217/782-2113 

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

and 

TITLE I PERMIT1

PERMITTEE

Quebecor World Mt. Morris II, Inc. 

Attn: Robert Carpenter 

404 North Wesley Avenue 

Mt. Morris, Illinois 61054 

Application No.: 95080108 I.D. No.: 141035AAA 

Applicant’s Designation: Date Received: August 23, 1995 

Operation of: Printing Facility 

Date Issued: November 17, 2003 Expiration Date2

: November 17, 2008 

Source Location: 404 North Wesley Avenue, Mt. Morris, IL, Ogle County 

Responsible Official: David Miller, Vice President and General Manager 

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

printing facility, 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 David 

Hulskotter at 217/782-2113. 

Donald E. Sutton, P.E. 

Manager, Permit Section 

Division of Air Pollution Control 

DES:DWH:psj 

cc: Illinois EPA, FOS, Region 2 

CES 

Lotus Notes 

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

compliance if determined applicable, of Title I of the CAA and regulations promulgated 

thereunder, including 40 CFR 52.21 – Federal PSD and 35 IAC Part 203 – Major Stationary 

Sources Construction and Modification. Any such terms and conditions are identified 

within this permit. 

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

TABLE OF CONTENTS 

 PAGE

 

1.0 SOURCE IDENTIFICATION 4 

 

 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 5 

 

3.0 INSIGNIFICANT ACTIVITIES 6 

 

 3.1 Identification of Insignificant Activities 

 3.2 Compliance with Applicable Requirements 

 3.3 Addition of Insignificant Activities 

 

4.0 SIGNIFICANT EMISSION UNITS AT THIS SOURCE 8 

 

5.0 OVERALL SOURCE CONDITIONS 10 

 

 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 NOT APPLICABLE TO THIS PERMIT 15 

 

7.0 UNIT SPECIFIC CONDITIONS 16 

 

 7.1 Rotogravure Printing Presses 

 7.2 Lithographic Offset Printing Presses 

 7.3 Paper Cutting and Shredding Operations 

 7.4 Gas Fired Boilers 

 7.5 Cleaning Tanks 

 7.6 Ink Jetting 

 7.7 Chromium Electroplating 

 

8.0 GENERAL PERMIT CONDITIONS 47 

 

 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 
3 

 PAGE

 

 8.6 Reporting Requirements 

 8.7 Obligation to Comply with Title I Requirements 

 

9.0 STANDARD PERMIT CONDITIONS 52 

 

 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 Requirements 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 

 

10.0 ATTACHMENTS 

 

 10.1 Attachment 1 - Example Certification by a Responsible 

Official 

1-1 

 10.2 Attachment 2 – Guidance on Revising This Permit 2-1 

 10.3 Attachment 3 – Form 199-CAAPP, Application For 

Construction Permit (For CAAPP Sources Only)

3-1 

 10.4 Attachment 4 – Guidance on Renewing This Permit 4-1 
4 

1.0 SOURCE IDENTIFICATION 

1.1 Source 

Quebecor World Mt. Morris, Inc. 

404 North Wesley Avenue 

Mt. Morris, Illinois 61054 

815/734-4121 

I.D. No.: 141035AAA 

Standard Industrial Classification: 2754, Gravure Printing 

2752, Lithographic Printing 

1.2 Owner/Parent Company 

Quebecor World Mt. Morris II, Inc. 

404 North Wesley Avenue 

Mt. Morris, Illinois 61054 

1.3 Operator 

Quebecor World Mt. Morris 

404 North Wesley Avenue 

Mt. Morris, Illinois 61054 

Robert Carpenter/Environmental Coordinator 

815/734-4121 

1.4 General Source Description 

Quebecor World is located at 404 North Wesley Avenue in Mt. 

Morris. Quebecor World is a commercial printer providing, 

binding and mailing services to the publishing industry. The 

primary products manufactured at this site include, but are not 

limited to, magazines, catalogs, newspaper inserts, tabloid 

magazines, and retail and wholesale advertising circulars. 
5 

2.0 LIST OF ABBREVIATIONS/ACRONYMS USED IN THIS PERMIT 

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

AP-42 Compilation of Air Pollutant 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 27711 

Btu British thermal unit 

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

CAAPP Clean Air Act Permit Program 

CAM Compliance Assurance Monitoring 

CFR Code of Federal Regulations 

CPDS Certified Product Data Sheets 

DSR Deviation Summary Report 

EDS Environmental Data Sheets 

ERMS Emissions Reduction Market System 

HAP Hazardous Air Pollutant 

hr hour 

IAC Illinois Administrative Code 

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

ILCS Illinois Compiled Statutes 

Illinois EPA Illinois Environmental Protection Agency 

kW kilowatts 

lb pound 

mmBtu Million British thermal units 

MSDS Material Safety Data Sheets 

NESHAP National Emission Standards for Hazardous Air Pollutants 

NOx Nitrogen Oxides 

NSPS New Source Performance Standards 

NSR New Source Review 

PM Particulate Matter 

PM10 Particulate matter with an aerodynamic diameter less than or 

equal to a nominal 10 microns as measured by applicable test 

or monitoring methods 

ppm parts per million 

PSD Prevention of Significant Deterioration 

RMP Risk Management Plan 

SO2 Sulfur Dioxide 

T1 Title I – identifies Title I conditions that have been 

carried over from an existing 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 permit and subsequently 

revised in this permit 

USEPA United States Environmental Protection Agency 

VOM Volatile Organic Material 
6 

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: 

Electrolytic Dechroming 

Shallow Tray Air Stripper 

Solvent Storage Tanks 

Ink Extender Storage Tanks 

Ink Storage Tanks 

Hot Melt Gluers 

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: 

Re-Etch Tanks 

Copper Plating Units 

Electrolytic Degreasing (Sodium Hydroxide and Water) 

Scrap Paper Balers 

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: 

a. 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)]. 

b. Equipment used for the melting or application of less 

than 50,000 lbs/year of wax to which no organic 

solvent has been added [35 IAC 201.210(a)(7)]. 

3.1.4 Activities that are considered insignificant activities 

pursuant to 35 IAC 201.210(b). 
7 

3.2 Compliance with Applicable Requirements 

Insignificant activities are subject to applicable requirements 

notwithstanding status as insignificant activities. In 

particular, in addition to regulations of general applicability, 

such as 35 IAC 212.301 and 212.123 (Condition 5.2.2), the 

Permittee shall comply with the following requirements, as 

applicable: 

3.2.1 For each cold cleaning degreaser, the Permittee shall 

comply with the applicable equipment and operating 

requirements of 35 IAC 215.182, 218.182, or 219.182. 

3.2.2 For each particulate matter process emission unit, the 

Permittee shall comply with the applicable particulate 

matter emission limit of 35 IAC 212.321 or 212.322. For 

example, the particulate matter emissions from a process 

emission unit shall not exceed 0.55 pounds per hour if the 

emission unit’s process weight rate is 100 pounds per hour 

or less, pursuant to 35 IAC 266.110. 

3.2.3 For each organic material emission unit that uses organic 

material, e.g., a mixer or printing line, the Permittee 

shall comply with the applicable VOM emission limit of 35 

IAC 215.301, 218.301, or 219.301, which requires that 

organic material emissions not exceed 8.0 pounds per hour 

or do not qualify as photochemically reactive material as 

defined in 35 IAC 211.4690. 

Note: Condition 3.2.3 applies only to insignificant 

activities. 

3.3 Addition of Insignificant Activities 

3.3.1 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). 

3.3.2 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. 

3.3.3 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). 
8 

4.0 SIGNIFICANT EMISSION UNITS AT THIS SOURCE 

Emission 

Unit Description 

Date 

Constructed

Emission Control 

Equipment 

RP5 Rotogravure Printing 

Press #5 

1962 Carbon Adsorption 

System 

RP6 Rotogravure Printing 

Press #6 

1967 Carbon Adsorption 

System 

RP9 Rotogravure Printing 

Press #9 

1987 Carbon Adsorption 

System 

RP10 Rotogravure Printing 

Press #10 with 

Imprinter 

1990 Carbon Adsorption 

System 

RP11 Rotogravure Printing 

Press #11 

1992 Carbon Adsorption 

System 

RP12 Rotogravure Printing 

Press #12 

1996 New Carbon Adsorption 

System 

PP1 Rotogravure Proof Press 

#1 

1990 Carbon Adsorption 

System 

CW1 Cylinder Wash Tank 1990 Carbon Adsorption 

System 

OP2 Lithographic Offset 

Printing Press #2 

1989 Thermal Regenerative 

Oxidizer 

OP4 Lithographic Offset 

Printing Press #4 

1989 Thermal Regenerative 

Oxidizer 

OP5 Lithographic Offset 

Printing Press #5 

1989 Thermal Regenerative 

Oxidizer 

PC1 Paper Cutting 

Operations #1 

1968 Cyclone #1 

PC2 Paper Cutting 

Operations #2 

1987 Cyclone #2 

PS1 Paper Shredding 

Operations #1 

1960 Cyclone #3 

BO2 Boiler #2 

16.7 mmBtu/hr 

1958 None 

BO3 Boiler #3 

16.7 mmBtu/hr 

1958 None 

BO4 Boiler #4 

16.7 mmBtu/hr 

1974 None 

BO5 Boiler #5 

20.35 mmBtu/hr 

1974 None 

BO6 Boiler #6 

20.35 mmBtu/hr 

1991 None 

CT1 Cleaning Tank #1 1995 None 

CT2 Cleaning Tank #2 1995 None 

CT3 Cleaning Tank #3 1993 None 

CT4 Cleaning Tank #4 1990 None 

IJ1 Ink Jetting Units 1983-1997 None 

ET1 Chromium Electroplating 

Tank #1 

1990 Multiple Stage 

Composite Mesh Pad 

Demister #1 
9 

Emission 

Unit Description 

Date 

Constructed

Emission Control 

Equipment 

ET2 Chromium Electroplating 

Tank #2 

1992 Multiple Stage 

Composite Mesh Pad 

Demister #2 
10 

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 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. No person shall cause or allow the emission of smoke 

or other particulate matter, with an opacity greater 

than 30 percent, into the atmosphere from any 

emission unit other than those emission units subject 

to the requirements of 35 IAC 212.122, pursuant to 35 

IAC 212.123(a), except as allowed by 35 IAC 

212.123(b) and 212.124. 

5.2.3 Ozone Depleting Substances 

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. 
11 

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. 

5.2.4 Risk Management Plan 

Should this stationary source, as defined in 40 CFR 

Section 68.3, become subject to the Accidental Release 

Prevention regulations in 40 CFR Part 68, then the owner 

or operator shall submit [40 CFR 68.215(a)(2)(i) and 

(ii)]: 

a. A compliance schedule for meeting the requirements of 

40 CFR Part 68 by the date provided in 40 CFR 

68.10(a); or 

b. A certification statement that the source is in 

compliance with all requirements of 40 CFR Part 68, 

including the registration and submission of the Risk 

Management Plan (RMP), as part of the annual 

compliance certification required by 40 CFR Part 70 

or 71. 

5.2.5 a. Should this stationary source become subject to a 

regulation under 40 CFR Parts 60, 61, or 63, or 35 

IAC after the date issued of this permit, then the 

owner or operator shall, in accordance with the 

applicable regulation(s), comply with the applicable 

requirements by the date(s) specified and shall 

certify compliance with the applicable requirements 

of such regulation(s) as part of the annual 

compliance certification, as required by 40 CFR Part 

70 or 71. 

b. No later than upon the submittal for renewal of this 

permit, the owner or operator shall submit, as part 

of an application, the necessary information to 

address either the non-applicability of, or 

demonstrate compliance with all applicable 

requirements of any potentially applicable regulation 

which was promulgated after the date issued of this 

permit. 

5.2.6 Episode Action Plan 

a. If the source is required to have an episode action 

plan pursuant to 35 IAC 244.142, the Permittee shall 

maintain at the source and have on file with the 

Illinois EPA a written episode action plan (plan) for 

reducing the levels of emissions during yellow 

alerts, red alerts, and emergencies, consistent with 

safe operating procedures. The plan shall contain 

the information specified in 35 IAC 244.144. 
12 

b. The Permittee shall immediately implement the 

appropriate steps described in this plan should an 

air pollution alert or emergency be declared. 

c. If a change occurs at the source which requires a 

revision of the plan (e.g., operational change, 

change in the source contact person), a copy of the 

revised plan shall be submitted to the Illinois EPA 

for review within 30 days of the change. Such plans 

shall be further revised if disapproved by the 

Illinois EPA. 

d. For sources required to have a plan pursuant to 35 

IAC 244.142, a copy of the original plan and any 

subsequent revisions shall be sent to: 

i. Illinois EPA, Compliance Section; and 

ii. For sources located in Cook County and outside 

of the city of Chicago: Cook County 

Department of Environmental Control; or 

iii. For sources located within the city of 

Chicago: Chicago Department of Environmental 

Control. 

5.2.7 CAM Plan 

This stationary source has a pollutant-specific emissions 

unit that is subject to 40 CFR Part 64, Compliance 

Assurance Monitoring (CAM) for Major Stationary Sources. 

The source must submit a CAM plan for each affected 

pollutant-specific emissions unit upon application for 

renewal of the initial CAAPP permit, or upon a significant 

modification to the CAAPP permit for the construction or 

modification of a large pollutant-specific emissions unit 

which has the potential post-control device emissions of 

the applicable regulated air pollutant that equals or 

exceeds major source threshold levels. 

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 
13 

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 

Volatile Organic Material (VOM) 2,662.22 

Sulfur Dioxide (SO2) ---- 

Particulate Matter (PM) 67.12 

Nitrogen Oxides (NOx) 54.58 

HAP, not included in VOM or PM 0.01 

TOTAL 2,783.93 

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 

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, including HAP 

emissions. 
14 

5.6.6 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 deviations of the source 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, including HAP emissions. 

5.8 General Operational Flexibility/Anticipated Operating Scenarios 

N/A 

5.9 General Compliance Procedures 

5.9.1 General Procedures for Calculating Emissions 

Compliance with the source-wide emission limits specified 

in Condition 5.5 shall be based on the recordkeeping and 

reporting requirements of this permit, and compliance 

procedures in Section 7 (Unit Specific Conditions) of this 

permit. 
15 

6.0 NOT APPLICABLE TO THIS PERMIT 
16 

7.0 UNIT SPECIFIC CONDITIONS 

7.1 Rotogravure Printing Presses 

7.1.1 Description 

These printing presses are doing publication rotogravure 

printing. Publication rotogravure is applicable for 

relatively long press runs and most suitable for 

publications printed on uncoated paper stock, commonly 

referred to as newsprint. The items produced on the 

rotogravure printing presses at this source are catalogs, 

magazines, newspapers, inserts and commercial printing. 

In the cylinder wash tank ink and grease is cleaned from 

the gravure design cylinders. All the equipment listed in 

7.1.2 is controlled by the carbon adsorption system. 

7.1.2 List of Emission Units and Air Pollution Control Equipment 

Emission 

Unit Description 

Emission Control 

Equipment 

RP5 Rotogravure Printing 

Press #5 

Carbon Adsorption 

System 

RP6 Rotogravure Printing 

Press #6 

Carbon Adsorption 

System 

RP9 Rotogravure Printing 

Press #9 

Carbon Adsorption 

System 

RP10 Rotogravure Printing 

Press #10 with Imprinter 

Carbon Adsorption 

System 

RP11 Rotogravure Printing 

Press #11 

Carbon Adsorption 

System 

RP12 Rotogravure Printing 

Press #12 

New Carbon 

Adsorption System 

PP1 Rotogravure Proof 

Press #1 

Carbon Adsorption 

System 

CW1 Cylinder Wash Tank Carbon Adsorption 

System 

7.1.3 Applicability Provisions and Applicable Regulations 

a. The “affected emission units” for the purpose of 

these unit-specific conditions, are the emission 

units listed in Condition 7.1.2. 

b. Each affected emission unit is subject to the 

emission limits identified in Condition 5.2.2. 

c. The rotogravure printing presses are subject to the 

National Emission Standard for Hazardous Air 

Pollutants (NESHAP) for the Printing and Publishing 

Industry, 40 CFR 63 Subparts A and KK and the New 

Source Performance Standards (NSPS) for Publication 

Rotogravure Printing, 40 CFR 60 Subparts A and QQ. 
17 

The Illinois EPA is administering NESHAP and NSPS in 

Illinois on behalf of the USEPA under a delegation 

agreement. 

i. Each publication rotogravure printing press 

shall limit emissions of organic HAP to no 

more than eight percent of the total volatile 

matter used each month. The emission 

limitation may be achieved by overall control 

of at least 92 percent of organic HAP used, by 

substitution of non-HAP materials for organic 

HAP, or by a combination of capture and 

control technologies and substitution of 

materials [40 CFR 63.824(b)]. 

ii. The owner or operator is subject to 40 CFR 

60.432 NSPS Publication Rotogravure Printing 

standards for volatile organic compounds. 

These standards require 84% control of VOC. 

Condition 7.1.5 is more stringent than this 

requirement therefore compliance with 

Condition 7.1.5 assures compliance with 40 CFR 

60.432. 

iii. No owner or operator of a publication 

rotogravure printing press and employing 

solvent-containing ink may cause or allow the 

operation of such press unless: 

The owner or operator installs and operates a 

carbon adsorption system which reduces the 

volatile organic emissions from the capture 

system by at least 90 percent by weight and an 

overall reduction in volatile organic material 

emissions of at least 75 percent [35 IAC 

215.401]. 

Condition 7.1.5 is more stringent than this 

requirement therefore compliance with 

Condition 7.1.5 assures compliance with 35 IAC 

215.401. 

7.1.4 Non-Applicability of Regulations of Concern 

a. The rotogravure printing presses are not subject to 

35 IAC 215.301, Use of Organic Material, because 35 

IAC 215.403 exempts emission units that comply with 

35 IAC 215 Subpart P, Printing and Publishing. 

b. This permit is issued based on the affected emission 

units not being subject to 40 CFR Part 64, Compliance 

Assurance Monitoring (CAM) for Major Stationary 

Sources, because the affected emission units are 
18 

subject to a NESHAP proposed after November 15, 1990, 

pursuant to 40 CFR 64.2(b)(1)(i). 

7.1.5 Operational and Production Limits and Work Practices 

a. i. Volatile organic compound (VOC) emissions from 

rotogravure press 12 shall be controlled by at 

least 97%. Compliance shall be demonstrated 

by a Permanent Total Enclosure (PTE) meeting 

100% capture, and continuous monitors on the 

inlet and outlet of the adsorption system 

meeting a minimum 97% removal efficiency, 

across a 24-hour average of at least hourly 

measurements of inlet VOC and outlet VOC, as 

determined by monitoring in accordance with 

Condition 7.1.8. 

ii. VOM emissions generated by Press 12 will 

exhaust to the new carbon adsorption system 

exclusively, except during emergency or 

breakdown circumstances during which time the 

exhaust shall be routed to the existing carbon 

adsorption system. 

iii. During emergency or breakdown circumstances, 

Press 12 shall not exhaust to the existing 

carbon adsorption system for periods exceeding 

72 hours. If the emergency or breakdown 

circumstance exceeds 72 hours, Permittee shall 

notify the Illinois EPA and seek authority to 

exhaust Press 12 emissions to the existing 

carbon adsorption system for more than 72 

hours. 

b. The carbon adsorption system for rotogravure printing 

presses, in conjunction with the capture systems, 

shall achieve at least 92% overall control of 

emissions of VOC from all rotogravure presses at the 

plant. That is, no more than 8% of the mass of VOC 

solvent used on the presses shall be discharged to 

the atmosphere. Compliance shall be determined 

according to the methodology of New Source 

Performance Standard, 40 CFR 60.433 using a monthly 

time period and such other adjustments authorized by 

the Illinois EPA. The use of this methodology does 

not indicate that all existing presses are subject to 

40 CFR 60, Subpart QQ. Compliance may be 

demonstrated across an accounting month or calendar 

month. 

The above limitations were established in Permit 

95080142, pursuant to 40 CFR 52.21, Prevention of 

Significant Deterioration (PSD). These limits ensure 

that the construction and/or modification addressed 
19 

in the aforementioned permit does not cause or 

contribute to air pollution in violation of the 

National Ambient Air Quality Standard (NAAQS) for 

ozone pursuant to Title 1 of the CAA, specifically 

the federal rules for Prevention of Significant 

Deterioration (PSD), 40 CFR 52.21 [T1]. 

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

operate the rotogravure presses, including associated 

air pollution control equipment, in a manner 

consistent with good air pollution control practice 

for minimizing emissions. 

d. The solvent usage from the cylinder washing machine 

with distiller is to be controlled by the common 

vapor recovery system. 

7.1.6 Emission Limitations 

In addition to Condition 5.2.2 and the source wide 

emission limitations in Condition 5.5, the affected 

emission units are subject to the following: 

a. Operation and emissions of all rotogravure printing 

operations, except Press 12, shall not exceed the 

following limits: 

Total Monthly 

VOM Emissions 

Total Annual VOM 

Emissions 

(Tons/Month) (Tons/Year)

 

157 1,570 

Compliance with annual VOC solvent usage and emission 

limits shall be determined from a running 12 months 

of data. 

The above limitations contain revisions to previously 

issued Permit 74100089. The source has requested 

that the Illinois EPA establish conditions in this 

permit that allow various refinements from the 

conditions of this aforementioned permit, consistent 

with the information provided in the CAAPP 

application. The source has requested these 

revisions and has addressed the applicability and 

compliance of Title I of the CAA, specifically 35 IAC 

Part 203, Major Stationary Sources Construction and 

Modification and/or 40 CFR 52.21, Prevention of 

Significant Deterioration (PSD). These limits 

continue to ensure that the construction and/or 

modification addressed in this permit do not 

constitute a new major source or major modification 

pursuant to these rules. These limits are the 
20 

primary enforcement mechanism for the equipment and 

activities permitted in this permit and the 

information in the CAAPP application contains the 

most current and accurate information for the source. 

Specifically, monthly ink and solvent usage limits 

have been removed and a monthly emission limit has 

been added. The annual emission limit remains the 

same [T1R]. 

b. Operation and emissions of Rotogravure Press 11 shall 

not exceed the following limits: 

Monthly VOM 

Emissions 

Annual VOM 

Emissions 

(Tons/Month) (Tons/Year)

 

53 530 

Compliance with annual VOC solvent usage and emission 

limits shall be determined from a running 12 months 

of data. 

The above limitations contain revisions to previously 

issued Permit 91010065 (this was a construction permit 

with a netting project). The source has requested 

that the Illinois EPA establish conditions in this 

permit that allow various refinements from the 

conditions of this aforementioned permit, consistent 

with the information provided in the CAAPP 

application. The source has requested these revisions 

and has addressed the applicability and compliance of 

Title I of the CAA, specifically 35 IAC Part 203, 

Major Stationary Sources Construction and Modification 

and/or 40 CFR 52.21, Prevention of Significant 

Deterioration (PSD). These limits continue to ensure 

that the construction and/or modification addressed in 

this permit do not constitute a new major source or 

major modification pursuant to these rules. These 

limits are the primary enforcement mechanism for the 

equipment and activities permitted in this permit and 

the information in the CAAPP application contains the 

most current and accurate information for the source. 

Specifically, monthly ink and solvent usage limits 

have been removed and a monthly emission limit has 

been added. The annual emission limit remains the 

same [T1R]. 

c. Operation and emissions of Press 12 shall not exceed 

the following limits: 

Monthly VOC Solvent Usage VOC Emissions 

(Tons/Mo*) (Tons/Yr) (Tons/Mo) (Tons/Yr)

 

950 11,400 47.5 570 
21 

* VOC Solvent Usage refers to the amount of VOC 

in ink as delivered to rotogravure presses, 

plus any thinning solvent and any VOC in ink 

extender and cleaning material. 

Compliance with annual VOC solvent usage and emission 

limits shall be determined from a running total of 12 

months of data. 

The above limitations were established in PSD 

Construction Permit 95080142, pursuant to 40 CFR 

52.21, Prevention of Significant Deterioration (PSD). 

These limits ensure that the construction and/or 

modification addressed in the aforementioned permit 

does not cause or contribute to air pollution in 

violation of the National Ambient Air Quality 

Standard (NAAQS) for ozone pursuant to Title 1 of the 

CAA, specifically the federal rules for Prevention of 

Significant Deterioration (PSD), 40 CFR 52.21 [T1]. 

7.1.7 Testing Requirements 

a. The owner or operator shall perform applicable 

testing for the rotogravure printing presses as 

specified by 40 CFR 63.827 Performance Test Methods 

and 40 CFR 60.435. 

b. Testing of VOC containing materials such as inks and 

coatings may be performed by the supplier of a 

material provided that the supplier provides 

appropriate documentation for such testing to the 

owner or operator and the owner’s or operator’s 

records directly reflect the application of such 

material and separately account for any additions of 

solvent. 

7.1.8 Monitoring Requirements 

a. i. A continuous monitoring system shall be 

operated, maintained and calibrated for VOC 

concentration in the exhaust for the carbon 

adsorption system to verify proper operation 

of the system. 

ii. This monitoring system shall monitor and 

record the VOM concentration during the period 

prior to commencing each regeneration of the 

carbon beds (to assure that “breakthrough” is 

not reached) and during a period at the 

beginning of adsorption (to assure that the 

bed has been regenerated). 
22 

iii. A continuous monitoring system shall be 

installed, operated, maintained and calibrated 

for VOC in the inlet and outlet from the 

carbon adsorption system controlling emissions 

from Press 12. 

iv. This monitoring system shall monitor and 

record the VOC concentration and air flow, so 

as to determine the mass of VOC in the inlet 

and outlet of the carbon adsorption system. 

b. The continuous monitoring systems shall be operated 

in accordance with the monitoring plan, as approved 

by the Illinois EPA. 

i. The Permittee shall inspect the carbon 

adsorption systems, including observing the 

stack exhausts during various phases of the 

operation of each carbon bed, on a regular 

schedule. 

ii. The Permittee shall conduct routine 

maintenance of the carbon adsorption systems 

in accordance with a written maintenance plan, 

which plan shall be kept current. 

c. The owner or operator is also subject to any 

remaining monitoring requirements in 40 CFR 63.828 

and 40 CFR 60.434 that are not covered by the above 

conditions. 

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 the affected emission units to demonstrate compliance 

with the permit conditions, pursuant to Section 39.5(7)(b) 

of the Act: 

a. The owner or operator shall retain the applicable 

records for the rotogravure printing presses as 

specified by 40 CFR 63.829 and 40 CFR 60.434. 

b. The use of ink and other materials for the affected 

emission units, so as to enable organic material 

emissions from the emission units and compliance with 

Condition 7.1.6. These records shall be compiled on 

at least a monthly basis. 

c. Monthly records for VOM solvent use and recovery for 

the affected emission units to allow compliance with 

Conditions 7.1.3 and 7.1.5 to be determined. 
23 

d. VOM contents of materials used. 

e. Monthly and annual VOM emissions, in tons. 

f. All breakdown and emergency circumstances requiring 

the re-routing of Press 12 exhaust to the existing 

carbon adsorption system shall be entered in a 

logbook and available to the Illinois EPA for 

inspection. 

7.1.10 Reporting Requirements 

The owner or operator shall promptly notify the Illinois 

EPA, Compliance Section, of deviations of the affected 

emission units 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. The owner or operator shall submit all applicable 

reports for the rotogravure printing lines as 

specified in 40 CFR 63.830. 

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

7.1.6 within 30 days of a record showing such an 

occurrence. 

7.1.11 Operational Flexibility/Anticipated Operating Scenarios 

The owner or operator is authorized to modify, change and 

otherwise alter any and all raw material formulas, 

characteristics and usage rates for the affected emission 

units provided these changes comply with the permit 

conditions. This condition does not affect the owner or 

operator’s obligation to properly obtain a construction 

permit in a timely manner for any activity constituting 

construction or modification of the source, as defined in 

35 IAC 201.102: 

7.1.12 Compliance Procedures 

a. Compliance with air pollution control efficiency 

requirements shall be determined according to the 

methodologies of 40 CFR 60.433 and 40 CFR 63.824. 

b. VOM emissions shall be determined using the emission 

formula listed below: 















 = − Efficiency

Overall Control x 1

Content

VOM x UsageMaterial

& Solvent Usage

from Ink, Coating

VOM Emissions
24 

7.2 Lithographic Offset Printing Presses 

7.2.1 Description 

These printing presses are doing heatset offset 

lithography printing. Heatset offset lithography is 

typically the process of choice for high-quality 

publications when the run length is either “short” or 

“medium”. The items produced on the lithographic printing 

presses at this source are magazines, catalogs, newspaper 

inserts and commercial printing. 

7.2.2 List of Emission Units and Air Pollution Control Equipment 

Emission 

Unit Description 

Emission Control 

Equipment 

OP2 Lithographic Offset 

Printing Press #2 

Thermal Regenerative 

Oxidizer 

OP4 Lithographic Offset 

Printing Press #4 

Thermal Regenerative 

Oxidizer 

OP5 Lithographic Offset 

Printing Press #5 

Thermal Regenerative 

Oxidizer 

7.2.3 Applicability Provisions and Applicable Regulations 

a. The “affected lithographic presses” for the purpose 

of these unit-specific conditions, are the 

lithographic presses listed in Condition 7.2.2. 

b. The affected lithographic presses are subject to the 

emission limits identified in Condition 5.2.2. 

c. The owner or operator may not cause or allow the 

operation of any heatest web offset press unless the 

fountain solution contains no more than eight (8) 

percent, by weight, of VOM [35 IAC 215.408(b)]. 

d. Operation in excess of the applicable emission 

standards during malfunction and breakdown is 

allowed. This allowance applies only to the 

following specific equipment: the lithographic 

presses. 

e. The owner or operator shall notify the Illinois EPA’s 

regional office by telephone as soon as possible 

during normal working hours upon the occurrence of 

excess emissions due to malfunctions, or breakdowns 

(excluding minor occurrences lasting less than 1 

hour). The owner or operator shall comply with all 

reasonable and safe directives of the regional office 

regarding such malfunctions and breakdowns. Within 

five (5) working days of such occurrence the owner or 

operator shall give a written follow-up notice to the 

Illinois EPA’s regional office providing an 
25 

explanation of the occurrence, including work 

performed, the length of time during which operation 

continued under such conditions, measures taken by 

the owner or operator to minimize excess emissions 

and correct deficiencies, and when normal operation 

resumed. 

7.2.4 Non-Applicability of Regulations of Concern 

a. The 8 pounds per hour organic material emission 

limitation of 35 IAC 215.301 does not apply to the 

affected lithographic presses because 35 IAC 215.403 

exempts printing presses in compliance with 35 IAC 

215 Subpart P: Printing and Publishing. 

7.2.5 Operational and Production Limits and Work Practices 

a. i. Not withstanding 35 IAC 215.106, seasonal 

shutdown of the thermal regenerative oxidizer 

is not allowed. 

ii. The thermal regenerative oxidizer controlling 

the affected lithographic presses shall be 

operated to achieve an overall control of 90% 

or better for volatile organic material (VOM) 

emissions. 

b. The thermal regenerative oxidizer shall be preheated 

to 1400°F prior to the introduction of any VOM 

emissions, and it shall be maintained at 1400°F 

whenever VOM emissions are being introduced. 

c. Natural gas shall be the only fuel burned in the 

thermal regenerative oxidizer. 

7.2.6 Emission Limitations 

In addition to Condition 5.2.2 and the source wide 

emission limitations in Condition 5.5, the affected 

lithographic presses are subject to the following: 

a. Operation and emissions of the affected lithographic 

presses as a group, shall not exceed the following 

limits: 

Maximum Ink 

Usage 

Annual Ink 

Usage 

Annual VOM 

Emissions 

(Lb/Hour) (Tons/Year) (Tons/Year)

 

570 1,007 39.5 

b. i. The VOM content of the inks used on the 

affected lithographic presses shall not exceed 

49% by weight. 
26 

ii. The VOM content of the damping or fountain 

solution used on these presses shall be 

negligible. 

c. The above limitations were established in Permit 

74100089, pursuant to 40 CFR 52.21, Prevention of 

Significant Deterioration (PSD). These limits ensure 

that the construction and/or modification addressed 

in the aforementioned 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]. 

7.2.7 Testing Requirements 

a. Emission testing pursuant to 35 IAC 215.410. 

i. Any required tests of volatile organic 

material emissions, including tests conducted 

to determine control equipment efficiency, 

shall be conducted in accordance with the 

methods and procedures specified in Section 

215.102. 

ii. Upon a reasonable request by the Illinois EPA, 

the owner or operator of a volatile organic 

material emission source required to comply 

with the limits of this Subpart shall conduct 

emissions testing, at his own expense, to 

demonstrate compliance. 

iii. A person planning to conduct a volatile 

organic material emissions test to demonstrate 

compliance with this permit shall notify the 

Illinois EPA of that intent not less than 30 

days before the planned initiation of the 

tests so the Illinois EPA may observe the 

test. 

b. Testing methods for volatile organic material content 

Upon request by the Illinois EPA, the volatile 

organic material content of printing inks, blanket 

wash, fountain solution and coatings shall be 

determined by Method 24, 40 CFR 60, Appendix A, 

incorporated by reference in Section 215.105 [35 IAC 

215.409]. 
27 

7.2.8 Monitoring Requirements 

The thermal oxidizer shall be equipped with a continuous 

temperature indicator for the thermal oxidizer combustion 

chamber temperature. 

7.2.9 Recordkeeping Requirements 

In addition to the records required by Condition 5.6, the 

owner or operator shall maintain records of the following 

items for the affected lithographic presses to demonstrate 

compliance with the permit conditions, pursuant to Section 

39.5(7)(b) of the Act: 

a. Usage of ink, fountain solution, coating and blanket 

wash in tons per month. 

b. The VOM content (VOM weight %) of the ink, fountain 

solution, coating and blanket wash used with basis, 

accompanied by a copy of the supporting information, 

e.g., supplier data sheet or laboratory analysis 

report. 

c. VOM emissions per month in tons. 

d. A log stating the following: 

Times when presses shut down due to RTO 

temperature falling below 1400°F. 

e. Malfunction and breakdown records, as a minimum these 

records shall include: 

i. Date and duration of malfunction or breakdown; 

ii. A full and detailed explanation of the cause 

for such emissions; 

iii. The contaminants emitted and an estimate of 

the quantity of emissions; 

iv. The measures used to reduce the quantity of 

emissions and the duration of the occurrence; 

and 

v. The steps taken to prevent similar 

malfunctions or breakdowns or reduce their 

frequency and severity. 

f. Combustion temperature monitoring data. 
28 

7.2.10 Reporting Requirements 

The owner or operator shall promptly notify the Illinois EPA, 

Compliance Section, of deviations of the affected 

lithographic printing presses 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. Emissions of VOM in excess of the limits in Condition 7.2.6 

within 30 days of a record showing such an occurrence. 

b. Any usage of fountain solution that contains more 

than 8 percent, by weight of VOM within 30 days of a 

record showing such an occurrence. 

7.2.11 Operational Flexibility/Anticipated Operating Scenarios 

The owner or operator is authorized to modify, change and 

otherwise alter any and all raw material formulas, 

characteristics and usage rates for the affected 

lithographic printing presses. This condition does not 

affect the owner or operator’s obligation to properly 

obtain a construction permit in a timely manner for any 

activity constituting construction or modification of the 

source, as defined in 35 IAC 201.102. 

7.2.12 Compliance Procedures 

a. Compliance with emission limits shall be determined 

using the emission factors and formulas listed below: 

Ink VOM Emissions (EI): 

EI = CI(1-RI)[1-(K)(JI)] 

Fountain Solution VOM Emissions (EF): 

EF = CF[1-(K)(JF)] 

Automatic Blanket Wash VOM Emissions (EA): 

EA = CA[1-(K)(JA)] 

Manual Blanket Wash VOM Emissions (EM) 

EM = CM(1-RM) 

Total VOM Emissions (ET): 

ET = EI + EF + EA + EM

Where: 
29 

CI = Ink VOM consumption (tons) 

CF = Fountain solution VOM consumption (tons) 

CA = Automatic blanket wash VOM consumption (tons) 

CM = Manual blanket wash VOM consumption (tons) 

RM = Retention factor for manual blanket wash 

 = 50%, for manual blanket wash with a VOM 

composite partial vapor pressure less than 10 

mmHg at 20°C and the used cleaning towels are 

kept in closed containers. 

 = 0% for other manual blanket wash 

RI = Percent of ink VOM retained in printed product 

(non-heatset = 95%, heatset = 20%) 

K = Control efficiency of afterburner (non-heatset = 

0%, heatset = 90% when afterburner is operating) 

JI = Capture efficiency of dryer and control system 

for ink VOM (non-heatset = 0%, heatset = 100%) 

JF = Capture efficiency of dryer and control system 

for fountain solution (non-heatset = 0%, 

heatset = 70%) 

JA = Capture efficiency of dryer and control system 

for automatic blanket wash VOM (non-heatset = 

0%, heatset = 40% when a blanket wash with a 

vapor pressure less than 10 mmHg at 20°C is 

used, otherwise capture efficiency = 0% 

b. Fuel combustion emissions shall be calculated based 

on the following: 

Pollutant

Natural Gas 

Emission Factors 

for Boilers 

(lb/106

 ft3)

 

 NOx 100 

 PM 7.6 

 SO2 0.6 

 VOM 5.5 

These are the emission factors for uncontrolled 

natural gas combustion, Table 1.4-1, and 1.4-2, 

AP-42, Volume I, Supplement F, March, 1998. 

Emissions (lb) = (Natural Gas Consumed, ft3

) x (The 

Appropriate Emission Factor) 
30 

7.3 Paper Cutting and Shredding Operations 

7.3.1 Description 

Paper is trimmed and shredded. Cyclones constructed in 

2000, control the particulate matter emissions from the 

cutting and shredding operations. 

7.3.2 List of Emission Units and Air Pollution Control Equipment 

Emission 

Unit Description 

Emission Control 

Equipment 

PC1 Paper Cutting Operations #1 Cyclone #1 

PC2 Paper Cutting Operations #2 Cyclone #2 

PS1 Paper Shredding 

Operations #1 

Cyclone #3 

7.3.3 Applicability Provisions and Applicable Regulations 

a. The “affected paper cutting operations” for the 

purpose of these unit-specific conditions, are the 

paper cutting operations listed in Condition 7.3.2. 

b. The emissions of particulate matter into the 

atmosphere in any one hour period from the affected 

paper cutting operations shall not exceed the 

allowable emission rates specified by the following 

equation [35 IAC 212.321]: 

E = A(P)B

Where: 

P = Process weight rate; and 

E = Allowable emission rate; and, 

1. For process weight rates up to 408 Mg/hr (450 T/hr): 

 Metric English

 

P Mg/hr T/hr 

E kg/hr lbs/hr 

A 1.214 2.54 

B 0.534 0.534 

2. For process weight rates in excess of 408 

Mg/hr (450 T/hr): 

 Metric English

 

P Mg/hr T/hr 

E kg/hr lbs/hr 

A 11.42 24.8 

B 0.16 0.16 
31 

Where: 

P = Process weight rate in metric or English 

tons per hour, and 

E = Allowable emission rate in kilograms or 

pounds per hour. 

7.3.4 Non-Applicability of Regulations of Concern 

N/A 

7.3.5 Operational and Production Limits and Work Practices 

The owner or operator shall follow good operating 

practices for the emission control equipment including 

periodic inspection, routine maintenance, repair of 

defects and visual emission checks. 

7.3.6 Emission Limitations 

N/A 

7.3.7 Testing Requirements 

N/A 

7.3.8 Monitoring Requirements 

N/A 

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 paper cutting operations to demonstrate 

compliance with Conditions of this permit, pursuant to 

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

a. Records of waste produced on a monthly basis in tons. 

b. A maintenance log for the emission control equipment 

detailing all routine and nonroutine maintenance 

performed. 

c. Annual PM emissions. 

7.3.10 Reporting Requirements 

The owner or operator shall promptly notify the Illinois 

EPA, Compliance Section, of deviations of the affected 

cutting operations with the permit requirements as 

follows, pursuant to Section 39.5(7)(f)(ii) of the Act. 
32 

Reports shall describe the probable cause of such 

deviations, and any corrective actions or preventive 

measures taken. 

7.3.11 Operational Flexibility/Anticipated Operating Scenarios 

The owner or operator is authorized to modify the process 

weight rate for the paper cutting operations. This 

condition does not affect the Permittee’s obligation to 

properly obtain a construction permit in a timely manner 

for any activity constituting construction or modification 

of the source, as defined in 35 IAC 201.102. 

7.3.12 Compliance Procedures 

a. Compliance with the PM limitations of Condition 7.3.3 

is demonstrated by proper operation of the affected 

paper cutting operations and associated emission 

control equipment including performance of the 

operational and work practice requirements of 

Condition 7.3.5 and recordkeeping requirements of 

Condition 7.3.9. 

b. Particulate matter emissions for the affected paper 

cutting operations may be estimated using the 

equations in Conditions 7.3.3(b) and (c). 
33 

7.4 Gas Fired Boilers 

7.4.1 Description 

Natural gas fired boilers are used for steam 

generation/heat generation. 

7.4.2 List of Emission Units and Air Pollution Control Equipment 

Emission 

Unit Description 

Emission Control 

Equipment 

BO2 Boiler #2 16.7 mmBtu/hr 

BO3 Boiler #3 16.7 mmBtu/hr 

BO4 Boiler #4 16.7 mmBtu/hr 

BO5 Boiler #5 20.35 mmBtu/hr 

BO6 Boiler #6 20.35 mmBtu/hr 

7.4.3 Applicability Provisions and Applicable Regulations 

a. The “affected boilers” for the purpose of these unitspecific conditions, are the emission units listed in 

Condition 7.4.2. 

b. Each affected boiler is subject to the emission 

limits identified in Condition 5.2.2. 

c. Boiler #6 is subject to a New Source Performance 

Standard (NSPS) for small Industrial, Commercial, and 

Industrial Steam Generating Units, 40 CFR 60, 

Subparts A and Dc. The Illinois EPA is administering 

NSPS in Illinois on behalf of the United States EPA 

under a delegation agreement. 

i. Pursuant to the New Source Performance 

Standard, the emission of gases into the 

atmosphere from Boiler #6, except during 

periods of startup, malfunction and shutdown, 

shall not exhibit an opacity greater than 20 

percent (6-minute average), except for one 6-

minute period per hour of not more than 27 

percent opacity [40 CFR 60.43c(c) and (d)]. 

d. The emission of carbon monoxide (CO) into the 

atmosphere from any affected boiler with actual heat 

input greater than 2.9 MW (10 MBtu/hr) shall not 

exceed 200 ppm, corrected to 50 percent excess air 

[35 IAC 216.121]. 

7.4.4 Non-Applicability of Regulations of Concern 

a. Each affected boiler is not subject to 35 IAC 

217.141, because the actual heat input of the 

affected boilers is less than 73.2 MW (250 MBtu/hr). 
34 

b. Pursuant to 35 IAC 215.303, each affected boiler, 

i.e., fuel combustion emission unit, is not subject 

to 35 IAC 215.301, Use of Organic Material. 

7.4.5 Operational and Production Limits and Work Practices 

Natural gas shall be the only fuel burned in the boilers. 

7.4.6 Emission Limitations 

In addition to Condition 5.2.2 and the source wide 

emission limitations in Condition 5.5, the affected boiler 

is subject to the following: 

Emissions and operation of boiler #6 shall not exceed the 

following limits: 

Firing Rate Nitrogen Oxides Carbon Monoxide 

(Million Btu/Hr) (Lb/Hr) (Ton/Yr) (Lb/Hr) (Ton/Yr)

 

20.35 2.85 12.5 0.71 3.1 

These limits are based on standard emission factors, the 

maximum firing rate, and maximum hours of operation, as 

indicated in the permit application. Compliance with 

annual limits shall be determined from a running total of 

12 months of data. 

The above limitations were established in Permit 74100089, 

pursuant to 40 CFR 52.21, Prevention of Significant 

Deterioration (PSD). These limits ensure that the 

construction and/or modification addressed in the 

aforementioned 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]. 

7.4.7 Testing Requirements 

None 

7.4.8 Monitoring Requirements 

None 

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 the affected boilers to demonstrate compliance with 

the Conditions of this permit, pursuant to Section 

39.5(7)(b) of the Act: 
35 

a. Total natural gas usage for the boilers (cubic 

feet/month and per year). 

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

emissions from the boilers, based on natural gas 

consumption and the applicable emission factors, with 

supporting calculations. 

7.4.10 Reporting Requirements 

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section, of deviations 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: 

a. Notification within 60 days of operation of an 

affected boiler that may not have been in compliance 

with the opacity limitations of the Permit. 

b. Emissions of NOx, PM, SO2, or VOM from the affected 

boilers in excess of the limits specified in 

Conditions 5.5.1 and 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 

a. Compliance provisions addressing Condition 7.4.3(d) 

are not set by this permit as compliance is assumed 

to be achieved by the normal work practices and 

maintenance activities inherent in operation of 

natural gas fired boilers. 

b. Compliance with emission limits in Condition 5.5 

shall be based on the recordkeeping requirements in 

Condition 7.4.9 and the emission factors and formulas 

listed below: 

 Emission Factor 

Pollutant (lb/106

 ft3)

 

NOx 100.0 

PM 7.6 

SO2 0.6 

VOM 5.5 

These are the emission factors for uncontrolled 

natural gas combustion in small industrial boilers 
36 

(<100 mmBtu/hr), Tables 1.4.1 and 1.4.2, AP-42, 

Volume I, 5th Edition, March 1998 Revision. 

Boiler emissions (lb) = natural gas consumed 

multiplied by the appropriate emission factor. 
37 

7.5 Cleaning Tanks 

7.5.1 Description 

Wipe cleaning is being performed to clean gravure design 

cylinders. 

7.5.2 List of Emission Units and Air Pollution Control Equipment 

Emission 

Unit Description 

Emission Control 

Equipment 

CT1 Cleaning Tank #1 None 

CT2 Cleaning Tank #2 None 

CT3 Cleaning Tank #3 None 

CT4 Cleaning Tank #4 None 

7.5.3 Applicability Provisions and Applicable Regulations 

a. i. The “affected cleaning tanks” for the purpose 

of these unit-specific conditions, are the 

cleaning tanks listed in Condition 7.5.2. 

ii. The affected cleaning tanks are subject to the 

emission limits identified in Condition 5.2.2. 

b. The owner or operator shall not cause or allow the 

discharge of more than 3.6 Kg/hr (8 lbs/hr) of 

organic material into the atmosphere from an affected 

cleaning tank [35 IAC 215.301]. If no odor nuisance 

exists this limitation shall apply only to 

photochemically reactive material. 

7.5.4 Non-Applicability of Regulations of Concern 

N/A 

7.5.5 Operational and Work Practices 

Used cleaning towels shall be kept in closed containers. 

7.5.6 Emission Limitations 

In addition to Condition 5.2.2 and the source wide 

emission limitations in Condition 5.5, the affected 

cleaning tanks are subject to the following: 

N/A 

7.5.7 Testing Requirements 

Upon request by the Illinois EPA, the percent 

concentration of solvent in the VOM containing waste from 

the affected cleaning tanks shall be determined according 
38 

to USEPA Test Methods for Evaluation of Solid Waste, 

Physical/Chemical Methods (SW-846), Test Method 8260. 

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 each affected plate washer to demonstrate compliance 

with the permit conditions, pursuant to Section 39.5(7)(b) 

of the Act: 

a. Annual pounds of cleaning compound used. 

b. VOM content of the cleaning compound. 

c. Annual pounds of waste solvent shipped offsite, if 

VOM emission credit is taken. 

d. VOM content of waste solvent shipped offsite, if VOM 

emission credit is taken. 

e. VOM emissions. 

7.5.10 Reporting Requirements 

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section, of deviations of an affected cleaning 

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. 

7.5.11 Operational Flexibility/Anticipated Operating Scenarios 

N/A 

7.5.12 Compliance Procedures 

a. Compliance provisions addressing Condition 7.5.3(b) 

are not set by this permit as compliance is assumed 

to be achieved by the normal work practices and 

maintenance activities inherent in operation of an 

affected cleaning tank. 

b. VOM emissions may be calculated using the emission 

formula listed below: 
39 

VOM Content

Compound

Cleaning

x

Usage(lb)

Compound

Cleaning

Compound Usage(lb)

from Cleaning

VOM Emissions

=
40 

7.6 Ink Jetting Units 

7.6.1 Description 

Ink jetting units are used for labeling. A number of ink 

jet units are used in the process. 

7.6.2 List of Emission Units and Air Pollution Control Equipment 

Emission 

Unit Description 

Emission Control 

Equipment 

IJ1 Ink Jetting Units None 

7.6.3 Applicability Provisions and Applicable Regulations 

a. The “affected ink jet operation” for the purpose of 

these unit-specific conditions, is the ink jet 

operation listed in Condition 7.6.2. 

b. The owner or operator shall not cause or allow the 

discharge of more than 3.6 Kg/hr (8 lbs/hr) of 

organic material into the atmosphere from any 

emission unit [35 IAC 215.301]. If no odor nuisance 

exists this limitation shall apply only to 

photochemically reactive material. 

c. The affected ink jet operation is subject to the 

emission limits identified in Condition 5.2.2. 

7.6.4 Non-Applicability of Regulations of Concern 

N/A 

7.6.5 Operational and Production Limits and Work Practices 

N/A 

7.6.6 Emission Limitations 

In addition to Condition 5.2.2 and the source wide 

emission limitations in Condition 5.5, the affected ink 

jet operation is subject to the following: 

N/A 

7.6.7 Testing Requirements 

Upon request by the Illinois EPA, the volatile organic 

material content of the inks shall be determined by Method 

24, 40 CFR 60, Appendix A, incorporated by reference in 

Section 215.105 [35 IAC 215.409]. 

7.6.8 Monitoring Requirements 

None 
41 

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 ink jet operation to demonstrate 

compliance with the permit conditions, pursuant to Section 

39.5(7)(b) of the Act: 

a. Annual pounds of inks and ink related material usage. 

b. VOM content of inks and ink related material used. 

c. VOM emissions. 

7.6.10 Reporting Requirements 

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section, of deviations of the affected ink 

jetting operation 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. 

7.6.11 Operational Flexibility/Anticipated Operating Scenarios 

The Permittee is authorized to change the ink 

manufacturer, formulation and content, and any other 

chemical used in such operation, provided these changes 

comply with the permit conditions. This condition does 

not affect the Permittee’s obligation to properly obtain a 

construction permit in a timely manner for any activity 

constituting construction or modification of the source, 

as defined in 35 IAC 201.102. 

7.6.12 Compliance Procedures 

a. Compliance provisions addressing Condition 7.6.3(b) 

are not set by this permit as compliance is assumed 

to be achieved by the normal work practices and 

maintenance activities inherent in operation of an 

affected ink jetting operation. 

b. VOM emissions may be calculated using the emission 

formula listed below: 

VOM Emissions (lb) = Material Usage (lb) x VOM Content 
42 

7.7 Chromium Electroplating 

7.7.1 Description 

Two electroplating tanks are used for chromium plating of 

gravure design cylinders. 

7.7.2 List of Emission Units and Air Pollution Control Equipment 

Emission 

Unit Description 

Emission Control 

Equipment 

ET1 Chromium Electroplating 

Tank #1 

Multiple Stage 

Composite Mesh Pad 

Demister #1 

ET2 Chromium Electroplating 

Tank #2 

Multiple Stage 

Composite Mesh Pad 

Demister #2 

7.7.3 Applicability Provisions and Applicable Regulations 

a. Chrome Plating Tanks #1 and #2 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 for Hard and Decorative 

Chromium Electroplating and Chromium Anodizing Tanks, 

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

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: 

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)]. 
43 

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 [35 IAC 

212.321(a)]. 

ii. The allowable emission rates of 35 IAC 212.321 

may be calculated by the following equation: 

E = A(P)B

Where: 

P = process weight rate; 

E = allowable emission rate; and, 

A. For process weight rates up to 408 mg/hr 

(450 T/hr): 

 Metric English

 

P Mg/hr T/hr 

E kg/hr lbs/hr 

A 1.214 2.54 

B 0.534 0.534 

7.7.4 Non-Applicability of Regulations of Concern 

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). 

7.7.5 Operational and Production Limits and Work Practices 

The operation and maintenance practices required by 40 CFR 

63.342(f) shall be implemented, including: 

a. 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 
44 

the operation and maintenance plan required by 40 CFR 

63.342(f)(3). 

b. Malfunctions shall be corrected as soon as 

practicable after their occurrence in accordance with 

the operation and maintenance plan required by 40 CFR 

63.342(f)(3). 

c. A quarterly visual inspection of composite mesh pad 

(CMP) system to ensure there is proper drainage, no 

chromic acid buildup on the pads, and no evidence of 

chemical attack on the structural integrity of the 

devices. 

d. A quarterly visual inspection of the back portion of 

the mesh pad closest to the fan to ensure there is no 

breakthrough of chromic acid mist. 

e. A quarterly visual inspection of duct work from the 

tank(s) to the control device to ensure there are no 

leaks. 

f. Perform washdown of the composite mesh-pads in 

accordance with manufacturer’s recommendations. 

g. The operation and maintenance plan shall specify 

procedures to follow to ensure that equipment or 

process malfunctions due to poor maintenance or other 

preventable conditions do not occur. 

7.7.6 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: 

N/A 

7.7.7 Testing Requirements 

The Permittee shall perform all applicable testing for the 

affected plating tanks and associated emission control 

equipment as specified by 40 CFR 63.344. 

7.7.8 Monitoring Requirements 

The Permittee shall perform all applicable monitoring for 

the affected plating tanks and associated emission control 

equipment as specified by 40 CFR 63.343 and 63.344, 

including: 

Composite mesh-pad systems. (i) During the initial 

performance test, the owner or operator of an 

affected source, or a group of affected sources under 
45 

common control, complying with the emission 

limitations in Section 63.342 through the use of a 

composite mesh-pad system shall determine the outlet 

chromium concentration using the test methods and 

procedures in Section 63.344(c), and shall establish 

as a site-specific operating parameter the pressure 

drop across the system, setting the value that 

corresponds to compliance with the applicable 

emission limitation, using the procedures in Section 

63.344(d)(5). An owner or operator may conduct 

multiple performance tests to establish a range of 

compliance pressure drop values, or may set as the 

compliant value the average pressure drop measured 

over the three test runs of one performance test and 

accept [plusmn]1 inch of water column from this value 

as the compliant range [40 CFR 63.343(c)(1)]. 

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 emission units to demonstrate compliance, 

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

The Permittee shall retain all the applicable records 

for the affected plating tanks as specified by 40 CFR 

63.346. 

7.7.10 Reporting Requirements 

The Permittee shall promptly notify the Illinois EPA, 

Compliance Section, of deviations of the affected plating 

tanks 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. The Permittee shall submit all applicable reports for 

the affected plating tanks as specified in 40 CFR 

63.347. 

7.7.11 Operational Flexibility/Anticipated Operating Scenarios 

N/A 

7.7.12 Compliance Procedures 

a. Compliance with Condition 7.7.3 for each affected 

plating tank is addressed by performance of the 

operational and work practices requirements of 

Condition 7.7.5, performance of monitoring 

requirements of Condition 7.7.8, performance of the 

testing required by Condition 7.7.7, and the 

recordkeeping required by Condition 7.7.9. 
46 

b. Emissions may be calculated based on the following: 

 Emission Factor 

Pollutant (gr/dscf)

 

Chromium 3.8 x 10-6

PM 8.0 x 10-6

These are the emission factors for hard chromium 

electroplating with composite mesh-pad mist 

eliminator, 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) 
47 

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 September 25, 2003 (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 that contravene express permit terms 

without applying for or obtaining an amendment to this 

permit, provided that [Section 39.5(12)(a)(i) of the 

Act]: 

a. The changes do not violate applicable requirements; 
48 

b. The changes do not contravene federally enforceable 

permit terms or conditions that are monitoring 

(including test methods), recordkeeping, reporting, 

or compliance certification requirements; 

c. The changes do not constitute a modification under 

Title I of the CAA; 

d. Emissions will not exceed the emissions allowed under 

this permit following implementation of the physical 

or operational change; and 

e. 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. This notice shall: 

i. Describe the physical or operational change; 

ii. Identify the schedule for implementing the 

physical or operational change; 

iii. 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; 

iv. Provide emission calculations which 

demonstrate that the physical or operational 

change will not result in a modification; and 

v. 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. 
49 

8.6 Reporting Requirements 

8.6.1 Monitoring Reports 

If monitoring is required by any applicable requirements 

or conditions of this permit, a report summarizing the 

required monitoring results, 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]: 

Monitoring Period Report Due Date

 

January - June 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 
50 

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; 

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 

5415 North University 

Peoria, Illinois 61614 
51 

iii. Illinois EPA - Air Permit Section 

Illinois Environmental Protection Agency 

Division of Air Pollution Control 

Permit Section (MC 11) 

P.O. Box 19506 

Springfield, Illinois 62794-9506 

iv. USEPA Region 5 - Air Branch 

USEPA (AE - 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. 
52 

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. 
53 

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 

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)(a) and 

(p)(ii) of the Act and 415 ILCS 5/4]: 

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 
54 

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 

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

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

pollutants authorized by this permit; 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 authorized 

by this permit. 

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 
55 

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 

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. 

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 annual compliance certifications. The compliance 
56 

certifications shall be submitted no later than May 1 or more 

frequently as specified in the applicable requirements or by 

permit condition. The compliance certifications shall be 

submitted to the Air Compliance Section, Air Regional Field 

Office, and USEPA Region 5 – Air Branch. The addresses for the 

submittal of the compliance certifications are provided in 

Condition 8.6.4 of this permit. 

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. 
57 

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]. 
58 

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; 

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]. 

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 
59 

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]. 
1-1 

10.0 ATTACHMENTS 

10.1 Attachment 1 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: ______________________________________________
2-1 

10.2 Attachment 2 Guidance on Revising This Permit 

The Permittee must submit an application to the Illinois EPA 

using the appropriate revision classification in accordance with 

Sections 39.5(13) and (14) of the Act and 35 IAC 270.302. 

Specifically, there are currently three classifications for 

revisions to a CAAPP permit. These are: 

1. Administrative Permit Amendment; 

2. Minor Permit Modification; and 

3. Significant Permit Modification. 

The Permittee must determine, request, and submit the necessary 

information to allow the Illinois EPA to use the appropriate 

procedure to revise the CAAPP permit. A brief explanation of 

each of these classifications follows. 

1. Administrative Permit Amendment

• Corrects typographical errors; 

• Identifies a change in the name, address, or phone 

number of any person identified in the permit, or 

provides a similar minor administrative change at the 

source; 

• Requires more frequent monitoring or reporting by the 

Permittee; 

• Allows for a change in ownership or operational 

control of the source where no other change in the 

permit is necessary, provided that a written 

agreement containing a specific date for transfer of 

permit responsibility, coverage, and liability 

between the current and new Permittees has been 

submitted to the Illinois EPA. This shall be handled 

by completing form 272-CAAPP, REQUEST FOR OWNERSHIP 

CHANGE FOR CAAPP PERMIT; or 

• Incorporates into the CAAPP permit a construction 

permit, provided the conditions of the construction 

permit meet the requirements for the issuance of 

CAAPP permits. 

2. Minor Permit Modification

• Do not violate any applicable requirement; 

• Do not involve significant changes to existing 

monitoring, reporting, or recordkeeping requirements 

in the permit; 
2-2 

• Do not require a case-by-case determination of an 

emission limitation or other standard, or a 

source-specific determination of ambient impacts, or 

a visibility or increment analysis; 

• Do not seek to establish or change a permit term or 

condition for which there is no corresponding 

underlying requirement and which avoids an applicable 

requirement to which the source would otherwise be 

subject. Such terms and conditions include: 

• A federally enforceable emissions cap assumed 

to avoid classification as a modification 

under any provision of Title I of the CAA; and 

• An alternative emissions limit approved 

pursuant to regulations promulgated under 

Section 112(i)(5) of the CAA. 

• Are not modifications under any provision of Title I 

of the CAA; 

• Are not required to be processed as a significant 

permit modification; and 

• Modifications involving the use of economic 

incentives, marketable permits, emissions trading, 

and other similar approaches. 

An application for a minor permit modification shall 

include the following: 

• A description of the change, the emissions resulting 

from the change, and any new applicable requirements 

that will apply if the change occurs; 

• The source’s suggested draft permit/conditions; 

• Certification by a responsible official that the 

proposed modification meets the criteria for use of 

minor permit modification procedures and a request 

that such procedures be used; and 

• Information as contained on form 271-CAAPP, MINOR 

PERMIT MODIFICATION FOR CAAPP PERMIT for the Illinois 

EPA to use to notify USEPA and affected States. 
2-3 

3. Significant Permit Modification

• Applications that do not qualify as either minor 

permit modifications or as administrative permit 

amendments; 

• Applications requesting a significant change in 

existing monitoring permit terms or conditions; 

• Applications requesting a relaxation of reporting or 

recordkeeping requirements; and 

• Cases in which, in the judgment of the Illinois EPA, 

action on an application for modification would 

require decisions to be made on technically complex 

issues. 

An application for a significant permit modification shall 

include the following: 

• A detailed description of the proposed change(s), 

including all physical changes to equipment, changes 

in the method of operation, changes in emissions of 

each pollutant, and any new applicable requirements 

which will apply as a result of the proposed change. 

Note that the Permittee need only submit revised forms 

for equipment and operations that will be modified. 

The Illinois EPA requires the information on the following 

appropriate forms to be submitted in accordance with the proper 

classification: 

• Form 273-CAAPP, REQUEST FOR ADMINISTRATIVE PERMIT 

AMENDMENT FOR CAAPP PERMIT; or 

• Form 271-CAAPP, MINOR PERMIT MODIFICATION FOR CAAPP 

PERMIT; or 

• Form 200-CAAPP, APPLICATION FOR CAAPP PERMIT (for 

significant modification). 

Application forms can be obtained from the Illinois EPA website 

at http://www.epa.state.il.us/air/forms. 

Note that the request to revise the permit must be certified for 

truth, accuracy, and completeness by a responsible official. 

Note that failure to submit the required information may require 

the Illinois EPA to deny the application. The Illinois EPA 

reserves the right to require that additional information be 

submitted as needed to evaluate or take final action on 

applications pursuant to Section 39.5(5)(g) of the Act and 35 IAC 

270.305. 
10.3 Attachment 3 Form 199-CAAPP, Application For Construction 

Permit (For CAAPP Sources Only) 

Illinois Environmental Protection Agency 

Division Of Air Pollution Control -- Permit Section 

P.O. Box 19506 

Springfield, Illinois 62794-9506 

This Agency is authorized to require and you must disclose this information under 415 ILCS 5/39. Failure to do so could result in the application 

being denied and penalties under 415 ILCS 5 et seq. It is not necessary to use this form in providing this information. This form has been 

approved by the forms management center.

 Printed on Recycled Paper 

199-CAAPP 

Page 1 of 2

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For Illinois EPA use only 

ID number: 

Permit number: Application For Construction 

Permit (For CAAPP Sources Only)

Date received: 

This form is to be used by CAAPP sources to supply information necessary to obtain a construction permit. Please attach other 

necessary information and completed CAAPP forms regarding this construction/modification project. 

Source Information 

1. Source name: 

2. Source street address: 

3. City: 4. Zip code: 

5. Is the source located within city limits? Yes No 

6. Township name: 7. County: 8. ID number: 

Owner Information 

9. Name: 

10. Address: 

11. City: 12. State: 13. Zip code: 

Operator Information (if different from owner) 

14. Name 

15. Address: 

16. City: 17. State: 18. Zip code: 

Applicant Information 

19. Who is the applicant? 20. All correspondence to: (check one) 

 Owner Operator Owner Operator Source 

21. Attention name and/or title for written correspondence: 

22. Technical contact person for application: 23. Contact person's telephone number: 
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199-CAAPP 

Page 2 of 2

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Summary Of Application Contents 

24. Does the application address whether the proposed project would 

constitute a new major source or major modification under each of the 

following programs: 

a) Non-attainment New Source Review – 35 IAC Part 203; 

b) Prevention of Significant Deterioration (PSD) – 40 CFR 52.21; 

c) Hazardous Air Pollutants: Regulations Governing Constructed or 

Reconstructed Major Sources – 40 CFR Part 63? 

 Yes No 

25. Does the application identify and address all applicable emissions 

standards, including those found in the following: 

a) Board Emission Standards – 35 IAC Chapter I, Subtitle B; 

b) Federal New Source Performance Standards – 40 CFR Part 60; 

c) Federal Standards for Hazardous Air Pollutants – 40 CFR Parts 61 

and 63? 

 Yes No 

26. Does the application include a process flow diagram(s) showing all 

emission units and control equipment, and their relationship, for which a 

permit is being sought? 

 Yes No 

27. Does the application include a complete process description for the 

emission units and control equipment for which a permit is being sought? Yes No 

28. Does the application include the information as contained in completed 

CAAPP forms for all appropriate emission units and air pollution control 

equipment, listing all applicable requirements and proposed exemptions 

from otherwise applicable requirements, and identifying and describing 

any outstanding legal actions by either the USEPA or the Illinois EPA? 

Note: The use of "APC" application forms is not appropriate for 

applications for CAAPP sources. CAAPP forms should be used to 

supply information. 

 Yes No 

29. If the application contains TRADE SECRET information, has such 

information been properly marked and claimed, and have two separate 

copies of the application suitable for public inspection and notice been 

submitted, in accordance with applicable rules and regulations? 

 Yes No 

 Not Applicable, No 

TRADE SECRET 

information in this 

application 

Note 1: Answering “No” to any of the above may result in the application being deemed incomplete. 

Signature Block 

 This certification must be signed by a responsible official. Applications without a signed 

certification will be returned as incomplete. 

30. I certify under penalty of law that, based on information and belief formed after reasonable 

inquiry, the statements and information contained in this application are true, accurate and 

complete.

Authorized Signature: 

 BY: 

_________________________________________________ _________________________________________________ 

 AUTHORIZED SIGNATURE TITLE OF SIGNATORY 

 

_________________________________________________ _______________ / _______________ / _______________ 

 TYPED OR PRINTED NAME OF SIGNATORY DATE 

Note 2: An operating permit for the construction/modification permitted in a construction permit must be 

obtained by applying for the appropriate revision to the source’s CAAPP permit, if necessary. 
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199-CAAPP 

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10.4 Attachment 4 Guidance on Renewing This Permit 

Timeliness - Pursuant to Section 39.5(5)(n) of the Act and 35 IAC 

270.301(d), a source must submit to the Illinois EPA a complete 

CAAPP application for the renewal of a CAAPP permit not later 

than 9 months before the date of permit expiration of the 

existing CAAPP permit in order for the submittal to be deemed 

timely. Note that the Illinois EPA typically sends out renewal 

notices approximately 18 months prior to the expiration of the 

CAAPP permit. 

The CAAPP application must provide all of the following 

information in order for the renewal CAAPP application to be 

deemed complete by the Illinois EPA: 

1. A completed renewal application form 200-CAAPP, 

APPLICATION FOR CAAPP PERMIT. 

2. A completed compliance plan form 293-CAAPP, COMPLIANCE 

PLAN/SCHEDULE OF COMPLIANCE FOR CAAPP PERMIT. 

3. A completed compliance certification form 296-CAAPP, 

COMPLIANCE CERTIFICATION, signed by the responsible 

official. 

4. Any applicable requirements that became effective during 

the term of the permit and that were not included in the 

permit as a reopening or permit revision. 

5. If this is the first time this permit is being renewed and 

this source has not yet addressed CAM, the application 

should contain the information on form 464-CAAPP, 

COMPLIANCE ASSURANCE MONITORING (CAM) PLAN. 

6. Information addressing any outstanding transfer agreement 

pursuant to the ERMS. 

7. a. If operations of an emission unit or group of 

emission units remain unchanged and are accurately 

depicted in previous submittals, the application may 

contain a letter signed by a responsible official 

that requests incorporation by reference of existing 

information previously submitted and on file with the 

Illinois EPA. This letter must also include a 

statement that information incorporated by reference 

is also being certified for truth and accuracy by the 

responsible official’s signing of the form 200-CAAPP, 

APPLICATION FOR CAAPP PERMIT and the form 296-CAAPP, 

COMPLIANCE CERTIFICATION. The boxes should be marked 

yes on form 200-CAAPP, APPLICATION FOR CAAPP PERMIT, 
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199-CAAPP 

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as existing information is being incorporated by 

reference. 

b. If portions of current operations are not as 

described in previous submittals, then in addition to 

the information above for operations that remain 

unchanged, the application must contain the necessary 

information on all changes, e.g., discussion of 

changes, new or revised CAAPP forms, and a revised 

fee form 292-CAAPP, FEE DETERMINATION FOR CAAPP 

PERMIT, if necessary. 

8. Information about all off-permit changes that were not 

prohibited or addressed by the permit to occur without a 

permit revision and the information must be sufficient to 

identify all applicable requirements, including 

monitoring, recordkeeping, and reporting requirements, for 

such changes. 

9. Information about all changes made under 40 CFR 

70.4(b)(12)(i) and (ii) that require a 7-day notification 

prior to the change without requiring a permit revision. 

The Illinois EPA will review all applications for completeness 

and timeliness. If the renewal application is deemed both timely 

and complete, the source shall continue to operate in accordance 

with the terms and conditions of its CAAPP permit until final 

action is taken on the renewal application. 

Notwithstanding the completeness determination, the Illinois EPA 

may request additional information necessary to evaluate or take 

final action on the CAAPP renewal application. If such 

additional information affects your allowable emission limits, a 

revised form 292-CAAPP, FEE DETERMINATION FOR CAAPP PERMIT must 

be submitted with the requested information. The failure to 

submit to the Illinois EPA the requested information within the 

time frame specified by the Illinois EPA, may force the Illinois 

EPA to deny your CAAPP renewal application pursuant to Section 

39.5 of the Act. 

Application forms may be obtained from the Illinois EPA website 

at http://www.epa.state.il.us/air/forms.html. 

If you have any questions regarding this matter, please contact a 

permit analyst at 217/782-2113. 

Mail renewal applications to: 

Illinois Environmental Protection Agency 

Division of Air Pollution Control 

Permit Section (MC 11) 
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199-CAAPP 

Page 2 of 2

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P.O. Box 19506 

Springfield, Illinois 62794-9506 

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