217/782-2113

TITLE V - CLEAN AIR ACT PERMIT PROGRAM (CAAPP) PERMIT

and

TITLE I PERMIT1

PERMITTEE

Caterpillar, Inc.

Attn.: Bruce H. Gilruth

P.O. Box 504

Joliet, Illinois 60434-0504

Application No.: 95120095 I.D. No.: 197809AAC

Applicant’s Designation: Date Received: December 7, 1995

Operation of: Heavy Off-Highway Equipment & Hydraulic Component Manufacturing

Date Issued: July 29, 1999

Source Location: 2200 Channahon Rd., Joliet, Will County

Responsible Official: Robert R. Macier, Business Unit Manager

Expiration Date2

: July 29, 2004

This permit is hereby granted to the above-designated Permittee to operate a 

Heavy Off-Highway Equipment & Hydraulic Component Manufacturing plant, 

pursuant to the above referenced permit application. This permit is subject 

to the conditions contained herein.

If you have any questions concerning this permit, please contact Robert 

Bernoteit at 217/782-2113.

Donald E. Sutton, P.E.

Manager, Permit Section

Division of Air Pollution Control

DES:RWB:psj

cc: Illinois EPA, FOS, Region 1

USEPA

1 This permit may contain terms and conditions which address the applicability, and 

compliance if determined applicable, of Title I of the Clean Air Act and regulations 

promulgated thereunder, including 40 CFR 52.21 - federal Prevention of Significant 

Deterioration (PSD) and 35 IAC Part 203 - Major Stationary Sources Construction and 

Modification. Any such terms and conditions are identified within the permit.

2 Except as provided in condition 8.7 of this permit.
2

TABLE OF CONTENTS

PAGE

1.0 SOURCE IDENTIFICATION 5

1.1 Source

1.2 Owner/Parent Company

1.3 Operator

1.4 General Source Description

2.0 LIST OF ABBREVIATIONS/ACRONYMS USED IN THIS PERMIT 6

3.0 INSIGNIFICANT ACTIVITIES 8

3.1 Identification of Insignificant Activities

3.2 Addition of Insignificant Activities

4.0 SIGNIFICANT EMISSION UNITS AT THIS SOURCE 10

5.0 OVERALL SOURCE CONDITIONS 13

5.1 Source Description

5.2 Applicable Regulations

5.3 Non-Applicability of Regulations of Concern

5.4 Source-Wide Operational and Production Limits and Work 

Practices

5.5 Source-Wide Emission Limitations

5.6 General Recordkeeping Requirements

5.7 General Reporting Requirements

5.8 General Operational Flexibility/ Anticipated Operating 

Scenarios

5.9 General Compliance Procedures

6.0 EMISSION REDUCTION MARKET SYSTEM (ERMS) 18

6.1 Description of ERMS

6.2 Applicability

6.3 Obligation to Hold Allotment Trading Units (ATUs)

6.4 Market Transaction

6.5 Emission Excursion Compensation

6.6 Quantification of Seasonal VOM Emissions

6.7 Annual Account Reporting

6.8 Allotment of ATUs to the Source

6.9 Recordkeeping for ERMS

6.10 Federal Enforceability

6.11 Exclusions from Further Reductions
3

PAGE

7.0 UNIT SPECIFIC CONDITIONS 25

7.1 Units CPS Cab Paint System

Controls CPS Cab Paint System Paint Booth Filters

7.2 Unit MJ5841 Building C Paint Booth

Control MJ5841 Building C Paint Booth Filters

7.3 Units MJ6501 and MJ6503 Building B Paint Booths

Controls MJ6501 and MJ6503 Building B Paint Booth Scrubber 

Systems

7.4 Units HX278-280& HX470 Chrome Plating Systems

Controls HX278-280& HX470 Chrome Plating Scrubber System

7.5 Units MJ8859/61,8886/88,8889/91 Heat Treating Furnaces

7.6 Unit VSRS Vacuum Solvent Recovery System

7.7 Units B1-4 Natural Gas-Fired Boilers (#1 - 4)

7.8 Units AH1-3 Make-Up Air Heaters (#1 - 3)

7.9 Unit TT0420 Gasoline Storage Tank

8.0 GENERAL PERMIT CONDITIONS 96

8.1 Permit Shield

8.2 Applicability of Title IV Requirements 

8.3 Emissions Trading Programs

8.4 Operational Flexibility/Anticipated Operating Scenarios

8.5 Testing Procedures

8.6 Reporting Requirements

8.7 Obligation to Comply with Title I Requirements

9.0 STANDARD PERMIT CONDITIONS 101

9.1 Effect of Permit

9.2 General Obligations of Permittee

9.3 Obligation to Allow Illinois EPA Surveillance

9.4 Obligation to Comply with Other Requirements

9.5 Liability 

9.6 Recordkeeping

9.7 Annual Emissions Report

9.8 Requirement for Compliance Certification

9.9 Certification

9.10 Defense to Enforcement Actions

9.11 Permanent Shutdown

9.12 Reopening And Reissuing Permit For Cause

9.13 Severability Clause

9.14 Permit Expiration and Renewal
4

PAGE

10.0 ATTACHMENTS

10.1 Attachment 1 - Emissions of Particulate Matter from New 

Process Emission Units

1-1

10.2 Attachment 2 - Example Certification by a Responsible 

Official

2-1
5

1.0 SOURCE IDENTIFICATION

1.1 Source

Caterpillar, Inc.

2200 Channahon Rd.

Joliet, Illinois 60436

815/729-6730

I.D. No.: 197809AAC

Standard Industrial Classification: 3531, Construction Machinery 

and Equipment

1.2 Owner/Parent Company

Caterpillar, Inc.

P.O. Box 504

Joliet, Illinois 60434-0504

1.3 Operator

Caterpillar, Inc.

P.O. Box 504

Joliet, Illinois 60434-0504

Bruce H. Gilruth, Environmental Coordinator

815/729-6730

1.4 General Source Description

Caterpillar, Inc. is located at 2200 Channahon Road in Joliet. 

The source primarily manufactures hydraulic components, including 

tanks, pumps, valves and cylinders. Each of these families of 

components have test stands within the manufacturing processes 

which are used to cycle and/or test finished products for their 

conformance to Caterpillar's specifications. The plant also 

manufactures miscellaneous components, including ground engaging 

tools, bearings and caps. In addition, large mining vehicles, 

including excavators, wheel loaders and motorgraders are assembled

on site. The manufacturing processes associated with the 

components and vehicles are machining, grinding, heat treating, 

welding, chrome plating, and painting.
6

2.0 LIST OF ABBREVIATIONS/ACRONYMS USED IN THIS PERMIT

AAGF Atomic Absorption Graphite Furnace

ACMA Alternative Compliance Market Account

Act Environmental Protection Act [415 ILCS 5/1 et seq.]

amp-hr ampere hours

AP-42 Compilation of Air Pollution Emission Factors, Volume 1, 

Stationary Point and Other Sources (and Supplements A

through F), USEPA, Office of Air Quality Planning and 

Standards, Research Triangle Park, NC 27717

ASTM American Society for Testing and Materials

ATU Allotment Trading Unit

BAT Best Available Technology

Btu British thermal unit

CAA Clean Air Act [42 U.S.C. Section 7401 et seq.]

CAAPP Clean Air Act Permit Program

CARB California Air Resources Board

cfm cubic feet per minute

CFR Code of Federal Regulations

CO Carbon Monoxide

CrO3 Chromic Acid or Chromium Anhydride

dscf dry standard cubic foot

dscm dry standard cubic meter

ERMS Emission Reduction Market System

°F degrees Fahrenheit

gal gallon

gr grains

hr hour

HAP Hazardous Air Pollutants

HVLP High Volume Low Pressure

IAC Illinois Administrative Code

ICPCR Ion Chromatography with a Post-column Reactor

I.D. No. Identification Number of Source, assigned by Illinois 

EPA

Illinois EPA Illinois Environmental Protection Agency

kg kilogram

kPa kilopascal

kW kilowatt

l liter

LAER Lowest Achievable Emission Rate

lb pound

m cubic meter 3

MACT Maximum Achievable Control Technology

Mft Million cubic feet 3

Mg Metric Tonnes or Megagrams

mg milligram

min minute

mmBtu Million Btus

mo month
7

MW Megawatts

NESHAP National Emission Standards for Hazardous Air Pollutants

NOx Nitrogen Oxides

NSPS New Source Performance Standards

OSHA Occupational Safety and Health Administration

oz ounce

PBS Packed-Bed Scrubber

PM Particulate Matter

PM Particulate matter with an aerodynamic diameter less 

than or equal to a nominal 10 microns as measured by

applicable test or monitoring methods

10

ppm parts per million

PSD Prevention of Significant Deterioration

psi pound per square inch

scf standard cubic feet

SO2 Sulfur Dioxide

SOP Standard Operating Procedure

T Ton

T1 Title I - identifies Title I conditions that have been 

carried over from an existing construction permit

T1N Title I New – identifies Title I conditions that are 

being established in this permit

T1R Title I Revised – identifies Title I conditions that 

have been carried over from an existing construction 

permit and subsequently revised in this permit

TANKS USEPA Emission Estimating Program for Storage Tanks

USEPA United States Environmental Protection Agency

VOL Volatile Organic Liquid

VOM Volatile Organic Material

VPL Volatile Petroleum Liquid

Wt Weight

yr year
8

3.0 INSIGNIFICANT ACTIVITIES

3.1 Identification of Insignificant Activities

The following activities at the source constitute insignificant 

activities as specified in 35 IAC 201.210:

3.1.1 Activities determined by the Illinois EPA to be 

insignificant activities, pursuant to 35 IAC 201.210(a)(1) 

and 201.211, as follows:

Antifreeze (Ethylene Glycol) Storage Tank

Welding and Cutting Equipment

Tool Room Lead Smelting Furnace

3.1.2 Activities that are insignificant activities based upon 

maximum emissions, pursuant to 35 IAC 201.210(a)(2) or 

(a)(3), as follows:

30,000 Gallon Propylene Storage Tank

3.1.3 Activities that are insignificant activities based upon 

their type or character, pursuant to 35 IAC 201.210(a)(4) 

through (18), as follows:

Direct combustion units designed and used for comfort 

heating purposes and fuel combustion emission units 

as follows: (A) Units with a rated heat input 

capacity of less than 2.5 mmBtu/hr that fire only 

natural gas, propane, or liquefied petroleum gas; (B) 

Units with a rated heat input capacity of less than 

1.0 mmBtu/hr that fire only oil or oil in combination 

with only natural gas, propane, or liquefied 

petroleum gas; and (C) Units with a rated heat input 

capacity of less than 200,000 Btu/hr which never burn 

refuse, or treated or chemically contaminated wood 

[35 IAC 201.210(a)(4)].

Storage tanks of organic liquids with a capacity of 

less than 10,000 gallons and an annual throughput of 

less than 100,000 gallons per year, provided the 

storage tank is not used for the storage of gasoline 

or any material listed as a HAP pursuant to Section 

112(b) of the CAA [35 IAC 201.210(a)(10)].

Storage tanks of any size containing virgin or rerefined distillate oil, hydrocarbon condensate from 

natural gas pipeline or storage systems, lubricating 

oil, or residual fuel oils [35 IAC 201.210(a)(11)].

Gas turbines and stationary reciprocating internal 

combustion engines of between 112 kW and 1,118 kW 

(150 and 1,500 horsepower) power output that are 

emergency or standby units [35 IAC 201.210(a)(16)].

Storage tanks of any size containing exclusively 

soaps, detergents, surfactants, glycerin, waxes, 

vegetable oils, greases, animal fats, sweeteners, 
9

corn syrup, aqueous salt solutions, or aqueous 

caustic solutions, provided an organic solvent has 

not been mixed with such materials [35 IAC 

201.210(a)(17)].

3.1.4 Activities that are considered insignificant activities 

pursuant to 35 IAC 201.210(b).

3.2 Addition of Insignificant Activities

3.2.1 The Permittee is not required to notify the Illinois EPA 

of additional insignificant activities present at the 

source of a type that is identified in Condition 3.1, 

until the renewal application for this permit is 

submitted, pursuant to 35 IAC 201.212(a).

3.2.2 The Permittee must notify the Illinois EPA of any proposed 

addition of a new insignificant activity of a type 

addressed by 35 IAC 201.210(a)and 201.211 other than those 

identified in Condition 3.1, pursuant to Section 

39.5(12)(b) of the Act.

3.2.3 The Permittee is not required to notify the Illinois EPA 

of additional insignificant activities present at the 

source of a type identified in 35 IAC 201.210(b).
10

4.0 SIGNIFICANT EMISSION UNITS AT THIS SOURCE

Emission

Unit Description

Date

Constructed

Emission Control

Equipment

CPS-P Columbus Industries Supra 

1 Collector Paint Spray 

Booth (Cab Paint System 

Prime Paint Booth)

July, 1993 Filters

CPS-TI Columbus Industries Supra 

1 Collector Paint Spray 

Booth (Cab Paint System 

Topcoat (Interior) Paint 

Booth)

July, 1993 Filters

CPS-TE Columbus Industries Supra 

1 Collector Paint Spray 

Booth (Cab Paint System 

Topcoat (Exterior) Paint 

Booth)

July, 1993 Filters

MJ5841 Haden-Schweitzer 30' 

Hydrospin Paint Spray 

Booth (Building C Paint 

Booth)

January, 1974 Filters

MJ6501 Haden-Schweitzer 101' 

Hydrospin Paint Spray 

Booth (Large Building B 

Paint Booth)

April, 1976 Scrubber System

MJ6503 Haden-Schweitzer 82' 

Hydrospin Paint Spray 

Booth (Small Building B 

Paint Booth)

April, 1976 Scrubber System

MJ7450 OMI Chrome Plating Tank 

MJ7450 (HX278 Chrome 

Plate System)

July, 1980 Fume Scrubber #1

MJ7451 OMI Chrome Plating Tank 

MJ7451 (HX278 Chrome 

Plate System)

July, 1980 Fume Scrubber #2

MJ7465 OMI Chrome Plating Tank 

MJ7465 (HX279 Chrome 

Plate System)

July, 1980 Fume Scrubber 

F101-20 (Scrubber 

HX279)

MJ7458 OMI Chrome Plating Tank 

MJ7458 (HX279 Chrome 

Plate System)

July, 1980 Fume Scrubber 

F101-20 (Scrubber 

HX280)

MJ8968 OMI Chrome Plating Tank 

MJ8968 (HX470 Chrome 

Plate System)

February, 1990 Fume Scrubber 

F103-18

MJ8970 OMI Chrome Plating Tank 

MJ8970 (HX470 Chrome 

Plate System)

February, 1990 Fume Scrubber 

F103-14
11

Emission

Unit Description

Date

Constructed

Emission Control

Equipment

MJ8859 Electric Furnace Co. 

Model #4725-4-E Heat 

Treating Furnace with 

North American Gas Burner 

Tubes (MJ8859 Hardening 

Furnace, 3.165 mmBtu/hr)

April, 1989 None

MJ8861 Electric Furnace Co. 

Model #4425-4-5 Heat 

Treating Furnace with 

North American Gas Burner 

Tubes (MJ8861 Temper 

Furnace, 1.175 mmBtu/hr)

April, 1989 None

MJ8886 Electric Furnace Co. 

Model #4725-4-E Heat 

Treating Furnace with 

North American Gas Burner 

Tubes (MJ8886 Hardening 

Furnace, 3.784 mmBtu/hr)

April, 1989 None

MJ8888 Electric Furnace Co. 

Model #4425-4-5 Heat 

Treating Furnace with 

North American Gas Burner 

Tubes (MJ8888 Temper 

Furnace, 2.505 mmBtu/hr)

April, 1989 None

MJ8889 Electric Furnace Co. 

Model #4725-4-E Heat 

Treating Furnace with 

North American Gas Burner 

Tubes (MJ8889 Hardening 

Furnace, 3.784 mmBtu/hr)

April, 1989 None

MJ8891 Electric Furnace Co. 

Model #4425-4-5 Heat 

Treating Furnace with 

North American Gas Burner 

Tubes (MJ8891 Temper 

Furnace, 2.505 mmBtu/hr)

April, 1989 None

VSRS Chemical Management 

Technology Model #CM55V 

Vacuum Solvent Recovery 

System

June, 1994 None

B1 Springfield Boiler 

(Cleaver Brooks) Model 

Max W.P. 200 Natural GasFired Boiler (Boiler #1, 

110 mmBtu/hr)

November, 1972 None
12

Emission

Unit Description

Date

Constructed

Emission Control

Equipment

B2 Springfield Boiler (Coen 

Burners) Model Max W.P. 

200 Natural Gas-Fired 

Boiler (Boiler #2, 112.6 

mmBtu/hr)

November, 1972 None

B3 Springfield Boiler (Coen 

Burners) Model Max W.P. 

200 Natural Gas-Fired 

Boiler (Boiler #3, 175 

mmBtu/hr)

November, 1972 None

B4 Springfield Boiler 

(Cleaver Brooks) Model 

Max W.P. 200 Natural GasFired Boiler (Boiler #4, 

137 mmBtu/hr)

November, 1972 None

AH1 Industrial Commercial 

Equipment BMA 148 Model S 

Make-Up Air Heater (MakeUp Air Heater #1, 4.5 

mmBtu/hr)

May, 1993 None

AH2 Industrial Commercial 

Equipment BMA 148 Model S 

Make-Up Air Heater (MakeUp Air Heater #2, 4.5 

mmBtu/hr)

May, 1993 None

AH3 Industrial Commercial 

Equipment BMA 148 Model S 

Make-Up Air Heater (MakeUp Air Heater #3, 4.5 

mmBtu/hr)

May, 1993 None

AH4 Industrial Commercial 

Equipment BMA 148 Model S 

Make-Up Air Heater (MakeUp Air Heater #4, 4.5 

mmBtu/hr)

May, 1993 None

TT0420 Gasoline Storage Tank 

TT0420 (10,000 gallons)

October, 1986 None

Fugitive 

VOM 

Emissions

Cab Assembly Area and 

Chrome Plating System 

Solvent Usage

- None
13

5.0 OVERALL SOURCE CONDITIONS

5.1 Source Description

5.1.1 This permit is issued based on the source requiring a 

CAAPP permit as a major source of NOx, VOM, and HAP 

emissions.

5.2 Applicable Regulations

5.2.1 Specific emission units at this source are subject to 

particular regulations as set forth in Section 7 (UnitSpecific Conditions) of this permit.

5.2.2 In addition, emission units at this source are subject to 

the following regulations of general applicability:

a. No person shall cause or allow the emission of 

fugitive particulate matter from any process, 

including any material handling or storage activity, 

that is visible by an observer looking generally 

overhead at a point beyond the property line of the 

source unless the wind speed is greater than 40.2 

kilometers per hour (25 miles per hour), pursuant to 

35 IAC 212.301 and 212.314.

Compliance with this requirement is considered to be 

assured by the inherent nature of operations at this 

source, as demonstrated by historical operation.

b. The emission of smoke or other particulate matter 

from any emission unit shall not exceed an opacity of 

greater than 30 percent, except that an opacity of 

greater than 30 percent but less than 60 percent 

shall be allowed for a period or periods aggregating 

8 minutes in any 60 minute period provided that such 

opaque emissions permitted during any 60 minute 

period shall occur from only one such emission unit 

located within a 305 meter (1000 feet) radius from 

the center point of any other such emission unit 

owned or operated by the Permittee, and provided 

further that such opaque emissions permitted from 

each such emission unit shall be limited to 3 times 

in any 24 hour period, pursuant to 35 IAC 212.123 and 

212.124.

5.2.3 Operating Program for Particulate Matter

a. This source shall be operated under the provisions of 

an operating program prepared by the Permittee and 

submitted to the Illinois EPA for its review. Such 

operating program shall be designed to significantly 

reduce fugitive particulate matter emissions [35 IAC 

212.309(a)].

b. The operating program shall be amended from time to 

time by the Permittee so that the operating program 

is current. Such amendments shall be consistent with 
14

the requirements set forth by this Condition and 

shall be submitted to the Illinois EPA [35 IAC 

212.312].

c. All normal traffic pattern roads and parking 

facilities located at this source shall be paved or 

treated with water, oils, or chemical dust 

suppressants. All paved areas shall be cleaned on a 

regular basis. All areas treated with water, oils, 

or chemical dust suppressants shall have the 

treatment applied on a regular basis, as needed, in 

accordance with the operating program [35 IAC 

212.306].

5.2.4 Should this stationary source, as defined in 40 CFR 

Section 68.3, become subject to the Accidental Release 

Prevention regulations in Part 68, then the owner or 

operator shall submit a Risk Management Plant (RMP) by the 

date specified in Section 68.10 and shall certify 

compliance with the requirements of Part 68 as part of the 

annual compliance certification as required by 40 CFR Part 

70 or 71.

5.2.5 The Permittee shall comply with the standards for 

recycling and emissions reduction of ozone depleting 

substances pursuant to 40 CFR Part 82, Subpart F, except 

as provided for motor vehicle air conditioners in Subpart 

B of 40 CFR Part 82:

a. Persons opening appliances for maintenance, service, 

repair, or disposal must comply with the required 

practices pursuant to 40 CFR 82.156.

b. Equipment used during the maintenance, service, 

repair, or disposal of appliances must comply with 

the standards for recycling and recovery equipment 

pursuant to 40 CFR 82.158.

c. Persons performing maintenance, service, repair, or 

disposal of appliances must be certified by an 

approved technician certification program pursuant to 

40 CFR 82.161.
15

5.3 Non-Applicability of Regulations of Concern

None

5.4 Source-Wide Operational and Production Limits and Work Practices

In addition to the source-wide requirements in the Standard Permit

Conditions in Section 9, the Permittee shall fulfill the following

source-wide operational and production limitations and/or work 

practice requirements:

None

5.5 Source-Wide Emission Limitations

5.5.1 Permitted Emissions for Fees

The annual emissions from the source, not considering 

insignificant activities as addressed by Section 3.0 of 

this permit, shall not exceed the following limitations. 

The overall source emissions shall be determined by adding 

emissions from all emission units. Compliance with these 

limits shall be determined on a calendar year basis. 

These limitations (Condition 5.5.1) are set for the 

purpose of establishing fees and are not federally 

enforceable.

Permitted Emissions of Regulated Pollutants

Pollutant Tons/Year

Nitrogen Oxides (NOx) 420.64

Particulate Matter (PM) 14.58

Sulfur Dioxide (SO2) 1.46

Volatile Organic Material (VOM) 323.09

HAP, not included in VOM or PM --

TOTAL 759.77

5.5.2 Emissions of Hazardous Air Pollutants

Source-wide emission limitations for HAPs as listed in 

Section 112(b) of the CAA are not set. This source is 

considered to be a major source of HAPs.

5.5.3 Other Source-Wide Emission Limitations

Other source-wide emission limitations are not set for 

this source pursuant to either the federal rules for 

Prevention of Significant Deterioration (PSD), 40 CFR 

52.21, Illinois EPA rules for Major Stationary Sources 

Construction and Modification, 35 IAC Part 203, or Section 

502(b)(10) of the CAA. However, there may be unit 

specific emission limitations set forth in Section 7 of 

this permit pursuant to these rules.

5.6 General Recordkeeping Requirements

5.6.1 Emission Records
16

The Permittee shall maintain records of the following 

items for the source to demonstrate compliance with 

Condition 5.5.1, pursuant to Section 39.5(7)(b) of the 

Act:

Total annual emissions on a calendar year basis for 

the emission units covered by Section 7 (Unit 

Specific Conditions) of this permit.

5.6.2 Records for Storage Vessels

Each storage vessel with a design capacity less than 

40,000 gallons is subject to no provisions of 35 IAC Part 

218 other than those required by maintaining readily 

accessible records of the dimensions of the storage vessel 

and analysis of the capacity of the storage vessel [35 IAC 

218.129(f)].

5.6.3 Retention and Availability of Records

a. All records and logs required by this permit shall be 

retained for at least five years from the date of 

entry (unless a longer retention period is specified 

by the particular recordkeeping provision herein), 

shall be kept at a location at the source that is 

readily accessible to the Illinois EPA or USEPA, and 

shall be made available for inspection and copying by 

the Illinois EPA or USEPA upon request.

b. The Permittee shall retrieve and print, on paper 

during normal source office hours, any records 

retained in an electronic format (e.g., computer) in 

response to an Illinois EPA or USEPA request for 

records during the course of a source inspection.

5.7 General Reporting Requirements

5.7.1 General Source-Wide Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section of noncompliance with the permit 

requirements as follows, pursuant to Section 

39.5(7)(f)(ii) of the Act. Reports shall describe the 

probable cause of such deviations, and any corrective 

actions or preventive measures taken.

5.7.2 Annual Emissions Report

The annual emissions report required pursuant to Condition 

9.7 shall contain emissions information for the previous 

calendar year.

5.8 General Operational Flexibility/Anticipated Operating Scenarios

N/A

5.9 General Compliance Procedures
17

N/A
18

6.0 EMISSION REDUCTION MARKET SYSTEM (ERMS)

6.1 Description of ERMS

The ERMS is a “cap and trade” market system for major stationary 

sources located in the Chicago ozone nonattainment area. It is 

designed to reduce VOM emissions from stationary sources to 

contribute to reasonable further progress toward attainment, as 

required by Section 182(c) of the CAA.

The ERMS addresses VOM emissions during a seasonal allotment 

period from May 1 through September 30. Once the ERMS begins, 

participating sources must hold “allotment trading units” (ATUs) 

for their actual seasonal VOM emissions. Each year participating 

sources are issued ATUs based on allotments set during initial 

issuance of the sources’ CAAPP permits. These allotments are 

established from historical VOM emissions or “baseline emissions” 

lowered to provide the emissions reductions from stationary 

sources required for reasonable further progress.

By December 31 of each year, the end of the reconciliation period 

following the seasonal allotment period, each source shall have 

sufficient ATUs in its transaction account to cover its actual VOM

emissions during the preceding season. A transaction account’s 

balance as of December 31 will include any valid ATU transfer 

agreements entered into as of December 31 of the given year, 

provided such agreements are promptly submitted to the Illinois 

EPA for entry into the transaction account database. The Illinois

EPA will then retire ATUs in sources’ transaction accounts in 

amounts equivalent to their seasonal emissions. When a source 

does not appear to have sufficient ATUs in its transaction 

account, the Illinois EPA will issue a notice to the source to 

begin the process for Emissions Excursion Compensation.

In addition to receiving ATUs pursuant to their allotments, 

participating sources may also obtain ATUs from the market, 

including ATUs bought from other participating sources and general

participants in the ERMS that hold ATUs (35 IAC 205.630) and ATUs 

issued by the Illinois EPA as a consequence of VOM emissions 

reductions from an Emissions Reduction Generator or an Intersector

Transaction (35 IAC 205.500 and 35 IAC 205.510). During the 

reconciliation period, sources may also buy ATUs from a secondary 

reserve of ATUs managed by the Illinois EPA, the “Alternative 

Compliance Market Account” (ACMA) (35 IAC 205.710). Sources may 

also transfer or sell the ATUs that they hold to other sources or 

participants (35 IAC 205.630).

6.2 Applicability

This source is considered a “participating source” for purposes of

the ERMS, 35 IAC Part 205.

6.3 Obligation to Hold Allotment Trading Units (ATUs)

a. Pursuant to 35 IAC 205.150(c)(1) and 35 IAC 205.720, and 

as further addressed by Condition 6.8, as of December 31 

of each year, this source shall hold ATUs in its account 

in an amount not less than the ATU equivalent of its VOM 
19

emissions during the preceding seasonal allotment period 

(May 1 - September 30), not including VOM emissions from 

the following, or the source shall be subject to 

“emissions excursion compensation,” as described in 

Condition 6.5.

i. VOM emissions from insignificant emission units and 

activities as identified in Section 3 of this permit, 

in accordance with 35 IAC 205.220;

ii. Excess VOM emissions associated with startup, 

malfunction, or breakdown of an emission unit as 

authorized in Section 7.0 of this permit, in 

accordance with 35 IAC 205.225;

iii. Excess VOM emissions to the extent allowed by a 

Variance, Consent Order, or Compliance Schedule, in 

accordance with 35 IAC 205.320(e)(3);

iv. Excess VOM emissions that are a consequence of an 

emergency as approved by the Illinois EPA, pursuant 

to 35 IAC 205.750; and

v. VOM emissions from certain new and modified emission 

units as addressed by Condition 6.8(b), if 

applicable, in accordance with 35 IAC 205.320(f).

b. Notwithstanding the above condition, in accordance with 35 

IAC 205.150(c)(2), if a source commences operation of a 

major modification, pursuant to 35 IAC Part 203, the 

source shall hold ATUs in an amount not less than 1.3 

times its seasonal VOM emissions attributable to such 

major modification during the seasonal allotment period, 

determined in accordance with the construction permit for 

such major modification or applicable provisions in 

Section 7.0 of this permit.

6.4 Market Transaction

a. The source shall apply to the Illinois EPA for and obtain 

authorization for a Transaction Account prior to 

conducting any market transactions, as specified at 35 IAC 

205.610(a).

b. The Permittee shall promptly submit to the Illinois EPA 

any revisions to the information submitted for its 

Transaction Account, pursuant to 35 IAC 205.610(b).

c. The source shall have at least one account officer 

designated for its Transaction Account, pursuant to 35 IAC 

205.620(a).

d. Any transfer of ATUs to or from the source from another 

source or general participant must be authorized by a 

qualified Account Officer designated by the source and 

approved by the Illinois EPA, in accordance with 35 IAC 

205.620, and the transfer must be submitted to the 
20

Illinois EPA for entry into the Transaction Account 

database.

6.5 Emission Excursion Compensation

Pursuant to 35 IAC 205.720, if the source fails to hold ATUs in 

accordance with Condition 6.3, it shall provide emissions 

excursion compensation in accordance with the following:

a. Upon receipt of an Excursion Compensation Notice issued by 

the Illinois EPA, the source shall purchase ATUs from the 

ACMA in the amount specified by the notice, as follows:

i. The purchase of ATUs shall be in an amount equivalent 

to 1.2 times the emissions excursion; or

ii. If the source had an emissions excursion for the 

seasonal allotment period immediately before the 

period for the present emissions excursion, the 

source shall purchase ATUs in an amount equivalent to 

1.5 times the emissions excursion.

b. If requested in accordance with paragraph (c) below or in 

the event that the ACMA balance is not adequate to cover 

the total emissions excursion amount, the Illinois EPA 

will deduct ATUs equivalent to the specified amount or any 

remaining portion thereof from the ATUs to be issued to 

the source for the next seasonal allotment period.

c. Pursuant to 35 IAC 205.720(c), within 15 days after 

receipt of an Excursion Compensation Notice, the owner or 

operator may request that ATUs equivalent to the amount 

specified be deducted from the source’s next seasonal 

allotment by the Illinois EPA, rather than purchased from 

the ACMA.
21

6.6 Quantification of Seasonal VOM Emissions

a. The methods and procedures specified in Sections 5 and 7 

of this permit for determining VOM emissions and 

compliance with VOM emission limitations shall be used for 

determining seasonal VOM emissions for purposes of the 

ERMS, with the following exceptions [35 IAC 205.315(b)]:

No exceptions

b. The Permittee shall report emergency conditions at the 

source to the Illinois EPA, in accordance with 35 IAC 

205.750, if the Permittee intends to deduct VOM emissions 

in excess of the technology-based emission rates normally 

achieved that are attributable to the emergency from the 

source’s seasonal VOM emissions for purposes of the ERMS. 

These reports shall include the information specified by 

35 IAC 205.750(a), and shall be submitted in accordance 

with the following:

i. An initial emergency conditions report within two 

days after the time when such excess emissions 

occurred due to the emergency; and

ii. A final emergency conditions report, if needed to 

supplement the initial report, within 10 days after 

the conclusion of the emergency.

6.7 Annual Account Reporting

a. For each year in which the source is operational, the 

Permittee shall submit, as a component of its Annual 

Emissions Report, seasonal VOM emissions information to 

the Illinois EPA for the seasonal allotment period. This 

report shall include the following information [35 IAC 

205.300]:

i. Actual seasonal emissions of VOM from the source;

ii. A description of the methods and practices used to 

determine VOM emissions, as required by this permit, 

including any supporting documentation and 

calculations;

iii. A detailed description of any monitoring methods that 

differ from the methods specified in this permit, as 

provided in 35 IAC 205.337;

iv. If a source has experienced an emergency, as provided 

in 35 IAC 205.750, the report shall reference the 

associated emergency conditions report that has been 

approved by the Illinois EPA;

v. If a source’s baseline emissions have been adjusted 

due to a Variance, Consent Order, or CAAPP permit 

Compliance Schedule, as provided for in 35 IAC 

205.320(e)(3), the report shall provide documentation 

quantifying the excess VOM emissions during the 
22

season that were allowed by the Variance, Consent 

Order, or Compliance Schedule, in accordance with 35 

IAC 205.320(e)(3); and

vi. If a source is operating a new or modified emission 

unit for which three years of operational data is not 

yet available, as specified in 35 IAC 205.320(f), the 

report shall specify seasonal VOM emissions 

attributable to the new emission unit or the 

modification of the emission unit.

b. This report shall be submitted by November 30 of each 

year, for the preceding seasonal allotment period.

6.8 Allotment of ATUs to the Source

a. i. The allotment of ATUs to this source is 325 ATUs per 

seasonal allotment period.

ii. This allotment of ATUs reflects the Illinois EPA's 

determination that the source's baseline emissions 

were 36.8295 tons per season.

iii. The source's allotment reflects 88% of the baseline 

emissions (12% reduction), except for the VOM 

emissions from specific emission units excluded from 

such reduction, pursuant to 35 IAC 205.405, including 

units complying with MACT or using BAT, as identified 

in Condition 6.11 of this permit.

iv. ATUs will be issued to the source's Transaction 

Account by the Illinois EPA annually. These ATUs 

will be valid for the seasonal allotment period 

following issuance and, if not retired in this 

season, the next seasonal allotment period.

v. Condition 6.3(a) becomes effective beginning in the 

seasonal allotment period following the initial 

issuance of ATUs by the Illinois EPA into the 

Transaction Account for the source.
23

b. Contingent Allotments for New or Modified Emission Units

Not applicable.

c. Notwithstanding the above, part or all of the above ATUs 

will not be issued to the source in circumstances as set 

forth in 35 IAC Part 205, including:

i. Transfer of ATUs by the source to another participant 

or the ACMA, in accordance with 35 IAC 205.630;

ii. Deduction of ATUs as a consequence of emissions 

excursion compensation, in accordance with 35 IAC 

205.720; and

iii. Transfer of ATUs to the ACMA, as a consequence of 

shutdown of the source, in accordance with 35 IAC 

205.410.

6.9 Recordkeeping for ERMS

The Permittee shall maintain copies of the following documents as 

its Compliance Master File for purposes of the ERMS [35 IAC 

205.700(a)]:

a. Seasonal component of the Annual Emissions Report;

b. Information on actual VOM emissions, as specified in 

detail in Sections 5 and 7 of this permit and Condition 

6.6(a); and

c. Any transfer agreements for the purchase or sale of ATUs 

and other documentation associated with the transfer of 

ATUs.

6.10 Federal Enforceability

Section 6 becomes federally enforceable upon approval of the ERMS 

by USEPA as part of Illinois' State Implementation Plan.

6.11 Exclusions from Further Reductions

a. VOM emissions from the following emission units shall be 

excluded from the VOM emissions reductions requirements 

specified in 35 IAC 205.400(c) and (e) as long as such 

emission units continue to satisfy the following [35 IAC 

205.405(a)]:

i. Emission units that comply with any NESHAP or MACT 

standard promulgated pursuant to the CAA;

ii. Direct combustion emission units designed and used 

for comfort heating purposes, fuel combustion 

emission units, and internal combustion engines; and

iii. An emission unit for which a LAER demonstration has 

been approved by the Illinois EPA on or after 

November 15, 1990.
24

The source has demonstrated in its ERMS application and 

the Illinois EPA has determined that the following 

emission units qualify for exclusion from further 

reductions because they meet the criteria as indicated 

above [35 IAC 205.405(a) and (c)]:

Boiler #1

Boiler #2

Boiler #3

Boiler #4

b. VOM emissions from emission units using BAT for 

controlling VOM emissions shall not be subject to the VOM 

emissions reductions requirement specified in 35 IAC 

205.400(c) or (e) as long as such emission unit continues 

to use such BAT [35 IAC 205.405(b)].

The source has demonstrated in its ERMS application and 

the Illinois EPA has determined that the following 

emission units qualify for exclusion from further 

reductions because these emission units use BAT for 

controlling VOM emissions as indicated above [35 IAC 

205.405(b) and (c)]:

None
25

7.0 UNIT SPECIFIC CONDITIONS

7.1 Units CPS Cab Paint System

Controls CPS Cab Paint System Paint Booth Filters

7.1.1 Description

The Cab Paint System is used on both components and 

finished product. The part to be painted is conveyed 

through a series of pretreatment steps, then sent to a 

paint booth. In the booth, the part is painted using a 

two-component urethane primer and topcoat. In the Cab 

Paint System, the coating is force cured using two natural 

gas-fired ovens operating at 185o

F. Each paint booth has 

an attached filter system to remove the paint particulates 

from the exhaust air, prior to outside ventilation. All 

VOM used in the process is emitted. Solvents used for 

cleanup is reclaimed with approximately 50% efficiency and 

reused after distillation to remove contaminants.

7.1.2 List of Emission Units and Pollution Control Equipment

Emission

Unit Description

Emission 

Control

Equipment

CPS-P Columbus Industries Supra 1 

Collector Paint Spray Booth (Cab 

Paint System Prime Paint Booth)

Filters

CPS-TI Columbus Industries Supra 1 

Collector Paint Spray Booth (Cab 

Paint System Topcoat (Interior) 

Paint Booth)

Filters

CPS-TE Columbus Industries Supra 1 

Collector Paint Spray Booth (Cab 

Paint System Topcoat (Exterior) 

Paint Booth)

Filters

7.1.3 Applicability Provisions and Applicable Regulations

a. The Cab Paint System Prime Paint Booth, the Cab Paint 

System Topcoat (Interior) Paint Booth, and the Cab 

Paint System Topcoat (Exterior) Paint Booth are 

“affected coating lines” for the purpose of these 

unit-specific conditions.

b. Each affected coating line is subject to the emission 

limits identified in Condition 5.2.2.

c. The affected coating lines are subject to 35 IAC 

212.321(a), which provides that:

i. No person shall cause or allow the emission of 

particulate matter into the atmosphere in any 

one hour period from any new process emission 

unit, either alone or in combination with the 

emission of particulate matter from all other 

similar process emission units for which 

construction or modification commenced on or 
26

after April 14, 1972, at a source or premises, 

exceeds the allowable emission rates specified 

in subsection (c) of 35 IAC 212.321 (see also 

Attachment 1) [35 IAC 212.321(a)].

ii. Because the expected process weight rate for 

each affected coating lines is less than 100 

pounds per hour, the allowable PM emission 

rate for each affected coating lines set by 35 

IAC 212.321 is 0.55 pounds per hour.

d. No person shall cause or allow the emission of sulfur 

dioxide into the atmosphere from any process emission 

unit to exceed 2000 ppm, [35 IAC 214.301].

e. Pursuant to 35 IAC 218.204, no owner or operator of a 

coating line shall apply at any time any coating in 

which the VOM content exceeds the following emission 

limitations for the specified coating. The following 

emission limitations are expressed in units of VOM 

per volume of coating (minus water and any compounds 

which are specifically exempted from the definition 

of VOM) as applied at each coating applicator, except 

where noted. Compounds which are specifically 

exempted from the definition of VOM should be treated 

as water for the purpose of calculating the "less 

water" part of the coating composition. The emission 

limitations are as follows:

i. Heavy Off-Highway Vehicle Products 

Coating/Extreme Performance Prime Coat [35 IAC 

218.204(k)(1)]:

kg/l lb/gal

0.42 3.5

ii. Heavy Off-Highway Vehicle Products 

Coating/Extreme Performance Top-Coat (Air 

Dried) [35 IAC 218.204(k)(2)]:

kg/l lb/gal

0.42 3.5
27

7.1.4 Non-Applicability of Regulations of Concern

a. The curing and drying ovens associated with the 

affected coating lines are not subject to 35 IAC 

216.121, Emissions of Carbon Monoxide from Fuel 

Combustion Emission Units, because the actual heat 

input is less than 2.9 MW (10 mmBtu/hr) and the 

curing and drying ovens are not by definition a fuel 

combustion emission unit.

b. The curing and drying ovens associated with the 

affected coating lines are not subject to 35 IAC 

217.121, emissions of nitrogen oxides from new fuel 

combustion emission sources, because the actual heat 

input is less than 73.2 MW (250 mmBtu/hr) and the 

curing and drying ovens are not by definition a fuel 

combustion emission unit.

c. The affected coating line is not subject to 35 IAC 

212.324, Process Emission Units In Certain Areas, 

because the source is not located in a non-attainment 

area for PM10, as identified in 35 IAC 212.324(a)(1).

d. The affected coating lines are not subject to are not 

subject to 35 IAC 218.204(k)(4) Heavy Off-Highway 

Vehicle Product All Other Coatings, and 35 IAC 

218.204(j)(2)(B), Miscellaneous Metal Parts and 

Products Extreme Performace Baked Coating, pursuant 

to 35 IAC 211.670 as the coatings are not cured or 

dried in an oven where the oven air temperature 

exceeds 90o

C (194o

F) or is cured in any manner that 

does not otherwise fit into the definition of "air 

dried coatings," as defined in 35 IAC 211.330.

e. No owner or operator of a coating line subject to the 

limitations of 35 IAC 218.204 is required to meet the 

limitations of 35 IAC 218.301 or 218.302, Use of 

Organic Material, after the date by which the coating 

line is required to meet 35 IAC 218.204 [35 IAC 

218.209].

7.1.5 Operational and Production Limits and Work Practices

a. The Permittee shall follow good operating practices 

for the paint booth filters, including periodic 

inspection, routine maintenance and prompt repair of 

defects.

b. The curing and drying ovens associated with the 

affected coating lines shall only be operated with 

natural gas as the fuel.

7.1.6 Emission Limitations

In addition to Condition 5.2.2 and the source wide 

emission limitations in Condition 5.5, the affected 

coating lines are subject to the following:
28

a. Emissions of volatile organic material (VOM) and 

operation of the primer spray booth, top coat 

(interior) spray paint booth, and top coat (exterior) 

spray paint booth combined shall not exceed the 

following limits:

VOM Content Coating Usage VOM Emissions

Coating (lb/gal) gal/mo gal/yr ton/mo

Primer

ton/yr

3.5 722 8,664 1.26 15.2

Topcoat 3.5 873 10,476 1.53 18.3

Total 33.5

i. These limits are based on the maximum monthly 

and annual coating usage, the allowable VOM 

content pursuant to 35 IAC 218.204(k)(1) and 

218.204(k)(2), and the maximum hours of 

operation (6,000 hr/yr).

ii. The above limitations were established in 

Construction Permit 97060025, pursuant to 35 

IAC Part 203. These limits ensure that the 

construction and/or modification addressed in 

the aforementioned Construction Permit does 

not constitute a new major source or major 

modification pursuant to Title I of the CAA, 

specifically 35 IAC Part 203.[T1]

b. i. Emissions of particulate matter (PM) from the 

primer spray paint booth controlled by the 

filter system shall not exceed 0.55 lb/hr and 

1.7 ton/yr. These limits are based on the 

allowable emission limit pursuant to 35 IAC 

212.321 at the maximum hours of operation 

(6,000 hr/yr).

ii. Emissions of particulate matter (PM) from the 

top coat (interior) spray paint booth 

controlled by the filter system and the top 

coat (exterior) spray paint booth controlled 

by the filter system shall not exceed 0.55 

lb/hr and 1.7 ton/yr, combined. These limits 

are based on the allowable emission limit 

pursuant to 35 IAC 212.321 at the maximum 

process weight rate (18 lb/hr) and the maximum 

hours of operation (6,000 hr/yr).

iii. The above limitations were established in 

Construction Permit 97060025, pursuant to 40 

CFR 52.21, Prevention of Significant 

Deterioration (PSD). These limits ensure that 

the construction and/or modification addressed 

in the aforementioned Construction Permit does 

not constitute a new major source or major 

modification pursuant to Title I of the CAA, 

specifically the federal rules for Prevention 

of Significant Deterioration (PSD), 40 CFR 

52.21.[T1]
29

c. Emissions of nitrogen oxides (NOx) and carbon 

monoxide (CO) and operation of the two ovens shall 

not exceed the following limits:

Operating E M I S S I O N S

Hours NOx CO

Oven (hr/yr) lb/hr ton/yr lb/hr

Topcoat (Interior) 

Flash Dry

ton/yr

7,200 0.243 0.88 0.10 0.44

Topcoat (Exterior)

Flash Dry 7,200 0.243 0.88 0.10 0.44

Totals 1.76 0.88

i. These limits are based on standard emission 

factors and the fuel(s), the maximum firing 

rate(s), and the maximum hours of operation. 

The annual limit is the product of the hourly 

limit and the maximum hours of operation.

ii. The above limitations were established in 

Construction Permit 97060025, pursuant to 40 

CFR 52.21, Prevention of Significant 

Deterioration (PSD). These limits ensure that 

the construction and/or modification addressed 

in the aforementioned Construction Permit does 

not constitute a new major source or major 

modification pursuant to Title I of the CAA, 

specifically the federal rules for Prevention 

of Significant Deterioration (PSD), 40 CFR 

52.21.[T1]

d. Compliance with annual limits shall be determined on 

a monthly basis from the sum of the data for the 

current month plus the preceding 11 months (running 

12 month total).

7.1.7 Testing Requirements

a. The VOM content of each coating shall be determined 

by the applicable test methods and procedures 

specified in 35 IAC 218.105 to establish the records 

required under Condition 7.1.9(b) (see also 35 IAC 

218.211) [35 IAC 218.211(a)].

b. Upon reasonable request by the Illinois EPA, pursuant 

to Section 39.5(7)(b) of the Act, the VOM content of 

specific coatings and cleaning solvents used on the 

affected coating line shall be determined as follows:

i. The VOM content of representative coatings "as 

applied" on the affected coating line shall be 

determined according to USEPA Reference 

Methods 24 and 24A of 40 CFR 60 Appendix A and 

the procedures of 35 IAC 218.105(a).

ii. This testing may be performed by the supplier 

of a material provided that the supplier 

provides appropriate documentation for such 
30

testing to the Permittee and the Permittee's 

records pursuant to Condition 7.1.9(b) 

directly reflect the application of such 

material and separately account for any 

additions of solvent.

7.1.8 Monitoring Requirements

None

7.1.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the 

Permittee shall maintain records of the following items 

for each affected coating line to demonstrate compliance 

with Conditions 5.5.1, 7.1.3, and 7.1.6, pursuant to 

Section 39.5(7)(b) of the Act:

a. Records of the testing of VOM content of coatings and 

cleaning solvents pursuant to Condition 7.1.7, which 

include the following [Section 39.5(7)(e) of the 

Act]:

i. Identification of material tested;

ii. Results of analysis;

iii. Documentation of analysis methodology; and

iv. Person performing analysis.

b. Pursuant to 35 IAC 218.211(c)(2), the Permittee shall 

collect and record all of the following information 

each day for the affected coating line and maintain 

the information at the source for a period of three 

years:

i. The name and identification number of each 

coating as applied on the affected coating 

lines; and

ii. The weight of VOM per volume of each coating 

(minus water and any compounds which are 

specifically exempted from the definition of 

VOM) as applied each day on the affected 

coating lines.

c. Records addressing use of good operating practices 

for the paint booth filters:

i. Records for periodic inspection of the paint 

booth filters with date, individual performing 

the inspection, and nature of inspection; and

ii. Records for prompt repair of defects, with 

identification and description of defect, 

effect on emissions, date identified, date 

repaired, and nature of repair.
31

d. Records of the coating usage for the affected coating 

lines, gal/mo and gal/yr;

e. The VOM content of coatings, % by Wt;

f. Density of coatings, lb/gal;

g. Records of the solvent usage for the affected coating 

lines, gal/mo and gal/yr;

h. Density of solvent, lb/gal;

i. The natural gas usage of the curing and drying ovens 

associated with the affected coating lines, Mft3

/mo

and Mft3

/yr;

j. The monthly and aggregate annual PM and VOM emissions 

from the affected coating lines based on the material 

usage, with supporting calculations; and

k. The monthly and aggregate annual CO, NOx, PM, SO2, 

and VOM emissions from the curing and drying ovens 

associated with the affected coating lines based on 

the fuel usage and standard emission factors, with 

supporting calculations.

7.1.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section of noncompliance of an affected coating 

line with the permit requirements as follows, pursuant to 

Section 39.5(7)(f)(ii) of the Act. Reports shall describe 

the probable cause of such deviations, and any corrective 

actions or preventive measures taken:

a. Pursuant to 35 IAC 218.211(c)(3)(A), the Permittee 

shall notify the Illinois EPA of any record showing 

violation of Condition 7.1.3(e) (see also 35 IAC 

218.204) within 30 days following the occurrence of 

the violation.

b. Continued operation of the affected coating line with 

a defect in the paint booth filters that may result 

in emissions of particulate matter in excess of 

limits in Conditions 7.1.3(c) and/or 7.1.6(b) within 

30 days of such an occurrence.

c. Emissions of VOM in excess of the limits in Condition 

7.1.6(a) within 30 days of such an occurrence.

d. Emissions of CO and/or NOx in excess of the limits in 

Condition 7.1.6(c) within 30 days of such an 

occurrence.

7.1.11 Operational Flexibility/Anticipated Operating Scenarios

N/A
32

7.1.12 Compliance Procedures

Compliance with the emission limits shall be based on the 

recordkeeping requirements in Condition 7.1.9 and the 

emission factors and formulas listed below:

a. Compliance with Condition 7.1.3(c) is assumed to be 

achieved by proper operation of the paint booth 

filters, as addressed by Condition 7.1.5(a).

b. Compliance with Condition 7.1.3(d) is assumed by the 

work-practices inherent in operation of natural gasfired curing and drying ovens.

c. To determine compliance with Conditions 5.5.1 and 

7.1.6, PM and VOM emissions from the affected coating 

lines shall be calculated based on the following:

i. Particulate Matter Emissions:

PM (lb) = (Coating Usage, gal) x (Coating 

Density, lb/gal) x (Wt % Solids) x [1 -

(Transfer Efficiency* (%)/100)] x [1 -

(Paint Booth Filter Efficiency* (%)/100)]

*

As specified by manufacturer or vendor of the 

spray booths and paint booth filters

ii. Volatile Organic Material Emissions:

VOM (lb) = (Coating Usage, gal) x (Coating 

Density, lb/gal) x (VOM Content of 

Coating, % by Wt.) + (Cleaning Solvent 

Usage, gal) x (Solvent Density, lb/gal)

d. To determine compliance with Conditions 5.5.1 and 

7.1.6(c), fuel combustion emissions from the curing 

and drying ovens associated with the affected coating 

line shall be calculated based on the following 

emission factors:

Emission Factor

Pollutant (lb/Mft3

CO

)

84

NOx 100

PM 7.6

SO2 0.6

VOM 5.5

These are the emission factors for uncontrolled 

natural gas combustion in small boilers (< 100 

mmBtu/hr), Tables 1.4-1 and 1.4-2, AP-42, Volume I, 

Fifth Edition, March, 1998.

Curing and Drying Oven Emissions (lb) = (Natural Gas 

Consumed, Mft3

) x (The Appropriate Emission 

Factor, lb/Mft3

)
33
34

7.2 Unit MJ5841 Building C Paint Booth

Control MJ5841 Building C Paint Booth Filters

7.2.1 Description

The Building C Paint Booth is used on both components and 

finished products for hydraulic pumps, motors, valves and 

hydrostatic transmissions. The part to be painted is 

conveyed through a series of pretreatment steps, then sent 

to a paint booth. In the booth, the part is painted using 

a two-component urethane primer and topcoat. The parts 

are painted using hand held high volume low pressure 

(HVLP) paint spray guns. In the Building C Paint Booth 

the paint is air dried and cured. The paint booth has an 

attached filter system to remove the paint particulates 

from the exhaust air, prior to outside ventilation. All 

VOM used in the process is emitted. Solvents used for 

cleanup is reclaimed with approximately 50% efficiency and 

reused after distillation to remove contaminants.

7.2.2 List of Emission Units and Pollution Control Equipment

Emission 

Unit Description

Emission 

Control 

Equipment

MJ5841 Haden-Schweitzer 30' Hydrospin 

Paint Spray Booth (Building C 

Paint Booth)

Filters

7.2.3 Applicability Provisions and Applicable Regulations

a. The Building C Paint Booth is an “affected coating 

line” for the purpose of these unit-specific 

conditions.

b. The affected coating line is subject to the emission 

limits identified in Condition 5.2.2.

c. The affected coating line is subject to 35 IAC 

212.321(a), which provides that:

i. No person shall cause or allow the emission of 

particulate matter into the atmosphere in any 

one hour period from any new process emission 

unit, either alone or in combination with the 

emission of particulate matter from all other 

similar process emission units for which 

construction or modification commenced on or 

after April 14, 1972, at a source or premises, 

exceeds the allowable emission rates specified 

in subsection (c) of 35 IAC 212.321 (see also 

Attachment 1) [35 IAC 212.321(a)].

ii. Because the expected process weight rate for 

the affected coating line is less than 100 

pounds per hour, the allowable PM emission 

rate for the affected coating line set by 35 

IAC 212.321 is 0.55 pounds per hour.
35

d. Pursuant to 35 IAC 218.204, no owner or operator of a 

coating line shall apply at any time any coating in 

which the VOM content exceeds the following emission 

limitations for the specified coating. The following 

emission limitations are expressed in units of VOM 

per volume of coating (minus water and any compounds 

which are specifically exempted from the definition 

of VOM) as applied at each coating applicator, except 

where noted. Compounds which are specifically 

exempted from the definition of VOM should be treated 

as water for the purpose of calculating the "less 

water" part of the coating composition. The emission 

limitations are as follows:

i. Heavy Off-Highway Vehicle Products 

Coating/Extreme Performance Prime Coat [35 IAC 

218.204(k)(1)]:

kg/l lb/gal

0.42 3.5

ii. Heavy Off-Highway Vehicle Products 

Coating/Extreme Performance Top-Coat (Air 

Dried) [35 IAC 218.204(k)(2)]:

kg/l lb/gal

0.42 3.5

7.2.4 Non-Applicability of Regulations of Concern

a. The affected coating line is not subject to 35 IAC 

212.324, Process Emission Units In Certain Areas, 

because the source is not located in a non-attainment 

area for PM10, as identified in 35 IAC 212.324(a)(1).

b. No owner or operator of a coating line subject to the 

limitations of 35 IAC 218.204 is required to meet the 

limitations of 35 IAC 218.301 or 218.302, Use of 

Organic Material, after the date by which the coating 

line is required to meet 35 IAC 218.204 [35 IAC 

218.209].

7.2.5 Operational and Production Limits and Work Practices

The Permittee shall follow good operating practices for 

the paint booth filters, including periodic inspection, 

routine maintenance and prompt repair of defects.

7.2.6 Emission Limitations

There are no specific emission limitations for this unit, 

however, there are source wide emission limitations in 

Condition 5.5 that include this unit.

7.2.7 Testing Requirements
36

a. The VOM content of each coating shall be determined 

by the applicable test methods and procedures 

specified in 35 IAC 218.105 to establish the records 

required under Condition 7.2.9(b) (see also 35 IAC 

218.211) [35 IAC 218.211(a)].

b. Upon reasonable request by the Illinois EPA, pursuant 

to Section 39.5(7)(b) of the Act, the VOM content of 

specific coatings and cleaning solvents used on the 

affected coating line shall be determined as follows:

i. The VOM content of representative coatings "as 

applied" on the affected coating line shall be 

determined according to USEPA Reference 

Methods 24 and 24A of 40 CFR 60 Appendix A and 

the procedures of 35 IAC 218.105(a).

ii. This testing may be performed by the supplier 

of a material provided that the supplier 

provides appropriate documentation for such 

testing to the Permittee and the Permittee's 

records pursuant to Condition 7.2.9(b) 

directly reflect the application of such 

material and separately account for any 

additions of solvent.

7.2.8 Monitoring Requirements

None

7.2.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the 

Permittee shall maintain records of the following items 

for the affected coating line to demonstrate compliance 

with Conditions 5.5.1 and 7.2.3, pursuant to Section 

39.5(7)(b) of the Act:

a. Records of the testing of VOM content of coatings and 

cleaning solvents pursuant to Condition 7.2.7, which 

include the following [Section 39.5(7)(e) of the 

Act]:

i. Identification of material tested;

ii. Results of analysis;

iii. Documentation of analysis methodology; and

iv. Person performing analysis.

b. Pursuant to 35 IAC 218.211(c)(2), the Permittee shall 

collect and record all of the following information 

each day for the affected coating line and maintain 

the information at the source for a period of three 

years:
37

i. The name and identification number of each 

coating as applied on the affected coating 

line; and

ii. The weight of VOM per volume of each coating 

(minus water and any compounds which are 

specifically exempted from the definition of 

VOM) as applied each day on the affected 

coating line.

c. Records addressing use of good operating practices 

for the paint booth filters:

i. Records for periodic inspection of the paint 

booth filters with date, individual performing 

the inspection, and nature of inspection; and

ii. Records for prompt repair of defects, with 

identification and description of defect, 

effect on emissions, date identified, date 

repaired, and nature of repair.

d. Records of the coating usage for the affected coating 

line, gal/mo and gal/yr;

e. The VOM content of coatings, % by Wt;

f. Density of coatings, lb/gal;

g. Records of the solvent usage for the affected coating 

line, gal/mo and gal/yr;

h. Density of solvent, lb/gal; and

i. The aggregate monthly and annual PM and VOM emissions 

from the affected coating line based on the material 

usage, with supporting calculations.

7.2.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section of noncompliance of the affected 

coating line with the permit requirements as follows, 

pursuant to Section 39.5(7)(f)(ii) of the Act. Reports 

shall describe the probable cause of such deviations, and 

any corrective actions or preventive measures taken:

a. Pursuant to 35 IAC 218.211(c)(3)(A), the Permittee 

shall notify the Illinois EPA of any record showing 

violation of Condition 7.2.3(d) (see also 35 IAC 

218.204) within 30 days following the occurrence of 

the violation.

b. Continued operation of the affected coating line with 

a defect in the paint booth filters that may result 

in emissions of particulate matter in excess of 

limits in Condition 7.2.3(c) within 30 days of such 

an occurrence.
38

7.2.11 Operational Flexibility/Anticipated Operating Scenarios

N/A

7.2.12 Compliance Procedures

Compliance with the emission limits shall be based on the 

recordkeeping requirements in Condition 7.2.9 and the

emission factors and formulas listed below:

a. Compliance with Condition 7.2.3(c) is assumed to be 

achieved by proper operation of the paint booth 

filters, as addressed by Condition 7.2.5.

b. To determine compliance with Condition 5.5.1, PM and 

VOM emissions from the affected coating line shall be 

calculated based on the following:

i. Particulate Matter Emissions:

PM (lb) = (Coating Usage, gal) x (Coating 

Density, lb/gal) x (Wt % Solids) x [1 -

(Transfer Efficiency* (%)/100)] x [1 -

(Paint Booth Filter Efficiency* (%)/100)]

*

As specified by manufacturer or vendor of the 

spray booths and paint booth filters

ii. Volatile Organic Material Emissions:

VOM (lb) = (Coating Usage, gal) x (Coating 

Density, lb/gal) x (VOM Content of 

Coating, % by Wt.) + (Cleaning Solvent 

Usage, gal) x (Solvent Density, lb/gal)
39

7.3 Units MJ6501 and MJ6503 Building B Paint Booths

Controls MJ6501 and MJ6503 Building B Paint Booth Scrubber 

Systems

7.3.1 Description

The Building B Paint Booths are used on large vehicle 

assemblies and components for mining excavators, wheel 

loaders, and motorgraders. The part to be painted is 

conveyed through a series of pretreatment steps, then sent 

to a paint booth. In these booths, the parts are painted 

using a two-component urethane primer and topcoat. The 

parts are painted using hand held high volume low pressure 

(HVLP) paint spray guns. In the Building B Paint Booths 

the paint is air dried and cured. The paint booths have 

attached filter systems to remove the paint particulates 

from the exhaust air, prior to outside ventilation. All 

VOM used in the process is emitted. Solvents used for 

cleanup is reclaimed with approximately 50% efficiency and 

reused after distillation to remove contaminants.

7.3.2 List of Emission Units and Pollution Control Equipment

Emission

Unit Description

Emission 

Control

Equipment

MJ6501 Haden-Schweitzer 101' Hydrospin 

Paint Spray Booth (Large 

Building B Paint Booth)

Scrubber 

System

MJ6503 Haden-Schweitzer 82' Hydrospin 

Paint Spray Booth (Small 

Building B Paint Booth)

Scrubber 

System

7.3.3 Applicability Provisions and Applicable Regulations

a. The Building B Paint Booths are “affected coating 

lines” for the purpose of these unit-specific 

conditions.

b. Each affected coating line is subject to the emission

limits identified in Condition 5.2.2.

c. The affected coating lines are subject to 35 IAC 

212.321(a), which provides that:

i. No person shall cause or allow the emission of 

particulate matter into the atmosphere in any 

one hour period from any new process emission 

unit, either alone or in combination with the 

emission of particulate matter from all other 

similar process emission units for which 

construction or modification commenced on or 

after April 14, 1972, at a source or premises, 

exceeds the allowable emission rates specified 

in subsection (c) of 35 IAC 212.321 (see also 

Attachment 1) [35 IAC 212.321(a)].
40

ii. Because the expected process weight rate for 

each affected coating line is less than 100 

pounds per hour, the allowable PM emission 

rate for each affected coating line set by 35 

IAC 212.321 is 0.55 pounds per hour.

d. No person shall cause or allow the emission of sulfur 

dioxide into the atmosphere from any process emission 

unit to exceed 2000 ppm, [35 IAC 214.301].

e. Pursuant to 35 IAC 218.204, no owner or operator of a 

coating line shall apply at any time any coating in 

which the VOM content exceeds the following emission 

limitations for the specified coating. The following 

emission limitations are expressed in units of VOM 

per volume of coating (minus water and any compounds 

which are specifically exempted from the definition 

of VOM) as applied at each coating applicator, except 

where noted. Compounds which are specifically 

exempted from the definition of VOM should be treated 

as water for the purpose of calculating the "less 

water" part of the coating composition. The emission 

limitations are as follows:

i. Heavy Off-Highway Vehicle Products 

Coating/Extreme Performance Prime Coat [35 IAC 

218.204(k)(1)]:

kg/l lb/gal

0.42 3.5

ii. Heavy Off-Highway Vehicle Products 

Coating/Extreme Performance Top-Coat (Air 

Dried) [35 IAC 218.204(k)(2)]:

kg/l lb/gal

0.42 3.5

iii. Heavy Off-Highway Vehicle Products 

Coating/Final Repair Coat (Air Dried) [35 IAC 

218.204(k)(3)]:

kg/l lb/gal

0.42 3.5

7.3.4 Non-Applicability of Regulations of Concern

a. The air make-up heaters and curing oven associated 

with the affected coating lines are not subject to 35 

IAC 216.121, Emissions of Carbon Monoxide from Fuel 

Combustion Emission Units, because the air make-up 

heaters and curing oven are not by definition fuel 

combustion emission units.

b. The air make-up heaters and curing oven associated 

with the affected coating lines are not subject to 35 

IAC 217.121, emissions of nitrogen oxides from new 

fuel combustion emission sources, because the actual 
41

heat of each unit input is less than 73.2 MW (250 

mmBtu/hr) and the air make-up heaters and curing oven 

are not by definition fuel combustion emission units.

c. The affected coating lines are not subject to 35 IAC 

212.324, Process Emission Units In Certain Areas, 

because the source is not located in a non-attainment 

area for PM10, as identified in 35 IAC 212.324(a)(1).

d. No owner or operator of a coating line subject to the 

limitations of 35 IAC 218.204 is required to meet the 

limitations of 35 IAC 218.301 or 218.302, Use of 

Organic Material, after the date by which the coating 

line is required to meet 35 IAC 218.204 [35 IAC 

218.209].

7.3.5 Operational and Production Limits and Work Practices

a. The Permittee shall follow good operating practices 

for the paint booth scrubber system, including 

periodic inspection, routine maintenance and prompt 

repair of defects.

b. Natural gas shall be the only fuel fired in the paint 

booth MJ6501 air make-up heater, paint booth MJ6503 

air make-up heater, paint booths MJ6501 and MJ6503 

washers air make-up heater, and paint booth MJ6503 

paint curing oven.

7.3.6 Emission Limitations

In addition to Condition 5.2.2 and the source wide 

emission limitations in Condition 5.5, the affected 

coating lines are subject to the following:

a. Emissions from Coating:

i. Emissions and operation of Building B scraper 

paint booth MJ6501 and Building B dozer paint 

booth MJ6503 shall not exceed the following 

limits:

Item of

Coating 

Usage

VOM 

Content

VOM 

Emissions

Equipment (gal/yr) (lb/gal) lb/hr

Paint Booth MJ6501

ton/yr

50,400 3.5 21.0 88.2

Paint Booth MJ6503 42,000 3.5 17.5 73.5

Total 161.7

These limits are based on the allowable 

emission limit pursuant to 35 IAC 218.204(k) 

at the maximum coating usage, allowable VOM 

content, and maximum hours of operation.

ii. Emissions of particulate matter from the 

Building B scraper paint booth MJ6501 

controlled by the scrubber shall not exceed 

0.55 lb/hr and 2.4 ton/yr. These limits are 
42

based on the allowable emission limit pursuant 

to 35 IAC 212.321 at the maximum process rate 

(71 lb/hr) and the maximum hours of operation 

(8,400 hr/yr).

iii. Emissions of particulate matter from the 

Building B dozer paint booth shall not exceed 

0.55 lb/hr and 2.4 ton/yr. These limits are 

based on the allowable emission limit pursuant 

to 35 IAC 212.321 at the maximum process rate 

(60 lb/hr) and the maximum hours of operation 

(8,400 hr/yr).

iv. Emissions and operation of Building B paint 

booths MJ6501 and MJ6503 solvent clean-up 

operations shall not exceed the following 

limits:

Item of

Solvent 

Usage

VOM 

Content

VOM 

Emissions

Equipment (gal/yr) (lb/gal) lb/hr

Paint Booths 

MJ6501 and MJ6503

ton/yr

13,440 7.2 11.6 48.8

These limits are based on the maximum solvent 

usage, the maximum VOM content, and maximum 

hours of operation.

v. The above limitations were established in 

Construction Permit 96030245, pursuant to 35 

IAC Part 203 and 40 CFR 52.21, Prevention of 

Significant Deterioration (PSD). These limits 

ensure that the construction and/or 

modification addressed in the aforementioned 

Construction Permit does not constitute a new 

major source or major modification pursuant to 

Title I of the CAA, specifically 35 IAC Part 

203 and the federal rules for Prevention of 

Significant Deterioration (PSD), 40 CFR 52.21. 

[T1]

b. Emissions from Natural Gas Combustion:

i. Emissions and operation of the natural gas 

fired paint booth MJ6501 air make-up heater 

shall not exceed the following limits:

Natural Gas

Consumption

NOx CO 

Emissions Emissions

PM 

Emissions

VOM 

Emissions

(ft3/yr) lb/hr T/yr lb/hr T/yr lb/hr T/yr lb/hr

214,512,000

T/yr

6.3 15.2 1.6 3.9 0.7 1.7 0.3 0.8

These limits are based on standard emission 

factors (140 lb/Mft3 for NOx, 35 lb/Mft3 for

CO, 13.7 lb/Mft3 for PM, and 5.8 lb/Mft3 for 

VOM), and the fuel, the maximum firing rate 

(44.69 mmBtu/hr), and the maximum hours of 

operation (4,800 hr/yr).
43

ii. Emissions and operation of the natural gas 

fired paint booth MJ6503 air make-up heater 

shall not exceed the following limits:

Natural Gas

Consumption

NOx CO 

Emissions Emissions

PM 

Emissions

VOM 

Emissions

(ft3/yr) lb/hr T/yr lb/hr T/yr lb/hr T/yr lb/hr

128,688,000

T/yr

3.8 9.2 1.0 2.4 0.4 1.0 0.2 0.5

These limits are based on standard emission

factors (140 lb/Mft3 for NOx, 35 lb/Mft3 for 

CO, 13.7 lb/Mft3 for PM, and 5.8 lb/Mft3 for 

VOM), and the fuel, the maximum firing rate 

(26.81 mmBtu/hr), and the maximum hours of 

operation (4,800 hr/yr).

iii. Emissions and operation of the natural gas 

fired paint booths MJ6501 and MJ6503 washers 

air make-up heater shall not exceed the 

following limits:
44

Natural Gas

Consumption NOx

Emissions

CO Emissions PM Emissions

(ft3/yr) lb/hr T/yr lb/hr T/yr lb/hr

42,912,000

T/yr

0.9 2.2 0.2 0.5 0.2 0.5

These limits are based on standard emission 

factors (100 lb/Mft3 for NOx, 21 lb/Mft3 for 

CO, and 12 lb/Mft3 for PM), and the fuel, the 

maximum firing rate (8.94 mmBtu/hr), and the 

maximum hours of operation (4,800 hr/yr).

iv. Emissions and operation of the natural gas 

fired paint booth MJ6503 paint curing oven 

shall not exceed the following limits:

Natural Gas E M I S S I O N S

Consumption NOx CO

(ft3/yr) lb/hr Ton/yr lb/hr

30,000,000

Ton/yr

0.7 1.7 0.2 0.5

These limits are based on standard emission 

factors (100 lb/Mft3 for NOx and 21 lb/Mft3 for 

CO), and the fuel, the maximum firing rate 

(6.25 mmBtu/hr), and the maximum hours of 

operation (4,800 hr/yr).

v. The above limitations were established in 

Construction Permit 96010110, pursuant to 35 

IAC Part 203 and 40 CFR 52.21, Prevention of 

Significant Deterioration (PSD). These limits 

ensure that the construction and/or 

modification addressed in the aforementioned 

Construction Permit does not constitute a new 

major source or major modification pursuant to 

Title I of the CAA, specifically 35 IAC Part 

203 and the federal rules for Prevention of 

Significant Deterioration (PSD), 40 CFR 52.21. 

[T1]

c. Compliance with annual limits shall be determined on 

a monthly basis from the sum of the data for the 

current month plus the preceding 11 months (running 

12 month total).

7.3.7 Testing Requirements

a. The VOM content of each coating shall be determined 

by the applicable test methods and procedures 

specified in 35 IAC 218.105 to establish the records 

required under Condition 7.3.9(b) (see also 35 IAC 

218.211) [35 IAC 218.211(a)].

b. Upon reasonable request by the Illinois EPA, pursuant 

to Section 39.5(7)(b) of the Act, the VOM content of 

specific coatings and cleaning solvents used on the 

affected coating line shall be determined as follows:
45

i. The VOM content of representative coatings "as 

applied" on the affected coating line shall be 

determined according to USEPA Reference 

Methods 24 and 24A of 40 CFR 60 Appendix A and 

the procedures of 35 IAC 218.105(a).

ii. This testing may be performed by the supplier 

of a material provided that the supplier 

provides appropriate documentation for such 

testing to the Permittee and the Permittee's 

records pursuant to Condition 7.3.9(b) 

directly reflect the application of such 

material and separately account for any 

additions of solvent.

7.3.8 Monitoring Requirements

None

7.3.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the 

Permittee shall maintain records of the following items 

for the affected coating lines to demonstrate compliance 

with Conditions 5.5.1 and 7.3.3, pursuant to Section 

39.5(7)(b) of the Act:

a. Records of the testing of VOM content of coatings and 

cleaning solvents pursuant to Condition 7.3.7, which 

include the following [Section 39.5(7)(e) of the 

Act]:

i. Identification of material tested;

ii. Results of analysis;

iii. Documentation of analysis methodology; and

iv. Person performing analysis.

b. Pursuant to 35 IAC 218.211(c)(2), the Permittee shall 

collect and record all of the following information 

each day for the affected coating line and maintain 

the information at the source for a period of three 

years:

i. The name and identification number of each 

coating as applied on the affected coating 

lines; and

ii. The weight of VOM per volume of each coating 

(minus water and any compounds which are 

specifically exempted from the definition of 

VOM) as applied each day on the affected 

coating lines.
46

c. Records addressing use of good operating practices 

for the paint booth scrubber system:

i. Records for periodic inspection of the paint 

booth scrubber system with date, individual 

performing the inspection, and nature of 

inspection; and

ii. Records for prompt repair of defects, with 

identification and description of defect, 

effect on emissions, date identified, date 

repaired, and nature of repair.

d. Records of the coating usage for the affected coating 

lines, gal/mo and gal/yr;

e. The VOM content of coatings, % by Wt;

f. Density of coatings, lb/gal;

g. Records of the solvent usage for the affected coating 

lines, gal/mo and gal/yr;

h. Density of solvent, lb/gal;

i. The operating schedule of the affected coating lines;

j. The natural gas usage of the air make-up heaters and 

curing oven associated with the affected coating 

lines, Mft3

/mo and Mft3

/yr;

k. The aggregate monthly and annual PM and VOM emissions 

from the affected coating lines based on the material 

usage, with supporting calculations; and

l. The monthly and aggregate annual CO, NOx, PM, SO2, 

and VOM emissions from the air make-up heaters and 

curing oven associated with the affected coating 

lines based on the fuel usage and standard emission 

factors, with supporting calculations.

7.3.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section of noncompliance of an affected coating 

line with the permit requirements as follows, pursuant to 

Section 39.5(7)(f)(ii) of the Act. Reports shall describe 

the probable cause of such deviations, and any corrective 

actions or preventive measures taken:

a. Pursuant to 35 IAC 218.211(c)(3)(A), the Permittee 

shall notify the Illinois EPA of any record showing 

violation of Condition 7.3.3(e) (see also 35 IAC 

218.204) within 30 days following the occurrence of 

the violation.

b. Continued operation of the affected coating lines 

with a defect in the paint booth scrubber system that 
47

may result in emissions of particulate matter in 

excess of limits in Conditions 7.3.6(a)(ii) or (iii) 

within 30 days of such an occurrence.

c. Emissions of VOM in excess of limits in Conditions 

7.3.6(a)(i) and/or (iv) within 30 days of such an 

occurrence.

d. Emissions of CO, NOx, PM and/or VOM in excess of the 

limits in Condition 7.1.6(b) within 30 days of such 

an occurrence.

7.3.11 Operational Flexibility/Anticipated Operating Scenarios

N/A

7.3.12 Compliance Procedures

Compliance with the emission limits shall be based on the 

recordkeeping requirements in Condition 7.3.9 and the 

emission factors and formulas listed below:

a. Compliance with Condition 7.3.3(c) is assumed to be 

achieved by proper operation of the paint booth 

scrubber system, as addressed by Condition 7.3.5.

b. Compliance with Condition 7.3.3(d) is assumed by the 

work-practices inherent in operation of natural gasfired air make-up heaters and a curing oven.

c. To determine compliance with Condition 5.5.1, PM and 

VOM emissions from the affected coating lines shall 

be calculated based on the following:

i. Particulate Matter Emissions:

PM (lb) = (Coating Usage, gal) x (Coating 

Density, lb/gal) x (Wt % Solids) x [1 -

(Transfer Efficiency* (%)/100)] x [1 -

(Paint Booth Scrubber System Efficiency*

(%)/100)]

*

As specified by manufacturer or vendor of the 

spray booths and paint booth scrubber system

ii. Volatile Organic Material Emissions:

VOM (lb) = (Coating Usage, gal) x (Coating 

Density, lb/gal) x (VOM Content of 

Coating, % by Wt.) + (Cleaning Solvent 

Usage, gal) x (Solvent Density, lb/gal)

d. To determine compliance with Conditions 5.5.1 and 

7.3.6(b), fuel combustion emissions from the air 

make-up heaters and curing oven associated with the 

affected coating line shall be calculated based on 

the following emission factors:
48

Emission Factor

Pollutant (lb/Mft3

CO

)

84

NOx 100

PM 7.6

SO2 0.6

VOM 5.5

These are the emission factors for uncontrolled 

natural gas combustion in small boilers (< 100 

mmBtu/hr), Tables 1.4-1 and 1.4-2, AP-42, Volume I, 

Fifth Edition, March, 1998.

Air Make-up Heater and Curing Oven Emissions (lb) = 

(Natural Gas Consumed, Mft3

) x (The 

Appropriate Emission Factor, lb/Mft3

)
49

7.4 Units HX278-280& HX470 Chrome Plating Systems

Controls HX278-280& HX470 Chrome Plating Scrubber System

7.4.1 Description

The chrome plating process is used exclusively on 

hydraulic cylinder rods that actuate the motions (i.e., 

swinging, lifting, and hoisting) of the implements on 

earthmoving equipment that Caterpillar manufactures. The 

chrome plating process involves conveying turned, heat 

treated, and ground rods via a programmable hoist through 

a series of pretreatment tanks for replate preparation, 

then to an electrified tanks containing a solution of 

chromic acid (32 oz/gal CrO3 in water) for the actual 

plating process. The process deposits 0.001" - 0.0035" 

(depending on rod application) of chrome on the rod. The 

chrome plating process generates hydrogen gas that has 

entrained droplets of chromic acid in it, which creates a 

mist. The ventilation system carries the mist through a 

scrubber system to strip the chromic acid and redissolve 

it in water which is then returned to a rinse tank. The 

rinse tank is used to makeup the solution level losses due 

to evaporation in the plating tank. The excess chromic 

acid containing rinse water is pumped to waste water 

treatment for reduction, precipitation and disposal.

7.4.2 List of Emission Units and Pollution Control Equipment

Emission

Unit Description

Emission Control

Equipment

MJ7450 OMI Chrome Plating Tank MJ7450 

(HX278 Chrome Plate System)

Fume Scrubber #1

MJ7451 OMI Chrome Plating Tank MJ7451 

(HX278 Chrome Plate System)

Fume Scrubber #2

MJ7465 OMI Chrome Plating Tank MJ7465 

(HX279 Chrome Plate System)

Fume Scrubber 

F101-20 

(Scrubber HX279)

MJ7458 OMI Chrome Plating Tank MJ7458 

(HX279 Chrome Plate System)

Fume Scrubber 

F101-20 

(Scrubber HX280)

MJ8968 OMI Chrome Plating Tank MJ8968 

(HX470 Chrome Plate System)

Fume Scrubber 

F103-18

MJ8970 OMI Chrome Plating Tank MJ8970 

(HX470 Chrome Plate System)

Fume Scrubber 

F103-14

7.4.3 Applicability Provisions and Applicable Regulations

a. Chrome Plating Tanks MJ7450, MJ7451, MJ7465, MJ7458, 

MJ8968, and MJ8970 are "affected plating tanks" for 

the purpose of these unit-specific conditions.

b. Each affected plating tank is subject to the emission 

limits identified in Condition 5.2.2.

c. The affected plating tanks are subject to the NESHAP 

for Chromium Emissions From Hard and Decorative 

Chromium Electroplating and Chromium Anodizing Tanks, 

40 CFR 63 Subparts A and N. The Illinois EPA is 
50

administering the NESHAP in Illinois on behalf of the 

USEPA under a delegation agreement. Because the 

affected plating tanks are used to apply a thick 

layer of chromium (typically 1.3 to 760 microns) 

which is electrodeposited on a base material to 

provide a surface with functional properties such as 

wear resistance, a low coefficient of friction, 

hardness, and corrosion resistance, they are 

considered to be hard chromium electroplating tanks 

and are subject to the following:

i. During tank operation, each owner or operator 

of an existing, new, or reconstructed affected 

source shall control chromium emissions 

discharged to the atmosphere from that 

affected source by not allowing the 

concentration of total chromium in the exhaust 

gas stream discharged to the atmosphere to 

exceed 0.015 mg/dscm of total chromium of 

ventilation air (6.6 x 10-6 gr/dscf) [40 CFR 

63.342(c)(1)(i)].

ii. When multiple affected sources performing the 

same type of operation (e.g., all are 

performing hard chromium electroplating), and 

subject to the same emission limitation, are 

controlled with an add-on air pollution 

control device that is not controlling 

emissions from any other type of affected 

operation or from any nonaffected sources, the 

applicable emission limitation identified in 

Condition 7.4.3(c)(i) (see also 40 CFR 63.342) 

must be met at the outlet of the add-on air 

pollution control device [40 CFR 

63.344(e)(2)].

d. The affected plating tanks are subject to 35 IAC 

212.321(a), which provides that:

i. No person shall cause or allow the emission of 

particulate matter into the atmosphere in any 

one hour period from any new process emission 

unit, either alone or in combination with the 

emission of particulate matter from all other 

similar process emission units for which 

construction or modification commenced on or 

after April 14, 1972, at a source or premises, 

exceeds the allowable emission rates specified 

in subsection (c) of 35 IAC 212.321 (see also 

Attachment 1) [35 IAC 212.321(a)].

ii. Because the expected process weight rate for 

the affected plating tanks is 4,166.24 pounds 

per hour, combined, the allowable PM emission

rate for the affected plating tanks set by 35 

IAC 212.321 is 3.76 pounds per hour, combined.

7.4.4 Non-Applicability of Regulations of Concern
51

The affected plating tanks are not subject to 35 IAC 

212.324, Process Emission Units In Certain Areas, because

the source is not located in a non-attainment area for 

PM10, as identified in 35 IAC 212.324(a)(1).

7.4.5 Operational and Production Limits and Work Practices

a. Pursuant to 40 CFR 63.342(f), all owners or operators 

subject to the standards in Condition 7.4.3(c)(i) 

(see also 40 CFR 63.342(c)) are subject to these work 

practice standards.

i. At all times, including periods of startup, 

shutdown, and malfunction, owners or operators 

shall operate and maintain any affected 

source, including associated air pollution 

control devices and monitoring equipment, in a 

manner consistent with good air pollution 

control practices, consistent with the 

operation and maintenance plan required by 

Condition 7.4.5(a)(iv) (see also 40 CFR 

63.342(f)(3)) [40 CFR 63.342(f)(1)(i)].

ii. Malfunctions shall be corrected as soon as 

practicable after their occurrence in 

accordance with the operation and maintenance 

plan required by Condition 7.4.5(a)(iv) (see 

also 40 CFR 63.342(f)(3)) [40 CFR 

63.342(f)(1)(ii)].

iii. Operation and maintenance requirements 

established pursuant to section 112 of the CAA 

are enforceable independent of emissions 

limitations or other requirements in relevant 

standards [40 CFR 63.342(f)(1)(iii)].

iv. Pursuant to 40 CFR 63.342(f)(3)(i), the owner 

or operator of an affected source subject to 

the work practices of Condition 7.4.5(a) (see 

also 40 CFR 63.342(f)) shall prepare an 

operation and maintenance plan. The plan 

shall include the following elements:

A. The plan shall specify the operation and 

maintenance criteria for the affected 

source, the add-on air pollution control 

device (if such a device is used to comply

with the emission limits), and the process

and control system monitoring equipment, 

and shall include a standardized checklist

to document the operation and maintenance 

of this equipment [40 CFR 

63.342(f)(3)(i)(A)];

B. Pursuant to 40 CFR 63.342(f)(3)(i)(B), for 

sources using an add-on air pollution 

control device or monitoring equipment to 
52

comply with 40 CFR 63 Subpart N, the plan 

shall incorporate the work practice 

standards for Packed-Bed Scrubber (PBS) 

systems or monitoring equipment, as 

identified in Table 1 of 40 CFR 63.342, as

follows:

1. Visually inspect device to ensure 

there is proper drainage, no chromic

acid buildup on the packed beds, and

no evidence of chemical attack on 

the structural integrity of the 

device once per quarter.

2. Visually inspect back portion of the 

chevron blade mist eliminator to 

ensure that it is dry and there is 

no breakthrough of chromic acid mist

once per quarter.

3. Visually inspect ductwork from tank 

to the control device once each 

quarter to ensure there are no leaks

once per quarter.

4. Add fresh makeup water to the top of 

the packed bed whenever makeup is 

added. If greater than 50 percent 

of the scrubber water is drained 

(e.g., for maintenance purposes), 

makeup water may be added to the 

scrubber basin. For horizontal-flow 

scrubbers, top is defined as the 

section of the unit directly above 

the packing media such that the 

makeup water would flow 

perpendicular to the air flow 

through the packing. For verticalflow units, the top is defined as 

the area downstream of the packing 

material such that the makeup water 

would flow countercurrent to the air

flow through the unit.

5. For pitot tubes, once each quarter, 

backflush with water, or remove from

the duct and rinse with fresh water. 

Replace in the duct and rotate 180 

degrees to ensure that the same zero

reading is obtained. Check pitot 

tube ends for damage. Replace pitot

tube if cracked or fatigued.

C. The plan shall specify procedures to be 

followed to ensure that equipment or 

process malfunctions due to poor 

maintenance or other preventable 
53

conditions do not occur [40 CFR 

63.342(f)(3)(i)(D)]; and

D. The plan shall include a systematic 

procedure for identifying malfunctions of 

process equipment, add-on air pollution 

control devices, and process and control 

system monitoring equipment and for 

implementing corrective actions to address

such malfunctions [40 CFR 

63.342(f)(3)(i)(E)].

v. If the operation and maintenance plan fails to 

address or inadequately addresses an event 

that meets the characteristics of a 

malfunction at the time the plan is initially 

developed, the owner or operator shall revise 

the operation and maintenance plan within 45 

days after such an event occurs. The revised 

plan shall include procedures for operating 

and maintaining the process equipment, add-on 

air pollution control device, or monitoring 

equipment during similar malfunction events, 

and a program for corrective action for such 

events [40 CFR 63.342(f)(3)(ii)].

vi. To satisfy the requirements of Conditions 

7.4.5(a)(iv) and (v) (see also 40 CFR 

63.342(f)(3)), the owner or operator may use 

applicable standard operating procedure (SOP) 

manuals, Occupational Safety and Health 

Administration (OSHA) plans, or other existing 

plans, provided the alternative plans meet the 

requirements of this section [40 CFR 

63.342(f)(3)(vi)].

b. The standards in Conditions 7.4.3(c)(i) (see also 40 

CFR 63.342) that apply to chromic acid baths shall 

not be met by using a reducing agent to change the 

form of chromium from hexavalent to trivalent [40 CFR 

63.342(g)].

c. The Permittee shall follow good operating practices 

for the scrubbers, including periodic inspection, 

routine maintenance and prompt repair of defects.

7.4.6 Emission Limitations

In addition to Condition 5.2.2 and the source wide 

emission limitations in Condition 5.5, the affected 

plating tanks are subject to the following:

a. Emissions and operation of the HX470 Chrome Plate 

System shall not exceed the following limits:

i. This permit is issued based upon a minimal 

hourly emission rate and negligible annual 

emissions (less than 0.1 ton/yr) of 
54

particulate matter from the two chrome plating 

tanks (MJ8968 and MJ8970). These limits are 

based on the maximum current usage of 110,244 

amp-hr/day/tank and maximum 300 days of 

operation in a year.

ii. This permit is issued based on negligible 

emissions of particulate matter from the 

aklaline clean tank. For this purpose, 

emissions shall not exceed nominal emission 

rates of 0.1 lb/hr and 0.28 ton/yr.

iii. The above limitations were established in 

Construction Permit 89100062, pursuant to 40 

CFR 52.21, Prevention of Significant 

Deterioration (PSD). These limits ensure that 

the construction and/or modification addressed 

in the aforementioned Construction Permit does 

not constitute a new major source or major 

modification pursuant to Title I of the CAA, 

specifically the federal rules for Prevention 

of Significant Deterioration (PSD), 40 CFR 

52.21.[T1]

b. Compliance with annual limits shall be determined on 

a monthly basis from the sum of the data for the 

current month plus the preceding 11 months (running 

12 month total).
55

7.4.7 Testing Requirements

Pursuant to Section 39.5(7)(b) of the Act, testing for 

chromium emissions from the affected plating tanks shall 

be performed upon reasonable request by the Illinois EPA 

as follows:

a. Pursuant to 40 CFR 63.344(a), performance tests shall 

be conducted using the test methods and procedures in 

40 CFR 63.344 and 40 CFR 63.7.

b. Pursuant to 40 CFR 63.344(c), each owner or operator 

subject to the provisions of 40 CFR 63 Subpart N 

shall use the test methods identified in Condition 

7.4.7 (see also 40 CFR 63.344) to demonstrate 

compliance with the standards in Condition 

7.4.3(c)(i) (see also 40 CFR 63.342).

i. Method 306 or Method 306A "Determination of 

Chromium Emissions From Decorative and Hard 

Chromium Electroplating and Anodizing 

Operations," appendix A of 40 CFR Part 63 

shall be used to determine the chromium

concentration from hard or decorative chromium 

electroplating tanks or chromium anodizing 

tanks. The sampling time and sample volume 

for each run of Methods 306 and 306A, appendix 

A of 40 CFR Part 63 shall be at least 120 

minutes and 1.70 dscm (60 dscf), respectively. 

Methods 306 and 306A, appendix A of 40 CFR 

Part 63 a measurement of either total chromium 

or hexavalent chromium emissions. For the 

purposes of this standard, sources using 

chromic acid baths can demonstrate compliance 

with the emission limits of Condition 

7.4.3(c)(i) (see also 40 CFR 63.342) by 

measuring either total chromium or hexavalent 

chromium. Hence, the hexavalent chromium 

concentration measured by these methods is 

equal to the total chromium concentration for 

the affected operations [40 CFR 63.344(c)(1)].

ii. Pursuant to 40 CFR 63.344(c)(2), the 

California Air Resources Board (CARB) Method 

425(which is available by contacting the 

California Air Resources Board, 1102 Q Street, 

Sacramento, California 95814) may be used to 

determine the chromium concentration from hard 

and decorative chromium electroplating tanks 

and chromium anodizing tanks if the following 

conditions are met:

A. If a colorimetric analysis method is used, 

the sampling time and volume shall be 

sufficient to result in 33 to 66 

micrograms of catch in the sampling train 

[40 CFR 63.344(c)(2)(i)].
56

B. If Atomic Absorption Graphite Furnace 

(AAGF) or Ion Chromatography with a Postcolumn Reactor (ICPCR) analyses were used,

the sampling time and volume should be 

sufficient to result in a sample catch 

that is 5 to 10 times the minimum 

detection limit of the analytical method 

(i.e., 1.0 microgram per liter of sample 

for AAGF and 0.5 microgram per liter of 

sample for ICPCR) [40 CFR 

63.344(c)(2)(ii)].

C. In the case of either Condition 

7.4.7(b)(ii)(A) or (B) (see also 40 CFR 

63.344(c)(2) (i) or (ii)), a minimum of 3 

separate runs must be conducted. The 

other requirements of 40 CFR 63.7 that 

apply to affected sources, as indicated in

Table 1 of 40 CFR 63 Subpart N, must also 

be met [40 CFR 63.344(c)(2)(iii)].

iii. Alternate test methods may also be used if the 

method has been validated using Method 301, 

appendix A of 40 CFR Part 63 and if approved 

by the Illinois EPA and/or USEPA. Procedures 

for requesting and obtaining approval are 

contained in 40 CFR 63.7(f) [40 CFR 

63.344(c)(4)].

7.4.8 Monitoring Requirements

a. Pursuant to 40 CFR 63.343(c), the owner or operator 

of an affected source subject to the emission 

limitations of 40 CFR 63 Subpart N shall conduct 

monitoring according to the type of air pollution 

control technique that is used to comply with the 

emission limitation. The monitoring required to 

demonstrate continuous compliance with the emission 

limitations is identified in this section for the air 

pollution control techniques expected to be used by 

the owners or operators of affected sources.

i. During the initial performance test, the owner 

or operator of an affected source, or group of 

affected sources under common control, 

complying with the emission limitations in

Condition 7.4.3(c)(i) (see also 40 CFR 63.342) 

through the use of a packed-bed scrubber 

system shall determine the outlet chromium 

concentration using the procedures in 

Condition 7.4.7(b) (see also 40 CFR 

63.344(c)), and shall establish as sitespecific operating parameters the pressure 

drop across the system and the velocity 

pressure at the common inlet of the control 

device, setting the value that corresponds to 

compliance with the applicable emission 

limitation using the procedures in Condition 
57

7.4.8(c) and (d) (see also 63.344(d)(4) and 

(5)). An owner or operator may conduct 

multiple performance tests to establish a 

range of compliant operating parameter values. 

Alternatively, the owner or operator may set 

as the compliant value the average pressure 

drop and inlet velocity pressure measured over 

the three test runs of one performance test, 

and accept ±1 inch of water column from the 

pressure drop value and ±10 percent from the 

velocity pressure value as the compliant range 

[40 CFR 63.343(c)(2)(i)].

ii. On and after the date on which the initial 

performance test is required to be completed 

under 40 CFR 63.7, the owner or operator of an 

affected source, or group of affected sources 

under common control, shall monitor and record 

the velocity pressure at the inlet to the 

packed-bed system and the pressure drop across 

the scrubber system once each day that any 

affected source is operating. To be in 

compliance with the standards, the scrubber 

system shall be operated within ±10 percent of 

the velocity pressure value established during 

the initial performance test, and within ±1 

inch of water column of the pressure drop 

value established during the initial 

performance test, or within the range of 

compliant operating parameter values 

established during multiple performance tests 

[40 CFR 63.343(c)(2)(ii)].

iii. If the owner or operator of an affected source 

uses both a fume suppressant and add-on 

control device and both are needed to comply 

with the applicable emission limit, monitoring 

requirements as identified in Conditions 

7.4.8(a)(i) and (ii) (see also 40 CFR 

63.343(c)(2)), and the work practice standards 

of Condition 7.4.5(a)(iv)(B) (see also Table 1 

of 40 CFR 63.342), apply for each of the 

control techniques used [40 CFR 

63.343(c)(7)(i)].

iv. If the owner or operator of an affected source 

uses both a fume suppressant and add-on 

control device, but only one of these 

techniques is needed to comply with the 

applicable emission limit, monitoring 

requirements as identified in Conditions 

7.4.8(a)(i) and (ii) (see also 40 CFR 

63.343(c)(2)), and work practice standards of 

Condition 7.4.5(a)(iv)(B) (see also Table 1 of 

40 CFR 63.342), apply only for the control 

technique used to achieve compliance [40 CFR 

63.343(c)(7)(ii)].
58

b. All monitoring equipment shall be installed such that 

representative measurements of emissions or process 

parameters from the affected source are obtained. 

For monitoring equipment purchased from a vendor, 

verification of the operational status of the 

monitoring equipment shall include execution of the 

manufacturer's written specifications or 

recommendations for installation, operation, and 

calibration of the system [40 CFR 63.344(d)(2)].

i. Specifications for differential pressure 

measurement devices used to measure velocity 

pressure shall be in accordance with section 

2.2 of Method 2 (40 CFR part 60, appendix A) 

[40 CFR 63.344(d)(2)(i)].

ii. Specification for differential pressure 

measurement devices used to measure pressure 

drop across a control system shall be in 

accordance with manufacturer's accuracy 

specifications [40 CFR 63.344(d)(2)(ii)].

c. Pursuant to 40 CFR 63.344(d)(4), The owner or 

operator of a source required to measure the velocity 

pressure at the inlet to an add-on air pollution 

control device in accordance with Conditions 

7.4.8(a)(i) and (ii) (see also 40 CFR 63.343(c)(2)), 

shall establish the site-specific velocity pressure 

as follows:

i. Locate a velocity traverse port in a section 

of straight duct that connects the hooding on 

the plating tank or tanks with the control 

device. The port shall be located as close to 

the control system as possible, and shall be 

placed a minimum of 2 duct diameters 

downstream and 0.5 diameter upstream of any 

flow disturbance such as a bend, expansion, or 

contraction (see Method 1, 40 CFR part 60,

appendix A). If 2.5 diameters of straight duct 

work does not exist, locate the port 0.8 of 

the duct diameter downstream and 0.2 of the 

duct diameter upstream from any flow 

disturbance [40 CFR 63.344(d)(4)(i)].

ii. A 12-point velocity traverse of the duct to 

the control device shall be conducted along a 

single axis according to Method 2 40 CFR part 

60, appendix A) using an S-type pitot tube; 

measurement of the barometric pressure and 

duct temperature at each traverse point is not 

required, but is suggested. Mark the S-type 

pitot tube as specified in Method 1 (40 CFR 

part 60, appendix A) with 12 points. Measure 

the velocity pressure (∆p) values for the 

velocity points and record. Determine the 

square root of the individual velocity point ∆

p values and average. The point with the 
59

square root value that comes closest to the 

average square root value is the point of 

average velocity. The ∆p value measured for 

this point during the performance test will be 

used as the reference for future monitoring 

[40 CFR 63.344(d)(4)(ii)].

d. Pursuant to 40 CFR 63.344(d)(5), the owner or 

operator of a source required to measure the pressure 

drop across the add-on air pollution control device 

in accordance with Conditions 7.4.8(a)(i) and (ii) 

(see also 40 CFR 63.343(c)(2)) may establish the 

pressure drop in accordance with the following 

guidelines:

i. Pursuant to 40 CFR 63.344(d)(5)(i), pressure 

taps shall be installed at any of the 

following locations:

A. At the inlet and outlet of the control 

system. The inlet tap should be installed

in the ductwork just prior to the control 

device and the corresponding outlet 

pressure tap should be installed on the 

outlet side of the control device prior to

the blower or on the downstream side of 

the blower [40 CFR 63.344(d)(5)(i)(A)];

B. On each side of the packed bed within the 

control system or on each side of each 

mesh pad within the control system [40 CFR

63.344(d)(5)(i)(B)]; or

C. On the front side of the first mesh pad 

and back side of the last mesh pad within 

the control system [40 CFR 

63.344(d)(5)(i)(C)].

ii. Pursuant to 40 CFR 63.344(d)(5)(ii) pressure 

taps shall be sited at locations that are:

A. Free from pluggage as possible and away 

from any flow disturbances such as 

cyclonic demisters [40 CFR 

63.344(d)(5)(ii)(A)].

B. Situated such that no air infiltration at 

measurement site will occur that could 

bias the measurement [40 CFR 

63.344(d)(5)(ii)(B)].

iii. Pressure taps shall be constructed of either 

polyethylene, polybutylene, or other 

nonreactive materials [40 CFR 

63.344(d)(5)(iii)].

iv. Nonreactive plastic tubing shall be used to 

connect the pressure taps to the device used 
60

to measure pressure drop [40 CFR 

63.344(d)(5)(iv)].

v. Any of the following pressure gauges can be 

used to monitor pressure drop: a magnehelic 

gauge, an inclined manometer, or a "U" tube 

manometer [40 CFR 63.344(d)(5)(v)].

vi. Prior to connecting any pressure lines to the 

pressure gauge(s), each gauge should be 

zeroed. No calibration of the pressure gauges 

is required [40 CFR 63.344(d)(5)(vi)].
61

7.4.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the 

Permittee shall maintain records of the following items 

for each affected plating tank to demonstrate compliance 

with Conditions 5.5.1, 7.4.3, 7.4.5, and 7.4.6 pursuant to 

Section 39.5(7)(b) of the Act:

a. Pursuant to 40 CFR 63.346(b), the owner or operator 

of an affected source subject to the provisions of 

this subpart shall maintain the following records for 

such source:

i. Inspection records for the add-on air 

pollution control device, if such a device is 

used, and monitoring equipment, to document 

that the inspection and maintenance required 

by the work practice standards of Condition 

7.4.5(a) (see also 40 CFR 63.342(f) and Table 

1 of 40 CFR 63.342) have taken place. The 

record can take the form of a checklist and 

should identify the device inspected, the date 

of inspection, a brief description of the 

working condition of the device during the 

inspection, and any actions taken to correct 

deficiencies found during the inspection [40 

CFR 63.346(b)(1)];

ii. Records of all maintenance performed on the 

affected source, the add-on air pollution 

control device, and monitoring equipment [40 

CFR 63.346(b)(2)];

iii. Records of the occurrence, duration, and cause 

(if known) of each malfunction of process, 

add-on air pollution control, and monitoring 

equipment [40 CFR 63.346(b)(3)];

iv. Records of actions taken during periods of 

malfunction when such actions are inconsistent 

with the operation and maintenance plan [40 

CFR 63.346(b)(4)];

v. Other records, which may take the form of 

checklists, necessary to demonstrate 

consistency with the provisions of the 

operation and maintenance plan required by 

Condition 7.4.5(a)(iv) (see also 40 CFR 

63.342(f)(3)) [40 CFR 63.346(b)(5)];

vi. Test reports documenting results of all 

performance tests [40 CFR 63.346(b)(6)];

vii. All measurements as may be necessary to 

determine the conditions of performance tests, 

including measurements necessary to determine 

compliance with the special compliance 
62

procedures of 40 CFR 63.344(e) [40 CFR 

63.346(b)(7)];

viii. Records of monitoring data required by 

Condition 7.4.8(a) (see also 40 CFR 63.343(c)) 

that are used to demonstrate compliance with 

the standard including the date and time the 

data are collected [40 CFR 63.346(b)(8)];

ix. The specific identification (i.e., the date 

and time of commencement and completion) of 

each period of excess emissions, as indicated 

by monitoring data, that occurs during 

malfunction of the process, add-on air 

pollution control, or monitoring equipment [40 

CFR 63.346(b)(9)];

x. The specific identification (i.e., the date 

and time of commencement and completion) of 

each period of excess emissions, as indicated 

by monitoring data, that occurs during periods 

other than malfunction of the process, add-on 

air pollution control, or monitoring equipment 

[40 CFR 63.346(b)(10)];

xi. The total process operating time of the 

affected source during the reporting period 

[40 CFR 63.346(b)(11)];

xii. For sources using fume suppressants to comply 

with the standards, records of the date and 

time that fume suppressants are added to the 

electroplating or anodizing bath [40 CFR 

63.346(b)(13)];

xiii. All documentation supporting the notifications 

and reports required by 40 CFR 63.9, 40 CFR 

63.10, and 40 CFR 63.347 [40 CFR 

63.346(b)(16)].

b. The owner or operator shall keep the written 

operation and maintenance plan on record after it is 

developed to be made available for inspection, upon 

request, by the Illinois EPA and/or USEPA for the 

life of the affected source or until the source is no 

longer subject to the provisions of 40 CFR 63 Subpart 

N. In addition, if the operation and maintenance 

plan is revised, the owner or operator shall keep 

previous (i.e., superseded) versions of the operation 

and maintenance plan on record to be made available 

for inspection, upon request, by the Illinois EPA 

and/or USEPA for a period of 5 years after each 

revision to the plan [40 CFR 63.342(f)(3)(v)].

c. Records of the testing of chromium emissions from the 

affected plating tanks pursuant to Condition 7.4.7, 

which include the following [Section 39.5(7)(e) of 

the Act]:
63

i. The date, place and time of sampling or 

measurements;

ii. The date(s) analyses were performed;

iii. The company or entity that performed the 

analyses;

iv. The analytical techniques or methods used;

v. The results of such analyses; and

vi. The operating conditions as existing at the 

time of sampling or measurement.

d. The operating schedule of the affected plating tanks; 

and

e. The monthly and aggregate annual chromium and PM 

emissions from the affected grinders based on the 

operating schedule and the typical hourly emission 

rate, with supporting calculations.

7.4.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section of noncompliance of an affected plating 

tank with the permit requirements as follows, pursuant to 

Section 39.5(7)(f)(ii) of the Act. Reports shall describe 

the probable cause of such deviations, and any corrective 

actions or preventive measures taken:

a. Pursuant to 40 CFR 63.347(g)(1), the owner or 

operator of an affected source that is located at a 

major source site shall submit a summary report to 

the Illinois EPA and/or USEPA to document the ongoing 

compliance status of the affected source. The report 

shall contain the information identified in Condition 

7.4.10(c) (see also 40 CFR 63.347(g)(3)), and shall 

be submitted semiannually except when:

i. The Illinois EPA and/or USEPA determines on a 

case-by-case basis that more frequent 

reporting is necessary to accurately assess 

the compliance status of the source [40 CFR 

63.347(g)(1)(i)]; or

ii. The monitoring data collected by the owner or 

operator of the affected source in accordance 

with Condition 7.4.8(a) (see also 40 CFR 

63.343(c)) show that the emission limit has 

been exceeded, in which case quarterly reports 

shall be submitted. Once an owner or operator 

of an affected source reports an exceedance, 

ongoing compliance status reports shall be 

submitted quarterly until a request to reduce 

reporting frequency under Condition 7.4.10(b) 
64

(see also 40 CFR 63.347(g)(2)) is approved [40 

CFR 63.347(g)(1)(ii)].

b. Request to reduce frequency of ongoing compliance 

status reports:

i. Pursuant to 40 CFR 63.347(g)(2)(i), an owner 

or operator who is required to submit ongoing 

compliance status reports on a quarterly (or 

more frequent basis) may reduce the frequency 

of reporting to semiannual if all of the 

following conditions are met:

A. For 1 full year (e.g., 4 quarterly or 12 

monthly reporting periods), the ongoing 

compliance status reports demonstrate that

the affected source is in compliance with 

the relevant emission limit [40 CFR 

63.347(g)(2)(i)(A)];

B. The owner or operator continues to comply 

with all applicable recordkeeping and 

monitoring requirements of Condition 

7.4.9(a) and (b) (see also 40 CFR 63 

Subpart A and 40 CFR 63 Subpart N) [40 CFR

63.347(g)(2)(i)(B)]; and

C. The Illinois EPA and/or the USEPA does not 

object to a reduced reporting frequency 

for the affected source, as provided in 

Condition 7.4.10(b)(ii) and (iii) (see 

also 40 CFR 63.347(g)(2)(ii) and (iii)) 

[40 CFR 63.347(g)(2)(i)(C)].

ii. The frequency of submitting ongoing compliance 

status reports may be reduced only after the 

owner or operator notifies the Illinois EPA 

and/or USEPA in writing of his or her 

intention to make such a change, and the 

Illinois EPA and/or USEPA does not object to 

the intended change. In deciding whether to 

approve a reduced reporting frequency, the 

Illinois EPA and/or USEPA may review 

information concerning the source's entire 

previous performance history during the 5-year 

recordkeeping period prior to the intended 

change, or the recordkeeping period since the 

source's compliance date, whichever is 

shorter. Records subject to review may 

include performance test results, monitoring 

data, and evaluations of an owner or 

operator's conformance with emission 

limitations and work practice standards. Such 

information may be used by the Illinois EPA 

and/or USEPA to make a judgment about the 

source's potential for noncompliance in the 

future. If the Illinois EPA and/or USEPA 

disapproves the owner or operator's request to 
65

reduce reporting frequency, the Illinois EPA 

and/or USEPA will notify the owner or operator 

in writing within 45 days after receiving 

notice of the owner or operator's intention. 

The notification from the Illinois EPA and/or 

USEPA to the owner or operator will specify 

the grounds on which the disapproval is based. 

In the absence of a notice of disapproval 

within 45 days, approval is automatically 

granted [40 CFR 63.347(g)(2)(ii)].

iii. As soon as the monitoring data required by 

Condition 7.4.8(a) (see also 40 CFR 63.343(c)) 

show that the source is not in compliance with 

the relevant emission limit, the frequency of 

reporting shall revert to quarterly, and the 

owner shall state this exceedance in the 

ongoing compliance status report for the next 

reporting period. After demonstrating ongoing 

compliance with the relevant emission limit 

for another full year, the owner or operator 

may again request approval from the Illinois 

EPA and/or USEPA to reduce the reporting 

frequency as allowed by paragraph Condition 

7.4.10(b) (see also 40 CFR 63.347(g)(2)) [40 

CFR 63.347(g)(2)(iii)].

c. Pursuant to 40 CFR 63.347(g)(3), contents of ongoing 

compliance status reports. The owner or operator of 

an affected source for which compliance monitoring is 

required in accordance with Condition 7.4.8(a) (see 

also 40 CFR 63.343(c)) shall prepare a summary report 

to document the ongoing compliance status of the 

source. The report must contain the following 

information:

i. The company name and address of the affected 

source [40 CFR 63.347(g)(3)(i)];

ii. An identification of the operating parameter 

that is monitored for compliance 

determination, as required by Condition 

7.4.8(a) (see also 40 CFR 63.343(c)) [40 CFR 

63.347(g)(3)(ii)];

iii. The relevant emission limitation for the 

affected source, and the operating parameter 

value, or range of values, that correspond to 

compliance with this emission limitation as 

specified in the notification of compliance 

status required by 40 CFR 63.347(e) [40 CFR 

63.347(g)(3)(iii)];

iv. The beginning and ending dates of the 

reporting period [40 CFR 63.347(g)(3)(iv)];
66

v. A description of the type of process performed 

in the affected source [40 CFR 

63.347(g)(3)(v)];

vi. The total operating time of the affected 

source during the reporting period [40 CFR 

63.347(g)(3)(vi)];

vii. A summary of operating parameter values, 

including the total duration of excess 

emissions during the reporting period as 

indicated by those values, the total duration 

of excess emissions expressed as a percent of 

the total source operating time during that 

reporting period, and a breakdown of the total 

duration of excess emissions during the 

reporting period into those that are due to 

process upsets, control equipment 

malfunctions, other known causes, and unknown 

causes [40 CFR 63.347(g)(3)(viii)];

viii. A certification by a responsible official, as 

defined in 40 CFR 63.2, that the work practice 

standards in Condition 7.4.5(a) (see also 40 

CFR 63.342(f)) were followed in accordance 

with the operation and maintenance plan for 

the source [40 CFR 63.347(g)(3)(ix)];

ix. If the operation and maintenance plan required 

by Condition 7.4.5(a)(iv) (see also 40 CFR 

63.342(f)(3)) was not followed, an explanation 

of the reasons for not following the 

provisions, an assessment of whether any 

excess emission and/or parameter monitoring 

exceedances are believed to have occurred, and 

a copy of the report(s) required by Condition 

7.4.10(d) (see also 40 CFR 63.342(f)(3)(iv)) 

documenting that the operation and maintenance 

plan was not followed [40 CFR 

63.347(g)(3)(x)];

x. A description of any changes in monitoring, 

processes, or controls since the last 

reporting period [40 CFR 63.347(g)(3)(xi)];

xi. The name, title, and signature of the 

responsible official who is certifying the 

accuracy of the report [40 CFR 

63.347(g)(3)(xii)]; and

xii. The date of the report [40 CFR 

63.347(g)(3)(xiii)].

d. If actions taken by the owner or operator during 

periods of malfunction are inconsistent with the 

procedures specified in the operation and maintenance 

plan required by Condition 7.4.5(a)(iv) (see also 40 

CFR 63.342(f)(3)(i)), the owner or operator shall 
67

record the actions taken for that event and shall 

report by phone such actions within 2 working days 

after commencing actions inconsistent with the plan. 

This report shall be followed by a letter within 7 

working days after the end of the event, unless the 

owner or operator makes alternative reporting 

arrangements, in advance, with the Illinois EPA 

and/or USEPA [40 CFR 63.342(f)(3)(iv)].

e. Emissions of PM in excess of limits in Condition 

7.4.6 within 30 days of such an occurrence.

7.4.11 Operational Flexibility/Anticipated Operating Scenarios

N/A

7.4.12 Compliance Procedures

Compliance with the emission limits shall be based on the 

recordkeeping requirements in Condition 7.4.9 and the 

emission factors and formulas listed below:

a. Compliance with Condition 7.4.3 is assumed to be 

achieved by proper operation of the packed bed 

scrubber systems, as addressed by Condition 7.4.5.

b. To determine compliance with Conditions 5.5.1 and 

7.4.6, chromium and PM emissions from the affected 

plating tanks shall be calculated based on the 

following:

Emission Factor

Pollutant

chromium

(gr/dscf)

2.1 x 10

PM

-5

4.4 x 10-5

These are the emission factors for hard chromium 

electroplating with packed-bed scrubber, Table 12.20-

1, AP-42, Volume I, Fifth Edition, Supplement D, 

July, 1996.

Plating Emissions (lb/hr) = (Air Flow, cfm) x (The 

Appropriate Emission Factor, gr/dscf) x (1 

lb/7,000 gr) x (60 min/hr)
68

7.5 Units MJ8859/61,8886/88,8889/91 Heat Treating Furnaces

7.5.1 Description

There are three large natural gas-fired direct 

harden/temper furnace combinations with firing rates of 6 

- 8 mmBtu/hr, each. These are used to harden and temper 

castings as well as miscellaneous components (i.e., ground 

engaging tools, bearings, caps, etc.). The process being, 

parts loaded into the direct harden furnace which operates 

at 1,700o

F, quenched with a polymer or water quench, then 

conveyed into a temper furnace operating at 1,000o

F. The 

combination of these two processes imparts hardness and 

toughness to the part being heat treated.

7.5.2 List of Emission Units and Pollution Control Equipment

Emission

Unit Description

Emission 

Control

Equipment

MJ8859 Electric Furnace Co. Model #4725-4-E 

Heat Treating Furnace with North 

American Gas Burner Tubes (MJ8859 

Hardening Furnace, 3.165 mmBtu/hr)

None

MJ8861 Electric Furnace Co. Model #4425-4-5 

Heat Treating Furnace with North 

American Gas Burner Tubes (MJ8861 

Temper Furnace, 1.175 mmBtu/hr)

None

MJ8886 Electric Furnace Co. Model #4725-4-E 

Heat Treating Furnace with North 

American Gas Burner Tubes (MJ8886 

Hardening Furnace, 3.784 mmBtu/hr)

None

MJ8888 Electric Furnace Co. Model #4425-4-5 

Heat Treating Furnace with North 

American Gas Burner Tubes (MJ8888 

Temper Furnace, 2.505 mmBtu/hr)

None

MJ8889 Electric Furnace Co. Model #4725-4-E 

Heat Treating Furnace with North 

American Gas Burner Tubes (MJ8889 

Hardening Furnace, 3.784 mmBtu/hr)

None

MJ8891 Electric Furnace Co. Model #4425-4-5 

Heat Treating Furnace with North 

American Gas Burner Tubes (MJ8891 

Temper Furnace, 2.505 mmBtu/hr)

None

7.5.3 Applicability Provisions and Applicable Regulations

a. The heat treating and tempering furnaces are 

“affected furnaces” for the purpose of these unitspecific conditions.

b. Each affected furnace is subject to the emission 

limits identified in Condition 5.2.2.

c. The affected furnaces are subject to 35 IAC 

212.321(a), which provides that:
69

i. No person shall cause or allow the emission of 

particulate matter into the atmosphere in any 

one hour period from any new process emission 

unit, either alone or in combination with the 

emission of particulate matter from all other 

similar process emission units for which 

construction or modification commenced on or 

after April 14, 1972, at a source or premises, 

exceeds the allowable emission rates specified 

in subsection (c) of 35 IAC 212.321 (see also 

Attachment 1) [35 IAC 212.321(a)].

ii. Because the expected process weight rate for 

the affected furnaces is 4,410 pounds per 

hour, combined the allowable PM emission rate 

for the affected furnaces set by 35 IAC 

212.321 is 3.87 pounds per hour, combined.

d. No person shall cause or allow the emission of sulfur 

dioxide into the atmosphere from any process emission 

unit to exceed 2000 ppm, [35 IAC 214.301].

e. No person shall cause or allow the discharge of more 

than 3.6 kg/hr (8 lb/hr) of organic material into the 

atmosphere from any emission unit, except as provided 

in 35 IAC 218.302, 218.303, 218.304 and the following 

exception: If no odor nuisance exists the limitation 

of 35 IAC 218 Subpart G shall apply only to 

photochemically reactive material [35 IAC 218.301].

7.5.4 Non-Applicability of Regulations of Concern

a. The affected furnaces are not subject to 35 IAC 

216.121, Emissions of Carbon Monoxide from Fuel 

Combustion Emission Units, because the actual heat 

input of each unit is less than 2.9 MW (10 mmBtu/hr) 

and the affected furnaces are not by definition fuel 

combustion emission units.

b. The affected furnaces are not subject to 35 IAC 

217.121, emissions of nitrogen oxides from new fuel 

combustion emission sources, because the actual heat 

input of each unit is less than 73.2 MW (250 

mmBtu/hr) and the affected furnaces are not by 

definition fuel combustion emission units.

c. The affected furnaces are not subject to 35 IAC 

212.324, Process Emission Units In Certain Areas, 

because the source is not located in a non-attainment 

area for PM10, as identified in 35 IAC 212.324(a)(1).

7.5.5 Operational and Production Limits and Work Practices

The affected furnaces shall only be operated with natural 

gas as the fuel.

7.5.6 Emission Limitations
70

In addition to Condition 5.2.2 and the source wide 

emission limitations in Condition 5.5, the affected 

furnaces are subject to the following:

a. i. Emissions of nitrogen oxides (NOx) and carbon 

monoxide (CO) from the hardening/temper 

furnaces MJ8859 and MJ 8861 shall not exceed 

2.4 and 0.5 ton/year, respectively. These 

limits are based on the standard emission 

factors for natural gas, a maximum of 8,400 

hours per year of operation, and the maximum 

firing rate.

ii. The above limitations were established in 

Construction Permit 89030028, pursuant to 40 

CFR 52.21, Prevention of Significant 

Deterioration (PSD). These limits ensure that 

the construction and/or modification addressed 

in the aforementioned Construction Permit does 

not constitute a new major source or major 

modification pursuant to Title I of the CAA, 

specifically the federal rules for Prevention 

of Significant Deterioration (PSD), 40 CFR 

52.21.[T1]

b. i. Emissions of nitrogen oxides (NOx) and carbon 

monoxide (CO) from the hardening/temper 

furnaces MJ8886 and MJ 8888 shall not exceed 

2.4 and 0.5 ton/year, respectively. These 

limits are based on the standard emission 

factors for natural gas, a maximum of 8,400 

hours per year of operation, and the maximum 

firing rate.

ii. The above limitations were established in 

Construction Permit 89030029, pursuant to 40 

CFR 52.21, Prevention of Significant 

Deterioration (PSD). These limits ensure that 

the construction and/or modification addressed 

in the aforementioned Construction Permit does 

not constitute a new major source or major 

modification pursuant to Title I of the CAA, 

specifically the federal rules for Prevention 

of Significant Deterioration (PSD), 40 CFR 

52.21.[T1]

c. i. Emissions of nitrogen oxides (NOx) and carbon 

monoxide (CO) from the hardening/temper 

furnaces MJ8889 and MJ 8891 shall not exceed 

2.4 and 0.5 ton/year, respectively. These 

limits are based on the standard emission 

factors for natural gas, a maximum of 8,400 

hours per year of operation, and the maximum 

firing rate.

ii. The above limitations were established in 

Construction Permit 89030030, pursuant to 40 

CFR 52.21, Prevention of Significant 
71

Deterioration (PSD). These limits ensure that 

the construction and/or modification addressed 

in the aforementioned Construction Permit does 

not constitute a new major source or major 

modification pursuant to Title I of the CAA, 

specifically the federal rules for Prevention 

of Significant Deterioration (PSD), 40 CFR 

52.21.[T1]

d. Compliance with annual limits shall be determined on 

a monthly basis from the sum of the data for the 

current month plus the preceding 11 months (running 

12 month total).

7.5.7 Testing Requirements

None

7.5.8 Monitoring Requirements

None

7.5.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the 

Permittee shall maintain records of the following items 

for the affected furnaces to demonstrate compliance with 

Conditions 5.5.1, 7.5.3, and 7.5.6 pursuant to Section 

39.5(7)(b) of the Act:

a. Records of the fuel usage for the affected furnaces, 

Mft3

/mo and Mft3

/yr;

b. The operating schedule of the affected furnaces; and

c. Records of monthly and aggregate annual CO, NOx, PM, 

SO2, and VOM emissions from the affected furnaces 

shall be maintained, based on fuel usage and the 

applicable emission factors, with supporting 

calculations.

7.5.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section of noncompliance of the affected 

furnaces with the permit requirements as follows pursuant 

to Section 39.5(7)(f)(ii) of the Act. Reports shall 

describe the probable cause of such deviations, and any 

corrective actions or preventive measures taken:

Emissions of CO and/or NOx from the affected furnaces 

in excess of the limits specified in Condition 7.5.6 

within 30 days of such an occurrence.

7.5.11 Operational Flexibility/Anticipated Operating Scenarios

N/A
72

7.5.12 Compliance Procedures

Compliance with the emission limits shall be based on the 

recordkeeping requirements in Condition 7.5.9 and the 

emission factors and formulas listed below:

a. Compliance with Condition 7.5.3 is assumed by the 

work-practices inherent in operation of natural gasfired heat treating furnaces.

b. To determine compliance with Conditions 5.5.1 and 

7.5.6, fuel combustion emissions from the affected 

furnaces shall be calculated based on the following 

emission factors:

Emission Factor

Pollutant (lb/Mft3

CO

)

84

NOx 100

PM 7.6

SO2 0.6

VOM 5.5

These are the emission factors for uncontrolled 

natural gas combustion in small boilers (< 100 

mmBtu/hr), Tables 1.4-1 and 1.4-2, AP-42, Volume I, 

Fifth Edition, Supplement D, March, 1998.

Heat Treating Furnace Emissions (lb) = (Natural Gas 

Consumed, Mft3

) x (The Appropriate Emission 

Factor, lb/Mft3

)
73

7.6 Unit VSRS Vacuum Solvent Recovery System

7.6.1 Description

The vacuum solvent recovery system is a small electrically 

heated batch processing distillation unit used to reclaim 

and reuse solvent from the line flushing process during 

paint booth cleanup.

7.6.2 List of Emission Units and Pollution Control Equipment

Emission

Unit Description

Emission 

Control

Equipment

VSRS Chemical Management Technology 

Model #CM55V Vacuum Solvent 

Recovery System

None

7.6.3 Applicability Provisions and Applicable Regulations

a. The Vacuum Solvent Recovery System is an "affected 

recovery system" for the purpose of these unitspecific conditions.

b. The affected recovery system is subject to the 

emission limits identified in Condition 5.2.2.

c. The affected recovery system is subject to 35 IAC 

212.321(a), which provides that:

i. No person shall cause or allow the emission of 

particulate matter into the atmosphere in any 

one hour period from any new process emission 

unit, either alone or in combination with the 

emission of particulate matter from all other 

similar process emission units for which 

construction or modification commenced on or 

after April 14, 1972, at a source or premises, 

exceeds the allowable emission rates specified 

in subsection (c) of 35 IAC 212.321 (see also 

Attachment 1) [35 IAC 212.321(a)].

ii. Because the expected process weight rate for 

the affected recovery system is less than 100 

pounds per hour, the allowable PM emission 

rate for the affected recovery system set by 

35 IAC 212.321 is 0.55 pounds per hour.

d. No person shall cause or allow the discharge of more 

than 3.6 kg/hr (8 lb/hr) of organic material into the 

atmosphere from any emission unit, except as provided 

in 35 IAC 218.302, 218.303, 218.304 and the following 

exception: If no odor nuisance exists the limitation 

of this Subpart shall apply only to photochemically 

reactive material [35 IAC 218.301].

7.6.4 Non-Applicability of Regulations of Concern
74

a. The affected recovery system is not subject to 35 IAC 

212.324, Process Emission Units In Certain Areas, 

because the source is not located in a non-attainment 

area for PM10, as identified in 35 IAC 212.324(a)(1).

b. This permit is issued based on the affected recovery 

system not being subject to 35 IAC 218 Subpart TT, 

Other Emission Units, because the affected recovery 

system does not meet the applicability of 35 IAC 

218.980(a) and (b). In particular, the affected 

recovery system has:

i. Maximum theoretical emissions of VOM that are 

less than 90.7 Mg (100 tons) per year; and

ii. A potential to emit for VOM that is less than 

22.7 Mg (25 tons) per year.

7.6.5 Operational and Production Limits and Work Practices

None

7.6.6 Emission Limitations

In addition to Condition 5.2.2 and the source wide 

emission limitations in Condition 5.5, the affected 

recovery system is subject to the following:

a. This permit is issued based on negligible emissions 

of volatile organic material from the solvent 

distillation unit. For this purpose, emissions from 

this emission unit shall not exceed nominal rates of 

0.1 lb/hr and o.44 ton/yr.

b. The above limitations were established in 

Construction Permit 94040008, pursuant to 35 IAC Part 

203. These limits ensure that the construction 

and/or modification addressed in the aforementioned 

Construction Permit does not constitute a new major 

source or major modification pursuant to Title I of 

the CAA, specifically 35 IAC Part 203.[T1]
75

7.6.7 Testing Requirements

None

7.6.8 Monitoring Requirements

None

7.6.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the 

Permittee shall maintain records of the following items 

for the affected recovery system to demonstrate compliance 

with Conditions 5.5.1, 7.6.3, and 7.6.6 pursuant to 

Section 39.5(7)(b) of the Act:

a. Records of the amount of solvent reclaimed in the 

affected recovery system, ton/mo and ton/yr;

b. The operating schedule of the affected recovery 

system; and

c. Records of monthly and aggregate annual PM and VOM 

emissions from the affected recovery system shall be 

maintained, based on fuel usage and the applicable 

emission factors, with supporting calculations.

7.6.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section of noncompliance of the affected 

recovery system with the permit requirements as follows 

pursuant to Section 39.5(7)(f)(ii) of the Act. Reports 

shall describe the probable cause of such deviations, and 

any corrective actions or preventive measures taken:

Emissions of PM or VOM in excess of the limits in 

Condition 7.6.6(a) based on the current month's 

records plus the preceding 11 months within 30 days 

of such an occurrence.

7.6.11 Operational Flexibility/Anticipated Operating Scenarios

N/A

7.6.12 Compliance Procedures

Compliance with the emission limits shall be based on the 

recordkeeping requirements in Condition 7.6.9 and the 

emission factors and formulas listed below:

To determine compliance with Conditions 5.5.1, 7.6.3, 

and 7.6.6, emissions from the affected recovery 

system shall be calculated based on the following 

emission factors:

Emission Factor

Pollutant (lb/ton)
76

PM 1.44

VOM 3.30

These are the emission factors for solvent 

reclaiming, Table 4.7-1, AP-42, Volume I, Fifth 

Edition, Supplement D, October, 1996. PM emission 

factor is based on the incinerator stack emission 

factor. VOM emission factor is based on the 

condenser vent emission factor.

Solvent Reclaiming Emissions (lb) = (Amount of 

Reclaimed Solvent, ton) x (The Appropriate 

Emission Factor, lb/ton)
77

7.7 Units B1-4 Natural Gas-Fired Boilers (#1 - 4)

7.7.1 Description

The source uses steam heat to heat the entire plant as 

well as providing heat for certain processes (i.e., 

aqueous washers, low temperature ovens, etc.) The burners 

for the boilers are exclusively natural gas fired.

7.7.2 List of Emission Units and Pollution Control Equipment

Emission

Unit Description

Rated Heat 

Input

B1 Springfield Boiler (Cleaver 

Brooks) Model Max W.P. 200 

Natural Gas-Fired Boiler (Boiler 

#1)

110 mmBtu/hr

B2 Springfield Boiler (Coen Burners) 

Model Max W.P. 200 Natural GasFired Boiler (Boiler #2)

112.6 

mmBtu/hr

B3 Springfield Boiler (Coen Burners) 

Model Max W.P. 200 Natural GasFired Boiler (Boiler #3)

175 mmBtu/hr

B4 Springfield Boiler (Cleaver 

Brooks) Model Max W.P. 200 

Natural Gas-Fired Boiler (Boiler 

#4)

137 mmBtu/hr

7.7.3 Applicability Provisions and Applicable Regulations

a. Boilers #1, #2, #3 and #4 are "affected boilers" for 

the purpose of these unit-specific conditions.

b. Each affected boiler is subject to the emission 

limits identified in Condition 5.2.2.

c. No person shall cause or allow the emission of carbon 

monoxide (CO) into the atmosphere from any fuel 

combustion emission source with actual heat input 

greater than 2.9 MW (10 mmBtu/hr) to exceed 200 ppm, 

corrected to 50 percent excess air [35 IAC 216.121].

7.7.4 Non-Applicability of Regulations of Concern

a. The NSPS for Industrial-Commercial-Institutional 

Steam Generating Units, 40 CFR 60, Subpart Db, 

applies to units for which construction, modification 

or reconstruction is commenced after June 19, 1984 

and that have a heat input capacity from fuels 

combusted in the steam generating unit of greater 

than 29 MW (100 mmBtu/hr). The affected boilers were 

constructed in 1972, therefore, these rules do not 

apply.

b. The affected boilers are not subject to 35 IAC 

217.121, emissions of nitrogen oxides from new fuel 

combustion sources, because the actual heat input of 

is less than 73.2 MW (250 mmBtu/hr).
78

c. Pursuant to 35 IAC 218.303, fuel combustion emission 

units are not subject to 35 IAC 218.301, Use Of 

Organic Material.

7.7.5 Operational and Production Limits and Work Practices

The affected boilers shall only be fired with natural gas 

as the fuel.

7.7.6 Emission Limitations

There are no specific emission limitations for these 

units, however, there are source wide emission limitations 

in Condition 5.5 that include these units.

7.7.7 Testing Requirements

None

7.7.8 Monitoring Requirements

None

7.7.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the 

Permittee shall maintain records of the following items 

for the affected boilers to demonstrate compliance with 

Conditions 5.5.1 and 7.7.3 pursuant to Section 39.5(7)(b) 

of the Act:

a. Natural gas fuel usage for the affected boilers, 

Mft3

/mo and Mft3

/yr; and

b. Monthly and annual aggregate NOx, PM, SO2, and VOM 

emissions from the affected boilers shall be 

maintained, based on fuel consumption and the 

applicable emission factors, with supporting 

calculations.
79

7.7.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section of noncompliance of the affected 

boilers with the permit requirements as follows pursuant 

to Section 39.5(7)(f)(ii) of the Act. Reports shall 

describe the probable cause of such deviations, and any 

corrective actions or preventive measures taken:

None

7.7.11 Operational Flexibility/Anticipated Operating Scenarios

N/A

7.7.12 Compliance Procedures

Compliance with the emission limits shall be based on the 

recordkeeping requirements in Condition 7.7.9 and the 

emission factors and formulas listed below:

a. Compliance with Conditions 7.7.3(c) is assumed to be 

achieved by the work-practices inherent in operation 

of natural gas-fired and distillate oil-fired 

boilers.

b. To determine compliance with the emission limits in 

Condition 5.5.1, emissions from the affected boilers 

burning natural gas shall be calculated based on the 

following emission factors:

Natural Gas

Pollutant

Emission Factor

(lb/Mft3

NO

)

x 280

PM 7.6

SO2 0.6

VOM 5.5

These are the emission factors for large wall-fired 

boilers/uncontrolled/pre-NSPS (> 100 mmBtu/hr), 

Tables 1.4-1 and 1.4-2, AP-42, Volume I, Fifth 

Edition, Supplement D, March, 1998.

Boiler Emissions (lb) = (Natural Gas Consumed, Mft3

) 

x (The Appropriate Emission Factor, lb/Mft3

)
80

7.8 Units AH1-3 Make-Up Air Heaters (#1 - 3)

7.8.1 Description

In order to heat an addition to Building B, three 4.5 

mmBtu/hr air make-up heaters were installed on the roof on 

the addition. The three units are identical and 

combustion products along with the heated air are 

exhausted to the building.

7.8.2 List of Emission Units and Pollution Control Equipment

Emission

Unit Description

Rated Heat 

Input

AH1 Industrial Commercial Equipment 

BMA 148 Model S Make-Up Air 

Heater (Make-Up Air Heater #1)

4.5 mmBtu/hr

AH2 Industrial Commercial Equipment 

BMA 148 Model S Make-Up Air 

Heater (Make-Up Air Heater #2)

4.5 mmBtu/hr

AH3 Industrial Commercial Equipment 

BMA 148 Model S Make-Up Air 

Heater (Make-Up Air Heater #3)

4.5 mmBtu/hr

AH4 Industrial Commercial Equipment 

BMA 148 Model S Make-Up Air 

Heater (Make-Up Air Heater #4)

4.5 mmBtu/hr

7.8.3 Applicability Provisions and Applicable Regulations

a. Make-Up Air Heaters #1, 2, and 3 are “affected 

heaters" for the purpose of these unit-specific 

conditions.

b. Each affected heater is subject to the emission 

limits identified in Condition 5.2.2.

c. No person shall cause or allow the emission of sulfur 

dioxide into the atmosphere from any process emission 

unit to exceed 2000 ppm, [35 IAC 214.301].

d. No person shall cause or allow the discharge of more 

than 3.6 kg/hr (8 lb/hr) of organic material into the 

atmosphere from any emission unit, except as provided 

in 35 IAC 218.302, 218.303, or 218.304 and the 

following exemption: If no odor nuisance exists the 

limitation of 35 IAC 218 Subpart G shall only apply 

to photochemically reactive material [35 IAC 

218.301].
81

7.8.4 Non-Applicability of Regulations of Concern

a. The affected heaters are not subject to 35 IAC 

216.121, emissions of carbon monoxide from fuel 

combustion emission units, because the affected 

heaters are not by definition fuel combustion 

emission units.

b. The affected heaters are not subject to 35 IAC 

217.121, Emissions of Nitrogen Oxides from New Fuel 

Combustion Emission Sources, because the actual heat 

input of each unit is less than 73.2 MW (250 

mmBtu/hr) and the affected heaters are not by 

definition fuel combustion emission units.

c. This permit is issued based on the affected heaters 

not being subject to 35 IAC 212.321 because due to 

the unique nature of this process, such rules cannot 

reasonably be applied.

d. The affected heaters are not subject to 35 IAC 

212.324, Process Emission Units In Certain Areas, 

because the source is not located in a non-attainment 

area for PM10, as identified in 35 IAC 212.324(a)(1).

7.8.5 Operational and Production Limits and Work Practices

The affected heaters shall only be operated with natural 

gas as the fuel.

7.8.6 Emission Limitations

There are no specific emission limitations for these units 

however, there are source wide emission limitations in 

Condition 5.5 that include these units.

7.8.7 Testing Requirements

None

7.8.8 Monitoring Requirements

None

7.8.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the 

Permittee shall maintain records of the following items 

for the affected heaters to demonstrate compliance with 

Conditions 5.5.1 and 7.8.3, pursuant to Section 39.5(7)(b) 

of the Act:

a. Natural gas fuel usage for the affected heaters, 

Mft3

/mo and Mft3

/yr; and

b. Monthly and aggregate annual NOx, PM, SO2, and VOM 

emissions from the affected heaters shall be 

maintained, based on fuel consumption and the 
82

applicable emission factors, with supporting 

calculations.

7.8.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section of noncompliance of the affected 

heaters with the permit requirements as follows pursuant 

to Section 39.5(7)(f)(ii) of the Act. Reports shall 

describe the probable cause of such deviations, and any 

corrective actions or preventive measures taken:

None

7.8.11 Operational Flexibility/Anticipated Operating Scenarios

N/A

7.8.12 Compliance Procedures

Compliance with the emission limits shall be based on the 

recordkeeping requirements in Condition 7.8.9 and the 

emission factors and formulas listed below:

a. Compliance with Condition 7.8.3 is assumed to be 

achieved by the work-practices inherent in operation 

of natural gas-fired heaters.

b. To determine compliance with the emission limits in 

Condition 5.5.1, emissions from the affected heaters 

burning natural gas shall be calculated based on the 

following emission factors:

Natural Gas

Pollutant

Emission Factor

(lb/Mft3

NO

)

x 100

PM 7.6

SO2 0.6

VOM 5.5

These are the emission factors for small boilers (< 

100 mmBtu/hr), Tables 1.4-1 and 1.4-2, AP-42, Volume 

I, Fifth Edition, Supplement D, March, 1998.

Heater Emissions (lb) = (Natural Gas Consumed, Mft3

) 

x (The Appropriate Emission Factor, lb/Mft3

)
83

7.9 Unit TT0420 Gasoline Storage Tank

7.9.1 Description

The gas used in plant vehicles (e.g., cars and pickup 

trucks) is dispensed from an underground storage tank. 

The tank is a 10,000 gallon, double walled fiberglass 

tank, with leak detection in the annular space and with a 

vapor recovery vent.

7.9.2 List of Emission Units and Pollution Control Equipment

Emission

Unit Description

Emission 

Control

Equipment

TT0420 Gasoline Storage Tank TT0420 

(10,000 gallons)

None

7.9.3 Applicability Provisions and Applicable Regulations

a. Gasoline Storage Tank TT0420 is an "affected tank" 

for the purpose of these unit-specific conditions.

b. No person shall cause or allow the loading of any 

organic material into any stationary tank having a 

storage capacity of greater than 946 l (250 gal), 

unless such tank is equipped with a permanent 

submerged loading pipe or an equivalent device 

approved by the Illinois EPA according to the 

provisions of 35 IAC 201, and further processed 

consistent with 35 IAC 218.108 [35 IAC 218.122(b)].

c. The affected tank is subject to 35 IAC 218.583(c), 

which provides no person shall cause or allow the 

transfer of gasoline from any delivery vessel into 

any stationary storage tank at a gasoline dispensing 

operation unless:

i. The tank is equipped with a submerged loading 

pipe [35 IAC 218.583(a)(1)]; and

ii. The vapors displaced from the storage tank 

during filling are processed by a vapor 

control system that includes one or more of 

the following:

A. A vapor collection system that meets the 

requirements of Condition 7.9.5(c) (see 

also 35 IAC 218.583(d)(4)) [35 IAC 

218.583(a)(2)(A)]; or

B. A refrigeration-condensation system or any 

other system approved by the Illinois EPA 

and approved by the USEPA as a SIP 

revision, that recovers at least 90 

percent by weight of all vaporized organic

material from the equipment being 

controlled [35 IAC 218.583(a)(2)(B)]; and
84

C. The delivery vessel displays the 

appropriate sticker pursuant to the 

requirements of 35 IAC 218.584(b) or (d) 

[35 IAC 218.583(a)(2)(C)]; and

iii. All tank vent pipes are equipped with 

pressure/vacuum relief valves with the 

pressure/vacuum relief valve shall be set to 

resist a pressure of at least 3.5 inches water 

column and to resist a vacuum of no less than 

6.0 inches water column [35 IAC 

218.583(a)(3)].

d. The affected tank is subject to 35 IAC 218.585, which 

provides that:

i. No person shall sell, offer for sale, 

dispense, supply, offer for supply, or 

transport for use in Illinois gasoline whose 

Reid vapor pressure exceeds the applicable 

limitations set forth in Conditions 

7.9.3(e)(ii) and (e)(iii) (see also 35 IAC 

218.585(b) and (c)) during the regulatory 

control periods, which shall be May 1 to 

September 15 for retail outlets, wholesale 

purchaser-consumer, operations, and all other 

operations [35 IAC 218.585(a)].

ii. The Reid vapor pressure of gasoline, a measure 

of its volatility, shall not exceed 9.0 psi 

(62.07 kPa) during the regulatory control 

period in 1990 and each year thereafter [35 

IAC 218.585(b)].

iii. The Reid vapor pressure of ethanol blend 

gasolines shall not exceed the limitations for 

gasoline set forth in Condition 7.9.3(e)(ii) 

(see also 35 IAC 218.585(b)) by more than 1.0 

psi (6.9 kPa). Notwithstanding this 

limitation, blenders of ethanol blend 

gasolines whose Reid vapor pressure is less 

than 1.0 psi above the base stock gasoline 

immediately after blending with ethanol are 

prohibited from adding butane or any product 

that will increase the Reid vapor pressure of 

the blended gasoline [35 IAC 218.585(c)].

7.9.4 Non-Applicability of Regulations of Concern

a. The affected tank is not subject to the NSPS for 

Volatile Organic Liquid Storage Vessels (Including 

Petroleum Liquid Storage Vessels) for Which 

Construction, Reconstruction, or Modification 

Commenced after July 23, 1984, 40 CFR 60 Subpart Kb, 

because the affected tank has a capacity less than 40 

m3

.
85

b. The affected tank is not subject to the limitations 

of 35 IAC 218.120, Control Requirements for Storage 

Containers of VOL, pursuant to 35 IAC 218.119, 

because the affected tank is used to store a 

petroleum liquid and the capacity is less than 151 m3

(40,000 gal).

c. The affected tank is not subject to the requirements 

of 35 IAC 218.121, Storage Containers of VPL, 

pursuant to 35 IAC 218.123(a)(2), which exempts 

storage tanks with a capacity less than 151.42 m3

(40,000 gal).

d. The affected tank is not subject to the requirements 

of 35 IAC 218.586, Gasoline Dispensing Operations -

Motor Vehicle Fueling Operations, pursuant to 35 IAC 

218.586(b), which exempts any gasoline dispensing 

operation which dispenses an average monthly volume 

of less than 10,000 gallons of motor vehicle fuel per 

month. Pursuant to 35 IAC 218.586(a)(1), average 

monthly volume means the amount of motor vehicle fuel

dispensed per month from a gasoline dispensing 

operation based upon a monthly average for the 2-year 

period of November, 1990 through October, 1992 or, if 

not available, the monthly average for the most 

recent twelve calendar months. Monthly averages are

to include only those months when the operation was 

operating.

7.9.5 Operational and Production Limits and Work Practices

a. The affected tank shall only be used for the storage 

of gasoline.

b. Pursuant to 35 IAC 218.583(c), each owner of a 

gasoline dispensing operation shall:

i. Install all control systems and make all 

process modifications required by Condition 

7.9.3(b) (see also 35 IAC 218.583(a)) [35 IAC 

218.583(c)(1)];

ii. Provide instructions to the operator of the 

gasoline dispensing operation describing 

necessary maintenance operations and 

procedures for prompt notification of the 

owner in case of any malfunction of a vapor 

control system [35 IAC 218.583(c)(2)]; and

iii. Repair, replace or modify any worn out or 

malfunctioning component or element of design 

[35 IAC 218.583(c)(3)].

c. Pursuant to 35 IAC 218.583(d), each operator of a 

gasoline dispensing operation shall:
86

i. Maintain and operate each vapor control system 

in accordance with the owner's instructions 

[35 IAC 218.583(d)(1)];

ii. Promptly notify the owner of any scheduled 

maintenance or malfunction requiring 

replacement or repair of a major component of 

a vapor control system [35 IAC 218.583(d)(2)];

iii. Maintain gauges, meters or other specified 

testing devices in proper working order [35 

IAC 218.583(d)(3)]; and

iv. Operate the vapor collection system and 

delivery vessel unloading points in a manner 

that prevents:

A. A reading equal to or greater than 100 

percent of the LEL (measured as propane) 

when tested in accordance with the 

procedure described in EPA 450/2-78-051 

Appendix B [35 IAC 218.583(d)(4)(A)]; and

B. Avoidable leaks of liquid during the 

filling of storage tanks [35 IAC 

218.583(d)(4)(B)].

7.9.6 Emission Limitations

In addition to Condition 5.2.2 and the source wide 

emission limitations in Condition 5.5, the affected tank 

is subject to the following:

a. Emissions of volatile organic material from the 

gasoline storage tank shall not exceed 0.1 ton/year. 

This limit is based on standard emission factors for 

gasoline tanks and 25,000 gallons/year throughput of 

the tank.

b. The above limitations were established in 

Construction Permit 86110017, pursuant to 35 IAC Part 

203. These limits ensure that the construction 

and/or modification addressed in the aforementioned 

Construction Permit does not constitute a new major 

source or major modification pursuant to Title I of 

the CAA, specifically 35 IAC Part 203.[T1]

7.9.7 Testing Requirements

a. Pursuant to 35 IAC 218.583(a)(4), no person shall 

cause or allow the transfer of gasoline from any 

delivery vessel into any stationary storage tank at a 

gasoline dispensing operation unless the owner or 

operator of a gasoline dispensing operation 

demonstrates compliance with Condition 7.9.3(c)(iii) 

(see also 35 IAC 218.583(a)(3)), by March 15, 1995 or 

30 days after installation of each pressure/vacuum 

relief valve, whichever is later, and at least 
87

annually thereafter, by measuring and recording the 

pressure indicated by a pressure/vacuum gauge at each 

tank vent pipe. The test shall be performed on each 

tank vent pipe within two hours after product 

delivery into the respective storage tank. For 

manifold tank vent systems, observations at any point 

within the system shall be adequate. The owner or 

operator shall maintain any records required by this 

Condition for a period of three years.

b. Within 15 business days after discovery of the leak 

by the owner, operator, or the Illinois EPA, repair 

and retest a vapor collection system which exceeds 

the limits of Condition 7.9.5(c)(4)(A) (see also 35 

IAC 218.583(d)(4)(A)) [35 IAC 218.583(d)(5)].

c. Upon reasonable request by the Illinois EPA, pursuant 

to Section 39.5(7)(b) of the Act, the Reid vapor 

pressure of gasoline and the ethanol content of 

ethanol blend gasolines shall be determine according 

to the methods specified below:

i. Pursuant to 35 IAC 218.585(d), all sampling of 

gasoline required pursuant to the provisions 

of Conditions 7.9.7(c)(ii) and (c)(iii) (see 

also 35 IAC 218.585(e) and (f)) shall be 

conducted by one or more of the following 

approved methods or procedures:

A. For manual sampling, ASTM D4057 [35 IAC 

218.585(d)(1)];

B. For automatic sampling, ASTM D4177 [35 IAC 

218.585(d)(2)]; or

C. Sampling procedures for Fuel Volatility, 

40 CFR 80 Appendix D [35 IAC 

218.585(d)(3)].

ii. The Reid vapor pressure of gasoline shall be 

measured in accordance with either test method 

ASTM D323 or a modification of ASTM D323 known 

as the "dry method" as set forth in 40 CFR 80, 

Appendix E. For gasoline - oxygenate blends 

which contain water-extractable oxygenates, 

the Reid vapor pressure shall be measured 

using the dry method test [35 IAC 218.585(e)].

iii. The ethanol content of ethanol blend gasolines 

shall be determined by use of one of the 

approved testing methodologies specified in 40 

CFR 80, Appendix F [35 IAC 218.585(f)].

7.9.8 Monitoring Requirements

None

7.9.9 Recordkeeping Requirements
88

In addition to the records required by Condition 5.6, the 

Permittee shall maintain records of the following items 

for the affected tank to demonstrate compliance with 

Conditions 5.5.1 and 7.9.3 pursuant to Section 39.5(7)(b) 

of the Act:

a. Records of the testing of the affected tank pursuant 

to Condition 7.9.7, which include the following 

[Section 39.5(7)(e) of the Act]:

i. The date, place and time of sampling or 

measurements;

ii. The date(s) analyses were performed;

iii. The company or entity that performed the 

analyses;

iv. The analytical techniques or methods used;

v. The results of such analyses; and

vi. The operating conditions as existing at the 

time of sampling or measurement.

b. Each storage vessel with a design capacity less than 

40,000 gallons is subject to no provisions of 35 IAC 

Part 218 other than those required by maintaining 

readily accessible records of the dimensions of the 

storage vessel and analysis of the capacity of the 

storage vessel [35 IAC 218.129(f)].

c. Design information for the tank showing the presence 

of a permanent submerged loading pipe;

d. Maintenance and repair records for the tank, as 

related to the repair or replacement of the loading 

pipe;

e. The throughput of the affected tank, gal/mo and 

gal/yr; and

f. The annual VOM emissions from the affected tank based 

on the material stored, the tank throughput, and the 

applicable emission factors and formulas with 

supporting calculations.

7.9.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section of noncompliance of an affected tank 

with the permit requirements as follows pursuant to 

Section 39.5(7)(f)(ii) of the Act. Reports shall describe 

the probable cause of such deviations, and any corrective 

actions or preventive measures taken:
89

a. Any storage of VOL in an affected tank that is not in 

compliance with the requirements of Conditions 

7.9.3(b) and (c)(i) (see also 35 IAC 218.122(b) and 

218.583(a)(1)), e.g., no "permanent submerged loading 

pipe," within five days of becoming aware of the noncompliance status. This notification shall include a 

description of the event, the cause for the noncompliance, actions taken to correct the noncompliance, and the steps taken to avoid future noncompliance;

b. Any storage of VOL in an affected tank that is out of 

compliance with the requirements of Conditions 

7.9.3(b) and (c)(i) (see also 35 IAC 218.122(b) and 

218.583(a)(1)) due to damage, deterioration, or other 

condition of the loading pipe, within 30 days of 

becoming aware of the non-compliance status. This 

notification shall include a description of the 

event, the cause for the non-compliance, actions 

taken to correct the non-compliance, and the steps to 

be taken to avoid future non-compliance;

c. Upon request by the Illinois EPA, the owner or 

operator of a gasoline dispensing operation which 

claims to be exempt from the requirements of 35 IAC 

218.586 shall submit records to the Illinois EPA 

within 30 calendar days from the date of the request 

which demonstrate that the gasoline dispensing 

operation is in fact exempt; and

d. The storage of any VOL or VPL other than the material 

specified in Condition 7.9.5(a) within 30 days of 

becoming aware of the non-compliance status. This 

notification shall include a description of the 

event, the cause for the non-compliance, actions 

taken to correct the non-compliance, and the steps to 

be taken to avoid future non-compliance.

7.9.11 Operational Flexibility/Anticipated Operating Scenarios

N/A

7.9.12 Compliance Procedures

Compliance with the emission limits shall be based on the 

recordkeeping requirements in Condition 7.9.9 and the 

emission factors and formulas listed below:

For the purpose of estimating VOM emissions from each 

affected tank, the version 3.1 of the TANKS program 

is acceptable.
90

8.0 GENERAL PERMIT CONDITIONS

8.1 Permit Shield

Pursuant to Section 39.5(7)(j) of the Act, the Permittee has 

requested and has been granted a permit shield. This permit 

shield provides that compliance with the conditions of this permit

shall be deemed compliance with applicable requirements which were

applicable as of the date the proposed permit for this source was 

issued, provided that either the applicable requirements are 

specifically identified within this permit, or the Illinois EPA, 

in acting on this permit application, has determined that other 

requirements specifically identified are not applicable to this 

source and this determination (or a concise summary thereof) is 

included in this permit.

This permit shield does not extend to applicable requirements 

which are promulgated after May 5, 1999 (the date of issuance of 

the draft permit) unless this permit has been modified to reflect 

such new requirements.

8.2 Applicability of Title IV Requirements (Acid Deposition Control)

This source is not an affected source under Title IV of the CAA 

and is not subject to requirements pursuant to Title IV of the 

CAA.

8.3 Emissions Trading Programs

No permit revision shall be required for increases in emissions 

allowed under any USEPA approved economic incentives, marketable 

permits, emissions trading, and other similar programs or 

processes for changes that are provided for elsewhere in this 

permit and that are authorized by the applicable requirement 

[Section 39.5(7)(o)(vii) of the Act].

8.4 Operational Flexibility/Anticipated Operating Scenarios

8.4.1 Changes Specifically Addressed by Permit

Physical or operational changes specifically addressed by 

the Conditions of this permit that have been identified as 

not requiring Illinois EPA notification may be implemented 

without prior notice to the Illinois EPA.

8.4.2 Changes Requiring Prior Notification

The Permittee is authorized to make physical or 

operational changes without applying for or obtaining an 

amendment to this permit, provided that the changes do not 

constitute a modification under Title I of the CAA, 

emissions will not exceed the emissions allowed under this 

permit following implementation of the physical or 

operational change and the Permittee provides written 

notice to the Illinois EPA, Division of Air Pollution 

Control, Permit Section, at least 7 days before 

commencement of the change [Section 39.5(12)(a) of the 

Act]. This notice shall:
91

a. Describe the physical or operational change;

b. Identify the schedule for implementing the physical 

or operational change;

c. Provide a statement of whether or not any New Source 

Performance Standard (NSPS) is applicable to the 

physical or operational change and the reason why the 

NSPS does or does not apply;

d. Provide emission calculations which demonstrate that 

the physical or operational change will not result in 

a modification; and

e. Provide a certification that the physical or 

operational change will not result in emissions 

greater than authorized under the Conditions of this 

permit.

8.5 Testing Procedures

Tests conducted to measure composition of materials, efficiency of

pollution control devices, emissions from process or control 

equipment, or other parameters shall be conducted using standard 

test methods. Documentation of the test date, conditions, 

methodologies, calculations, and test results shall be retained 

pursuant to the recordkeeping procedures of this permit. Reports 

of any tests conducted as required by this permit or as the result

of a request by the Illinois EPA shall be submitted as specified 

in Condition 8.6.

8.6 Reporting Requirements

8.6.1 Monitoring Reports

A report summarizing required monitoring as specified in

the conditions of this permit shall be submitted to the 

Air Compliance Section of the Illinois EPA every six 

months as follows [Section 39.5(7)(f) of the Act]:
92

Monitoring Period

January - June

Report Due Date

September 1

July - December March 1

All instances of deviations from permit requirements must 

be clearly identified in such reports. All such reports 

shall be certified in accordance with Condition 9.9.

8.6.2 Test Notifications

Unless otherwise specified elsewhere in this permit, a 

written test plan for any test required by this permit 

shall be submitted to the Illinois EPA for review at least 

60 days prior to the testing pursuant to Section 

39.5(7)(a) of the Act. The notification shall include at 

a minimum:

a. The name and identification of the affected unit(s);

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

analysis and their experience with similar tests;

c. The specific conditions under which testing will be 

performed, including a discussion of why these 

conditions will be representative of maximum 

emissions and the means by which the operating 

parameters for the source and any control equipment 

will be determined;

d. The specific determination of emissions and operation 

which are intended to be made, including sampling and 

monitoring locations;

e. The test method(s) which will be used, with the 

specific analysis method, if the method can be used 

with different analysis methods;

f. Any minor changes in standard methodology proposed to 

accommodate the specific circumstances of testing, 

with justification; and

g. Any proposed use of an alternative test method, with 

detailed justification.

8.6.3 Test Reports

Unless otherwise specified elsewhere in this permit, the 

results of any test required by this permit shall be 

submitted to the Illinois EPA within 60 days of completion 

of the testing. The test report shall include at a 

minimum [Section 39.5(7)(e)(i) of the Act]:

a. The name and identification of the affected unit(s);

b. The date and time of the sampling or measurements;

c. The date any analyses were performed;
93

d. The name of the company that performed the tests 

and/or analyses;

e. The test and analytical methodologies used;

f. The results of the tests including raw data, and/or 

analyses including sample calculations;

g. The operating conditions at the time of the sampling 

or measurements; and

h. The name of any relevant observers present including 

the testing company’s representatives, any Illinois 

EPA or USEPA representatives, and the representatives 

of the source.

8.6.4 Reporting Addresses

a. The following addresses should be utilized for the 

submittal of reports, notifications, and renewals:

i. Illinois EPA - Air Compliance Section

Illinois Environmental Protection Agency

Bureau of Air

Compliance Section (MC 40)

P.O. Box 19276

Springfield, Illinois 62794-9276

ii. Illinois EPA - Air Regional Field Office

Illinois Environmental Protection Agency

Division of Air Pollution Control

Eisenhower Tower

1701 First Avenue

Maywood, Illinois 60153
94

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

Illinois Environmental Protection Agency

Division of Air Pollution Control

Permit Section

P.O. Box 19506

Springfield, Illinois 62794-9506

iv. USEPA Region 5 - Air Branch

USEPA (AR - 17J)

Air & Radiation Division

77 West Jackson Boulevard

Chicago, Illinois 60604

b. Unless otherwise specified in the particular 

provision of this permit, reports shall be sent to 

the Illinois EPA - Air Compliance Section with a copy 

sent to the Illinois EPA - Air Regional Field Office.

8.7 Obligation to comply with Title I requirements

Any term, condition, or requirement identified in this permit by 

T1, T1R, or T1N is established or revised pursuant to 35 IAC Part 

203 or 40 CFR 52.21 (“Title I provisions”) and incorporated into 

this permit pursuant to both Section 39.5 and Title I provisions. 

Notwithstanding the expiration date on the first page of this 

permit, the Title I conditions remain in effect pursuant to Title 

I provisions until the Illinois EPA deletes or revises them in 

accordance with Title I procedures.
95

9.0 STANDARD PERMIT CONDITIONS

9.1 Effect of Permit

9.1.1 The issuance of this permit does not release the Permittee 

from compliance with State and Federal regulations which 

are part of the Illinois State Implementation Plan, as 

well as with other applicable statutes and regulations of 

the United States or the State of Illinois or applicable 

ordinances, except as specifically stated in this permit 

and as allowed by law and rule [Section 39.5(7)(j)(iv) of 

the Act].

9.1.2 In particular, this permit does not alter or affect the 

following:

a. The provisions of Section 303 (emergency powers) of 

the CAA, including USEPA's authority under that 

Section;

b. The liability of an owner or operator of a source for 

any violation of applicable requirements prior to or 

at the time of permit issuance;

c. The applicable requirements of the acid rain program 

consistent with Section 408(a) of the CAA; and

d. The ability of USEPA to obtain information from a 

source pursuant to Section 114 (inspections, 

monitoring, and entry) of the CAA.

9.1.3 Notwithstanding the conditions of this permit specifying 

compliance practices for applicable requirements, any 

person (including the Permittee) may also use other 

credible evidence to establish compliance or noncompliance 

with applicable requirements.

9.2 General Obligations of Permittee

9.2.1 Duty to Comply

The Permittee must comply with all terms and conditions of 

this permit. Any permit noncompliance constitutes a 

violation of the CAA and the Act, and is grounds for any 

or all of the following: enforcement action, permit 

termination, revocation and reissuance, modification, or 

denial of a permit renewal application [Section 

39.5(7)(o)(i) of the Act].

The Permittee shall meet applicable requirements that

become effective during the permit term in a timely manner 

unless an alternate schedule for compliance with the 

applicable requirement is established.

9.2.2 Duty to Maintain Equipment

The Permittee shall maintain all equipment covered under 

this permit in such a manner that the performance or 
96

operation of such equipment shall not cause a violation of 

applicable requirements.

9.2.3 Duty to Cease Operation

No person shall cause, threaten or allow the continued 

operation of any emission unit during malfunction or 

breakdown of the emission unit or related air pollution 

control equipment if such operation would cause a 

violation of an applicable emission standard, regulatory 

requirement, ambient air quality standard or permit 

limitation unless such malfunction or breakdown is allowed 

by a permit condition [Section 39.5(6)(c) of the Act].

9.2.4 Disposal Operations

The source shall be operated in such a manner that the 

disposal of air contaminants collected by the equipment 

operations, or activities shall not cause a violation of 

the Act or regulations promulgated thereunder.

9.2.5 Duty to Pay Fees

The Permittee must pay fees to the Illinois EPA consistent 

with the fee schedule approved pursuant to Section 

39.5(18) of the Act, and submit any information relevant 

thereto [Section 39.5(7)(o)(vi) of the Act]. The check 

should be payable to "Treasurer, State of Illinois" and 

sent to: Fiscal Services Section, Illinois Environmental 

Protection Agency, P.O. Box 19276, Springfield, Illinois 

62794-9276.

9.3 Obligation to Allow Illinois EPA Surveillance

Upon presentation of proper credentials and other documents, the 

Permittee shall allow the Illinois EPA, or an authorized 

representative to perform the following [Section 39.5(7)(p)(ii) 

of the Act]:

a. Enter upon the Permittee's premises where an actual or 

potential emission unit is located; where any regulated 

equipment, operation, or activity is located or where 

records must be kept under the conditions of this permit;

b. Have access to and copy, at reasonable times, any records 

that must be kept under the conditions of this permit;

c. Inspect during hours of operation any sources, equipment 

(including monitoring and air pollution control 

equipment), practices, or operations regulated or required 

under this permit;

d. Sample or monitor any substances or parameters at any 

location:

i. At reasonable times, for the purposes of assuring 

permit compliance; or
97

ii. As otherwise authorized by the CAA, or the Act.

e. Obtain and remove samples of any discharge or emission of 

pollutants; and

f. Enter and utilize any photographic, recording, testing, 

monitoring, or other equipment for the purposes of 

preserving, testing, monitoring, or recording any 

activity, discharge or emission at the source.

9.4 Obligation to Comply With Other Requirements

The issuance of this permit does not release the Permittee from 

applicable State and Federal laws and regulations, and applicable 

local ordinances addressing subjects other than air pollution 

control.

9.5 Liability

9.5.1 Title

This permit shall not be considered as in any manner 

affecting the title of the premises upon which the 

permitted source is located.

9.5.2 Liability of Permittee

This permit does not release the Permittee from any 

liability for damage to person or property caused by or 

resulting from the construction, maintenance, or operation 

of the sources.

9.5.3 Structural Stability

This permit does not take into consideration or attest to 

the structural stability of any unit or part of the 

source.

9.5.4 Illinois EPA Liability

This permit in no manner implies or suggests that the 

Illinois EPA (or its officers, agents or employees) 

assumes any liability, directly or indirectly, for any 

loss due to damage, installation, maintenance, or 

operation of the source.

9.5.5 Property Rights

This permit does not convey any property rights of any 

sort, or any exclusive privilege [Section 39.5(7)(o)(iv) 

of the Act].

9.6 Recordkeeping

9.6.1 Control Equipment Maintenance Records

A maintenance record shall be kept on the premises for 

each item of air pollution control equipment. As a 
98

minimum, this record shall show the dates of performance 

and nature of preventative maintenance activities.

9.6.2 Records of Changes in Operation

A record shall be kept describing changes made at the 

source that result in emissions of a regulated air 

pollutant subject to an applicable requirement, but not 

otherwise regulated under this permit, and the emissions 

resulting from those changes [Section 39.5(12)(b)(iv) of 

the Act].

9.6.3 Retention of Records

a. Records of all monitoring data and support 

information shall be retained for a period of at 

least 5 years from the date of the monitoring sample, 

measurement, report, or application. Support 

information includes all calibration and maintenance 

records, original strip-chart recordings for 

continuous monitoring instrumentation, and copies of 

all reports required by this permit [Section 

39.5(7)(e)(ii) of the Act].

b. Other records required by this permit shall be 

retained for a period of at least 5 years from the 

date of entry unless a longer period is specified by 

a particular permit provision.
99

9.7 Annual Emissions Report

The Permittee shall submit an annual emissions report to the 

Illinois EPA, Compliance Section no later than May 1 of the 

following year, as required by 35 IAC Part 254.

9.8 Requirements for Compliance Certification

Pursuant to Section 39.5(7)(p)(v) of the Act, the Permittee shall 

submit compliance certifications annually or more frequently as 

specified in the applicable requirement or by permit condition.

a. The certification shall include the identification of each 

term or condition of this permit that is the basis of the 

certification; the compliance status; whether compliance 

was continuous or intermittent; the method(s) used for 

determining the compliance status of the source, both 

currently and over the reporting period consistent with 

the conditions of this permit.

b. All compliance certifications shall be submitted to USEPA 

Region 5 in Chicago as well as to the Illinois EPA.

c. All compliance reports required to be submitted shall 

include a certification in accordance with Condition 9.9.

9.9 Certification

Any document (including reports) required to be submitted by this 

permit shall contain a certification by a responsible official of 

the Permittee that meets the requirements of Section 39.5(5) of 

the Act [Section 39.5(7)(p)(i) of the Act]. An example 

Certification by a Responsible Official is included as an 

attachment to this permit.

9.10 Defense to Enforcement Actions

9.10.1 Need to Halt or Reduce Activity Not a Defense

It shall not be a defense for the Permittee in an 

enforcement action that it would have been necessary to 

halt or reduce the permitted activity in order to maintain 

compliance with the conditions of this permit [Section 

39.5(7)(o)(ii) of the Act].

9.10.2 Emergency Provision

a. An emergency shall be an affirmative defense to an 

action brought for noncompliance with the technologybased emission limitations under this permit if the 

following conditions are met through properly signed, 

contemporaneous operating logs, or other relevant 

evidence:

i. An emergency occurred as provided in Section 

39.5(7)(k) of the Act and the Permittee can 

identify the cause(s) of the emergency. 
100

Normally, an act of God such as lightning or 

flood is considered an emergency;

ii. The permitted source was at the time being 

properly operated;

iii. The Permittee submitted notice of the 

emergency to the Illinois EPA within two 

working days of the time when emission 

limitations were exceeded due to the 

emergency. This notice must contain a 

detailed description of the emergency, any 

steps taken to mitigate emissions, and 

corrective actions taken; and

iv. During the period of the emergency the 

Permittee took all reasonable steps to 

minimize levels of emissions that exceeded the 

emission limitations, standards, or 

regulations in this permit.

b. This provision is in addition to any emergency or 

upset provision contained in any applicable 

requirement. This provision does not relieve a 

Permittee of any reporting obligations under existing 

federal or state laws or regulations.

9.11 Permanent Shutdown

This permit only covers emission units and control equipment while

physically present at the indicated source location(s). Unless 

this permit specifically provides for equipment relocation, this 

permit is void for the operation or activity of any item of 

equipment on the date it is removed from the permitted location(s)

or permanently shut down. This permit expires if all equipment is

removed from the permitted location(s), notwithstanding the 

expiration date specified on this permit.

9.12 Reopening and Reissuing Permit for Cause

9.12.1 Permit Actions

This permit may be modified, reopened, and reissued, for 

cause pursuant to Section 39.5(15) of the Act. The filing 

of a request by the Permittee for a permit modification, 

revocation, and reissuance, or of a notification of 

planned changes or anticipated noncompliance does not stay 

any permit condition [Section 39.5(7)(o)(iii) of the 

Act].

9.12.2 Reopening and Revision

This permit must be reopened and revised if any of the 

following occur [Section 39.5(15)(a) of the Act]:

a. Additional requirements become applicable to the 

equipment covered by this permit and three or more 

years remain before expiration of this permit;
101

b. Additional requirements become applicable to an 

affected source for acid deposition under the acid 

rain program;

c. The Illinois EPA or USEPA determines that this permit 

contains a material mistake or inaccurate statement 

when establishing the emission standards or 

limitations, or other terms or conditions of this 

permit; and

d. The Illinois EPA or USEPA determines that this permit 

must be revised to ensure compliance with the 

applicable requirements of the Act.

9.12.3 Inaccurate Application

The Illinois EPA has issued this permit based upon the 

information submitted by the Permittee in the permit 

application. Any misinformation, false statement or 

misrepresentation in the application shall be grounds for 

revocation under Section 39.5(15)(b) of the Act.

9.12.4 Duty to Provide Information

The Permittee shall furnish to the Illinois EPA, within a 

reasonable time specified by the Illinois EPA any 

information that the Illinois EPA may request in writing 

to determine whether cause exists for modifying, revoking 

and reissuing, or terminating this permit, or to determine 

compliance with this permit. Upon request, the Permittee 

shall also furnish to the Illinois EPA copies of records 

required to be kept by this permit, or for information 

claimed to be confidential, the Permittee may furnish such 

records directly to USEPA along with a claim of 

confidentiality [Section 39.5(7)(o)(v) of the Act].
102

9.13 Severability Clause

The provisions of this permit are severable, and should any one or

more be determined to be illegal or unenforceable, the validity of

the other provisions shall not be affected. The rights and 

obligations of the Permittee shall be construed and enforced as if

this permit did not contain the particular provisions held to be 

invalid and the applicable requirements underlying these 

provisions shall remain in force [Section 39.5(7)(i) of the Act].

9.14 Permit Expiration and Renewal

The right to operate terminates on the expiration date unless the 

Permittee has submitted a timely and complete renewal application. 

For a renewal to be timely it must be submitted no later than 9 

and no sooner than 12 months prior to expiration. The equipment 

may continue to operate during the renewal period until final 

action is taken by the Illinois EPA, in accordance with the 

original permit conditions [Section 39.5(5)(l), (n), and (o) of 

the Act].
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10.0 ATTACHMENTS

10.1 Attachment 1 Emissions of Particulate Matter from New Process 

Emission Units

10.1.1 Process Emission Units for Which Construction or 

Modification Commenced On or After April 14, 1972

a. No person shall cause or allow the emission of 

particulate matter into the atmosphere in any one 

hour period from any new process emission unit, 

either alone or in combination with the emission of 

particulate matter from all other similar process 

emission units for which construction or modification 

commenced on or after April 14, 1972, at a source or 

premises, exceeds the allowable emission rates 

specified in subsection (c) of 35 IAC 212.321 [35 IAC 

212.321(a)].

b. Interpolated and extrapolated values of the data in 

subsection (c) of 35 IAC 212.321 shall be determined 

by using the equation [35 IAC 212.321(b)]:

E = A(P)B

where

P = Process weight rate; and

E = Allowable emission rate; and,

i. Up to process weight rates of 408 Mg/hr (450 

T/hr):

Metric English

P Mg/hr T/hr

E kg/hr lb/hr

A 1.214 2.54

B 0.534 0.534

ii. For process weight rate greater than or equal 

to 408 Mg/hr (450 T/hr):

Metric English

P Mg/hr T/hr

E kg/hr lb/hr

A 11.42 24.8

B 0.16 0.16

c. Limits for Process Emission Units For Which 

Construction or Modification Commenced On or After 

April 19, 1972 [35 IAC 212.321(c)]:

Metric English

P E P E

Mg/hr kg/hr T/hr lb/hr

0.05 0.25 0.05 0.55

0.1 0.29 0.10 0.77

0.2 0.42 0.2 1.10
1-2

0.3 0.64 0.30 1.35

0.4 0.74 0.40 1.58

0.5 0.84 0.50 1.75

0.7 1.00 0.75 2.40

0.9 1.15 1.00 2.60

1.8 1.66 2.00 3.70

2.7 2.1 3.00 4.60

3.6 2.4 4.00 5.35

4.5 2.7 5.00 6.00

9.0 3.9 10.00 8.70

13.0 4.8 15.00 10.80

18.0 5.7 20.00 12.50

23.0 6.5 25.00 14.00

27.0 7.1 30.00 15.60

32.0 7.7 35.00 17.00

36.0 8.2 40.00 18.20

41.0 8.8 45.00 19.20

45.0 9.3 50.00 20.50

90.0 13.4 100.00 29.50

140.0 17.0 150.00 37.00

180.0 19.4 200.00 43.00

230.0 22.0 250.00 48.50

270.0 24.0 300.00 53.00

320.0 26.0 350.00 58.00

360.0 28.0 400.00 62.00

408.0 30.1 450.00 66.00

454.0 30.4 500.00 67.00
2-1

10.2 Attachment 2 Example Certification by a Responsible Official

I certify under penalty of law that this document and all 

attachments were prepared under my direction or supervision in 

accordance with a system designed to assure that qualified 

personnel properly gather and evaluate the information submitted. 

Based on my inquiry of the person or persons directly responsible 

for gathering the information, the information submitted is, to 

the best of my knowledge and belief, true, accurate, and complete. 

I am aware that there are significant penalties for submitting 

false information, including the possibility of fine and 

imprisonment for knowing violations.

Signature ______________________________________________

Name ______________________________________________

Official Title ______________________________________________

Telephone No. ______________________________________________

Date Signed ______________________________________________

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