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(ii) Equipped with a barrier fluid system degassing reservoir that is 

routed to a process or fuel gas system or connected by a closed-vent 

system to a control device that complies with the requirements of 40 

C.F.R. §61.242-11; or 

(iii) Equipped with a system that purges the barrier fluid into a process 

stream with zero VHAP emissions to atmosphere. 

(c) The barrier fluid shall not be in VHAP service and, if the compressor is 

covered by standards under 40 C.F.R. Part 60, shall not be in VOC service. 

(d) The Permittee shall equip each barrier fluid system as described in 

40 C.F.R. § 61.242-3 (a)-(c) with a sensor that will detect failure ofthe seal 

system, barrier fluid system, or both. 

(e) The Permittee shall check each sensor as required in 40 C.F.R. § 61.242-

3(d) daily or shall equip the sensor with an audible alarm unless the 

compressor is located within the boundary of an unmanned plant site. 

(f) The Permittee shall determine, based on design considerations and 

operating experience, a criterion that indicates failure of the seal system, 

the barrier fluid system, or both. 

(g) If the sensor indicates failure of the seal system, the barrier fluid system, or 

both based on the criterion determined under paragraph (e)(2) of 40 C.F.R. 

§ 61.242-3, a leak is detected. 

(h) When a leak is detected, the Permittee shall repair it as soon as practicable, 

but not later than 15 calendar days after it is detected, except as provided in 

40 CF.R. § 61.242-10. 

(i) The Permittee shall make a first attempt at repair no later than 5 calendar 

days after each leak is detected. 

(j) A compressor is exempt from the requirements of 40 C.F.R. § 61.242-3(a) 

and (b) if it is equipped with a closed-vent system to capture and transport 

leakage from the compressor drive shaft back to a process or fuel gas 

system or to a control device that complies with the requirements of 

40 CF.R. § 61.242-11, except as provided in 40 C.F.R. § 61.242-3(i). 

(k) Any compressor that is designated, as described in 40 C.F.R. 

§ 61.246(e)(2), for no detectable emission as indicated by an instrument 

reading of less than 500 ppm above background is exempt from the 

requirements of 40 CF.R. § 61.242-3(a)-(h) if the compressor: 
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(i) Is demonstrated to be operating with no detectable emissions, as 

indicated by an instrument reading of less than 500 ppm above 

background, as measured by the method specified in 40 C.F.R. 

§ 61.245(c); and Is tested for compliance with 40 C.F.R. § 61.242-

3(i)(l) initially upon designation, annually, and at other times 

requested by the Administrator. 

4. Open-ended valves or lines: [40 C.F.R. § 61.242-6] 

(a) The Permittee shall equip each open-ended valve or line with a cap, blind 

flange, plug, or a second valve, except as provided in 40 C.F.R. § 61.242-

1(c). 

(b) The cap, blind flange, plug, or second valve shall seal the open end at all 

times except during operations requiring process fluid flow through the 

open-ended valve or line. 

(c) The Permittee shall operate each open-ended valve or line equipped with a 

second valve in a manner such that the valve on the process fluid end is 

closed before the second valve is closed. 

(d) When a double block and bleed system is being used, the bleed valve or 

line may remain open during operations that require venting the line 

between the block valves but shall comply with 40 CF.R. § 61.242-6(a) at 

all other times. 

(e) Open-ended valves or lines in an emergency shutdown system which are 

designed to open automatically in the event of a process upset are exempt 

from the requirements of 40 C.F.R. § 61.242-6(a), (b) and (c). 

(f) Open-ended valves or lines containing materials which would 

autocatalytically polymerize or would present an explosion, serious 

overpressure, or other safety hazard if capped or equipped with a double 

block and bleed system as specified in 40 CF.R. § 61.242-6(a) through (c) 

are exempt from the requirements of 40 CF.R. § 61.242-6(a) through (c). 

5. Valves: [40 C.F.R. §61.242-7] 

(a) The Permittee shall monitor each valve monthly to detect leaks by the 

method specified in 40 CF.R. § 61.245(b) and shall comply with 40 C.F.R. 

§ 61.242-7(b)-(e), except as provided in 40 C.F.R. § § 61.242-7(1), (g), and 

(h), 61.243-1 or 61.243-2, and 61.242-l(c). 

(b) If an instrument reading of 10,000 ppm or greater is measured, a leak is 

detected. 
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(c) The Permittee may monitor any valve for which a leak is not detected for 2 

successive months the first month of every quarter, beginning with the next 

quarter, until a leak is detected. 

(d) If a leak is detected, the Permittee shall monitor the valve monthly until a 

leak is not detected for 2 successive months. 

(e) When a leak is detected, the Permittee shall repair it as soon as practicable, 

but no later than 15 calendar days after the leak is detected, except as 

provided in 40 CF.R. § 61.242-10. 

(f) The Permittee shall make a first attempt at repair no later than five calendar 

days after each leak is detected. 

(g) First attempts at repair include, but are not limited to, the following best 

practices where practicable: 

(i) Tightening of bonnet bolts; 

(ii) Replacement of bonnet bolts; 

(iii) Tightening of packing gland nuts; and 

(iv) Injection of lubricant into lubricated packing. 

(h) Any valve that is designated, as described in 40 C.F.R. § 61.246(e)(2), for 

no detectable emissions, as indicated by an instrument reading of less than 

500 ppm above background, is exempt from the requirements of 40 C.F.R. 

§ 61.242-7(a)ifthe valve: 

(i) Has no external actuating mechanism in contact with the process 

fluid; 

(ii) Is operated with emissions less than 500 ppm above background, as 

measured by the method specified in 40 CF.R. § 61.245(c); and 

(iii) Is tested for compliance with 40 C.F.R. § 61.242-7(f)(2) initially 

upon designation, annually, and at other times requested by the 

Administrator. 

(i) Any valve that is designated, as described in 40 C.F.R. § 61.246(f)(1), as an 

unsafe-to-monitor valve is exempt from the requirements of 40 C.F.R. 

§ 61.242-7(a)if: 

VES017602 
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(i) The Permittee demonstrates that the valve is unsafe to monitor 

because monitoring personnel would be exposed to an immediate 

danger as a consequence of complying with 40 C.F.R. § 61.242-7(a); 

and 

(ii) The Permittee has a written plan that requires monitoring ofthe 

valve as frequent as practicable during safe-to-monitor times. 

(j) Any valve that is designated, as described in 40 C.F.R. § 61.246(f)(2), as a 

difficult-to-monitor valve is exempt from the requirements of paragraph (a) 

of40C.F.R. § 61.242-7 if: 

(i) The Permittee demonstrates that the valve cannot be monitored 

without elevating the monitoring personnel more than 2 meters 

above a support surface; 

(ii) The process unit within which the valve is located is an existing 

process unit; and 

(iii) The Permittee follows a written plan that requires monitoring of the 

valve at least once per calendar year. 

6. Alternative standards for valves in VHAP service - allowable percentage of 

valves leaking: [40 C.F.R. § 61.243-1] 

(a) The Permittee may elect to have all valves within a process unit comply 

with an allowable percentage of valves leaking of equal to or less than 2.0 

percent. 

(b) The following requirements shall be met if the Permittee decides to comply 

with an allowable percentage of valves leaking: 

(i) The Permittee must notify the Administrator that it has elected to 

have all valves within a process unit to comply with the allowable 

percentage of valves leaking before implementing this alternative 

standard, as specified in 40 C.F.R. § 61.247(d). 

(ii) The Permittee conducts a performance test as specified in 40 C.F.R. 

§ 61.243-l(c) initially upon designation, annually, and at other times 

requested by the Administrator. 

(iii) If a valve leak is detected, the Permittee shall repair it in accordance 

with 40 C.F.R. § 61.242-7(d) and (e). 

(c) The Permittee shall conduct performance tests in the following manner: 
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(i) The Permittee shall monitor all valves in VHAP service within the 

process unit within 1 week by the methods specified in 40 C.F.R. 

§ 61.245(b). 

(ii) If an instrument reading of 10,000 ppm or greater is measured, a leak 

is detected. 

(iii) The Permittee shall determine the leak percentage by dividing the 

number of valves in VHAP service for which leaks are detected by 

the number of valves in VHAP service within the process unit. 

(d) If the Permittee elects to have all valves comply with this alternative 

standard, no process unit shall have a leak percentage greater than 2.0 

percent. 

(e) If the Permittee decides no longer to comply with 40 C.F.R. § 61.243-1, the 

Permittee must notify the Administrator in writing that it will follow the 

work practice standard described in 40 C.F.R. § 61.242-7(a)-(e). 

7. Alternative standards for valves in VHAP service: [40 C.F.R. § 61.243-2] 

(a) The Permittee may elect for all valves within a process unit to comply with 

one of the alternative work practices specified in 40 C.F.R. § 61.243-

2(b)(2) and (3). 

(b) The Permittee must notify the Administrator before implementing one of 

the alternative work practices, as specified in 40 C.F.R. § 61.247(d). 

(c) The Permittee shall comply initially with the requirements for valves, as 

described in 40 C.F.R. § 61.242-7. 

(d) After two consecutive quarterly leak detection periods with the percentage 

of valves leaking equal to or less than 2.0, the Permittee may begin to skip 

one of the quarterly leak detection periods for the valves in VHAP service. 

(e) After five consecutive quarterly leak detection periods with the percentage 

of valves leaking equal to or less than 2.0, the Permittee may begin to skip 

three of the quarterly leak detection periods for the valves in VHAP 

service. 

(f) If the percentage of valves leaking is greater than 2.0, the Permittee shall 

comply with the requirements as described in 40 C.F.R. § 61.242-7, but 

may again elect to use 40 C.F.R. § 61.243-2. 
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(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)] 

1. The Permittee shall comply with the following test methods and procedures 

requirements of 40 C.F.R. § 61.245: 

(a) The Permittee shall monitor, as required in 40 C.F.R. §§ 61.242, 61.243, 

61.244, and 61.135, as follows: 

(i) The Permittee shall monitor as required by Method 21 of 40 C.F.R. 

Part 60, Appendix A. 

(ii) The detection instrument shall meet the performance criteria of 

Method 21. 

(iii) The instrument shall be calibrated before use on each day of its use 

by the procedures specified in Method 21. 

(iv) Calibration gases shall be: 

A. Zero air (less than 10 ppm of hydrocarbon in air); and 

B. A mixture of methane or n-hexane and air at a concentration of 

approximately, but less than, 10,000 ppm methane or n-hexane. 

(v) The instrument probe shall be traversed around all potential leak 

interfaces as close to the interface as possible, as described in 

Method 21 of 40 C.F.R. Part 60, Appendix A. 

(b) When equipment is tested for compliance with or monitored for no 

detectable emissions, the Permittee shall comply with the following 

requirements: 

(i) The Permittee shall test equipment as required by 40 C.F.R. 

§ 61.245(b)(1) through (4). 

(ii) The background level shall be determined, as set forth in Method 21 

of 40 C.F.R. Part 60, Appendix A. 

(iii) The instrument probe shall be traversed around all potential leak 

interfaces as close to the interface as possible as described in Method 

21 of 40 C.F.R. Part 60, Appendix A. 

(iv) The arithmetic difference between the maximum concentration 

indicated by the instrument and the background level is compared 

with 500 ppm for determining compliance. 

VES017605 
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(c) Each piece of equipment within a process unit that can conceivably contain 

equipment in VHAP service is presumed to be in VHAP service unless the 

Permittee demonstrates that the piece of equipment is not in VHAP service. 

For a piece of equipment to be considered not in VHAP service, it must be 

determined that the percent VHAP content can be reasonably expected 

never to exceed 10 percent by weight. For purposes of determining the 

percent VHAP content ofthe process fluid that is contained in or contacts 

equipment, the Permittee shall use procedures that conform to the methods 

described in ASTM Method D-2267 (incorporated by reference as specified 

in40C.F.R. §61.18). 

(d) The Permittee may use engineering judgment rather than the procedures in 

40 C.F.R. § 61.245(d)(1) to demonstrate that the percent VHAP content 

does not exceed 10 percent by weight, provided that the engineering 

judgment demonstrates that the VHAP content clearly does not exceed 10 

percent by weight. When the Permittee and the Administrator do not agree 

on whether a piece of equipment is not in VHAP service, however, the 

Permittee shall use the procedures in 40 C.F.R. § 61,245(d)( 1). 

(e) If the Permittee determines that a piece of equipment is in VHAP service, 

the determination can be revised only after following the procedures in 

paragraph 40 C.F.R. § 61.245(d)(1). 

(f) Samples used in determining the percent VHAP content shall be 

representative ofthe process fluid that is contained in or contacts the 

equipment or the gas being combusted in the flare. 

2. Requirements of 40 C.F.R. §61.246: 

(a) The Permittee may comply with the recordkeeping requirements for 

multiple process units subject to the provisions of 40 C.F.R. Part 61, 

Subpart V, in one recordkeeping system if the system identifies each record 

by each process unit. 

(b) When each leak is detected as specified in 40 C.F.R. §§ 61.242-2, 61.242-

3, 61.242-7, and 61.242-8, the following requirements apply: 

(i) The Permittee shall attach a weatherproof and readily visible 

identification, marked with the equipment identification number, to 

the leaking equipment: 

(ii) The Permittee may remove the identification on a valve after it has 

monitored the valve for 2 successive months as specified in 40 
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C.F.R. § 242-7(c) and no leak has been detected during those 2 

months. 

(iii) The Permittee may remove the identification on equipment, except 

on a valve, after it has repaired the equipment. 

(c) When the Permittee has detected each leak as specified in 40 C.F.R. 

§§ 61.242-2, 61.242-3, 61.242-7, 61,242-8, and 61.135, the Permittee shall 

record the following information in a log and shall keep the information for 

2 years in a readily accessible location: 

(i) The instrument and operator identification numbers and the 

equipment identification number; 

(ii) The date the leak was detected and the dates of each attempt to repair 

the leak; 

(iii) Repair methods applied in each attempt to repair the leak; 

(iv) "Above 10,000" if the maximum instrument reading measured by 

the methods specified in 40 C.F.R. § 61.245(a) after each repair 

attempt is equal to or greater than 10,000 ppm; 

(v) "Repair delayed" and the reason for the delay if a leak is not repaired 

within 15 calendar days after discovery of the leak; 

(vi) The signature ofthe responsible official whose decision it was that 

repair could not be affected without a process shutdown; 

(vii) The expected date of successful repair of the leak if a leak is not 

repaired within 15 calendar days; 

(viii) Dates of process unit shutdowns that occur while the equipment is 

unrepaired; and 

(ix) The date of successful repair ofthe leak. 

(d) The Permittee shall record in a log and keep in a readily accessible location 

the following information pertaining to all equipment to which a standard 

applies: 

(i) A list of identification numbers for equipment (except welded 

fittings) subject to the requirements of 40 C.F.R. Part 61, Subpart V; 
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(ii) A list of identification numbers for equipment that the Permittee 

elects to designate for no detectable emissions as indicated by an 

instrument reading of less than 500 ppm above background; 

(iii) The designation ofthis equipment for no detectable emissions shall 

be signed by a responsible official; 

(iv) The dates of each compliance test required in 40 CF.R. §§ 61.242-

2(e), 61.242-3(i), 61.242-4, and 61.242-7(f); 

(v) The background level measured during each compliance test; and 

(vi) The maximum instrument reading measured at the equipment during 

each compliance test. 

(e) The Permittee shall record in a log and keep in a readily accessible location 

the following information pertaining to all valves subject to the 

requhements of 40 C.F.R. § 61.242-7(g) and (h) and to all pumps subject to 

the requirements of 40 C.F.R. § 61.242-2(g): 

(i) A list of identification numbers for valves and pumps that are 

designated as unsafe to monitor, an explanation for each valve or 

pump stating why the valve or pump is unsafe to monitor, and the 

plan for monitoring each valve or pump; and 

(ii) A list of identification numbers for valves that are designated as 

difficult to monitor, an explanation for each valve stating why the 

valve is difficult to monitor, and the planned schedule for monitoring 

each valve. 

(f) The Permittee shall record and keep in a readily accessible location the 

following information: 

(i) Design criterion required in 40 C.F.R. §§ 61.242-2(d)(5) and 61.242-

3(e)(2), and an explanation of the design criterion; and 

(ii) Any changes to this criterion and the reasons for the changes. 

(g) Hours of operation of each component. 

(h) Emissions of VOC. 

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)] 
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1. The Permittee shall promptly notify the permitting authority of deviations of the 

affected leaking equipment from the permit requirements. Reports shall describe 

the probable cause of such deviations, and any corrective actions or preventive 

measures taken. [40 C.F.R. § 71.6(a)(3)(iii)(B)] 

2. Requirements of 40 C.F.R. § 61.247: 

(a) The Permittee shall submit a statement in writing notifying the 

Administrator that it is implementing the requirements of 40 C.F.R. 

§§ 61.242, 61.245, 61.246, and 61.247. 

(b) In the case of an existing source or a new source which has an initial 

startup date preceding the effective date, the Permittee shall submit the 

statement to the Administrator along with the information required under 

40 C.F.R. § 61.10 within 90 days ofthe effective date, unless a waiver of 

compliance is granted under 40 C.F.R. § 60.11. If a waiver of compliance 

is granted, the Permittee must submit the statement on a date scheduled by 

the Administrator. 

(c) The Permittee must include tlie following information for each source in 

the statement: 

(i) Equipment identification number and process unit identification; 

(ii) Type of equipment (for example, a pump or pipeline valve); 

(iii) Percent by weight VHAP in the fluid at the equipment; 

(iv) Process fluid state at the equipment (gas/vapor or liquid); and 

(v) Method of compliance with the standard (for example, "monthly 

leak detection and repair" or "equipped with dual mechanical 

seals"). 

(d) The Permittee shall submit to the Administrator a report, semiannually 

starting 6 months after the initial report required in 40 C.F.R. § 61.247(a), 

that includes the following information: 

(i) Process unit identification; 

(ii) For each month during the semiannual reporting period: 

A. Number of valves for which leaks were detected as described 

in 40 C.F.R. §§ 61.242-7(b) or 61.243-2; 
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B. Number of valves for which leaks were not repaired as required 

in40C.F.R. § 61.242-7(d); 

C. Number of pumps for which leaks were detected as described 

in 40 C.F.R. § 61.242-2(b) and (d)(6); 

D: Number of pumps for which leaks were not repaired as 

required in 40 C.F.R. § 61.242-2(c) and (d)(6); 

E. Number of compressors for which leaks were detected as 

described in 40 CF.R. § 61.242-3(f); 

F. Number of compressors for which leaks were not repaired as 

required in 40 C.F.R. § 6I.242-3(g);.and 

G. The facts that explain any delay of repairs and, where 

appropriate, why a process unit shutdown was technically 

infeasible. 

2.10 INSIGNIFICANT EMISSION UNITS AND ACTIVITIES 

(A) List of Insignificant Emission Units and Activities [40 CF.R. § 71.5(c)(ll)] 

The following are insignificant emission units and activities at the facility: 

1. One 2.5 mmBtu/hr Tioga portable boiler; 

2. One horizontal 550-gallon kerosene tank; 

3. Two horizontal 550-gallon No. 2 diesel fuel tanks; 

4. Ash handling; 

5. Handling of spent dry scrubber solids; 

6. Lime unloading and proportioning; 

7. Gasoline storage and dispensing; 

8. Use of absorbent material; 

9. General vehicle maintenance and servicing (assumed to include diesel fuel 

handling); 

10. Laboratory (chemical and physical analysis); 

11. Piping and storage system for natural gas; 

12. Non-halogenated cold cleaning degreasers; 

13. Internal combustion engines of motor vehicles; and 

14. Storage and handling of closed drums. 
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(B) Applicable Requirements [40 C.F.R. § 71.6(a)(1)] 

1. For each particulate matter process emission unit, the Permittee shall comply 

with the applicable particulate matter emission limit of 35 IAC 212.321 or 

212.322 and 35 IAC Part 266. For example, the particulate matter emissions 

from a process emission unit shall not exceed 0.55 pounds per hour if the 

emission unit's process weight rate is 100 pounds per hour or less, pursuant to 35 

IAC 266.110. [35 IAC 212.321 or 212.322 and 35 IAC Part 266] 

2. For each organic material emission unit that uses organic material, e.g., a mixer 

or printing line, the Permittee shall comply with the applicable VOM emission 

limit of 35 IAC 215.301, which requires that organic material emissions not 

exceed 8.0 pounds per hour or, if no odor nuisance exists, do not qualify as 

photochemically reactive material as defined in 35 IAC 211.4690. [35 IAC 

215.301] 

3. For each open burning activity, the Permittee shall comply with 35 IAC Part 237, 

including the requirement to obtain a permit for open burning in accordance with 

35 IAC 237.201, if necessary. [35 IAC Part 237] 

(C) Compliance with Applicable Requirements [40 C.F.R. § 71.6(a)(3)] 

1. The Permittee shall keep current a file for the affected insignificant emission 

units, which may contain estimated emissions, throughput, inspection, 

maintenance and repair log, and other information necessary to demonstrate 

compliance with the applicable requirements and classification of the units as 

insignificant emissions units. [40 C.F.R. § 71.6(a)(3)(i)(B)] 

2. The Permittee must maintain records of results of any emissions testing 

conducted on the affected emission units. [40 C.F.R. § 71.6(a)(3)(i)(B)] 
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3.0 FACILITY-WIDE PERMIT REQUIREMENTS 

3.1. GENERAL PART 71 RECORDKEEPING 

(A) Required Records [40 C.F.R. § 71.6(a)(3)(ii)] 

The Permittee shall keep records of required monitoring information that include the 

following: 

1. The date, place, and time of sampling or measurements; 

2. The date(s) analyses were performed; 

3. The company or entity that performed the analyses; 

4. The analytical techniques or methods used; 

5. The results of such analyses; and 

6. The operating conditions existing at the time of sampling or measurement. 

(B) Record Retention Schedule [40 C.F.R. § 71.6(a)(3)(ii)] 

The Permittee shall retain records of all required monitoring data and support 

information for a period of at least 5 calendar years from the date of the monitoring 

sample, measurement, report, or application. Support information includes, but is 

not limited to, all calibration and maintenance records, all original strip-chart 

recordings for continuous monitoring instrumentation, and copies of all reports 

required by this permit. 

(C) Emissions Calculation Methodology [40 C.F.R. § 71.6(a)(3)(i)(B)] 

1. If an applicable requirement contained in this permit does not require the use of a 

specific methodology for calculating emissions, the Permittee must follow the 

following hierarchy (in order of preference) when selecting the appropriate 

methodology for calculating emissions: 

(a) CEM data from the stationary source; 

(b) Performance test data from the stationary source; 

(c) Manufacturer's emissions performance guarantee; 

(d) CEM data from a similar stationary source or sources; 

(e) Performance test data from a similar stationary source or sources; 

(f) Industry-derived emission factors; 
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(g) Emission factors published in the latest version of EPA's Compilation of 

Air Pollutant Emission Factors (AP-42), with "A"-rated AP-42 emission 

factors being considered before the lower rated emission factors; 

(h) Engineering judgment. 

2. The Permittee must document that it reviewed the hierarchy in condition 

3.1(C)(1), above, before selecting the emissions calculation methodology 

including a demonstration ofthe selected emission factors' appropriateness for 

the specific emission units from which emissions are being calculated. 

3. The Permittee's choice of emission calculation methodology pursuant to 

condition 3.1(C)(1), above, does not preclude any person, such as EPA, the 

public and other regulatory agencies, from using other credible evidence to 

establish compliance or noncompliance with applicable requirements as provided 

by the Act. [42 U.S.C. § 7413] 

3.2. GENERAL PART 71 REPORTING [40 C.F.R. § 71.6(a)(3)(iii)] 

(A) Semi-annual Reports 

1. The Permittee shall submit to EPA semi-annual reports of all required 

monitoring each six month reporting period from January 1 to June 30 and from 

July 1 to December 31. All reports shall be submitted to the EPA and shall be 

postmarked by the 30th day following the end ofthe reporting period. All 

instances of deviations from permit requirements must be clearly identified in 

such reports. All required reports must be certified by a responsible official 

consistent with condition 4.8(A)(1) ofthis permit. [40 C.F.R. 

§71.6(a)(3)(iii)(A)] 

2. A monitoring report submitted pursuant to condition 3.2(A)(1) must include the 

following: 

(a) The company name and address; 

(b) The beginning and ending dates of the reporting period; 

(c) The emissions unit or activity being monitored; 

(d) The emissions limitation or standard, including operational requirements 

and limitations (such as parameter ranges), specified in the permit for 

which compliance is being monitored; 

(e) All instances of deviations from permit requirements whether demonstrated 

by referenced test method, monitoring, or through any other credible 
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evidence, including those attributable to upset conditions as defined in this 

permit, and the date on which each deviation occurred; 

(f) The total time when monitoring required by this pennit was not performed 

during the reporting period and, at the source's discretion, either the total 

duration of deviations indicated by such monitoring or the actual records of 

deviations; 

(g) All other monitoring results, data, or analyses required to be reported by 

the applicable requirement; and 

(h) The name, title, and signature of the responsible official who is certifying 

to the truth, accuracy, and completeness ofthe report. 

(i) Any report required by an applicable requirement that provides the same 

information described in conditions 3.2(A)(2)(a) through (h), above, shall 

satisfy the requirement under condition 3.2(A)(1). 

[40 C.F.R. § 71.6(a)(3)(iii)(A)] 

(B) Deviations 

1. "Deviation" means any situation in which an emissions unit fails to meet a 

permit term or condition. A deviation is not always a violation. A deviation can 

be determined by observation or through review of data obtained from any 

testing, monitoring, or record keeping established in accordance with 40 C.F.R. 

§ 71.6(a)(3)(i) and (ii). For a situation lasting more than 24 hours, each 24-hour 

period is considered a separate deviation. "Deviations" includes, but is not 

limited to, any ofthe following: [40 C.F.R. § 71.6(a)(3)(iii)(C)] 

(a) A situation when emissions exceed an emission limitation or standard; 

(b) A situation where process or emissions control device parameter values 

indicate that an emission limitation or standard has not been met; and 

(c) A situation in which observations or data collected demonstrates 

noncompliance with an emission limitation or standard or any work 

practice or operating condition required by the permit. 

2. The Permittee shall promptly report to the EPA deviations from permit 

requirements, including those attributed to malfunction, emergency or other 

upset conditions, the probable cause of such deviations, and any corrective 

actions or preventive measures taken. "Prompt" is defined as follows: 

[40C.F.R.§71.6(a)(3)(iii)(B)] 
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(a) Any definition of "prompt" or specific timeframe for reporting deviations 

provided in an underlying applicable requirement (as identified in this 

permit); or 

(b) Where the underlying applicable requirement does not define prompt or 

provide a timeframe for reporting deviations, reports of deviations will be 

submitted based on the following schedule: 

(i) For emissions of a hazardous air pollutant or a toxic air pollutant (as 

identified in an applicable regulation) that continue for more than an 

hour in excess of permit requirements, the report must be made 

within 24 hours of the occurrence. 

(ii) For emissions of any regulated pollutant excluding a hazardous air 

pollutant or a toxic air pollutant that continue for more than two 

hours in excess of permit requirements, the report must be made 

within 48 hours. 

(iii) For all other deviations from permit requirements, the report shall be 

submitted with the semi-annual monitoring report required in 

condition 3.2(A)(1) ofthis permit. 

3. If any ofthe requirements in condition 3.2(B)(1)(a) through (c), above, are met, 

the Permittee must notify EPA by telephone or facsimile based on the timetable 

listed. A written notice, certified consistent with condition 4.8(A), must be 

submitted within 10 working days ofthe occurrence. All deviations reported 

under this condition must also be identified in the semi-annual report required 

under condition 3.2(A)(1), above. 

3.3. PERFORMANCE TESTING [40 C.F.R. § 71.6(a)(3)(i)] 

The Permittee shall provide performance testing facilities that include the following: 

(A) Sampling ports adequate for the applicable test methods; 

(B) Safe sampling platform(s); 

(C) Safe access to sampling platform(s); and 

(D) Utilities for sampling and testing equipment. 
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3.4. FACILITY-WIDE APPLICABLE REQUIREMENTS 

(A) Fugitive Particulate Matter Restrictions [35 IAC 212.301] 

The Permittee shall not cause or allow the emission of fugitive particulate matter 

from any process, including any material handling or storage activity that is visible 

by an observer looking generally toward the zenith at a point beyond the property 

line of the emission source. 

(B) Open Burning Prohibitions [35 IAC 237.102] 

1. The Permittee shall not cause or allow open burning, except as provided in 

35 IAC 237. 

2. The Permittee shall not cause or allow open burning of any refuse in any 

chamber or apparatus, unless such chamber or apparatus is designed for the 

purpose of disposing of the class of refuse being burned. 

(C) Visible Emissions [35 IAC 212.123(a)] 

The Permittee shall not cause or allow the emission of smoke or other particulate 

matter, with an opacity greater than 30 percent, into the atmosphere from any 

emission unit other than those emission units subject to the requirements of 35 IAC 

212.122, except as allowed by 35 IAC 212.123(b) and 35 IAC 212.124. 

(D) Recycling and Emissions Reduction [40 C.F.R. Part 82, Subpart F] 

The Permittee shall comply with the standards for recycling and emissions reduction 

of ozone depleting substances pursuant to 40 C.F.R. Part 82, Subpart F, except as 

provided for motor vehicle air conditioners in 40 C.F.R. Part 82, Subpart B: 

1. Persons opening appliances for maintenance, service, repair, or disposal must 

comply with the required practices pursuant to 40 C.F.R. § 82.156. 

2. Equipment used during the maintenance, service, repair, or disposal of 

appliances must comply with the standards for recycling and recovery equipment 

pursuant to 40 C.F.R. § 82.158. 

3. Persons performing maintenance, service, repair, or disposal of appliances must 

be certified by an approved technician certification program pursuant to 40 

CF.R. § 82.161. 
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(E) Risk Management Plan (RMP) [40 C.F.R. § 68.215(a)(2)(i) and (ii)] 

Should this stationary source, as defined in 40 C.F.R. § 68.3, become subject to the 

federal regulations for Chemical Accident Prevention in 40 CF.R. Part 68, then the 

Permittee shall submit the items below: 

1. A compliance schedule for meeting the requirements of 40 C.F.R. Part 68 by the 

date provided in 40 C.F.R. § 68.10(a); or 

2. A certification statement that the source is in compliance with all requirements of 

40 C.F.R. Part 68, including the registration and submission of the RMP, as part 

of the annual compliance certification. 

(F) Episode Action Plans [35 IAC 244, Subpart C] 

The Permittee shall maintain at the source and have on file with the IEPA a written 

episode action plan (plan) for reducing the levels of emissions during yellow alerts, 

red alerts, and emergencies, consistent with safe operating procedures. The plan 

shall contain the information specified in 35 IAC 244.144 and is incorporated by 

reference into this permit. 

(G) Annual Benzene Waste Quantity Determination [40 C.F.R. § 61.355] 

The Permittee shall determine the total annual benzene quantity from facility waste 

by the following procedure: 

1. For each waste stream subject to 40 C.F.R. Part 61, Subpart FF, having a flow 

weighted annual average water content greater than 10 percent water, on a 

volume basis as total water, or which is mixed with water or other wastes at any 

time and the resulting mixture has an annual average water content greater than 

10 percent as specified in 40 C.F.R. § 61.342(a), the Permittee shall: 

(a) Determine the annual waste quantity for each waste stream using the 

procedures specified in 40 CF.R. § 61.355(b). 

(b) Determine the flow-weighted annual average benzene concentration for 

each waste stream using the procedures specified in 40 CF.R. § 61.355(c). 

(c) Calculate the annual benzene quantity for each waste stream by multiplying 

the annual waste quantity of the waste stream times the flow-weighted 

annual average benzene concentration. 

(d) Total annual benzene quantity from facility waste is calculated by adding 

together the annual benzene quantity for each waste stream generated 
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during the year and the annual benzene quantity for each process unit 

turnaround waste annualized according to 40 C.F.R. § 61.355(b)(4). 

2. If the total annual benzene quantity from facility waste is equal to or greater than 

10 megagram per year (11 ton/yr), then the Permittee shall comply with the 

requirements of 40 C.F.R. § 61.342(c), (d), or (e). 

(H) General Prohibition on Air Pollution [35 IAC 201.141] 

No person shall cause or threaten or allow the discharge or emission of any 

contaminant into the environment in any State so as, either alone or in combination 

with contaminants from other sources, to cause or tend to cause air pollution in 

Illinois, or so as to violate the provisions of 35 IAC, Subtitle B, Chapter I, or so as to 

prevent the attainment or maintenance of any applicable ambient air quality 

standard. [35 IAC 201.141] 

(I) Facility-wide Testing [40 C.F.R. § 71.6(a)(3)(i)] 

1. Testing Required by 35 IAC 201.282. 

Every emission source and all air pollution control equipment shall be subject to 

the following testing requirements for the purpose of determining the nature and 

quantities of specified air contaminant emissions and for the purpose of 

determining ground level and ambient air concentrations of such air contaminants: 

(a) Testing by the Perm ittee. The IEPA may require the Permittee to conduct 

tests in accordance with procedures adopted by the IEPA, at such 

reasonable times as may be specified by the IEPA and at the expense ofthe 

Permittee. The IEPA may adopt procedures detailing methods of testing 

and formats for reporting results of testing. Such procedures and formats, 

and revisions thereto, shall not become effective until filed with the Index 

Division ofthe Office of the Secretary of State as Required by "An Act 

concerning administrative rules," approved June 14, 1951, as amended. All 

such tests shall be made by or under the direction of a person qualified by 

training and/or experience in the field of air pollution testing. The IEPA 

shall have the right to observe all aspects of such tests. 

(b) Testing by the IEPA. The IEPA shall have the right to conduct such tests 

at any time at its own expense. Upon request ofthe IEPA, the Permittee 

shall provide, without charge to the IEPA, necessary holes in stacks or 

ducts and other safe and proper testing facilities, including scaffolding, but 

excluding instruments and sensing devices, as may be necessary. 
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2. Determination of annual benzene waste quantity for off-site wastes [40 C.F.R. 

§ 61.355] 

(a) The determination of annual benzene waste quantity for the off-site wastes 

received by the Permittee shall be made by using the methods and 

procedures established in 40 CF.R. § 61.355 along with the following: 

(b) Forthe purposes ofthe calculation required by 40 C.F.R. § 61.355(a), the 

Permittee shall determine the flow-weighted annual average benzene 

concentration in a manner that meets the requirements given in 40 C.F.R. 

§ 61.355(c)(1) using either ofthe methods given in 40 C.F.R. 

§ 61.355(c)(2) and (c)(3). 

(i) The determination for wastes that are received from offsite shall be 

made at the point where the waste enters the hazardous waste 

treatment, storage, or disposal facility. 

(ii) Knowledge of the waste. The Permittee shall provide sufficient 

information to document the flow-weighted annual average benzene 

concentration of each waste stream. Examples of information that 

could constitute knowledge include material balances, records of 

chemicals purchases, or previous test results provided the results are 

still relevant to the current waste stream conditions. If test data are 

used, then the Permittee shall provide documentation describing the 

testing protocol and the means by which sampling variability and 

analytical variability were accounted for in the determination of the 

flow-weighted annual average benzene concentration for the waste 

stream. When the Permittee and the Administrator do not agree on 

determinations of the flow-weighted annual average benzene 

concentration based on knowledge of the waste, the procedures 

under 40 C.F.R. § 61.355(c)(3) shall be used. 

(iii) Measurements of the benzene concentration in the waste stream in 

accordance with the following procedures: 

A. Collect a minimum of three representative samples from each 

waste stream. Where feasible, samples shall be taken from an 

enclosed pipe prior to the waste being exposed to the 

atmosphere. 

B. For waste in enclosed pipes, the following procedures shall be 

used: 
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I. Samples shall be collected prior to the waste being 

exposed to the atmosphere in order to minimize the loss 

of benzene prior to sampling. 

II. A static mixer shall be installed in the process line or in 

a by-pass line unless the Permittee demonstrates that 

installation of a static mixer in the line is not necessary 

to accurately determine the benzene concentration ofthe 

waste stream. 

IH. The Sampling tap shall be located within two pipe 

diameters of the static mixer outlet. 

IV. Prior to the initiation of sampling, sample lines and 

cooling coil shall be purged with at least four volumes of 

waste. 

V. After purging, the sample flow shall be directed to a 

sample container and the tip of the sampling tube shall 

be kept below the surface ofthe waste during sampling 

to minimize contact with the atmosphere. 

VI. Samples shall be collected at a flow rate such that the 

cooling coil is able to maintain a waste temperature less 

than 10°C (50°F). 

VII. After filling, the sample container shall be capped 

immediately (within 5 seconds) to leave a minimum 

headspace in the container. 

VIII. The sample containers shall immediately be cooled and 

maintained at a temperature below 10°C (50°F) for 

transfer to the laboratory. 

C. When sampling from an enclosed pipe is not feasible, a 

minimum of three representative samples shall be collected in a 

manner to minimize exposure of the sample to the atmosphere 

and loss of benzene prior to sampling. 

D. Each waste sample shall be analyzed using one of the 

following test methods for determining the benzene 

concentration in a waste stream: 

I. Method 8020, Aromatic Volatile Organics, in "Test 

Methods for Evaluating Solid Waste, Physical/Chemical 

VES017620 
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Methods," EPA Publication No. SW-846 (incorporation 

by reference as specified in 40 C.F.R. § 61.18); 

II. Method 8021, Volatile Organic Compounds in Water by 

Purge and Trap Capillary Column Gas Chromatography 

with Photoionization and Electrolytic Conductivity 

Detectors in Series, in "Test Methods for Evaluating 

Solid Waste, Physical/Chemical Methods," EPA 

Publication No. SW-846 (incorporation by reference as 

specified in 40 C.F.R. § 61.18); 

III. Method 8240, Gas Chromatography/Mass Spectrometry 

for Volatile Organics, in "Test Methods for Evaluating 

Solid Waste, Physical/Chemical Methods," EPA 

Publication No. SW-846 (incorporation by reference as 

specified in 40 C.F.R. § 61.18); 

IV. Method 8260, Gas Chromatography/Mass Spectrometry 

for Volatile Organics: Capillary Column Technique, in 

"Test Methods for Evaluating Solid Waste, 

Physical/Chemical Methods," EPA Publication No. SW846 (incorporated by reference as specified in 40 CF.R. 

§61.18); 

V. Method 602, Purgeable Aromatics, as described in 40 

C.F.R. Part 136, Appendix A, Test Procedures for 

Analysis of Organic Pollutants, for wastewaters for 

which this is an approved EPA methods; or 

VI. Method 624, Purgeables, as described in 40 C.F.R. Part 

136, Appendix A, Test Procedures for Analysis of 

Organic Pollutants, for wastewaters for which this is an 

approved EPA method. 

E. The Permittee shall calculate the flow-weighted annual average 

benzene concentration by averaging the results ofthe sample 

analyses as follows: 

C = — x 2 (QiXQ) 

Qt i = i 

Where: 
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(QiXCi) average benzene concentration 

1. 

2. 

Qt = Total annual waste quantity for waste stream, kg/yr 

(lb/yr). 

n = Number of waste samples (at least 3). 

Qi = Annual waste quantity for waste stream represented 

by Ci, kg/yr (lb/yr). 

Ci = Measured concentration of benzene in waste sample i, 

ppmw. 

:ility-wide Recordkeeping [40 .C.F.R § 71.6(a)(3)(i)(B)] 

If testing is required by condition 3.4(1), the Permittee shall keep records of the 

testing, including the test date, conditions, methodologies, calculations, test 

results, and any discrepancies between the test results. 

Reporting requirements established by 40 C.F.R. Part 61, Subpart FF: [40 

C.F.R. § 61.357] 

If the total annual benzene quantity from facility waste is equal to or greater than 

10 Mg/yr (11 ton/yr), then the Permittee shall submit to the Administrator the 

following reports: 

(a) The Permittee shall submit annually to the Administrator a report that 

updates the information listed in 40 C.F.R. § 61.357(a)(1) through (a)(3). 

If the information in the annual report required by 40 C.F.R. § 61.357(a)(1) 

through (a)(3) is not changed in the following year, the Permittee may 

submit a statement to that effect. 

(b) The Permittee must include the following information in the annual report: 

[40 C.F.R. § 61.357(a)(1) through (a)(3)] 

(i) Total annual benzene quantity from facility waste determined in 

accordance with 40 C.F.R. § 61.355(a). 

(ii) A table identifying each waste stream and whether or not the waste 

stream will be controlled for benzene emissions in accordance with 

the requirements of 40 C.F.R. Part 61, Subpart FF. 

(iii) For each waste stream identified as not being controlled for benzene 

emissions in accordance with the requirements of 40 C.F.R. Part 61, 
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Subpart FF, the Permittee shall add the following information to the 

table: 

A. Whether or not the water content of the waste stream is greater 

than 10 percent; 

B. Whether or not the waste stream is a process wastewater 

stream, product tank drawdown, or landfill leachate; 

C. Annual waste quantity for the waste stream; 

D. Range of benzene concentrations for the waste stream; 

E. Annual average flow-weighted benzene concentration for the 

waste stream; and 

F. Annual benzene quantity for the waste stream. 

(c) Beginning 3 months after the date that the equipment necessary to comply 

with 40 CF.R. Part 61, Subpart FF, has been certified in accordance with 

40 CF.R. § 61.357(d)(1), the Permittee shall submit quarterly to the 

Administrator a certification that all of the required inspections have been 

carried out in accordance with the requirements of 40 C.F.R. Part 61, 

Subpart FF. 

(d) Beginning 3 months after the date that the equipment necessary to comply 

with 40 CF.R. Part 61, Subpart FF, has been certified in accordance with 

40 C.F.R. § 61.357(d)(1), the Permittee shall submit a report quarterly to 

the Administrator that includes: 

(i) If a treatment process or wastewater treatment system unit is 

monitored in accordance with 40 CF.R. § 61.354(a)(1), then each 

period of operation during which the concentration of benzene in the 

monitored waste stream exiting the unit is equal to or greater than 10 

parts per million by weight. 

(ii) If a treatment process or wastewater treatment system unit is 

monitored in accordance with 40 C.F.R. § 61.354(a)(2), then each 3-

hour period of operation during which the average value ofthe 

monitored parameter is outside the range of acceptable values or 

during which the unit is not operating as designed. 

(iii) If a treatment process or wastewater treatment system unit is 

monitored in accordance with 40 CF.R. § 61.354(b), then each 

period of operation during which the flow-weighted annual average 
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concentration of benzene in the monitored waste stream entering the 

unit is equal to or greater than 10 ppmw and/or the total annual 

benzene quantity is equal to or greater than 1.0 mg/yr. 

(iv) For a control device monitored in accordance with 40 C.F.R. 

§ 61.354(c), each period of operation monitored during which any of 

the conditions established by 40 C.F.R. § 61.357(d)(7)(iv) occur, as 

applicable to the control device. 

(v) For a cover and closed-vent system monitored in accordance with 40 

CF.R. § 61.354(g), the Permittee shall submit a report quarterly to 

the Administrator that identifies any period in which the pressure in 

the waste management unit is equal to or greater than atmospheric 

pressure. 

3. The Permittee shall submit annually to the Administrator a report that 

summarizes all inspections required by 40 CF.R. §§ 61.342 through 61.354 

during which detectable emissions are measured or a problem (such as a broken 

seal, gap or other problem) that could result in benzene emissions is identified, 

including information about the repairs or corrective action taken. 
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4.0 GENERAL PART 71 REQUIREMENTS 

4.1. DEFINITIONS [40 C.F.R. § 71.2] 

Terms and conditions not otherwise defined in this permit have the meaning assigned to 

them in 40 C.F.R. Part 71 unless other regulations or statutes are referenced. 

4.2. ANNUAL FEE PAYMENT [40 C.F.R. §§ 71.6(a)(7) and 71.9] 

A. The Permittee shall pay an annual permit fee in accordance with the procedures 

outlined below. [40 CF.R. § 71.9(a)] 

B. The Permittee shall submit an annual report of its actual emissions for the preceding 

calendar year, a fee calculation work sheet (based on the report), and full payment of 

the annual fee each year. The Permittee shall submit the annual report and pay the 

annual permit fee each year on or before the anniversary date (3 months from the 

issuance of this permit) of its initial fee calculation work sheet. 

The Permittee shall submit the annual report to: 

Air Permits Section (AR-18J) 

Air and Radiation Division 

EPA Region 5 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

C The fee payment shall be in United States currency and shall be paid by money 

order, bank draft, certified check, corporate check, or electronic funds transfer 

payable to the order of the U.S. Environmental Protection Agency. 

D. The Permittee shall send fee payment and a completed fee filing form to: 

U.S. Environmental Protection Agency 

FOIA and Miscellaneous Payments, 

Cincinnati Finance Center, 

P.O. Box 979078, 

St. Louis, MO 63197-9000 

E. The Permittee shall send an updated fee calculation worksheet form and a photocopy 

of each fee payment check (or other confirmation of actual fee paid) submitted 

annually by the same deadline as required for fee payment to the address listed in 

condition 4.8(B) ofthis permit. (The Permittee should note that an annual emissions 

report, required at the same time as the fee calculation worksheet by 40 C.F.R. 

§ 71.9(h), has been incorporated into the fee calculation worksheet form as a 

convenience.) 

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F. Basis for calculating annual fee: 

1. The annual emissions fee shall be calculated by multiplying the total tons of 

actual emissions of all regulated pollutants (for fee calculation) emitted from the 

source, including fugitive emissions by the presumptive emissions fee (in 

dollars/ton) in effect at the time of calculation. 

(a) "Actual emissions" means the actual rate of emissions in tons per year of 

any "regulated pollutant (for fee calculation)" emitted from a Part 71 

source over the preceding calendar year. Actual emissions shall be 

calculated using each emissions unit's actual operating hours, production 

rates, in-place control equipment, and types of materials processed, stored, 

or combusted during the preceding calendar year. [40 CF.R. § 71.9(c)(6)] 

(b) Actual emissions shall be computed using methods required by the permit 

for determining compliance, such as monitoring or source testing data. 

[40 CF.R. § 71.9(h)(3)] 

(c) If actual emissions cannot be determined using the compliance methods in 

the permit, the Permittee shall use other federally recognized procedures. 

[40 C.F.R. § 71.9(e)(2)] 

(d) The term "regulated pollutant (for fee calculation)" is defined in 40 C.F.R. 

§71.2. 

(e) Prior to the start of each calendar year, EPA will revise for inflation rate 

and make available the presumptive fee amount. 

2. The Permittee shall exclude the following emissions from the calculation of fees: 

(a) The amount of actual emissions of each regulated pollutant (for fee 

calculation) that the source emits in excess of 4,000 tons per year; 

[40C.F.R.§71.9(c)(5)(I)] 

(b) Actual emissions of any regulated pollutant (for fee calculation) already 

included in the fee calculation; [40 C.F.R. § 71.9(c)(5)(ii)] and 

(c) The quantity of actual emissions (for fee calculation) of insignificant 

activities [defined in 40 C.F.R. § 71.5(c)(l l)(i)] or of insignificant 

emissions levels from emissions units identified in the Permittee's 

application [pursuant to 40 C.F.R. § 71.5(c)(l l)(ii)]. [40 C.F.R. 

§71.9(c)(5)(iii)] 
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G. Fee calculation worksheets shall be certified as to truth, accuracy, and completeness 

by a responsible official in accordance with condition 4.8(A). (The Permittee should 

note that the fee calculation worksheet incorporates a section to help meet this 

responsibility.) 

H. The Permittee shall retain fee calculation worksheets and other emissions-related 

data used to determine fee payment for 5 years following submittal of fee payment. 

Emission-related data include, for example, emissions-related forms provided by the 

EPA and used by the Permittee for fee calculation purposes, emissions-related 

spreadsheets, and emissions-related data, such as records of emissions monitoring 

data and related support information required to be kept in accordance with 40 

CF.R. § 71.6(a)(3)(h). [40 C.F.R. § 71.9(1)] 

I. Failure of the Permittee to pay fees in a timely manner shall subject the Permittee to 

assessment of penalties arid interest in accordance with 40 C.F.R. § 71.9(1). 

J. When notified by the EPA of underpayment of fees, the Permittee shall remit full 

payment within 30 days of receipt of notification. [40 C.F.R. § 71.9(j)(l) and (2)] 

K. A Permittee who believes that the EPA assessed fee is ia error and who wishes to 

challenge such fee shall provide a written explanation of the alleged error to the EPA 

along with full payment ofthe EPA assessed fee. [40 C.F.R. § 71.9(j)(3)] 

4.3. COMPLIANCE STATEMENT [40 C.F.R. § 71.6(a)(6)] 

(A) The Permittee must comply with all conditions of this Part 71 permit. Any 

noncompliance with this permit constitutes a violation of the CAA and is grounds 

for: [40C.F.R. § 71.6(a)(6)(I)] 

1. Enforcement action; 

2. Permit termination, revocation and reissuance, or modification; or 

3. Denial of a permit renewal application. 

(B) It shall not be a defense for a Permittee in an enforcement action that it would have 

been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the conditions ofthis permit. [40 CF.R. § 71.6(a)(6)(h)] 

4.4. COMPLIANCE CERTIFICATIONS [40 C.F.R. § 71.6(c)(5)] 

The Permittee shall submit to EPA a certification of compliance with all permit terms and 

conditions, including emission limitations, standards, or work practices, each calendar 

year for the reporting period from January 1 to December 31, except the first reporting 

period shall begin on the effective date ofthis permit and end on December 31. All 
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reports shall be submitted to the EPA and shall be postmarked by the 30th day following 

the end ofthe reporting period. The compliance certification shall be certified as to truth, 

accuracy, and completeness by a responsible official in accordance with condition 4.8(A) 

of this permit. The certification shall include the following: 

(A) Identification of each permit term or condition that is the basis of the certification; 

(B) Identification ofthe method(s) or other means used for determining the compliance 

status of each term and condition during the certification period, and whether such 

methods or other means provide continuous or intermittent data. If necessary, the 

Permittee also shall identify any other material mformation that must be included in 

the certification to comply with section 113(c)(2) of the CAA, which prohibits 

knowingly making a false certification or omitting material information; 

(C) The compliance status of each term and condition of the permit, including whether 

monitoring data is continuous and whether that data or any other credible evidence 

shows the compliance is continuous. The certification shall identify each deviation 

and take it into account in the compliance certification; and 

(D) A statement indicating the compliance status of the source with any applicable 

monitoring and compliance certification requirements of the CAA. 

4.5. SCHEDULE OF COMPLIANCE [40 C.F.R. §§ 71.6(c)(3) and 71.5(c)(8)(iii)] 

(A) The Permittee will comply with all requirements of the permit. 

(B) For applicable requirements that will become effective during the permit term, the 

Permittee shall timely comply with such requirements. 

4.6. DUTY TO PROVIDE AND SUPPLEMENT INFORMATION 

[40 C.F.R. §§ 71.6(a)(6)(v) and 71.5(b)] 

(A) The Permittee shall furnish to the EPA, within a reasonable time, any information 

that the EPA may request in writing to determine whether cause exists for 

modifying, revoking and reissuing, or terminating this permit or to determine 

compliance with this permit. Upon request, the Permittee shall also furnish to EPA 

copies of records that are required to be kept pursuant to the terms of this permit, 

including information claimed to be confidential. Information claimed to be 

confidential should be accompanied by a claim of confidentiality according to the 

provisions of 40 C.F.R. Part 2, Subpart B. 

(B) The Permittee, upon becoming aware that any relevant facts were omitted or 

incorrect information was submitted in the permit application, shall promptly submit 

such supplementary facts or corrected information. The Permittee shall also provide 
Veolia ES Technical Solutions, L.L.C. Page 167 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

ExpirationDate: DRAFT 

additional information as necessary to address any requirements that become 

applicable to the facility after this permit is issued. 

4.7. ENFORCEABILITY [40 C.F.R. § 71.6(b)] 

All terms and conditions in this permit, including any provisions designated to limit the 

source's potential to emit, are enforceable by the EPA and citizens in accordance with the 

CAA. 

4.8. SUBMISSIONS [40 CF.R. §§ 71.5(d), 71.6 and 71.9] 

(A) A responsible official of the Permittee shall certify as to the truth, accuracy, and 

completeness of any document required to be submitted by this permit. Such 

certifications shall state that based on information and belief formed after reasonable 

inquiry, the statements and information in the document are true, accurate, and 

complete. Except as otherwise noted, the Permittee shall submit all documents 

required to be submitted by this permit to: 

Air Enforcement and Compliance Assurance Branch (AE-17J) 

Air and Radiation Division 

EPA Region 5 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

(B) The Permittee shall submit permit applications, applications for permit amendments, 

and other applicable permit information, which includes but is not limited to 

installation of control equipment, replacement of an emissions unit, fee calculation 

worksheets, and applications for renewals and permit modifications, to: 

Air Permits Section 

Air Programs Branch (AR-18J) 

EPA Region 5 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

4.9. SEVERABILITY CLAUSE [40 C.F.R. § 71.6(a)(5)] 

The provisions of this permit are severable, and in the event of any challenge to any 

portion of this permit, or if any portion is held invalid, the remaining permit conditions 

shall remain valid and in force. 

4.10. PERMIT ACTIONS [40 C.F.R. § 71.6(a)(6)(iii)] 

The EPA may modify, revoke, reopen and reissue this permit, or terminate it for cause. 

The filing of a request by the Permittee for a pennit modification, revocation and 
Veolia ES Technical Solutions, L.L.C. Page 168 of 172 

Permit No.: V-IL-1716300103 -2014-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

reissuance, or termination, or of a notification of planned changes or anticipated 

noncompliance does not stay any permit condition. 

4.11. ADMINISTRATIVE PERMIT AMENDMENTS [40 C.F.R. § 71.7(d)] 

The Permittee may request the use of administrative permit amendment procedures for a 

permit revision in accordance with 40 C.F.R. § 71.7(d). 

4.12. MINOR PERMIT MODIFICATIONS [40 C.F.R. § 71.7(e)(1)] 

The Permittee may request the use of minor permit modification procedures for those 

modifications that meet the requirements contained in 40 C.F.R. § 71.7(e)(1). 

4.13. SIGNIFICANT PERMIT MODIFICATIONS [40 C.F.R. § 71.7(e)(3)] 

The Permittee must request the use of significant permit modification procedures for 

those modifications that meet the requirements contained in 40 C.F.R. § 71.7(e)(3). 

4.14. REOPENING FOR CAUSE [40 C.F.R. § 71.7(f)] 

The EPA shall reopen and revise the permit prior to expiration under any ofthe following 

circumstances: 

(A) Additional applicable requirements under the CAA become applicable to this source 

if the remaining permit term is 3 or more years. 

(B) The EPA determines that the permit contains a material mistake or that inaccurate 

statements were made in establishing the emissions standards or other terms or 

conditions of the permit. 

(C) The EPA determines that the permit must be revised or revoked to assure 

compliance with the applicable requirements. 

4.15. PROPERTY RIGHTS [40 CF.R. § 71.6(a)(6)(iv)] 

This permit does not convey any property rights of any sort, or any exclusive privilege. 

4.16. INSPECTION AND ENTRY [40 C.F.R. § 71.6(c)(2)] 

Upon presentation of credentials and other documents as may be required by law, the 

Permittee shall allow EPA or an authorized representative to perform the following as 

authorized by the CAA: 
Veolia ES Technical Solutions, L.L.C. Page 169 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

ExpirationDate: DRAFT 

(A) Enter upon the Permittee's premises where the Part 71 source is located or 

emissions-related activity is conducted, or where records are kept under the 

conditions of the permit; 

(B) Have access to and copy, at reasonable times, any records that must be kept under 

the conditions of the permit; 

(C) Inspect at reasonable times any facilities, equipment (including monitoring and air 

pollution control equipment), practices, or operations regulated or required under the 

permit; and 

(D) Sample or monitor at reasonable times substances or parameters for the purpose of 

assuring compliance with the permit or applicable requirements. 

4.17. EMERGENCY PROVISIONS [40 C.F.R. § 71.6(g)] 

(A) In addition to any emergency or upset provision contained in any applicable 

requirement, the Permittee may seek to establish that noncompliance with a 

technology-based emission limitation under this permit was due to an emergency. 

To do so, the Permittee shall demonstrate the affirmative defense of emergency 

through properly signed, contemporaneous operating logs, or other relevant evidence 

that: 

1. An emergency occurred and that the Permittee can identify the cause(s) of the 

emergency; 

2. The permitted facility was at the time being properly operated; 

3. During the period of the emergency the Permittee took all reasonable steps to 

minimize levels of emissions that exceeded the emissions standards, or other 

requirements in this permit; and 

4. The Permittee submitted notice of the emergency to EPA within 2 working days 

of the time when emission limitations were exceeded due to the emergency. This 

notice must contain a description of the emergency, any steps taken to mitigate 

emissions, and corrective actions taken. This notice fulfills the requirements of 

condition 3.2(B) of this permit, concerning prompt notification of deviations. 

(B) In any enforcement proceeding, the Permittee attempting to establish the occurrence 

of an emergency has the burden of proof. 

(C) An "emergency" means any situation arising from sudden and reasonably 

unforeseeable events beyond the control of the source, including acts of God, which 

situation requires immediate corrective action to restore normal operation, and that 

causes the source to exceed a technology-based emission limitation under the permit 
Veolia ES Technical Solutions, L.L.C. Page 170 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

ExpirationDate: DRAFT 

due to unavoidable increases in emissions attributable to the emergency. An 

emergency shall not include noncompliance to the extent caused by improperly 

designed equipment, lack of preventive maintenance, careless or improper operation, 

or operator error. 

4.18. OFF PERMIT CHANGES [40 CF.R. § 71.6(a)(12)] 

The Permittee is allowed to make certain changes without a pennit revision, provided that 

the following requirements are met: 

(A) Each change is not addressed or prohibited by this permit; 

(B) Each change must comply with all applicable requirements and may not violate any 

existing pennit term or condition; 

(C) Changes under this provision may not include changes subject to any requirement of 

40 C.F.R. Parts 72 through 78 or modifications under any provision of Title I of the 

CAA; 

(D) The Permittee must provide contemporaneous written notice to EPA of each change, 

except for changes that qualify as insignificant activities under 40 C.F.R. 

§ 71.5(c)(l 1). The written notice must describe each change, the date of the change, 

any change in emissions, pollutants emitted, and any applicable requirements that 

would apply as a result of the change; 

(E) The permit shield does not apply to changes made under this provision; and 

(F) The Permittee must keep a record describing all changes that result in emissions of 

any regulated air pollutant subject to any applicable requirement not otherwise 

regulated under this permit, and the emissions resulting from those changes. 

4.19. PERMIT EXPIRATION AND RENEWAL [40 C.F.R. §§ 71.5(a)(l)(iii), 71.6(a)(ll), 

71.7(b), 71.7(c)(l)(i) and (ii), 71.8(d)] 

(A) Except as provided in conditions 4.19(C) and (D), below, this permit shall expire 

five years from the effective date. 

(B) Expiration of this permit terminates the Permittee's right to operate unless the 

Permittee has submitted a timely and complete permit renewal application to the 

permitting authority at least 6 calendar months, but not more than 18 calendar 

months, prior to the date of expiration ofthis permit. 

(C) If the Permittee submits a timely and complete permit application for renewal, 

consistent with 40 C.F.R. § 71.5(a)(1) and (2) and condition 4.19(B), above, but the 

permitting authority fails to issue or deny the renewal permit, then this permit shall 

VES017632 
Veolia ES Technical Solutions, L.L.C. Page 171 of 172 

PermitNo.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

ExpirationDate: DRAFT 

not expire until the permitting authority has issued or denied a renewal permit. Any 

permit shield granted under condition 4.21 of this permit may be extended during the 

period that the permitting authority fails to act on the renewal application. 

(D) If the Permittee has submitted a timely and complete application for renewal 

consistent with 40 C.F.R. § 71.5(a)(1) and (2) and condition 4.19(B), above, the 

Permittee's failure to have a Part 71 permit is not a violation of Part 71 or the CAA 

until the permitting authority takes final action on the permit renewal application. 

This protection shall cease to apply if, subsequent to the completeness 

determination, the Permittee fails to submit any additional information identified as 

being needed to process the application by the deadline specified in writing by the 

permitting authority. 

(E) Renewal of this permit is subject to the same procedural requirements that apply to 

initial permit issuance, including those for public participation and affected state and 

tribal review. 

(F) The application for renewal shall include the current permit number, description of 

permit revisions and off-permit changes that occurred during the permit term, any 

applicable requirements that were promulgated and not incorporated into the permit 

during the permit term, and other information required by the application form. 

4.20. OPERATIONAL FLEXIBILITY [40 C.F.R. § 71.6(a)(13)] 

The Permittee may make changes within the permitted facility without a permit revision, 

including the addition of a new generator or replacement of an existing generator, 

provided the following conditions are. met: 

(A) The changes are not modifications under any provision of Title I of the CAA; 

(B) The changes do not exceed the emissions allowed under this permit (whether 

expressed therein as a rate of emissions or in terms of total emissions); and 

(C) The Permittee notifies the EPA at least 7 days in advance ofthe proposed changes. 

The written notification shall include a brief description of the change within the 

permitted facility, the date on which the change will occur, any change in emissions, 

and any permit term or condition that is no longer applicable as a result ofthe 

change. 

4.21. PERMIT SHIELD [40 C.F.R. § 71.6(f)] 

(A) Except as noted in conditions 4.21(A)(1) and (2), below, compliance with the 

conditions of this permit shall be deemed compliance, as of the date of pennit 

issuance, with any applicable requirements that are specifically identified and 
Veolia ES Technical Solutions, L.L.C. Page 172 of 172 

PermitNo.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

included in this permit or that are specifically identified in this permit as not 

applying to the facility. 

1. Compliance with this permit shall not be deemed to be compliance with any 

requirement of 40 C.F.R. Part 63, Subpart EEE, (including the appendix and any 

requirement of the General Provisions (40 C.F.R. Part 63, Subpart A) identified 

in Table 1 as applicable to 40 C.F.R. Part 63, Subpart EEE). 

2. The permit shield shall not apply, and compliance with this permit shall not be 

deemed to be compliance with, Parts C and D of Title I of the CAA, or any 

requirements of the Illinois SIP, or federal or state regulations that govern the 

permitting of major modifications to sources of air emissions. 

(B) Nothing in this permit shall alter or affect the following: 

1. The liability of the Permittee for any violation of applicable requirements prior to 

or at the time of permit issuance; 

2. The ability of EPA to obtain information under Section 114 of the CAA; 

3. The applicable requirements ofthe acid rain program, consistent with section 

408(a) of the CAA; or 

4. The provisions of section 303 of the CAA (emergency orders), including the 

authority ofthe Administrator under that section. 

4.22. CREDIBLE EVIDENCE [62 Fed. Reg. 8314 (February 24,1997); 42 U.S.C. § 7413] 

Notwithstanding the conditions of this permit specifying compliance practices for 

applicable requirements, any person (including the Permittee) may also use other credible 

evidence to establish compliance or noncompliance with applicable requirements. 
VES017635-017638.pdf 
Multi-Metals Continuous Emissions 

Monitoring System (CEMS) 

Descriptio n 

CES' Xact 640 system uses reel-to-ree! (RTR) filter tape sampling and 

nondestructive X-ray fluorescence (XRF) analysis to monitor stack 

metal emissions. An isokinetic sub-sample of stack gas is taken from 

the stilling chamber and drawn through a chemically reactive filter 

tape. Vapor phase metals, including mercury (Hg), are deposited along 

with the particulate matter (PM) on the filter tape. 

The deposit is automatically advanced and analyzed by XRF for 

selected metals as the next sample is being collected. Sampling and 

analysis are performed continuously and simultaneously, except 

during advancement ofthe tape (-20 sec) and during daily-automated 

quality assurance checks. 

In 2007, through its Clean Air Excellence Award, the EPA recognized 

the Xact 640 CEMS as an outstanding achievement in innovative 

clean air technology. The EPA also approved the Xact 640 CEMS as an 

alternative method for periodic Method 29 testing and feed stream 

analysis, as well as for monitoring emissions during plant operation. 

Feature s 

Automatic quality assurance, alarms, and control features 

Gas phase calibration not required 

Identification and measurement of as many as 23 elements 

simultaneously (refer to the periodic table on the Elements 

Supported page ofthis data sheet) 

Internal calibration check incorporated with every sample analyzed 

• Proven RTR/XRF technology demonstrated on the ocean floor, Mars, 

and in thousands of beta attenuation monitors 

Daily, automatic upscale, blank, and flow checks 

Recognized by the EPA as an innovative clean air technology (Clean 

Air Excellence Award, 2007) 

Sampling, analysis, and near-real-time reporting (every 15,30,60 

and 120 minutes) 
Single monitor platform for Hg and HAP metals monitor compliance 

No PM monitor needed to comply with Mercury & Air Toxics (MATS) rule for power plants 

May be used to meet 40 CFR Part 60 and 63 regulations 

Measures total elemental, oxidized, and particulate mercury in pg/dscm 

Multi-metal analysis reduces expenses, time, and resources 

Non-destructive analysis allows for sample archiving 

Sensitive and reliable (ng/m3 to ug/m3 range) 

Application s 

The Xact 640 monitoring system can simultaneously identify and measure multiple metals in flue gas to provide 

data for use in the following applications. 

• Hg CEMS 

• HAP metals CEMS 

Baselining a new process 

Optimization of emission controls 

Permitting 

Regulatory compliance 

Risk management 
i 

VES017637 
§•4 ••••l i 

Xact 640 monitoring systems identify and measure the 63 elements highlighted in the table below. Minimum 

detection limits (MDLs) forthe elements highlighted in blue can be found on the Performance page ofthis 

data sheet.The system is capable of measuring the elements highlighted in dark gray, but MDLs have not been 

developed. 

To place an order or for more information about the Xact 640 continuous emissions monitoring system, 

contact your regional CES representative or email us at info@cooperenvironmental.com 

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VES017638 
VES017639-017668.pdf 
Presented at A&WMA's 

2014 International Conference on 

Thermal Treatment Technologies 

(IT3) & Hazardous Waste 

Combustors 

Specialty Conference 

Baltimore, MD 

October 13-15, 2014 

VES017639 
Review of Monitoring 

Experience with the Xact® 

Multi-Metals CEMS 

Krag A. Petterson, Cooper Environmental Services, LLC 

Paper # 29 
Baltimore 

2014 

Regulation of Metal Emissions From 

Stationary sources 

• HAP Metals Regulated Using Maximum Achievable Control 

Technology (MACT) Approach 

• Several Source Categories Have Regulated Metal Emissions 

• Portland Cement 

• Hazardous Waste Incinerators 

• Coal fired power plants 

• Medical Waste Incinerators 

VES017641 
MACT Rules Approaches to "Measuring" 

Metal Emissions from Sources 

• Particulate Matter (PM) as a Surrogate 

• Several MACT Rules either require or allow the use of P M as a surrogate 

for metals (e.g. EGU Mact, Portland Cement MACT, Boiler MACT) 

• PM may be monitored using 

• PM CEMS (EGU, Portland Cement, Boiler) 

• PM CPMS (EGU, Portland Cement, Boiler) 

• Periodic Method 5 tests (EGU) 

• Period Performance Tests 

• Removal efficiency for metals is determined with Method 29 testing (e.g. 

Hazardous Waste Incinerators, Medical Waste Incinerators) 

VES017642 
EPA May Be Moving in the Direction of 

Requiring Continuous Monitoring for Metals 

• EPA is generally requiring more sophisticated CEMS on sources 

(e.g. Hg CEMS, P M CEMS and HCI CEMS) 

• Original 1996 HWI MACT Included Multi-Metal CEMS 

• 2013 - EPA attempted to Require HWI in greater St. Louis to have 

a M M CEMS 

• Secondary Lead Smelter MACT Proposal in 2011 requested 

comment on the use of Pb CEMS 

VES017643 
Xact CEM S Summary 

• Based on X-ray 

Fluorescence (XRF) 

• Utilizes Reactive Filter 

Tape and Chemical 

Dopant to Capture 

Vapor Phase and 

Particulate Phase 

Metals 

• Able to Measure up to 

20 Metals 

Simultaneously 

VES017644 
Xact CEM S Overall C 

IT3/HWC 

Baltimore 

2014 

Transport Line 

Stilling Chamber/ 

Interface 

Sampling & Flow 

Measurement 

Dopant/Dilution 

X-ray Analysis 

Data Recorder/Display 

Air sample intake 

Ironi slack (200 lpn>» 

I'xlmiiM return 

lo stack 

Dopant ailililion 

(0.1 lpm) 

Isokinetic sample intake 

tor XRJ- analysis i 1 lpm) 

VES017645 
XACT SAMPLING AND ANALYSIS 
Review of Some Stack Sampling 

Experiences with the Xact 

• Method 301 Validation 

• Quality Assurance Data Over 5 years of Operation at a Hazardous 

Waste Incinerator 

• Multi-Metals Measurement At a Coal Fired Facility 

• Mercury Measurement at Coal Fired Power Plants 

Baltimore 

2014 

VES017647 
Method 301 Validation 

• Method 301 is the Procedure by which new stack measurement 

methods are evaluated for accuracy and precision 

• At Eli Lilly's Tippecanoe Laboratories Hazardous Waste Incinerator 

• Xact Evaluated Using a Reference Aerosol of 5 metals (As, Cd, Cr, 

Pb, Hg) at three concentration levels 

• Reference Aerosol Generated using the Quantitative Aerosol 

Generator (QAG) 

• QAG Itself was Method 301 Validated, and P M version of QAG has 

been extensively validated with EPRI support 

• Method 29's Accuracy and Precision isn't sufficient (15% or more) 

VES017648 
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Method 301 Testing Resu Its - Linearity 

IT3/HWC 

Baltimore 

2014 

140 

120 

I 100 

O) 3. 

C 

o 

o 

re 

X 

8 0 

6 0 

4 0 

Z 2 0 

y = 0.952x-1.1 0 

r = 0.99 5 

n =96 0 

QAG Reference Concentration (ug/dscm) 

Passed M301 

Requirements for 

slope, intercept and 

correlation 

coefficient 

All Data Included 

VES017650 
Method 301 Testing Results Precision 

• Required <10% 

Relative 

Standard 

Deviation 

• Easily Met 

M301 Precision 

Requirement 

VES017651 
Method 301 Xact Validation 

t 

IT3/HWC 

Baltimore 

2014 

Goal Test Result Pass? 

192 Pas s 

-Ml % Pas s 

H f J ) 7% Pns s 

I 

Pjss 

ND ND 

If ij S < rp l N P i 1(1 ND 

All mc » »!i»ement resi' ? ^ i i 1 'ded 

N D : No t Define d 

Cooper Environmental Services 13 

VES017652 
Xact Operation at a Hazardous Waste 

Incinerator 

• Xact operated as a compliance instrument for five plus years at Eli 

Lilly Tippecanoe Laboratories 

• Xact incorporated into Eli Lilly's Alternative Monitoring Plan 

• Evonik Degussa purchased facility 

• Evonik successfully used the Xact to do CPT Performance Test in 

2010 in lieu of using Method 29 

• Xact not currently used because of limited use ofthe incinerator 

• Xact meet initial and on-going performance criteria 

VES017653 
Initial and On-going Performance 

Criteria for the Xact 

IT3/HWC 

Baltimore 

2014 

Test 

Category 

Test Test Requirements Test 

Criteria 

Seve n Da y 

Stabilit y 

(Automatic , 

Daily ) 

Zero Drift 

Monitor Zero standard for 7 

consecutive days 

< 20 % 

Seve n Da y 

Stabilit y 

(Automatic , 

Daily ) 

Upscal e Drift 

Monitor upscale standard for 7 

consecutive days 

<15% 

Seve n Da y 

Stabilit y 

(Automatic , 

Daily ) 

Flow Drift 

Monitor Flow drift for 7 

consecutive days 

< 20 % 

Calibratio n 

Chec k 

(Quarterly ) 

X R F Calibration 

Drift 

Chec k a standard for each 

compliance element measured 

< 10% 

Calibratio n 

Chec k 

(Quarterly ) 

Flow Calibration 

Drift 

Compar e sample flow meter to 

NIST Traceable meter 

< 10 % 

Accurac y 

(Annua!! y) 

Linearity RATA 

(Dynamic Spiking) 

3 concentration levels 

Spike into transport line as close to 

probe as possible 

Slope = 0.80 

to 1.20 

R > 0 90 

Intercept < 

20% of 

emission lirnit 

VES017654 
Xact Daily Upscale Results for a Year 

2500 

| 2000 

oi 

f

1

 1500 

g 

£ 1000 

a> 

o 

c 

o 

o 500 

Xact Upscale March 2006 - March 2007 

• Cd 

• Cr 

a Hg 

Pb 

_ ; was. 

0 H 1 1 1 1 

Feb-0 6 May-06 Aug-06 Nov-06 Mar-07 

Date 

VES017655 
Daily Flow QA/QC Check - Percent 

Difference 

10.00 i 

VES017656 
Thin Film Standards 

Used to calibrate the Xact 

IT3/HWC 

Used to perform XRF audits on the 

Xact (Quarterly) 

Recommended by 10 3.3 for 

calibration of XRF instruments 

Gravimetrically NIST traceable 

Baltimore 

2014 

VES017657 
Xact Long Term QA Data -

Quarterly Audits 

Baltimore 

2014 

Audit Year Quarter Audit Date Flow Error 

XRF Audit Error 

Audit Year Quarter Audit Date Flow Error Cr As Cd Hg Pb 

2007 

1 3/1/2007 3.04% 1,46% 2.18% 2.84% 1,75% 2.34% 

2007 

2 5/25/2007 3.13% 3,32% 0.13% 4.23% 2.60% 2.96% 

2007 

3 8/29/2007 0.68% -3.74% 2.18% -4.13% 2.36% 2.76% 2007 

4 12/26/2007 1.42% 6.50% 0.36% 7.36% 4.18% 0.40% 

2008 

1 2/15/2008 NA 0.22% 0.11% 1.20% -0.99% 0.87% 

2008 2 3/17/2008 1.07% 1.93% 0.66% 1.82% 2.16% 2.34% 2008 

3 5/20/2008 0.53% 2.96% 2.61% 3.30% 2.53% 0.68% 2008 

4 10/20/2008 1.37% 1.77% 0.72% 1.48% 0.56% 1.06% 

2009 

1 1/7/2009 2.10% 0.60% 2.94% 1.52% 3.45% 0.46% 

2009 

2 5/6/2009 3.67% 1.49% 4.09% 1.07% 1.78% 0.30% 

2009 

3 7/9/2009 0.84% 2.00% 5.43% 2.78% 0.72% 0.22% 2009 

4 NA NA NA NA NA NA NA 

2010 

1 1/12/2010 NA 1.60% 5.13% 0.45% 0.71% 2.11% 

2010 2 4/25/2010 NA 1.61% 5.92% 1.12% 4.00% 0.96% 2010 

3 7/13/2010 1.68% -3.47% -0.92% -2.82% -2.42% -2.11% 2010 

4 12/10/2010 ~2ji % 

1 WE 

. 1-77% 1.35% 2.16% 1.66% 1.68% 1.22%. 

NA - Data Not Available 

VES017658 
Schematic of Dynamic Spiking for 

Annual RATA 

IT3/HWC 

Baltimore 

2014 

VES017659 
Annual RATA Results 

Year 

Slope 

Cr As Cd Hg Pb Average 

2006 0.83 0.90 0.85 0.82 0.85 0.85 

2006 (Quarterly) 0.91 0.77 0.95 0.92 0.93 0.89 

2007 0.84 0.82 0.88 0.84 0.81 0.84 

2008 0.96 0.71 0.98 0.99 0.97 0.92 

2009 0.96 0.99 0.99 1.10 1.00 1.01 

2010 0.97 1.06 1.11 1.02 1.04 1.04 

Average 0.91 0,87 0.96 0.95 0.93 0.93 

Passed All Required Annual an 

Quarterly Audits During its 

Operatio n 

VES017660 
Testing at a Coal Fired Facility 

• Coal Fired furnace - EPA's Multi-Pollutant Control Research 

Facility 

• 4 million BTU facility operating with ESP and wet scrubber 

• Spike a subsample of effluent with the QAG at three 

concentration levels 

• Compare Xact to QAG 

• Funded under an EPA SBIR Grant 

VES017661 
Xact Accuracy Results on a Coal Fired 

Source 

c 

o 

u 

tJ 

X 

Xact vs. QAG for All Elements 

350.00 

300.00 

250.00 

200.00 

150.00 

100.00 

50.00 

0.00 

y= 1.1041X- 1.3829 

R

2

 =0.9912 

• Cr 

• As 

A Cd 

X H g 

» Pb 

0.00 50,00 100.00 150.00 200.00 250.00 300.00 

QAG Cone (ng/m) 

Excellent Linearity 

Excellent Correlation 

Coal Fuel Source has 

no impact on the 

Xact's measurement 

ability 

VES017662 
Baltimore 

2014 

Mercury Measurement on a Coal Fired 

Power Plant - Study 1 

• 585 Mwatt Coal Fired Power Plant 

• Downstream of Electrostatic Precipitator 

• Measurement of Stack Concentrations of Hg 

• Comparison with Method 30B and an on-site operating Thermo 

Mercury Freedom Unit 

• Xact was installed and operating within 2 days 

VES017663 
Hg Measurement on a Coal Fired Power 

Plant 

E 

u 1/t 

=L 

u 

c 

o 

u 

>. 

3 

u i~ (U 

2 

10 

9 

8 

7 

6 

5 

4 

3 

2 

1 

0 

n • j~j ? P ® C3 D 

1 h'.'rmo QA Period 

• CES Xact 

• Method 30B 

A Thermo CM M 

0 1 2 3 4 5 6 7 8 9 10 11 12 13 

RATA Number 

Cooper Environmental Services 

VES017664 
Mercury Measurement on a Coal Fired 

Power Plant - Study 2 

• 750 M W Source burning Lignite/PRB Blend (60/40 and 80/20) 

Equipped with ESP and Wet FGD Controls 

• Mercury Control Strategy Testing- Brominated Powder Activated 

Carbon and EMO (separately and in combination) 

• Sampling done downstream of a single ESP module 

• Side by side sampling with speciated Method 30B at various times 

each day 

• Xact Measured Hg, Br, As, Se, and Pb - gas phase and very small 

particulate 

• Test length - about 2 weeks 

VES017665 
Mercury Measurement on a Coal Fired 

Power Plant - Study 2 

IT3/HWC 

Baltimore 

2014 

Fual 

Conditions 

Time Hg Controls 

Method 30B 

Hg (^g/dscm) 

Xact Hg 

(ng/dscm) 

Percent 

Difference 

10/3/2012 11:45 Baseline 24.57 22 59 -8.1% 

10/3/2012 14:45 EMO Only 14.85 15.33 I 3.2% 

10/3/2012 16:45 EMO Only 16 30 1583 -2.9% 

10/5/2012 12:15 EMO & PAC 9.25 10.09 9.0% 

60% Lignite 10/5/2012 16:15 EMO & PAC 1152 12.74 10.6% 

40% PRB 10/5/2012 17:45 EMO a PAC 4.05 5.88 45.2% 

10/6/2012 10:45 Baseline 2403 24.55 2.2% 

10/6/2012 13:45 EMO & PAC 11.14 12.34 10,8% 

10/6/2012 15:45 EMO & PAC 5.74 38.8% 

10/6/2012 18:45 EMO & PAC 13.92 15.72 13,0% 

10/9/2012 10:15 Baseline 28.14 25.07 -10.9% 

10/9/2012 12:15 PAC Only 19.01 19.26 1.3% 

10/9/2012 16:15 PAC Only 7.00 7.34 4.9% 

10/10/2012 10:30 Baseline 23 19 23.98 3.4% 

80% Lignite 

20 % PRB 

10/10/2012 13:45 EMO Only 1873 20 22 8.0% 

80% Lignite 

20 % PRB 10/10/2012 16:45 EMO Only 20.10 22.10 10 0% 80% Lignite 20 % PRB 

10/10/2012 19:45 EMO Only 18 60 22.10 18.8% 

10/10/2012 9:00 Baseline 21.57 18.69 -13.4% 

10/11/20129:00 Baseline 24,00 23.53 -1.9% 

10/11/2012 10:45 EMO Only 20.52 18.90 -7.9% 

10/11/2012 11:30 EMO Only 21 38 19.55 -8.6% 

Average Percent Difference Baseline Conditions -4.8% 

Average Percent Difference with Hg Control 7.6% 

Overall Average Percent Difference 6.0% 

VES017666 
What's Next? 

• Demonstration Study with Xact 640 on two Secondary Lead 

Smelters 

• Study required by South Coast Air Quality Management District 

• Instrument Installed on each for approximately four months 

• Arsenic and lead are key HAPs of interest 

• QAG spiking and manual stack tests 

• Installation approximately January of 2015 

VES017667 
QUESTIONS ? 

k ra g p @ coo pe re n v i ro n m e nt a I . co m 

VES017668 
VES017669-017795.pdf