 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. 

4.8.8 Operational Measurements 

a. The Permittee shall conduct measurements of the silt loading on 

various affected roadway segments and parking areas 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. 

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

test reports for these measurements as specified by General 

Condition 5.1, 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. 
81 

d. The Permittee shall keep records for the measurements conducted 

for affected units pursuant to Condition 4.8.8, including 

records for the sampling and analysis activities and results. 

4.8.9 Recordkeeping Requirements 

a. The Permittee shall keep a file that contains: 

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

amount of activity associated with the affected units or 

the PM emissions from the affected units, with supporting 

documentation. 

ii. The designated PM emission rate, in tons/year, from each 

category of affected units (e.g., traffic associated with 

receiving of coal, with supporting calculations and 

documentation. The sum of these rates shall not exceed 

the annual limit on emissions in Condition 4.8.6. 

b. The Permittee shall maintain records documenting implementation 

of the operating program required by Condition 4.8.5, 

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 

measures were implemented due to particular activities, 

including description, date, a statement of explanation, 

and expected duration of such circumstances. 

c. The Permittee shall record any period during which an affected 

unit was not properly controlled as required by this permit, 

which records shall include at least the information specified 
82 

by Condition 5.3 and an estimate of the additional PM emissions 

that resulted, if any, with supporting calculations. 

d. The Permittee shall maintain records for the PM emissions of 

the affected units, based on operating data for the 

gasification block 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. 

4.8.10 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 4.1.11(c). These notifications 

shall include the information specified by Condition 5.4. 

b. The Permittee shall submit semi-annual reports to the Illinois 

EPA for affected units that include the following: the dates 

any necessary control measures were not implemented; a listing 

of those control measures; the reasons that the control 

measures were not implemented; and any corrective actions 

taken. This information includes, but is not limited to, those 

dates when controls were not implemented based on a belief that 

implementation of such control measures would have been 

unreasonable given prevailing weather conditions. This report 

shall be submitted to the Illinois EPA with the periodic 

compliance reports required by Condition 4.1.11(c). 
83 

CONDITION 4.9: LEAKING COMPONENTS 

4.9.1 Description 

The affected units for purpose of these unit-specific conditions are 

equipment components, such as pumps, valves, and flanges in the 

piping for organic liquids, such as the Rectisol solution used in 

the acid gas removal units or leaks from the CO2 compression 

equipment, which have the potential to emit VOM if they leak. These 

VOM emissions are minimized by a formal Leak Detection and Repair 

Program to identify such leaks and repair them. 

4.9.2 Non-Applicability Provisions 

a. The affected components are not subject to the NSPS for 

Equipment Leaks of VOC in the Synthetic Organic Chemicals 

Manufacturing Industry (SOCMI), 40 CFR 60, Subpart VVa, because 

the synthetic natural gas and sulfuric acid produced at this 

plant are not products covered by the SOCMI NSPS. 

b. The affected components are not subject to the requirements of 

35 IAC Part 215, Subpart Q, Leaks from Synthetic Organic 

Chemical and Polymer Manufacturing Equipment, pursuant to the 

applicability provisions at 35 IAC 215.420, because none of the 

chemicals produced at the plant are synthetic organic chemicals 

or polymers listed in 35 IAC Part 215, Appendix D. 

c. This permit does not address the applicability of 35 IAC 

215.142 to certain affected components because the vapor 

pressure of Rectisol solution and other volatile organic 

liquids (VOL) used at the plant be below 2.5 psia at 70 °F. 

4.9.3 Operating Requirements 

a. The Permittee shall implement a leak detection and repair 

program for affected components that are in VOC service, as 

defined by 40 CFR 60.481a, other than components in vacuum 

service, that is consistent with the inspection requirements 

set forth in 40 CFR 60.482-1a (Standards: General), 60.482-2a 

(Standards: Pumps in light liquid service), 60.482-3a 

(Standards: Compressors), 60.482-4a (Standards: Pressure 

relief devices in gas/vapor service), 60.482-5a (Standards: 

Sampling connection systems), 60.482-6a (Standards: Open-ended 

valves or lines), 60.482-7a (Standards: Valves in gas/vapor 

service and light liquid service)*, 60.482-8a (Standards: 

Pumps, valves and connectors in heavy liquid service, and 

pressure relief devices in light liquid or heavy liquid 

service), 60.482-9a (Standards: Delay of repair), 60.482-10a 

(Standards: Closed vent systems and control devices) and 

60.482-11a (Standards: Connectors in gas/vapor service and in 

light liquid service). 
84 

* The Permittee may elect to utilize the alternative 

standards of 40 CFR 60.483-1a through 60.483-2a, where 

applicable. 

b. For affected components, the Permittee shall repair any 

affected component from which a leak of volatile organic liquid 

(VOL) is detected or observed. The repair shall be completed 

as soon as practicable but no later than 21 days after the leak 

is found. If the leaking component cannot be repaired until 

the process unit is shut down, the leaking component must then 

be repaired before the unit is restarted. 

c. Leakless design pumps shall be the only pumps used in light 

liquid service. 

d. Closed loop sampling systems shall be the only sampling systems 

used. 

4.9.4 Emission Limitations 

Emissions of VOM and HAPs from the affected components shall not 

exceed 2.5 and 1.79 tons/year, total, respectively, as determined by 

use of appropriate USEPA methodology for estimating emissions from 

leaking components. 

4.9.5 Recordkeeping Requirements 

a. The Permittee shall maintain relevant records as specified in 

40 CFR 60.486a for the affected components that are in VOC 

service. 

b. The Permittee shall maintain a leaking component monitoring log 

or other similar records for the affected components that are 

in VOC service, that contain the following information. 

Notwithstanding other provisions of this permit, the Permittee 

need only retain these records for a minimum of two years from 

the date on which information was entered in the records. 

i. The name of the area and process equipment where the 

component is located; 

ii. The type of component (e.g., valve, pump seal); 

iii. The identification number of the component; 

iv. The date on which a leaking component is discovered; 

v. The date on which a leaking component is repaired; 

vi. The date and instrument reading of the recheck procedure 

after a leaking component is repaired; 

vii. A record of the calibration of the monitoring instrument; 
85 

viii. The identification number of leaking components which 

cannot be repaired until process unit shutdown; and 

ix. The total number of components inspected and the total 

number of components found leaking during that monitoring 

period. 

c. The Permittee shall maintain records on at least an annual 

basis of the VOM and HAP emissions of the affected components 

(tons/year), with supporting documentation and calculations. 

4.9.6 Reporting Requirements 

a. The Permittee shall submit relevant reports as specified in 40 

CFR 60.486a for the affected components that are in VOC service. 

b. The Permittee shall notify the Illinois EPA with the periodic 

reports required by Condition 4.1.11(c) of deviations from 

applicable requirements for affected components that are not 

addressed by the regular reporting required above. These 

notifications shall include the information specified by 

Condition 5.4. 
86 

SECTION 5: GENERAL PERMIT CONDITIONS

CONDITION 5.1: 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. 

* For a particular test, the Illinois EPA may at its 

discretion accept shorter advance notification provided 

that it does not interfere with the Illinois EPA’S 

ability to observe testing. 
87 

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 

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 pollutant emitted per 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. fuel, raw material 

analysis, sulfur content in material.) 

- Control equipment information, i.e., equipment condition 

and pressure drop, flow rates, and other 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 5.2: 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. 
88 

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. 

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 practices. 

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 5.3: 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 
89 

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 5.4: GENERAL REQUIREMENTS FOR REPORTING OF DEVIATIONS 

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

reports for deviations: 

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. i. For the purpose of determining whether a deviation must be 

reported prior to a periodic compliance report, a deviation 

shall be considered to continue even if operation an emission 

unit is interrupted if the deviation is still present when 

operation of the unit is resumed. 

ii. When this permit requires immediate notification, such 

notification shall be provided by telephone and followed by 

facsimile or e-mail transmittal of a narrative report. 

d. Upon issuance of a CAAPP permit for the plant, the provisions of the 

CAAPP permit with respect to reporting of deviations will supersede 

the requirements of this permit. 
1-1 

ATTACHMENTS

Attachment 1: Summary of the Permitted Emissions of the Plant (Tons per Y

Pollutant 

Gasification 

Block 

Steam Superheaters & 

Auxiliary 

Boiler 

Startup Burners 

Sulfuric 

Acid 

Plants 

Cooling 

Tower 

Storage 

Tanksc

Material Handling 

& 

Storage Roadways 

Leak

Normal Compo

a Otherb

SO2 96.6 73.1 3.8 0.1 342.4 --- --- --- --NOx 23.4 5.3 106.7 9.9 38.6 --- --- --- --- --CO 532.5 18.8 121.9 5.0 75.7 --- --- --- --- --VOM 8.01 1.20 15.4 1.0 2.4 --- 1.3 --- --- 2PM 3.8 0.52 31.4 0.5 0.33 6.2 --- 14.3 2.0 --Sulfuric Acid Mist 0.05 1.46 --- --- 14.4 --- --- --- --- -

Total Reduced Sulfur 0.43 1.90 --- --- 2.4 --- --- --- --- --

Fluorides 0.10 --- --- --- --- --- --- --- --- --Methanol 7.2 0.10 --- --- --- --- 0.79 --- --- 1.Other Indiv. HAPsd 1.14 0.06 4.4 0.1 0.44 --- --- --- --- --Total HAPs 8.34 0.16 4.4 0.1 0.44 --- 0.79 --- --- 1.

Notes: a. “Normal” addresses stack emissions of the Gasification Block, including both the AG

flares, during periods other than startup, shutdown and malfunction. 

b. “Other” addresses stack emissions during startup, shutdown and malfunction of the Gc. “Storage Tanks” addresses storage tanks for alcohol and for other organic materials 

fuel). 

d. “Other individual HAPs” addresses individual HAPs other than methanol. 
2-1 

ATTACHMENT 2: 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 Illinois 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, has 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. 
2-2 

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. 

July, 1985, Revised, May, 1999 

IL 532-0226