Veol ia ES Techni cal Solutions , L .L .C. Pennit No.: V

-IL ·1 7 1 6300 103 · 2 0 14 · 10 Issuance Date: DRAFT Expiration Date : DRAFT Page 123 of 172
(f) A l ist of cost-effective energy con s ervation measures that are within the facility 's control; (g) A list of the energy savings potential of the energy conservation me asures i dentified ; and (h) A comprehensive report detailing the ways to impr ove efficie ncy , the cos t of s pecific improvements, benefits, and the time frame for reco uping thos e investments
. [40 C
. F .R. 

### § 63.7500 and Appendix to 40 C.F .R. Part 

### 63, S u bpart 

### DDDDD, Table 3 ( It em 4)] 5
. At all times, the Permittee must operate and maintai n Boile r #1, including any associated air pollution control equipment and m on i toting equipment, i n a manner cons i sten t with safety and good air pollut ion control practices for minimi zing emissions. Determination of whether such operat i on a n d m aintenance procedures are being u s ed 

### will be based on information available to t he Administrator that may inc lude , but is not limited to, monitori ng resul ts, review of operation and maintenance procedures , review ofoperation and maintenance records , and inspection ofthe source . [40 C.P.R.§ 63.7500(a)(3)) ( D) Mo ni toring and Testing (4 0 C.F.R. 

### § 7l.6(a)( 3 )) I
. The Penn ittee shall perform an annual Method 9 tes t to ensure complian ce with the opacity 

### limit. [40 C.F.R
. § 71.6(a)(3)(i)(B)) 2. The Penmittee m u st co nduct an ann ual tune-up of Boiler# I to d emonstrate continuous compliance with the work practice standards of 40 C.F.R. Part 63, Subpart 

### DDDDD , as specified below: (a) Inspect the burner, and clean or replace any components oftbe burner as nec essary . T he Permittee may delay the burner inspection unti l the next sched u led unit shutdown ; (40 C.P
. R.§ 63.7540(a)(lO)(i)) (b) Inspect the flame pattern, and adjust the b urner as necessary to optimize the flame pattern. The adjustment shou l d be consistent w i th the ma n ufucturer's specifications, i f a vai l able; [ 40 C
. F
. R. § 6 3.7540(aXlO)(ii)) (c) Tnspect the sy s tem controlling the air

- to
- fuel ratio, and ensure that it is correctly calibrated and function in g properly
. The Permittee may delay the inspection until the next scheduled unit shutdown; ( 40 C.F
. R. 

### § 63.7540(a)(IO)(iii) ] (d) Optimize total emissions of 

### CO. This optimization should be consis tent w ith the manufacturer's specifications, if availa bl e, and w i th any 

### NO x



### VES009200Veoli a ES Techni cal Solutions, L. L .C. Pennit No
. : V

- IL

- 17 16300103 -2014

- 10 Iss u an

ce Date: DRAFT Expirat i on Date: DRAFT requirement to which Boiler #I is sub j ect; and (40 C.P.R
. § 63 .75 40( a)(IO)(iv)] Page 1 24 of 172

(e) Measure the concentra ti ons in the effluent stream ofCO and N Ox in parts per million, by volume , and oxygen in volume percent, before and after the adjustments are made. Measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made
. Measurements may be taken using portable CO and NOx analyzers
. [40 C. F. R. § 63.7540(a ) (lO)(v); 40 C.F.R. § 71.6(a)(3)(i)(B)] 3. IfB o il er # I is not opera ti ng on the required date for a tune-up, the tune - u p must be condu cted wi t hin 30 calendar days of startup. (40 C.F.R- § 63.7540(a)(l3)) 4
. The Permittee m ust conduct performance tests for CO and NOx from the affected boiler at a frequency of no le ss than once every 

### 5 years to demo ns trate compliance with the CO and NOx e m ission limits in con dition 2.7(A)(2). Each perfomtance test must be conducted between 48 and 60 months after the pre vio us perfonnance test. T he Permittee mus t do the follow i ng duri ng the perfortnance tests: (a

) Select the sampling ports location and the number of traverse point s using Met hod I in 4 0 C. FK Part 60 , Appendix A; (b) Determ i ne oxygen and carbon dioxide concentrations of the stack gas using Method 3A or 38 i n 40 C. F R. Part 60, Appendix A, or ASTM 06522

- 00 (ffiR, s ee40C.F.R
. § 63.14(b)) , or ASMEPTC 19 , Part 1 0 (1981) (IBR , 

### see 40 C.F.R. § 63 .1 4(i ) ); (c) Measure the moisture conten t ofthe stack gas using Method 4 in 40 C.F.R. Part 60 , Appendix A ; (d

) Measure the NOx e m ission concen tration using Method 7 or 7E in Appen dix A to 40 C
. F.R. Part 60 , or ASTM 06522--()() (ffiR, 

### see 40 C.F.R. 

### § 63.14(b)): and (e) Measure the CO emission concentration using Method 10, lOA, or lOB in Appendix A to 40 C.F
. R
. Pat1 60, or ASTM 06522

- 00 (IBR , 

### see 40 C
. F
. R. § 63.14(b)) when the ft t el is n a tu ral gas. [ 40 C .F .R. § 7 1 .6(a)(3)(i)(B)] (E) Recordkeeping and Re porting (40 C.F .R 

### § 71.6(a)(3)] I
. The Penni ttee m ust record and maintain onsite:



### VES00920 1V eol ia ES Technica l Solutions, L
. L
.C. Pertnit N o .: V

- I L

- 1716300103

- 2014

- 10 Issuance Date: DRAFT Expirntion Date : DRAFT Page 125 of 172
(a) Monthly records of natural gas usage; (40 C.F.R. § 60.48c(g)] (b) Arulual records of natural gas usage (million standard cubic feet per year); [Const ruction Pennit 95080025 ] (c) An annual report containing the following infomtation: (i) The concentrations of CO and NOx in the effluenl stream in parts per million by volume, and oxygen in volume percent, measured at high fire or typical operating l oad, before and after the tune-up ofthe boiler; and (ii) A description of any corrective actions taken as a part of the tune-up. [40 C.F.R. § 63.7540{a)(10)(vi); 40 C .F .R. § 71.6(a)(3)(i)(B)) (d) A summary of the results of all required perfonnance tests. [40 C.F.R. § 71.6(a)(3)(i)(B)] 2. The Pennittee must subm it annually a compliance report which contains: (a) Company name and address; (b) Statement by a responsible official with that official's name, titl e, and signature ,**certif)~ng** the tmth, accuracy , and completeness of the content of dte report; (c) Date ofreport and beginning and ending dates of the reporting period; (d) A summary of the results ofthe annual tune-ups , including the date of the most rec en t burner inspection if it was no t done annually and was delayed unti l the next s chedu led or unscheduled unit shutdown. The Pennittee shall make actual tune-up results avail able to tl1e Administrator upon request; ( e) A summary of the results ofperformance test s conducted during the reponing period. The Pennittee shall make actua l test results available to the Administrator upon request; (1) The hours of operation for the boiler for eac h calendar month within the reporting period; (g) The amount of natural gas used during the reporting period (million s t

andard cubic feet per year) ; and (h) If the boiler had a startu p , sh utdown, or m alfunction during the reporting period a nd the Pennittee took actions consistent with the SSMP, the



### VES009202Voolia BS Technica l Solutions, L
. L.C
. Pcnnit No. : V-!L-1716300 1 03-201 4- 10 Issuance Date: DRAFT Expiration Date: DRAFT 

### compliance report mus t include the infonnation in 40 C.F.R. § 

### 63.10(d){S)(i). (40 C
. P.R § 

### 63
. 7550(c)(l); 40 C.F.R. § 7 1. 6(a)(3){i)(B)) Page 1 26 of 172



### 3
. The Pennittee shall notify the IEPA prior t o any change in tl1e types of fue l used in the boiler. [Construction Permit 95080025] 

### 2
. 8 EMER<..'ENCY GENERATORS (A ) 

### Emission Limitations and S tandards ( 40 C.F.R. 

### § 71.6(a)(l) ) The two diesel fuel-fired emergency generators, each with 

### a site rat ing ofless than 112 HP, are subject to the NESHAP for Stationary Rec i procating Internal Combustion Engines (RICE), 40 C.P.R. Part 63, Subpart ZZZZ. However, there are no numerical emission limi tations that apply. [ 40 C
. P
. R.§§ 63.6585 , 63.6602) (B) 

### No n applica ble R eg ul ation s (40 C.F.R. 

### § 7 1
. 6(1) ( 1 ) ) I
. The emergency gen erators are no t subject to !he Standards of Performance for Stationary Compress ion Ignition Internal Combustion Engines , 40 C.P.R. Part 60, Subpart Illl , 

### beca use construction o f the emergency generator e ng ines did not commence, as defined at 

### 40 C.P.R. § 

### 60.4200(a) , after Ju ly I I , 2005 and the engines h ave not been modified or reconstructed after July 

### 11, 2005. [ 40 C.P
. R.§ 60.4200] 2. The emergency generators are not subject to the Standards of Performance for Station ary Spa r k Ignit ion Int ernal Combustion Engines , 40 C.F .R. Part 60 , Subpart JJJJ , 

### because the emergency generator engines are not spark ignition engines 

### as de fined a t 40 C.P.R.§ 60.4248. [40 C.F.R. 

### § 60.4230) 3. 

### The emergency generat ors are not subject to 40 

### C.F.R. Prut 64, Compliance Assurance Monitoring, because tbe emergency generat ors do not use an add

- on control device to achieve compliance with an emission limitation or standard
. [40 

### C.P.R. § 64.2(a)) ( C) 

### Work P rac ti ce and Operatio nal R e

quirements ( 40 C.F.R. 

### § 71 .6(a)(l) ) I. In order for each engine to be considered an emergency stationary RICE under 40 C.F.R. Part 63, Subpart ZZZZ, any operation other than emergency operation, maintenance and testing, emergency demand response , and operation in 

### non emergency situa tions for 50 hours per year, as described in condition 2.8(C)(2), below, is prohibit ed. lf the Pennittee does not ope rate the engine according to t he req uiremen ts in condition 2.8(C)(2), below, the engine w ill not be considered



### VES 009203Veolia ES Tcclwi cal Solutions, W...C. Pennit No
. : V
. JL
. J 716300103 · 2014 · 10 Is suance Date: DRAFT Exp iratio n Date : DRAfT Page 1 27 o f 1 72



### an emergency engine and must meet all requirements for non - emergency engines in 40 C.P.R. Part 63, Subpart ZZZZ
. [ 40 C.F.R. § 

### 63.6640(1)] 2. The Permittee must operate each emergency generator according to the following requirements: ( 40 C
. F.R. § 63
. 6640(1)] (a) Ther e is no time limit on the use of the emergency generators in emergency situations. (b) 

### The Permittee may operate each emergency generator for any combination of !he purposes specified in (i) through (iii) , below, for a maximum of 100 hours per calendar year. Any operation for n on-emergency s itu ations as allowed by condition 2.8(C)(2)(c) , below, counts as part of the 100 hours per calendar year . (i) The Perm ittee may operate each emergency generator for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing aut hority and transmission operator, or the insurance c.ompany associated with the engine
. The Permittee may petition the Administrator for approval ofadditional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains**record~** 

### indicating that federal, state, or local standards require maintenance and testing of !he emergency generator beyond I 00 hours per calendar year. (ii) The Permittee may operate each emergency generator for emergency demand response for periods in which the Reliability Coordinator under th e North American Electric Reliability Corporation (NERC) Reliability Standard EOP

- 002

- 3 , Capacity and Energy Emergencies (incorporated by reference, se.e 

### 40 C. P.R.§ 63.14), or other authorized entity as determin ed by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Rel iability S tandard EOP-002-3. (iii) The Pennittee may operate each emergency generator for periods where there is a deviation of voltage or frequency of 5 percent or b'teater below standard voltage or frequency. (c) The Pennittee may operate each emergency generator for u p t o 50 hours per calendar year in non - emergency s ituations. Th e 50 hours of operation in non- emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency d emand response provided in condition 2.8(C)(2)(b), above. T he 5 0 hours per year for non

### VES009204Veolia ES Technica l Solutions, LL.C
. Perm i t No.: V-!L-17 16300 1 03

- 201 4 -1 0 lssu anoe Dale : DRAFI' Expiration Dat e: DRAFT Page 1 28 o f 1 72

emergency situations cannot be use d for peak shaving or non-emergency demand response, or to ge n erate income for a facility to sup ply power to an electric grid or otherwise supply power as part of a financia l arrangement with another e n tity. (40 C
. F.R. 

### § 63.6640(0(3)] 3
. The Permittee shall perform the following work practices for each emergency generator e x cept during p e riods of s t artup. T h e Pemtittee can petition the Administrator pursuant to 40 C. F
. R. § 63
. 6(g) for alternative work practices. (a) Change oil and filter every 500 hours of operation or annually , whichever comes first. The Permittee has the opt ion to utilize an oil analysis program as described in condi t ion 2.8(C)(6) , below. (b) Inspect air cleaner every 1, 000 hours of operation or annually, whichever comes first, and replace a s necessary. (c) I nspect a ll hoses and bel ts every 500 ho u rs of operation or annual ly, whichever comes first , and replace as necessary. [Table 2c, Item 1 , t o 4 0 C
. P
. R. Part 63, Su bpart ZZZZ] 4. D u ring p eriod s of startup, the Perminee minimize the engine's time spent at i dle and min. imize t he engine 's startup time at startup to a period needed for appropri at e and safe loading ofthe engine, not to exceed 30 minutes, atrer wh ich time the non-startup e miss ion limitations apply. The Pemtittee can petition the Administrator pursuant to 40 C.F.R § 63.6(g) for alternative wo rk practices. [Table 2c, Item I, to 40 C .F
. R. Part 63 , Subpart ZZZZ ] 5. If an emergency e ngin e is operating d u ring an emergency and it is not possible to shut down the engine in order to perform the work practice requiremen ts on the schedu le required io condit ion 2
. 8(C)(3), above, or if performing the work practice on t he required schedule would otherwise pose an unacceptable ris k u

n der federal , state, or local l aw, the work practi ce can be delayed unti l the e mergency i s over or the u n acceptable risk u n der fede ral, state , or local law has abated. The work practice s h o u ld be perform e d as soon as pract icable after the emergency has ended or the unacceptable ri sk under federa l , state, or local law has abated
. [Table 2c to 40 C
. F.R. Part 63 , Subpart ZZZZ, footnote I] 6. The Permittee h as the option of utilizing an oil analysis program in order to extend the specified oil c hange re quiremen t in condition 2.8(C)(3), above. Th e oil analysis mus t be perfonued a t the same frequency specified for c h angi ng the o il in co n d

i tion 2.ll(C)(3), above. The analysis program must at a minimum a

n alyze the followi n g three p arameters: Total Base Number , viscosity, and percent water con te n t. The condemning limits for these parameters are as follows: T otal Base Nwuber is less than 30 percent of the Total Base Number o f



### VES009205Voo l ia ES Techni cal Solut io ns, LL.C. Permit No.: V

- Jl-1716300103

- 20 1 4

- 1 0 

### Iss u ance Date: DRAFT Expirat i on Dat e: DRAFT Page 129 of 172



### the oil when new ; viscosity of lhe oil has changed by more than 20 percent fro m the viscosity of the oi l whe n new; or percent water content (by volwne) is greater t han 0.5. If 

### all of these condemnin g limits are not ex.ceeded,lhe Permittee is not required to cha n ge the oil. If 

### any of lhe limits are exceeded , the Permittee must change the oil within 2 business days of receiving t he results ofthe analysis; if lhe engine is not in operation when the res u lts of the analysis are rec e ived, the Permittee must change lhe oil wi t hin 2 business days or b e for e commencing operation, whichever is later. The Permittee must keep records of the parameters lhat are analyzed as part of the program, the results of the analysis, and lhe oil changes for the engine. The analysis program must be part of the maintenance plan for the engine. [ 40 C.F.R. 

### § 63.6625(i)] 7. The P ennittee shall operate and maintain each emergency generator and after

treatment control device (if any) according to tbe manufacturer's emissionrelated operation and maintenance instruct ions; or develop and follow your own maintenance plan which must provide to the extent practicable for the maintenance and operation of each engine in a manner consistent with good air pollut ion control practice for min imizing emissions. [ 40 C.F.R. § 63.6625(e) ; Table 6 , 

### Item 9, to 40 C.F.R. Part 63 , Subpart ZZZZJ 8
. The Pennittee must be in compliance wilh the applicable emission limitations , operat i ng limitations, and other requirements in 40 C.P.R. Part 63, Subpart ZZZZ, at aU t imes
. [40 C
. F
. R. § 63
. 6605(a) ] 9. At all times the Permittee mus t operate and m aintain each e mergency ge n erator, including associated air pollution control equipment and monitoring equipment (if

### any) , in a manner consisten t with safety and good air pollution control practices for minimizing emissioiiS. Determination of whelher such operation and maintenance procedures are being used will be based on infonnation available to the Administrator which may i nclude, but is not lim i ted to, monitoring results , review of operation and maintenance procedures, review of operation and maintenance records , and inspection of the source. [ 40 C
. F.R. § 

### 63.6605(b) ] 10. Beginning J anuary I, 2015, the Permittee must use d iesel fuel t hat meets tbe following requ irements of 40 C.F.R. § 

### 80.510(b) for nonroad diesel fuel, except tbat an y existing diesel fuel purchased (or otherwise obtained) prior to Janu ary I , 2015, may be used until depleted: (a) Sulfur content of 15 ppm maximum for nonroad diesel fuel. (b) Cetane index or aromatic content, as follows: (i) A minimu m cetane index of40; or



### VES009206Veolia ES Technical Solutions, U
.C
. Penni t No.: V· lL

- 1716300103 · 2014 ·1 0 Issu ance Date: DRAFT Expiration Date: DRAFT (ii) 

### A max imum aromatic content of 35 volume percent. [40 C.P
. R.§ 63.6604(b)] Page 13 0 ofl72



### II. The P ermittee must minimize the engine's time spent at idle during startup and minimize the engine's startup time to 

### a period needed for appropriate and safe loading of the engine, not to 

### exceed 30 minutes, after which time the emission standards applicable to all t i mes otber tban startup apply. (40 C.F .R. § 

### 63.6625(h)] ( D) M oni t orin g a nd T est in g [ 40 C.F. R. 

### § 71
. 6 (a)( 3)J I
. The Permittee m ust install a non-resettable hour meter on each emergency generator if one is n ot already installed. (40 C.F .R. 

### § 63.6625(£)] 2
. Except for monitor malfunctions, associated repairs , required performance evaluations , and required quality assurance or contro l acti v ities, the Pennittee must operate any required monitors continuous l y at all times that the emergency generator is operati n g. A mo nit oring mal functio n is any sudden, infrequent, not reasonab ly p r eventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operat ion are not malfunctions. [ 40 C.F.R. § 

### 63.6635{b)] 3. The Permittee may not use data recorded during monitoring ma lfunctions, associated repairs , and required quality assurance or control activities in data averages and calculations used to report emiss ion or operating levels. The Penuit tee must, however, us e all the valid data collected during al l other p eriods
. [40 C.P.R.§ 63.6635(c) ] (E) 

### R ecordkeeping and R e porting [40 C.F. R. 

### § 71. 6( a)(3)J I
. If

### the emergency generator operates or is contractually obligated to be available for more than 15 hours per year for the purposes specified in conditions 2.8(C)(2)(b)(ii) and (iii) , the Permittee must report the following information annually according to the requirements in condition 2.8(E)(2), below: (a) Company name and address whe re the engine is located. {b) Date of the report and bet:tinning and en<ling dates of the reporting period. (c) E n

gine site rating and model year. (d) Latitude and longitude of the engine in decimal degrees reported t o the fifth decimal place.



### VES009207Veolia ES Technic "! Solutions, L.L.C. Penni t No.: Y

- IL-17 1 6300 I 03-201 4

- 10 Issuance Date: DRAFT Expiration Date: DRAFT Page 131 of 172
(e) Hours operated for t h e purposes specified in conditions 2
. 8(C)(2)(b)(ii) and (iii) , including the date, start time, and end time for engine operation for the purposes specified in conditions 2. 8 (C)(2)(b)(ii) and (iii). (f) N u mber ofholU's the eng i ne is contractually obligated to be available for the pwposes specified in co n ditions 2.8(C)(2)(b)(ii) and (iii). (g) Hours spent for operation for the purpose specified in condition 2.8(C)(2)(d)(ii) , including the date , start time, and end time for engine operation for the purposes specified in condition 2.8(C){2)(d)(ii). The report must also identify the entity that dis patched the engine and the situation that necessitated the d ispatc h of the engine. (h) If there were no deviations from the fuel requirements in 40 C.P
. R. 

### § 63.6604 that apply to the engine (if any), a statement that there were no d

eviation s from t he fuel requirements during the reporting period. (i) Tft h ere were deviations from the fitel requirements in 40 C.F
. R. 

### § 63
. 6604 that apply to the engi n e (if any) , information on the number, durat io n, and cause of deviations, and the corrective action taken. ( 4 0 C
. F.R. 

### § 63
. 6650(h)(l); Table 7, Item 4, to 40 C.P.R. Part 63, Subpart ZZZZ ] 2
. The firs t annual report, for purposes of cond ition 2.8(E)(J), above, must cover the calendar year 20 1 5 and must be s u bmitted no lat er than March 31, 2016, to t h e Administrator at the a d dress in condition 4
. 8(A). S u bsequent annual reports for each calendar year must be submitted no later than March 31 of the following calendar year. ( 40 C.P.R.§ 63.6650(h)(2)-(3)] 3. The Pe rmittee must report each instance in which the Perm i ttee did not meet each operating limitation in condition 2.8(C), above, and the app li cable requirements in Tab l e 8 of 40 C.F .R. Part 63, Subpart ZZZZ. These ins tances are deviatio ns from the emission and operating l imitations in 40 C.P
. R. Part 63, S u bpart ZZZZ. The Perm ittee must report such deviations according to conditio n 3.2(B). [ 40 C.P. R
. §§ 63.6640(b) and (e), 63.6650(b)(5)] 4. The Permittee must keep oosite, and make available to the Administrator upon request, the fo llowing information: (a) A copy of each notification and report d tat t he Permittee submitted to EPA to comply with 40 C
. P.R. Part 63, Subpart ZZZZ, includ ing all documentation supporting any Init i al Notification or Notification of Compliance Status that the Permittee submitted, according to the requirement in 40 C.P.R
. § 63.10(b)(2)( xi v)
. [ 40 C
. P
. R.§ 63
. 6655(a)(l)]



### VES009208Veolia ES Technical**Solution~** LL.C. Pennit No.: V-IL-17 16300103-2014-10 Issuance Date: DRAFT Expil111ion Date : DRAFT Page 132 ofl72
(b) 

### Operation and maintenance plan, which includes either the manufacturer ' s emission-related operation and maintenance instructions or the Permit tee 's own maintenance plan that provides to the extent practicable for the maintenance and operation of the engine in a manner consisten t with good air pollution control practice for minimizing emissions. [40 C.F 

### .R § 

### 63.6655(d)] (c) Records of any maintenance conducted on tlte emergency generator in order to demonstrate that lhe Permittee operated and maintained the e ngine and after-treatment control device (if 

### any) according to the Permittee's maintenance plan. ( 40 C.F
. R. § 63
. 6655(e)] (d) Records ofall required maint enance performed on the air pollution control and monitoring equipmen t [ 40 C.F.R. § 

### 63.6655(a)(4)) (e) Hours of operation of the engine as recorded through the non - resettable hour meter. The Pemtittee mus t document how many hours are spent for emergency operation, inc luding what classified the operation as emergenc y and how many h ours are spent for non-emergency operation. Ifthe engine is used for the purposes specifi ed in 40 C.P.R.§ 63.6640(1)(2)(ii ) or (iii) or 40 C.F.R. § 63.6640(f)(4)(ii), the Permittee must keep recor ds ofthe notification of the emergency situation, and the date, start tinte, and e n

d time ofengine operation for these purpo ses. [40 C
. P.R. § 

### 63
. 6655(!) ] (f) Records of the occurrence and duration of each malfunction ofoperation (i.e., p rocess equipment) or the air pollution control and monitoring equipment. [40 C.P.R.§ 63.6655(a)(2)] (g) 

### Records of actions taken during periods of malfunction t o minimize em i ssions in accordance with 40 C
. F.R
. 

### § 63
. 6605(b), including corrective actions to restore malfunctioning process and air po llution control and monitoring equipment to its normal or usual manner of operation . [ 40 C
. F
. R. 

### § 63.6655(aX5) ] 5. T he P ermittee must report acco r di n g to condition 3.2(B) any failure to perform the work practices on t he schedule required in condition 2.8(C)(3) as a result of the circum stances spec ified in 

### condition 2 .8(C)(5 ) and tbe federal , state or local law under which t he risk was deemed unacceptable
. [Table 2c to 40 C. F .R. Part 63, Subpart ZZZZ, foot n ote I ] 6. The Permittee must keep each record readily accessible in hard copy or elect ronic form for at least 5 years after the date of each occurrence, measurement, mai ntenance, corrective action, report, or record. [40 C
. F
. R. § 63.6660]



### VES009209Vcolia ES Techni cal Sol utions , L.L
.C
. Pennit No.: V · IL · l7 1 6300103 · 2014 · 10 Issuance Date: DRAFT Expiration Date: DRAFT



### 2
. 9 FUGITIVE E MISS IO NS ( A) E m iss ion Limita tio ns an d S t a ndard s [ 40 C.F.R. 

### § 7 1. 6( a)( l) ) Page 1 33 o f l72



### I
. Any leaking equipment is sub j ect to the foUowing requirements of351AC Part 219 , Subpart C: (a) Pumps and Compressors: ( 35 lAC 219
. 142] The Permittee shall not cause or allow the discharge of more than 32.8 ml (2 cu i n ) of VOL with vapor pressure of I7
. 24 kilo pascals (2.5 pounds per square inch absolute) or greater at 294.3 °K (70 °F) into the atmosphere from any pump or compressor i n any 15 minute period at standard conditions. (b) 

### Vapor Blowdowo: (35 lAC 219. 1 4 3 ] The Permitt e

e shall not cause or allow the emission of organic material into t h

e atmosphere from any vapor blowdown system or any safety relief valve , except such safety relief valves not capable of causing an excessive release, unless such emission is controlled:

(i) 

### To 10 ppm equivalent methane (molecular weight 16.0) or less; or (ii) 

### By combustion in a smokeless flare; or (iii) By other air pollution control equipme n t approved by the !EPA according to provi s ions of351AC 201 and further processed consistent with 35 lAC 2 1 9. I 08. 2. Natio n al Emissions Standards for Equipment Lea k s (40 C.F.R. Part 61, S ubparts J and V] 

### Any affected equipment t h

at is a source of fugitive emissions of benzene or other volatile hazardous air pollutants (leaking equipment) is subject to 40 C
. F. R. Part 6 1 , Subparts V and J. 

### The Permi tt ee shall comply with the standards and requirements of40 C.F
. R. Part 61, Subpart V , for pumps, compressors, pressure relief devices, sampling coonection systems, open - ended valves or lines, valves, connectors, smge cont ro l vessels, b ottoms receivers, and control**devi~-es** 

### or systems required by 40 C.F.R. Part 61, Subpart V. (40 C.F.R
. § 61. I 12(a)]



### VES009210Vcol ia ES Tccbui cal Solufions.l..L. C
. Perm i t No.: V

- I L

· 17 16300103 · 20 14 · 10 Issuance Date: DRAFT Expiratio n Da te: DRAFT (B) N on a pplic able Regulation s (40 C
. F.R
. § 7 1
. 6(1)(1 )) Page 1 3 4 o f 172

I. The leaking equipment i s not su bject to the New Source Performa n ce Sta n

dards (NSPS) for the Synthetic O rganic Chemica l s Manufacturing Ind ustry, 40 C.F 

### .R Part 60 , Subparts VV , 

## m, NNN, and RRR; and the NESHAP for the Synthetic Organic Chemicals Manufacturing In d us try, 40 C.F.R. Part 63, Subparts F, G, H, and I , because it is no t assoc iated with the man ufacture or production of the affected organi c chemicals
. [40 C.F.R. 

### §§ 60.480; 60.610; 60.660 ; 60 .7 00 ; 63.100 ; 63.1 10; 63.160] 2. The leaking equipment is not s ubjec t to 40 C
. F
. R. Part 64, C ompliance Assurance Monitoring, because the it does not use add-on control devices to achieve compl i ance with an emission limitation or standard
. [40 C.F
. R. § 64
. 2 (a) ] (C) Wo rk Practice and Operational Req uirem e nt s ( 40 C .F. R. § 71
. 6 ( a )(l ) ( The Permittee s hall com p ly with tbe following s tandards of 40 C.F
. R
. Part 61, Subp a rt V : I. General: [ 40 C.F .R § 6 1.242-1 ] (a) The Permi ttee s ha ll demonstrate com pliance wit h the requireme nts o f 40 C.F.R
. 

### §§ 61.242

- 1 to 61.242

- 11 for each new and existing source as required in 40 C.F.R. § 61.05, except as provided in 40 C
. F.R
. §§ 61.243 and 61.244
. (b) Compl i a

nc e with 40 C.F.R. Part 61, Subpart V, w ill be d etermined by review of records , review of performance tes t results, and inspection us i ng t he methods and procedures specifi ed in 40 C
. F.R
. § 6 1. 24 5
. (c) The Pem1 ittee shall mark each piece of equipment to which 40 C
. F .R. Part 61 , Subpart V , applies in such a manner that it can be d i st i n guis hed readily from other pieces of equipment. 2
. Pumps: [ 40 C.P
. R.§ 61.242-2) (a) The Perm ittee shal l monitor each pump monthly to det ect leaks by the methods specified in 40 C.F
. R
. § 61.245(b), except as provided in 40 C. P
. R.§§ 61.242

- l(c) and 61.242

- 2(d) , (e) , (I) an d (g )
. (b) The Perm i ttee shall check eac h pump by visua l inspection each calendar week for indications of liquids dripping from the ptunp sea l.



### VES009211Vcol ia ES Tcclwic a l Solutions, L.L
.C. Perm it No
. : v . JL

- 1 716300 103 · 2014 · 10 Issu ance Date: DRAFT E

xpirat io

n Date: DRAFT Page 1 35 of 1 72
(c) !fan instrument reading of 10,000 ppm or greater is measured, a leak is detected. (d) If there are i ndications ofliquids dripping from the pump seal, a l eak is detected
. (e) When a leak is detected, the Permittee shall repair it as soon as practicable , but not later than 1 5 calendar days after it i s detected, except as provided in 40 C.F
. R. § 61.242

- 10. (I) The Permittee shall make a first attempt at repair no l ater th an 5 calendar d ays after each leak is detected. (g) Each pump equipped wi th a d ual m echanica l sea l system that includes a barrier fluid sys t em is exempt from the requirements of cond itions 2. 8(C)(2)(a) through (d) of this permit , p rovided the following requirements are met:

(i) Each dual m echan i cal seal system is: A. Operated with the barrier flu id at a pressure that is at all ti m es greater than the p ump stuffing box pressure; or B. Equipped with a banier fluid degassing reservoir that i s route d to a proc ess or fuel gas system or connec ted by a closed-vent sys tem to a control dev i ce that complies with the requirements of40 C.F.R. § 61.242 -1 1 ; or C. E quipped with a system that p urge s the banier fluid into a process stream with zero volatile hazardous air pollutant (VHAP) e missions to atmosphere . (ii) The barrier flu i d is not in VHAP service and , if the pump is covered by standards under 40 C
. P
. R. Part 60, is not in VO C service. ( i ii) Each banier fluid system i s equipped with a sensor that wi ll detec t failure of the seal sys te m , t he b anier flui d system, or both. (iv) Each pump is checked by vi s ual inspection each calendar week for indicatio ns ofli qui ds dripping from the pum p seal. A. I f there are indications of l iq u id d rippi ng from the pump seal at the time of the weekly inspection, the Permi ttee s hall mo n i t or the pump as specified in 40 C.F
. R
. § 61
.245 to determine the presence ofVOC and VHAP in the banier fluid.



### VES009212VeoUa ES Techn i cal Solutions. L.L.C. Permit No.: V- lL-1 716300103-2014- 10 Issuance Date: DRAFT Page 1 36 o f 172 Expiration Date: DRAFT
B
. If the monitorreading (taking into account any background readings) indicates the presence o f VHAP , a leak is detected. For the purpose ofthis pa r agraph, the monitor may be ca l ibrated with VHAP , or m ay employ a gas chromatography column to limit the response of the mon i tor to VHAP , at the option of the Penninee. C. ! fa n instrument reading of 1 0 , 000 ppm or greater (toral VOC) is measured , a leak is detected. (v) The Pennittee must check each sensor as described in 40 C.F.R. 

### § 6I. 2 4 2-2{d}{3) daily unless it i s equi pped with an audible alarm
. (vi) The Pennittee m us t determine , based on design co ns i deratio ns and operating experience, criteria app licable to th e presence and frequency of drips and to the sensor that indicates fa ilure ofthe seal system, the banier fluid system , or both
. (vii) If indications of liquids dripping from the pump seal exceed the criteria established i n condition 2.8(C}(2)(g)(vi) ofthis pennit, o r i f, based on the crite ria established in condi tion 2.8(C)(2)(g)(vi) of this permit, the sensor indica tes failure of the seal system , the barrier fluid system, or both, a leak is detected. (viii) When a le ak is detected, the Permittee shall repair it as soon as practicab l e, b ut no la ter than I 5 calendar days after it is detected, except as provided in40 C.F.R. 

### § 6 1. 242-10. (ix) The Permittee sha ll make a first attempt at repair no later than 5 calendar days a fte r each lea k is detected
. (x) Any pump th at is designated, as described in 40 C .F .R. § 6 1. 24 6( e)(2) , for no detec table emissions, as indicated by an instrument reading of less than 500 ppm above background, is exempt !Tom the req ui rements of para graph s (a), (c), and (d) if the pump:

A
. Has no externally actuated shaft penetrating the pump housin g; B
. Is demonstrated to be operating 'vith no detectable emissions, as indicated by an i ns tru ment reading of less th an 500 ppm above background , as me asured by the method specified in 40 C
. P
. R
. § 61.245( c) ; and



### VES00 9213Veol ia ES Tcclwi cal Solut
. ions. Ll..C
. Pennit No.: V

- IL · 1 116300103 · 2 01 4· · 10 Iss uance Da t e: DRAFT Page 137 of 172 Expiratio n Dare: DRAFT C. Is tested for compli ance with paragraph 40 C.F.R. 

### § 6l.242

- 2(eX2) init ially upo n designation, annua lly, and at other times requested by the Administrator. (xi) If aoy pump is equipped with 

### a closed-vent system capable of capturiug aod transporting any leakage from the seal or s eals to a proce s s or fue l 

### gas system or to a con trol device that compl ies with d1e requirements of40 C
. F
. R. 

### § 6 1
. 242 -1 1, it i s exempt from the requirements of40 C.F. R. § 6 1
. 242-2(a) t hrough (e). (xii) Any pump that is designated , as described ill 40 C.F.R. § 6l.246(f)(I ) , as 

### an unsafe-to-monitor pump is e xem pt from the monitoriug and inspe<."'ion requirement s of 40 C.F. R
. § 61.24 2-2(a) and (d)( 4) through (6) if: A. The Penn ittee demonstrate s that the p u mp is u nsafe to monitor because monitoring person nel woul d be exposed to an immediate danger 

### as a consequence of complying with 40 C.F.R. 

### § 61.242-2(a); and B. Th e Pennittee has 

### a written plan that requi r es monitoring of the pump as fr equently as practicable during safe- t o-monitor times but not more freq u ently than the periodic monitoring schedule otherwise applicable, and repair of t he equipment accordin g to the procedures in 40 C.F.R § 61.2 42-2(c) if a leak is detected. ( xiii ) Any p u mp that is loca ted within the boundary of an unmanned pl a nt s i

te is exempt from the week ly visual inspection requirement of 4 0 C.F.R. § 6 1. 242-2(aX2) and (d)(4) , and the daily requirements of 40 C.F.R. § 6 1. 242

- 2(d)(5) , provided th a t the Pennittee visually inspects each pump 

### as often 

### as practica b le and at 

### least monthly. 3. Compressors: (40 C.F.R
. 

### § 61.242 -3 ) (a) Each c ompressor s h all be equipped with a seal system that includes a barrier fluid system and that prevents leakage ofproce s s fluid to atmosphere , except as prov ided in 40 C.F.R §§ 61. 2 42-l(c) and 61.242- 3(h) and (i). (b) Each compressor seal system required in paragraph 2.8(C)(3Xa), above, sh

all be: (i) Opera ted with the barrier flu id at a p r ess u re t hat is g reater than the compressor s tuffing box pressure; or



### VES009214Veolia E S T echni cal Solut ions, W..C
. Pemtit No.: V

- I L · I7 1 6300 1 03 · 2014 · 10 Issu ance Dat e: DRAFT Page 1 38 of l72 Expiration D a te: DRAFT 

### (ii) Equipped with a barrier fluid sys t em degassing reservoir that is routed to a process or fuel gas system or connected by a closed-vent system t o a control device that complies with the req u irements of 40 C.F. R
. § 

### 61.242

- 11; or (iii) Equipped with a system t h

at purges t he barrier fluid into a process stream with zero VHAP emissions to atm osphere. (c) The barrier fluid shall not be in VHAP service and, if the compressor is covered by standards under 40 C
. P.R. Part 60 , shall not be in VOC service. (d) The Permittee shall equip each barrier fluid system as described in 40 C.F.R. § 6 1.2 42

- 3 ( a)

- (c) wit h a sensor that will detect failure of the seal sys t em, barrier fluid system, or both. (e) The Permittee s hall check each sensor as requ ired in40 C.F.R
. § 

### 61.242- 3(d) daily or shall equip the sensor with an audib le alarm unless the compressor i s located within the boun dary ofan unmanned plant si t e . (I) 

### The Pemtittee shall dete.mi ne, based on design considerations and operatin g experience , a criterion that indicates fail ure of the seal system, t h

e barrier fl u id system, or both. (g) Ifthe sen sor indicates failure of the sea l system, th e barrier fluid system, or both based on the cri t erion detennined under paragraph ( e)(2) of40 C. F .R. 

### § 6 1. 242-3, a leak is detected. (h) When a leak is detected , the Permittee shall repair i t as soon as p racticab le , but not l ater than 15 calendar days after it is detected, except as provided in 40 C
. P
. R. 

### § 6 1. 2 42 -10. (i) The Permittee shall make a firs t attempt at repair no later than 

### 5 calendar days afte r each leak is det ected. (j) 

### A compressor is exempt from the requ irements of40 C .F.R. § 

### 61.242-3(a) and (b) 

### if i t is equipped with a closed

- v ent syste m to capture and transport leakage from the c o mpre ssor dri ve shaft back to a process or fuel gas system or to a control de v ice that cQm plies with the requir ements of 40 C. P .R.§ 61.242

- 11, except as provided in 40 C.F.R. § 

### 61.242-3(i)
. (k) Any compressor that is designated, as described in 

### 40 C
. P.R
. § 

### 6 I .246(e)(2), for no detectable emission as indicated by an instrument r e

ading ofless t han 500 ppm above backgro u nd is exempt from the requirements of40 C.P.R.§ 61.242

- 3(a)-(h) if the compressor:



### V ES00921 5Veol ia BS Tecbnical**Solution~** L
. L.C
. Pennit No.: V-IL-1716300103-2014- 1 0 Iss u ance Da<e: DRAFT Page 139 of 172 Expi ration Date : DRAFT (i) Is demonstrated to be operating with no detectable emissions, as indicated by an instrUment reading of Jess t han 500 ppm above background, as measured by the method specified in 40 C.P.R. § 61.245(c); and Is tested for compliance with 40 C.P.R .§ 61.242

- 3 (i)(l) initially upon designation, annually , and at other times req uested by the Administrator. 4. Open-ended valves or lines: [ 40 C.F.R. § 61.242-6 ] (a) The Pennittee shall equip each open-ended valve or line with a cap, blind flange, plug, or a second valve , except as provided in 40 C
. F. R
. 

### § 61.242- l(c). (b) The cap, blind flange , plug , or second valve shall seal t h

e open end at all times except during operations req u iring proces s fluid flow through the open-ended valve or line
. (c) The Petmittee s hall operate each open-ended val v e or line equipped with a second valve in a manner such lhat lhe valve on the process fluid end is closed before lhe second valve is closed. (d) When a double block and bleed system is being used, the bleed valve or line may remain open during operations that require venting the line between the block valves but shall comply with 40 C.F.R
. § 61.242

- 6(a) at all other times. (e) Open

- ended valve s or Jines in an emergency shutdown system which are desig n ed to open automatically in the event of a process upset are exempt from the requirements of 40 C.F.R. § 61.242-6(a), (b) and (c). (f) Open-ended valves or lines containing materials which wou ld autocatalytically polymerize or would present an explo s ion, serious overpressure, or oilier safety hazard if capped or equipped with a do ub le block and bleed sys t e m as specified in40 C.F.R. § 61.242-6(a) through (c) are exempt from the requirements of40 C.F.R. § 61 .242-6(a) lhrough (c). 5. Valves: [ 40 C.P.R.§ 61.242

- 7] (a) The Permittee shall monitor e-ach valve monlhly to detect leaks b y the method specified iu40 C.P. R. § 61.24 5(b) and shall comply with 40 C.F.R. § 61.242-7(b)-(e), except as provided in 40 C
. F.R. §§ 61.242-7(1) , (g), and (h), 61.243-1 or 6 1. 2 4 3-2, and 61.242- I (c). ( b) If an instrument reading of I 0 ,000 ppm or greater is measured, a leak is detected.



### VES009216**Veo~a** ES Technica l Solutions, L.L
.C
. Pennit No.: Y · IL-1716300 1 03 · 2014 · 10 Issuance Dat e: DRAFT Expiration Date: DRAFT Page 140 o f 1 72

(c) The Pemt ittee may monitor a ny valve for which a leak is not detected for 2 successive months the first month of every quarter, beginning with the ne x t quarter, until a leak is detected. (d) Ifa leak is detected, the Permittee shall monitor the valve monthly until a leak is not det ected for 2 successive months. (e) When a leak is detected. the Pennittee shall repair it as soon as practicable , but n o later th a n 

### 1 5 calendar days after the leak is detected, except as provided in 4() 

### C.F .R. § 61.242 -1 0
. (t) The P emtittee shall make a 

### first attempt at repair no later than five calendar days after each leak is detec ted
. (g) First attempts at repair include, b u t are not limited to, the following best practices where pract icable: (i) Tighten i n g of bonnet bolts; (ii) Replacem ent of bonnet bolts; ( iii) Tightening of packing gland nuts ; and (iv) Injection of lubricant into lubricated p acking. (h) Any valve dtat is designated. as described in 40 

### C.F.R § 61.246(eX2), for no det ectable emissions, as indicated by an instrument reading of less th an 500 ppm above background , is exempt from the requirements of40 

### C
. F
.R
. § 61.242 -7(a) if the valve: (i) Has no external actuating mechanism in contact with the process fluid ; (ii) Is operat ed with emissions less than 500 ppm above background , as measured by the method specified in 40 

### C
. F.R. § 61.24 5(c); and (iii) 

### Is t ested for compliance w it

h 40 

### C
.F
.R § 61.242-7(1)(2) initially upon de s ignation, annually, and at other t inles requested by the Administrator. (i) Any valve t h

at is designated , as described in 40 C
. F.R. § 6 1. 246(f)( I ), as an unsafe

- to -moni tor valve is exempt from the requirements of 40 C. F.R
. 

### § 61.242 · 7(a) 

### if :



### VES009217Veol ia ES Tc<lmical Sol utiou s, J...L
.C
. Penn i t No .: 

### V

- JL

- 1

7 1

6300 103 · 2014 ·1 0 Issuance Date: DRAFT E

xpiratio n Date: DRAFT Page 141 o f 1 72


### (i) The Pennittee demon strates that the valve is unsafe t o monitor because monitoring personnel would be 

### exposed to an inunediate danger as a consequence of complying with 40 C.F .R. § 

### 61.242

- 7(a); and (ii) 

### The Pennittee has a written pla n th at requires monit oring of the va lve as frequen t as practicable during sa f(}-t o- monitor times. (j) 

### Any v alve that is designated, as described in 40 C .F.Il § 

### 6 1. 2 4 6(f)(2), as a difficult-to-monitor valve i s exempt from t he requirements of paragrap h (a) of 40 C.F. R. 

### § 61
. 242-7 if: (i) The Pennittee demo nstrates that the valve catmot be 

### monitored without e levating the monitoring personnel more than 2 meters above a support surface; (ii) The process unit within which the valve is located is an existing process unit; and (iii) The Pennittee follows a written plan that requires monitoring oft he valve at least once per calendar year. 6. Alternative standards for valves i n 

### VHAP service

- allowable percentage of valves leaking: (40 C.F. R . § 61.24 3

- 1 ] (a) The Perm ittee may elect to have all valves within a process un it comply with an allowab le percentage of valves leaking of equal to or less than 2 .0 percent. (b) 

### The following requ irements s h all be met if the Permittee dec ides to comply with an allowable percentage of valves leaking: (i) The Permittee must notif:Y the Administrator that it has elected to have all valves within a process unit to comply with the allowable percentage of valves leak ing before im p

lementing this alternative standard, as specified in 40 C.F.R
. § 

### 61.247(d). (ii) 

### The Permittee conducts a performance test as speci tied in 

### 40 C.F 

### .R. § 

### 6 1. 243-l(c) initially upon designation, aunuaUy, and at other times requested by the Administrator. (iii) If a valve leak is detected, t he Permittee sha ll repair it 

### in accordance with 40 C.P.R.§ 61.242-7(d) and (e). (c) The Permittee s h all co nduc t perfonnance t ests in the following manner:



### VE S009218Veol ia ES Techo i cal Solut ions. L
. L .C. Pennit No.: V

- IL

- 17 1 6300103-20 14 -10 Issuance Da t e: DRAFT Expi ration Date: DRAFT Page 142 of 172

(i) The Perm i ttee shall monitor all valves in VHAP service within the process unit within I week by the methods specified in 40 C.F 

### .R § 61.245(b}. (ii) If an instrument reading of I 0,000 ppm or great er is measured, a lea k is detected. (iii ) The Permittee shall determine the leak percentage by d i viding the number of valves in VHAP se rvice for which leaks are detected by the number of valves in VHAP service within the process unit. (d) 

### If the Permittee elect s to have all va l ves comply wi th this alternative stand ar d, no process unit sha ll have 

### a leak percentage greater than 2.0 percent. (e) [fthe Permi ttee deci des no longer to c omply with 40 C.P.R. 

### § 61.243-1, the Permittee must notify the Administrator i n writing that it \vi ii follow the work practice standard described in 40 

### C.F.R. § 61.242-7(a)-(e). 7. Alternative stand ards for valves in VHAP service: ( 40 C.P
. R
. § 61.243-2] (a) Tite Permittee m ay elect tor all valves within a process unit to compl y with one of the alternative work practices specified in 4 0 C.P.R. § 61.243

- 2(b )(2) and (3). (b) Tite Permittee m ust notify the Administrator before implementing one of the alternat i ve work practices, as specified in 40 C.P.R. 

### § 61 .247(d). (c) The Permittee shall comp l y initially with t he r equirements for valves , as described in 40 

### C.F .R. § 61.24 2

- 7. (d) After t wo consecutive quarterly leak detecti on peri ods with the percen tage of valves leaking equal to or Jess th an 2.0 , tbe Permittee may begin to skip one of the quarterly Je.ak detection periods tor the va l ves i n VHAP service. (e) After five con secutive quarterly leak detection periods**\\~th** the percentage of valves leaking equal to or Jess th an 2.0, the Permittee may begin to skip th

. ree of the quarterly leak d e tec t ion periods for the valves in VHAP service. (f) l f t he pe rcentag e of valves leak i ng is greate r than 2
. 0, the Permittee shall comply with the r equirements as described i n 40 C
. F.R. 

### § 61.24 2 -7 , b ut may again elect to use 40 C.P.R. 

### § 61.24 3

- 2
.



### V E S009219Vc:ol ia EST ecbnica l Sol ut

. ions , L .L
.C
. Penni t N o . : V

- IL · 1 71 6300103 · 20 1 4 · 10 Issuance Date: DRAFT Page 1 43 of 172 Expi ration Date: DRAFT 

### (D ) Mo nitorin g a nd T es tin g (40 C .F.R. § 

### 7 1. 6( a )(3)(1)(A)) 1. 

### The P ermittee shall comply with the followi n g te st methods and procedures requirements of 40 C.P.R.§ 

### 61.245: (a) The Pennittee shall monitor, as required in 

### 40 C.F.R. §§ 61.24 2, 61.243, 61.244, and 61.135, as follows: (i) The Permittee shall monitor as required by Method 21 of 40 C
. F.R
. Part 60, Appendix A. (ii) The detection instrumen t shall meet the perfonnanc e criteria of Method 21. (iii) TI1e instrument shall 

### be cal i b rat ed before use on each day 

### of its use by the procedu res specified in Method 2 1. ( iv) Ca libration gases sh all be: A. Z ero air (less than 10 ppm ofhydrocarbon in air) ; and 

### B
. A mix ture of methane or n·hexane and air at a concentra t ion of approxima te ly, but Jess 

### th a n , I 

### 0,000 ppm methane or n·bexan e . (v) The instrument probe shall be t mversed armmd all potential leak i nterf aces 

### as close to the interface 

### as possible, 

### as described in Method 21 of40 C.F. R
. Part 60 , 

### Appendix A. (b) When eq u ipment is tes t ed for compliance with or monitored t or no detectab l e emiss ion s , t he Perm ittee shall comply wi th the followi n g requirements: (i) The Perm ittee shall test equipment a s required by 40 C
. P .R
. § 61.245(b)(l) thro u gh (4). (ii) The backgro u n d level shall be 

### detennined , as set forth in M ethod 21 of 40 C
. F.R. Part 60 , Appendix A. (iii) T h

e i nsttument probe shall be traversed around all potential leak interfaces as close to 

### tl1e interface as pos sible as described in M ethod 21 of40 C
. F.R. Part 60, Append ix A. (iv) The arithmetic difference between the maximu m concen trat ion indicat ed by th e instrument and the background level is compa red wi th 500 ppm fo r det erminin g compliance.



### VES009220Veol ia ES Tedmical Solut ions, L.L.C. Penni t No.: V- IL-17 1 63001 0 3

- 20 1 4

- 10 Issuance Dare : DRAFT Expi ration Dote: DRAFT Page 144 of 172



### (c) Each p iece of equipment within a process unit that can conceivably contain eq uipment in VHAP service is presumed to be 

### in VHAP service unless the Permittee demonstrates t hat the piece ofequipment is n ot in 

### VHAP service. For a piece ofequipment to be 

### considered not in VHAP service, i t must be determined that the percent VHAP content can be reasonably expect ed never to exceed I 

### 0 percent by weight For purposes of determining the percent VHAP content of the pr ocess fluid that is contained in or contacts equipment , the Permittee shall use procedures that conform t o the methods described in ASTM Method D-2267 (incorporated by reference as specified i n 40 C.P.R.§ 61.18). (d) 

### Tbe Permi ttee may us e engineering judgment rather than the procedures i n 40 C.P.R
. § 6!.245(d)(l) to demonstrate that t h e percent VHAP con tent does not exceed I0 percent by weight, provided that the engineering judgment demonstrates that the VHAP content clearly does not exceed 10 percent by weight . When the Permittee and the Administrator do not agree on whether a piece of equipment is no t in VHAP service , however, the Permittee shall use the procedures in 4 0 C.P.R
. § 61.245(d)(l). (e) If 

### the Permittee determines th at a piece of equipmen t is in VHAP service, the determination can be 

### revised only after following the procedures in paragraph 40 C.P.R. 

### § 6 1.2 45(d)(l ). (f) 

### Samples used in determining the percent VHAP content shall be 

### representat i ve of the process fluid that is conta i ned in or contacts the equipment or the gas being combusted in the flare
. 2
. Requirements of 40 C
. P. R. § 61.246: (a) The**Permit~e** 

### may comply with the recordkeeping requirements for m

u ltiple process units subject to 

### the pro v isions of40 C.P.R. Pa rt 61 , Subpart V, in one rec ordkeeping system ifthe sys t em iden t ifies each record by each p roces s unit. (b) 

### When each leak i s det ected as specified in 40 C.F.R
. §§ 61.242

- 2, 61.242- 3, 6 1. 2 42-7 , and 61.242-8, the follow i ng req u irements app l y: (i) The Permittee shall attach a weatherproof a nd readily visib le iden t ification, marked with the equipment ident ification number, to the leaking equipme nt. (ii) The Pem1ittee may remove the identification on a valv e after i t 

### has monitored t he valve for 2 successive months as specified in 40



### VES00922lVeol i a ES Technica l So l urion s , L.L.C
. Penni r N o.: V-IL-1716300 103-2014

- 10 Issuance Dat e: DRAFT Expiration Date: DRAFT Page 14 5of l72

C.P.R. 

### § 242

- 7(c) and no leak bas been detected during those 2 months. (iii ) The Permittee may remove the identification on equi pment, except on a valve, after it has repaired the equipment. (c) When the Permittee bas detected each leak as specified i
. n 40 C
. P.R. 

### §§ 6 1. 242-2, 61.242-3, 61.242-7 , 61.242-8 , and 61.135, the Penni ttee shall record the following information in a log and shall keep the infonnarion for 2 years in a readily accessible location: (i) T he instrumen t and operator identification numbers and the equipment identification number; (ii) The date the leak was detected and the dates of each attempt to repair the leak; (i ii ) Repair methods applied in eac . h a ttempt to repair the leak; (iv) "Above 1 0,000" if the maximum instrument reading measured by the methods specified in 4() C.P
. R.§ 61.245(a) after each r epair attempt is equal to o r greater than I 0,000 ppm; (v) "Repair de layed " a nd the reason for the delay if a leak is not repaired**"~thin** 1 5 ca l endar days after discovery ofthe leak ; (vi) The signature of the responsible official whose decision it was that repair could no t be aff ected without a process shutdown; (vii) The expected date**ofsucces..~ful** repair of the leak if a leak is not repaired 

### within 15 calendar days; ( viii) Dates of process u nit shutdowns th at occur while th e equipment is unrepaired ; and (ix) The date of successful repair of the leak. (d) The Permittee shall record i n a log and keep in a readily accessible location the following infom1at ion perta i ni n g to all equipment to which a stan dard applies: (i) A list of identification numbers for equipm ent (except welded fittings) subject to the requirement s of 40 C.F.R. Part 61, Subpa rt V;



### VES009222Veolia ES Techn i c al Solutions, LL.C. Penni t No.: V-IL

- 1716300 103

- 20 1 4

- 10 Issuance Date: DRAFT E

x

pirat i on Date: DRAFT Page 1 46 of 17 2


### (ii) A Jist ofidentification numbers for equipment that the Permittee elects to designate for no detectable emissions as indicated by 

### an instrument readi ng of less than 500 ppm above background ; (ii i ) The designation oftbis equipment for no detectable emissions shall be signed by a responsible official; (iv) The dates of eac h compliance test required in 40 C.F
. R
. 

### §§ 61.242

- 2{e), 61.242-3(i), 61.242-4, and 61.242-7(!); (v) The background l evel measured during each compliance test; and (vi) The maximum instrument reading measured at the equipment during each compliance test. (e) The P ennittee shall record in a l og and keep in a readily accessible location the following information pertaining to all v alves s ubject to the requirements of40 C.F.R. § 

### 6!.242-7(g) and (h) 

### and to all p u mps subject to the requirements of40 C
. F.R
. 

### § 61.242

-2(g): (i) A 

### list of identificat i on num bers fo r valves and pumps that are designated as unsafe to monitor, an explanation for each valve or pump stating why the valve or pump is u nsafe t o monitor, and the plan for monitoring each valve or pump; and (ii) A Jist of identification numbers for valves that 

### are designated as diffic u lt to monitor, a n e xplanation for each valve stating why t he va lve is difficult to monitor, and 

### the planned schedule for monitoring each v al ve. (f) 

### The Permittee shall record and keep in a readily accessib le location the following information: (i) Design criterion required in40 C.F.R. §§ 

### 61.242-2(d)(5) a n

d 61.242- 3(e)(2), and an explanation of the design criterion; and (ii) Any changes to thi s criterion and the reasons for t he changes. (g) 

### Hours ofoperation of each component. (h) 

### Emissions ofVOC
. (E) R ecordkeeplng and Reporting [ 40 C. F.It 

### § 71.6(a)(3))



### VES009223Veolia ES Teclulica l Solutions, L.L.C. Pennit No.: V-IL- 1 716300103

- 2014- 10 Issuance Date: DRAFT Expiration Date: DRAFT Page 1 47 of 172

I
. The Permitt ee shall promptly notify the permitt ing authority of deviations of the affected leaking equipment from the permit requirements. Reports shall describe the probable cause of su ch deviations, and any corrective actions or prevent ive m easures taken. (40 C.F-R. 

### § 7 1. 6(a)(3)(iii)(B) ] 2. Requirements of40 C.F.R. § 61.247: (a) The Permittee s hall s ubmit a statement in writing notiJYing the Adminis trator that it is implementing the requirements of 40 C.F.R. §§ 61.242, 61.245, 61.246 , and 61.247. (b) In the case of an existing source or a new source which has an initia l startup date preceding the effective date , the P ennittee shall submit the statement to the Administrator along with the informat ion required under 40 C.F.R
. 

### § 61.10 within 90 days of the effective date, unless a waiver of compl i ance is granted under 40 C.F.R. § 60.11. If a waiver of compliance is grant ed , the Permittee must submit the statement on a date scheduled by the Administrator. (c) The Pennittee must i nclude the followi ng infonnation for each source in the s tatemen t: (i) Equipment identification number and process unit identification ; (ii) Type of equipment (for example , a pump or pipeline valve); (iii) Percent by weight VHAP in the fluid a t the equipment ; (iv) Process fluid state at the equipment (gas/v apor or li quid); and (v) Method of compl iance with the standard (for example, "monthly leak detection and repair" or "eq uipped with dual mechanical seals"). (d) The Perm ittee shall submit to the Administrator a report, semiannually starting 6 months after the initial report required in 40 C.F .R
. 

### § 6 1 .247 (a), that includes the following information: (i) Process unit i dentificatio n; (ii) For each month d uring the semiaWlual reporting per i od: A. Number of valves for which leaks were detected as described in 40 C.P.R.§§ 61.242-7(b) or 61.243-2;



### VES009224Veo l ia ES Tc c ho i cal Solutions, I.. L. C
. Pennit No.: V

-JL

- 1716300103 -2014- 10 Issuance Date: DRAFT Jlxpiration Date: DRAFT Page 1 48 of l 72



### B. Number ofvalves for w hich leaks were not repaired as required in 40 C.F.R. § 61.242-?(d); C. Number of pumps for which leaks were detected as described in40 C.F.R. 

### § 61.242-2(b)and (d)(6 ); D. Number ofp umps for which leaks were not repaired as required in 40 C.P.R.§ 61.242-2(c) and (d)(6); E. Number of compressors for which leaks were detected as described in 40 C
. P.R. § 

### 61.242-3(1); F. Number ofcompressors for which leaks were not repaired as requ ired in 40 C.F.R. § 

### 61.242-3(g); an d G. The facts t hat explain any del ay of repairs and, w h ere appropriate, why a process unit shutdown was technically infeasible
. 2
. 10 INSIG NIF I CANT EMI SS I ON UNITS AND ACTIVITIES (A ) Li s t o f In s ignifi ca

nt Emissio n Units and Acti v it

ies (40 C. F
. R. 

### § 7l .S(c)(ll ) ) 

### The following are ins ignificant emission units and activities at the facility: I
. One 2.5 mmBtu/hr Tioga portable boiler; 2. One horizontal 550-gallon kerosene tank; 3. Two horizontal 550-gallon No
. 2 diesel fuel tan ks; 4. Ash handling; 5. Handling of spent dry scrubber solids; 6. Lime unloading and proportioning; 7. Gasoline storage a n

d dispensing; 8. Use of absort>ent mat erial ; 9. General vehicle maintenance and servicing (assumed to include diesel fuel handling); 10. Laboratory (chemical and physical analysis); 11. P iping and storage system for natural gas; 12. Non-halogenated cold cleaning**de~:,'re-<~sers ;**  

### 13
. Internal combustion engines of motor vehicles; and 14. S torage and handling o f closed d rums .



### VES009225Veolia ES Techni c al Solutions. L. L
.C
. Pennit No.: V

-IJ. A7 1 6300 103 · 2014 · 10 Issuance Date: DRAFT Expiration Dote: DRAFT 

### (B ) Applicable Require ment s ( 40 

### C .F.R. § 

### 7 1.6( a ) ( l )( Page 1 4 9 of 1 72



### J. For each particulate matter process emission unit, the Permittee shal l comply with the app l icable particulate matter em issi on limit of351AC 212.321 o r 212.322 and 

### 35 lAC P art 266
. For example , the particulate matter emissions from a process emission unit shall not exceed 0.55 pou nds per hour if the emission unit's process weight rate is I 

### 00 pounds p er hour or less , pursuant 10 

### 35 lAC 

### 266.110. (35 lAC 

### 212.321 or 2 1 2.322 and 35 lAC 

### Part 266] 2. For each organic material emission unit th at uses organic material, e.g., a mixer or printing line, the Permittee shall comply with the applicable VOM 

### emission li

mit of35 lAC 

### 215.30 1, which requires tha t organic material emissions no! exceed 

### 8
. 0 pounds per h our or, if n o odor nu isance exists, do n ot qua l ify 

### as photoche mically reactive mat erial 

### as defi ned i n 35 lAC 

### 2 1 1.4690. (3 5 lAC 

### 2 1 5 .3 01) 3. For each open b u rning activity, the Permittee shaU comply with 35 lAC Part 237, including the requirement to 

### obtai n a permit for open burning in accordance wi th 3 5 lAC 

### 237
. 20 1 , if necessary. ( 35 lAC 

### Part 237] ( C) Complianc e wi th Applica ble Require m e n ts (40 

### C .F. R. 

### § 71
. 6( a )( 3 )( I
. The P emti ttee shall keep cun-ent a fi l e for the affec ted insignificant emiss i on units, which may contain estimated e m

iss ions, throughput, inspec t ion, maintenance and repair log, and other information necessary to demonstrate co

m

p liance with the applicable req u ir

ements and c lassification of the units as insignifican t emission s units . ( 40 C
. F
. R. § 

### 71.6(a)(3)(i)(B)] 2. The Permittee must maintain records of results o f any em iss ion s t es t ing conducted on the affected emission units. [40 

### C.F
. R. § 71 .6(a)(3)(i)(B)]



### VES009226Veolia ES Techn i c al Soluti ons, L. t. .C
. Pen nit No. : V

- IL-17 16300103-20 14 -10 Iss uance Date: DRAFT Page I SO o f 172 Expirat i on Date: DRAFT 

## 3 . 0 

## FAC ILITY-WIDE PERMIT REQUIREMENTS

3.1. GENE RAL 

### PART 7 1 RECORD KEEPI NG 

### (A) Require d Records [ 40 C
. F.R. § 71.6(a)(3)(ii) J 

### The Permittee shall keep 

### records of required monitori ng information that inclu d e the following: I. 

### The date , p lace, and time of sampling or measurements; 2. 

### The date(s) analyses were perfom1ed; 3. 

### The company or entity that performed the analyses; 4. 

### The analytical techniques or methods used; 5. 

### The results of s uch ana l yses; and 6. 

### The operating conditions existing at 

### tbe time of sampling or measurement (B) R ecord R et ention Schedule [40 C.F.R. 

### § 71.6(a)(3 ) (U)] 

### The Pennittee shall retai n records ofall required monitoring data and support information for a per iod o f at leas t 5 

### calendar years from the date of the monitori n g sample, measurement, report, or application. Support information includes, b u t is not limited to , all calibration and maintenance record s , all 

### original strip-chart recordinb>S for continuous monitoring instrumentation, and copies of all reports required by thi s pe1m it . (C) 

### Emission s Calc ul atio n Methodolo gy 

### [ 40 C.F.R. 

### § 71.6(a)(3)(1)(B)) 

### I. If 

### an applicab l e requirement contained in this permit does not require the
. use of a specific methodology for calculatin g em i ssions, the Permittee must follow the follow i ng hierarchy (in order of preference) wh en selecting the approptiate methodo l ogy for calculating emissions: (a) CEM data from the stationary source; (b) Performance test data from the station ary source; (c) Manufact urer 's emissions perfonnance b'llarantee; (d) CEM data from a similar stationary source or sou r ces ; (e) Performan ce test data from a similar stationary source or sources; (f) 

### Industry-derived emission factors;



### VES009227Voolia ES Technica l Snl ut

. ion s, L .L
.C. Pcnnit N o .: V

- IL

- 1116300103 · 2014 · 10 I ssuance Date: DRAFT Expiration Dale: DRAFT (g) Emiss ion factors published i n the latest versio n of EPA's Compilation of Air Pollutant E mi ssion Factors (AP-42), with "A"-rated AP-42 emission factors being considered before the lower rated emiss ion factors; (b) Engineeringjudgment. 2. The P ermittee must document that it reviewed the hierarchy in condition 3
. l(C)(I), above, before selecting the emiss ions calculation methodology i ncluding a demonstration of the selected emission fac t ors ' appropriateness for the spe cific emission u nits from which emissions are being calcula t ed. 3. The Permitt ee's c h oice ofem i ssion ca l cu l ation methodology pursuant to condition 3.J(C)(J), above, does not preclude any person, such as EPA, the public and other regulatory agencies , from using other credible e vidence to establish compliance or n oncompliance witb applicable requirements as provided by the Act [42 U.S.C. § 7413 ] 3.2
. GENERAL PART 71 REPORTING [ 40 C.F. R
. § 71.6(a)(3)(iii) ] (A) Semi

-annual Reports I. The Permittee shall submit to EPA sem i-annual reports ofall required monitoring each six month reporting period from J anuary I to June 30 and fro m July Ito December 31. All reports shall be submitt ed to t h

e EPA and shall be postmarked by the 30th day following the end ofthe reporting period. AU instances ofdeviations from permit requirements must be clearly identified in such reports. All required reports mus t be certified by a responsible official consistent with condit ion4.8(A){I) o f this permit. [ 40 C
. F.R. § 71.6(a)(3)(iii)(A) ] 2. A monitoring report s ubmitted pursuant to condition 3.2(A){l) mus t include the following: (a) The company name a n

d address; (b) The beginni ng and ending dates of t he reporting period ; (c) Th e emissions unit or activity bein g monitored ; (d) The emissions limitation or standard, including operational requirements and limitations (such as parameter ranges) , specified i n t11e pem1 it fo r which compliance is being monitored; (e) Al l ins tances ofdeviations f rom permit requirements whether demonstrated b

y r eferenced te st method, mo n itoring, or t hrough any other credible



### VES00 9228Veolia ES Tecltoi cal Sol utions, L.L.C. Pennit No.: Y· IL · l 7 16300t03 · 2014·10 Iss uance Date: DRAFT Expiration Dat e: DRAFT Page 152 of 172
evidence, including those attributable to upset conditions as defined in this permit, and t he date on which each dev i ation occurred ; (f) The total time when monitoring required by this permit was not performed during the reporting period a n

d, at the source's di scretion , either the t otal duration of deviations indicated by such monitoring or the actual records of deviations; (g) All other monitoring results , data, or analyses required to be reponed by the applicable requirement; and (h) The name, title, and signature of the responsible official who is cenifying to t he truth, accuracy, and completeness of the repon. (i) Any reporl required by an applicable requirement that provides the same information described in conditions 3.2(A)(2)(a) through (h), above, shall satisfy the requirement under condition 3.2(A)(I ). ( 40 C.F.R. 

### § 7 1.6(a)(3)(iii)(A)] (B) D eviatio n s I. "Devi atio n" means any situation in which an emissions unit fails to meet a penn it tenn or condit ion. A deviation is not al ways a violation
. A deviation can be determined by observation or through review of data obtained ftom any testing, monitoring, or record keeping established in accordance with 

### 40 C.F
. R. § 71.6(a)(3)(i) and (ii). For a situation lasting more than 24 hours, each 24-hour period is considered a separate deviation. "Deviations" includes, but is not limit ed to, any oft he following: (40 C.P.R
. § 71.6(a)(3)(iii)(C) ] (a) A situation when emissions exceed a n emission limitation or standard; (b) A situation where process or emissions control device parame t er values indicate that an e mission limitation or standar d bas not been met; and (c) A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any wodc practice or operating condition required by the permit 2. TI1 e Permittee shall promptly report to the EPA deviations from permit requirements , including those attributed to malf u

nction , emergency or other upset conditions, the probable cause of such deviations, and any corrective actions or preventive measures taken. "Prompt" is defined as follows: (40 C.F.R. 

### § 71.6(a)(3)(iii)(B)]



### VES009229Ve<:>Ua ES Technica l Solu tions, L.L.C. Permit No.: V

- J.L- 17 1 6300103

- 2014

- 10 lss uruwe Date: DRAFT Page 153 of 172 Expiration Date: DRAFT (a) Any definition of"prompt" or specific timeframe for reporting deviations provided in an underlying applicable requirement (as identified in this perm it); or (b) Where the underlying applicable requirement does not define prompt or provi de a time frame for reporting deviations, reports ofdevi ations will be submitted based on the following schedule : (i) For eoUssions of a hazardou s air pollu tant or 

### a toxic air pollutant (as identified in an applicable regulation) that continue for more than an hour in excess ofpermit requirements, the report must . be made within 24 hours of the occurrence. (ii) For emi ssions of a ny regulated pollutant excluding a hazardous air pollutan t or a toxic air pollutant that con tinue for more than two hours in excess of permit require ments, the report must be made within 48 hours. ( i ii) For all other deviations from p ermit requirements, the report shall be submitted with the semi-annual monitoring report required in condi t ion 3
. 2(A)( l } of this permit 3. lfany of the requiremen ts in con dition 3.2(B)( l )(a) t hrough (c), above , are met, the Permittee mu s t notify EPA by telephone or facsimile based on the timetable listed
. A written notice, certified consisten t with condition 4.8(A), must be submitted within I0 working days ofthe occurrence . All de viations reported u

nder this con dit ion mu st also be ide ntifi ed in tile semi-annual report required under condition 3.2(A)(I), above.
3.3. P E R FORMANCE T ES T ING [40 C. F
. R
. § 7 1. 6( a )(3)(i ) ) The Permittee shall provide performance testing facilities that in clude the following: (A) Samp li ng ports adequate for the applicable test methods; (B) Safe sampling platform(s) ; (C) Safe access to sampling platform(s); and (D) U t ilit ies for sampl ing and testing equipment.



### VES 0092 30Veolia ES Techni cal Sol uliOI!S_ L.l.C. Penni! No.: V

- !L

- 17 1 6300103

- 20 14- 1 0 Issuance Dale: DRAFT E

x

piration Da1e: DRAFT 

### 3.4. FAC ILITY -WIDE APPLICABLE REQUffiEMENTS (A) 

### Fugiti ve Parti c ulate Matter Restrictions [3 5 lAC 212.301 ) Page !54 ofl72



### The Permittee shall not cause or allow the emission of fugitive particulate matter from an y process, includi ng any material handling or storage activity that is visib le by an observer looking generally toward me zenith at a 

### point beyond the property line of the emission source. (B) 

### Op e n Burning Pro hib itio n s [ 35 1AC 2 37. 102) 

### I
. The Permittee shall not cause or allo w open burning, except as provided i n 35 lAC 237
. 2
. The Permittee shall not cau se or allow open burning of any refuse in any chamber or apparat us, unless such chambe r or apparatus i s designed for the purpose ofdisposing of the class of refuse being burned. (C) V i sible Emi ss ions [35 1AC 

### 2 12
. 123(a) ] The Permittee shall not cause or allow the emission of smoke or other particulate matter, with an opacity greater than 30 percent, into the atmosphere from any emission unit other t h an those emission un its subject to the requirements of 35 lAC 212.122, except 

### as allowed by 351AC 212. 123(b) and 35 lAC 212. 1 24. (D) 

### Rec y cling and Emissions Reduction [40 

### C.F.R. Part 82 , Subpart F J The P ermittee shall comply with the standards for recycling and emissions reduction ofozone depleting s u bstances pursuant to 40 C.F.R. Part 82, Subpart F, except as provided for motor vehi c le air conditioners in 40 C.F.R. Pa rt 82 , Subpart B: 1. Persons opening appliances for maintenance, service, repair, or disposal mus t comply wi th the required practices pursuant to 40 C.P.R.§ 82.156. 2. Equipment used during the maintenance , service, repair, or dispos a l of appliances must comply with the standards for recycling and recovery equipment pursuant to 

### 40 C.F.R. § 82.158
. 3. Persons performing maintenance, service, repair, or disposal ofappliance s must be certified by an approved t echnician certification program pursuant to 40 C.F.R. 

### § 82.161.



### VES009231Veolia ES Technical Solutions , L .L.C. Permit No
. : V

- l!J. l 716300103-2014- I O Issuance Date: DRAFT Expiration Date: DRAFT Page 1 55 of 172
(E) Ri sk Mana ge m e n t Pl a n (RMP ) [40 C. F
. R. 

### § 68. 21 S(a)(2)(1 ) a nd ( II) J Should this stationary source, as defined in 40 C
. F.R. 

### § 68.3, become subject to the federal regulations for Chemical Accident Prevention in 40 C.P
. R. Part 68 , then the Pemtittee shall s ubmit the items be l ow: I. A compliance schedu l e for meeting the requirement s of40 C.F
. R. Part 68 by the date provided in 40 C.F.R.. § 68.1 O(a); or 2
. A certification statement that the source is in compliance with all requirements of 40 C
. F.R. Part 68, incl uding the registration and submission o f th e RMP, as pa rt of the annual compliance certification. (F) E p is ode Ac t i on Pl ans [3 5 lAC 244 , S ubp art 

### CJ The Permittee shall m aintai n at the source and have on ftle with the !EPA a written episode actio n plan (plan) for reducing the levels of emissions during yellow alerts, red alerts, and emergenci es, consistent with safe operating proced ures. T he plan shall contain the information specified in 35 IAC244
. 144 and is i ncorporated by ref erence into this permit. (G ) Annual Benzene Wa s t e Q u a ntity D et e rmination (40 C
. F. R. 

### § 61 .35 5 ]

The Permittee shall determine the t otal annual be nzene quantity from facility was te by the following procedure : I. For each waste stream subject to 40 C.F.R. Part 6 1, Subpart FF , having a flow weighted annual average water content greater than I0 percent water , on a vo l ume basis as total water , or which is mixed with water or other wastes at any t ime and the resulting m i xture has an annual average water content greater than 10 percent as specified i n 40 C
. F. R. § 61.342(a) , the Permi ttee shall: (a) Determ ine the annual waste quantity for each was te s tream us ing the procedures specified in 40 C
. F.R.. 

### § 6l.355(b). (b) Detenni ne the flow-weighted annual average benzene concentration for each waste stream using the procedures specified in 40 C.F
. R. § 61
. 355(c). (c) Calc ulate the annual benzene quantity for each waste stream by multiplying the annual waste quantity of the waste stream times t he flow-weighted annual average benzene concentration
. (d) T otal annual benzene quantity from faci l ity waste is calculated by adding together the annual benzene q uantity for each waste stream generated



### VES009232Veolia ES Techn i cal Solutions, LL
. C. Pennit No
. : V-JL

- 17 1 6300103

- 20 1 4 · 10 Issuance Date: DRAFT E

x

pirati on Date: DRAFT Page 156 of 172



### duri n g the year and tl1e annual benzene quantity for each process unit turnaround waste annualized according to 40 C.F.R. § 

### 61.355(bX4). 2. If

### the total annual benzene quantity from facility waste is equal to or greater than 1 0 megagramper year (11 ton/yr), then thePemUttee shall comply with t h

e requirements of 40 C.P.R.§ 

### 61.342(c), (d), or (e). ( H ) 

### Ge n eral P ro hibition on Air P ollu ti o n (35 lAC 20 1.141) 

### No person shall cause or threaten or allow the discharge or emission of any contaminant int o the 

### environment in a ny State 

### so as, either alone or in combination with contaminants from o t her sou rces, to cause or tend to cause air pollution in Illinois, or so as to violate the provisions of35 lAC, Subtitle B, 

### Chapter I , 

### or so as to prevent the attainme nt or maintenance of any applicable ambient air quality standard. [35 lAC 201.141] ( I) 

### Faclllty-w lde Testing [40 

### C.F. R. 

### § 71 .6(aX3)(i) ] I
. Testing Required by 35 lAC 20 1 .28 2
. Every emission source and all air pollution**c<~ntrol** 

### equipment shall be subject to the following testi ng requirements for the purpose of determining the nature and quantities of specified air contaminant emissions and for the purpose of determin i n g g rou nd level and ambient air concentrations of such air contaminants: (a) Te sting by the Permittee. The !EPA may require the Permittee to conduct tests in accordance with procedures adopted by the IEPA , at such reasonable times as may be specified by the !EPA and at the expense of the Permittee. The IEPA may adopt procedures detailing methods of testing and formats for reporting results of testi ng. Such p rocedures a n d forma ts, and revi s ions thereto, shall not become effective until filed with the Index Division of the Office of the Secretary of State as Required by "An 

### Act concerning administrative rules , " approved June 14 , 195 1 , as amended. All such tests shall b e made by or under the direction of a person qualified by training and/or experience in the field of air 

### pollution testing. Tbe !EPA shall have the right to observe all aspects ofsuch t ests . (b) 

### Test ing 

### by the IEP A. The !EPA shall have the right to conduct such tests at any time at its own expense. Upon request of the IEPA. the Permittee shall provide , without charge to the !EPA, necessary holes in stacks or d

ucts an d other saf e and proper testing facilities, i nc luding scaffolding, but excluding instruments and sensing devices, as may be necessary .



### VES009233Veolin E S Technical Sol uti

ons, L.L.C. Pennit No.: V

- JL.. 17 1 6300103-201 4- IO Issuance Date: DRAFT E

xpir ation Date: DRAFT Page 157 of 1 72



### 2. Determination ofannual benzene waste quantity for off-site wastes [ 40 C
. F
. R. § 61.355) (a) TI1e detenniuation of annual benzene waste quantity for the off-site wastes received by the Pennittee shall be made by us i ng the methods and procedures established iu 40 C.F.R. § 6 1. 355 along with the following: (b) 

### For the purposes of the calculation required by 40 

### C.F.R. § 61.35 5(a), the Pennittee s hall detenniue the flow-weighted annual average benzene concentration in a manner that meets the requirements given in 4 0 C.P.R. § 

### 61.355(c)(l) using either of the methods given in 40 

### C.F.R. 

### § 61.355(c)(2) and (cX3)
. (i) The det enn i nation for wastes that are received from oflSite shall be made at the poiut where the waste enters the hazardous waste treatment, storage, or disposal facility
. (ii) Know l edge of the waste. The P ermittee s h all provide sufficient information to document the flow-weig h ted an nual average benzene con centration of each waste stream. Examples of information that could const illlte knowledge inc lude material balances, records of chem icals purchases , or previous test results provided the results are still re levant to tl1e current waste s tream conditions
. If test data are used, t hen the Permittee shall provide documentatio n describing the testiug protocol and the means by which sampling variability and analytical variability were accou nted for iu the determination of the flow

- weighted aruma( average benzene concentration for the waste strea m. When the Permittee and the Administrator do not agree on determinatio n s of t he flow-we ighted annual average benzene concentration based on knowledge of the waste, the procedures under 40 

### C.F
. R
. 

### § 61.355(c)(3) shall be used. (iii ) Measurement s of the benzene concentration in the waste stream in accordance with the follow ing procedures:

A
. Collect a minimum of three representative samp l es from each waste stream. Where feasible, samples shall be take n from an enclosed pipe prior t o the waste being exposed to the atmosphere
. D
. For waste in e n closed pipes , the following procedures shall be used:



### VES009234**Veo~a** ES Techni cal Solutions , L l. C
. Page I SS o f 172 Pem1 i t No.: V

- JL-1 7 1 6300103 · 2014 · 10 Issuance Dat e: DRAFT Expiration Date: DRAFT I. Samples shall be colle cted prior to the waste being expos ed t o the atmosphere in orde r to minimize the loss of benzene prior to sampling
. II. A static mixer shall be installed in th e process 

### line or in a by

- pass lin e un l ess t h e Penniltee demonstrates that i nstallation of a static m ixer i n the line i s not necessary to accurately determine the benzene concentration of t he waste stream. ill. The sampling tap shall be located within two pipe diamet ers oft h e static m i x

er outlet. IV
. P rior to the initiation of sampling , sample lines and cooling coil shall be purged with at least four vol u mes of waste. V
. After purging, the sample flow sha ll be dire cted to a sample containe r and the tip ofthe sampling tube shall be k ept below t he surface ofthe waste d uring sampling to minimize contact with the atmosphere. VI. Samples shall be collected at a flow rate such that the cooling coil is able to maintain a was t e temperature less than J0°C (50°F). VII. After filling, the sample container shaH be capped immediately (within 

### 5 seconds} to leave a nunimum headspace in the container
. VIU. The sampl e containers shall immediat e ly b e cooled and maintained at a temperature below I0 ° C (50°F) fo r transfer to th e laboratory. C. When sampl i ng from an enclosed pipe is not feasible, a min imu m o ftl1 ree represent a t ive samples shall be co ll ected in a manner to minimize exposure of the sampl e to the atmosphere and loss of benzene prior to sampling. D. Each waste sample sha ll be analyzed using o n e oft he fo ll owing tes t met h ods for d e t ennining the benzen e concentration i n a waste stream: I. Method 8020, Aromatic Volatile Organics , in "Test Methods fo r Evaluatin g Solid**Wa~'te,** Physical/Chemical



### VES009235Veol ia ES T echnical Solut ion s, L. l.
.C
. Pennit No
. : V

- IL

- 17 1 6300103

- 20 1 4 · 10 Issuance Date: DRAFT Expiration Date : DRAFT Page 159 of 172

Methods,'' EPA Publication No. SW-846 (incorporation by reference as specified in 40 C.F .R. 

### § 61.18); lL Met hod 8021, Volatile Organic Compounds in Water by Purge and Trap Capillary Column Gas Chromatography with Photoionization and Electrolytic Conductivity Detectors in Series, in "Test Methods for Evaluating Solid Waste , Physical / Chemica l Med1ods , " EPA Publication No
. SW-8 4 6 (incorporation by reference as specified in 40 C. P .R
. § 61.18); 111
. Method 8240, Gas Chromatography/Mass Spectrometry for Volatile Organics, i n "Test Methods for Evaluating Solid Waste, Physical / Chemical Methods, " EPA Publication N o. SW-846 (incorporation by reference as specified in 40 C.P.R. § 61.18); IV. Method 8260, Gas Chromatography/Mass Spectrometry for Volatile Organics: Capillary Column Technique, in "Test Methods for Eval u ating Solid Waste, P hysicaVChemical Methods , " EPA Publication No
. SW846 (incorporated by reference as specified in 40 C
. F.R. 

### § 6l.J8); V. Method 602 , Purgeabl e Aromatics, as desc ri bed in 40 C.F.R. Pan 136, Appendix A , Test Procedures for Analysis ofOrganic Pollutants, for wastewaters for which thi s is an appro v ed EPA methods; or Vl. Method 624 , Purgeabl es, as described i n 40 C. P .R. Part 136, Appendix A , Test Procedures for Analysis of Organic Pollutants , for wastewaters for which this is an appr oved E PA meth od. E
. T he Perm i ttee sh all c al culat e th e flow

- weighted annual average benzene concentration by averaging the results of the sample analys e s as follows:

Where:



### VES009236Veolia ES Techuica l Solutions, l. L .C. Permit No.: V

- I L

- 1716300 10 3

- 2014- 1 0 Issuance O.tc: DRAFT E.'piration Da t e: DRAFT Page I 60ofl72


## C = 

### Flow-weighted annual average benzene concentration for waste stream, ppmw . Q, 

## = Total annual waste quan t i

ty for waste stream, kglyr (lb/ yr).
n = 

### Number of waste samples (at least 3). 

### Q

; 

## =Atmual waste q u antity for waste stream represented by Ci, kglyr (lb/yr). C; 

## = Measured concentration of benzene in waste sample i, ppmw. (J) 

### Facility

- wi d e R ec ordkee ping [ 40
. C.F .R § 

### 71
. 6 ( a)(3)(i)(B) J I
. I f testing is required by condit . ion 3.4(1) , the Permittee shall keep records of the testing, including the test date, conditions, methodologies, calculations, test results, and any discrepancies between the test results. 2
. Reporting requirements established by 40 C.F.R. Part 6 1 , S u bpart FF: (40 C.F.R. § 

### 61.357 ] If the total annual benzene quantity from facility waste is equal t o or greater than 10 Mgiyr (I I tonlyr), then the Perm ittee shall subm it to the Administrator the following reports: (a) The P ermittee shall submit annually to the Administrator a report that updates the information listed in40 C
. P.R.§ 61.357(a)(l) through (aX3). If 

### the information in 

### the annual report required by 40 C
. P.R.§ 61.357(a)(l) through (a)(3) is not changed in the following year, the Permittee may submit a statement t o that effect. (b) The Permittee must include the foUowing information in the annual report: (40 C.F.R. § 61.357(a)(I) through (a)(3) ] (i) Total anuual benzene quantity from facility was t e d etermin ed in accordanc e wi th 40 C.F.R. § 

### 61.355(a). (ii) A table identifying each waste stream and whether or not the waste stream will be contro ll e d for benzene emissio n s in accorda n ce with the requ ire ments of 40 C.F.R. Part 61, Subpart FF. (iii) For each waste stream iden t ified as not being controUed for benzene emissions in accordance with the requirements of 40 C.P.R. P art 61,



### VES009237Veotin ES Techn i cal Snlutions, LL.C. Pcnnit No.: V

- IL · 1 71 6300103 · 201 4 · l0 Iss u ance Date: DRAFT Page 1 61 of 172 Expirlltion Dat e: DRAFT 

### Subpart FF, the Permittee shall add the foUow ing information to the table:

A. Whether or not the wat er content ofthe waste stream is greater than I0 percent; B. Whether or not the waste stream is a process wastewater stream, product tank draw down, or landfill leachate; C. Annual waste quantity for the waste stream; D
. Range of benzene concentration s for the waste s t ream; E
. Annual average flow-weighted benzene concentra t ion for the waste stream; and F
. Annual benzene quantit y for the waste stream. (c) Beginning 3 months after the date that the equipmen t necessary t o comply with 40 C
. P.R. Part 61, S u bpart FF, has been certified in accordance with 40 C
. F .R. § 

### 6 1 .357(d)(l), the Pemtittee shall submit quarter ly t o t he Administrator a certification that all ofthe required inspections have been carried out in accordance with the requirements of 40 C.P.R. Part 61, Subpart F F
. (d) Beginning 3 months after the date that the equ ipment necessary to compl y with 40 C.P
. R. Part 61, Subpart FF , has been cert i fied in accordance with 40 C.P.R
. § 

### 61.357(d)(l ) , the Perm i ttee shall submit a report quarterly to the Administrat or that includes: (i) ff a treatment p rocess o r wastewater treatment system unit is monitored in accordance with 40 C.F.R
. 

### § 61.354(a)(l) , t hen each period of operation during which the concentration ofbenzen e in t he monitored waste stream exiting the wtit is equal to or greater than I0 parts per million by weight. (ii) If a treatment process or wastewater treatment system unit is monitored in accordance w i th 40 C.F.R. § 

### 6 1.354(a)(2) , then each 3- hour period of operdt ion during which the averdge value of the monitored parame ter is outs i d e the ran ge ofacceptable values or during which the unit is not operating as designed. (iii) If a treatment process or wastewater treatment system unit is monitored in accordance with 40 C.F
. R
. § 

### 61.354(b) , t hen each period ofoperation during which the flow

- weighted annual average



### V E S009238Veo l ia ES Technic al Solut ions, L. L. C. Penni! No
. : V-1 L

- 17 16300103-201 4-1 0 Issuance Da <e: DRAFT Pa&e 162 of 1 72 Expiration Da te : DRAFT concentration of benzene in tbe monitored waste stream entering the unit i s equal to or greater tha n I0 ppmw and/ or the total annual benzene quantity is equal to or greater than 1.0 mg/yr. (iv) For a control d evice monitored in accordance with 40 C.F.R. § 61.354(c) , each per i od of oper ation moni tored during whi ch any o f the condit i ons estab lished by 4 0 C.F.R
. § 61.357(d)(7)(iv) occur , as applicable to tbe control d evice. (v) For a cov er and closed

- vent system monitored i n accordance with 40 C.F
. R. 

### § 61.354(g) , the Pennittee shall subm i t a report quarterly to the Administrator that identifies any period i n which the pressure in the waste management un . it is equal to or greater than atmospheric pressure. 3. The Pennittee shall submit annually to the Administrator a report that smnm atizes all inspections requ i red by 40 C.F.R. 

### §§ 61.342 through 61.354 duri ng which detectable emiss i ons are m easured or a prob l em (s uch as a b roken seal, gap or o ther probl em) that could result in benzene emissions is i dentified, including information about the repairs or correct i ve action taken
.



### VES 0 09239Veolia ES Technical Solutions, I.. I...C. Perm it No
. : V-!L-17 1 6300103-201 4

- 10 Issuan ce Dat e: DRAFT Expirat ion Dille: DRAFT 

## 4
. 0 G E NERAL 

## PART 71 REQUIREMENTS

4.1
. DEFINITIO NS [ 40 C.F. R § 71
. 2
. 1 Page 163 ofl72

Tenns and co n ditions not othenvise defined in this permit have the me31Jing assigned to the m in 

### 40 C.P.R. Part 

### 71 unless other regulatio ns or statutes are referenced. 4 .2. ANNU AL FEE PAYMENT ( 40 C
. F
. R. 

### §§ 7 1. 6 (a )(7 ) and 7 1
. 9 ) A. The Permittee shall pay an ann ual permit fee in accordance with the procedures out lined below. (40 

### C.P
. R. § 71.9(a)] B. Th e Permitt ee s hall submit an annual 

### report of its aetna! emissions for the preceding calendar year, a fee calculation work sheet (based on the report), and full payment of the annual 

### fee each year. The Perm ittee 

### shall submit the annual report and pay the ann ual pen n it fee each year on or before tl1e anniversary date (3 months from the issuance ofthis permit) of its initial fee ca l c u lation work sheet. The Pe
. rmi ttee shall submit the annual report to: A

ir P e rmit s S ection ( AR

- 18J) Air a nd Radiati on Divi s ion EPA R egi on S 77 W es t Jackson Boule var d Chicago , DUnoi s 

### 60604 C. The fee payment shall be in United States currency and shall be paid by money order, bank draft, certified check, corporate check , or electronic funds transfer payable to the order of the U.S
. Environmental Protection Agency. D. TI1e Permittee shall se11d fee payment and a completed fee filing form to: 

### U
. S
. Emironme ntal Protection Agenc y F OIA and l\U s cellaneou s Pay me nts, C incinn ati Fin a nc e Cen ter, P
. O. Box 979078 , 

### S t. Loui s, MO 631 97- 9000 E. The Permittee shall send an updated fee calculation worksheet form and a photocopy of each fee payment check (or other confi rmation of actua l fee paid) submitted annually by the same deadline as required for fee payment to the address li sted in condition 4.8(B) of**thi~** permit
. (The Permittee should note that an annual emissions report, requ ired at the same time as the fee calcu lation worksheet by 40 

### C.F
. R. § 7 I .9(h), has b een inc orporat e d into the fee calculation worksheet form as a convenience.)



### VES00924 0Veolia ES TeclUiica l Solution s, L L
.C. Permit No.: V

- IL

- 1716300103

- 2014--10 Issuance Date: DRAFT E.xpirat i on Dat e: DRAFT
F
. Basis for calculating annual fee: Page 1 64 of 17 2

I. The annual emissions 

### fee shall be calcu lated by multiplying the total tons of actual emissions of all regula ted pollutants (for fee cal culation) emitted from the source, including fugitive emissions by the presumptive emissions fee (in dollars/ton) in effect at the time of calculation. (a) "Actual em i ssions" means the actual rate of em i ssions in tons per year of any "regulat ed pollutant (for fee calc ulation)" emitted from a Part 7 1 source over the preceding calendar year. Actual emissions shall be calculated using each emissions unit's actual operating hours, production rates, in

- place control equipment, and types of materials processed, stored, or combusted during the preceding calendar year . (40 C
. P.R
. § 71.9(c)(6)) (b) Actual emissions shall be computed using methods required by the pemrit for detennining compliance , such as monitoring or source testing d at a. [40 C.P.R
. § 71.9(h)(3)] (c) If actual emissions cannot be determined using the compliance methods in the pennit, the Permittee shall use o ther federally recognized procedures. [40 

### C.F.R. § 71.9(e)(2)) (d) The term "regulated pollutant (for fee calculation)" is defined in 40 

### C.P.R
. § 71.2. (e) Prior to the start of each calendar year, EPA 

### will revise for inflation rate and make available the presumptive fee amount. 2. The Permittee s h all exclude the following emissions from the calculation of fees: (a) The amount of actual emissions ofeach regulated poUutant (for fee calculation) that the source em i ts in excess of4 , 000 tons per year; (40 

### C.F.R. § 71.9(c )(5){I)] (b) Actual emissions ofany regulated pollutant (for fee calculation) already included in the fee calculat i on; [40 C.F.R. 

### § 71.9(cX5)(ii)] and (c) The quantity of actual emissions (for fee calculation) of insignificant activities [defined in 40 C.P.R.§ 7 1. 5(c){ll)(i)] or of insignificant emissions levels from emissions units identified in the Permittee's application [pursuant to 40 C .F.R
. 

### § 71
. 5(c){J l ){ i i) )
. [ 40 

### C.P.R. § 71.9(c)(5){iii) ]



### VES009241Vcolia ES Tedmical Soluti ons, LL.C. Pennit No
. : V

- IL-17 1 6300 1 03 · 201 4 · 10 Issuance Date: DRAFT Expiration Da te: DRAFT Page 1 65 of 172

G. Fee calculation worksheets shall be certified as to t ruth , accuracy, and completeness by a responsible official in accordance with condition 4.8(A). (The Permittee should note that the fee calculation worksheet incorporates 

### a section to help meet this responsibility.) 

### H. Tite Permittee shall retain fee calculation worksheets and other emissions-rela t ed data used to determine fee payment for 5 years following submittal of fee payment. Emission-rela t ed data inc l ude , for example , emi s sions

- related forms provided by the EPA and used by the Permittee for fee calculation purposes, emissions-related spreadsheets , and emissions-related data, such as records ofemissions monitoring data and related support infonnatio n required to be kept i n accordance with 40 C.F. R
. § 71.6(aX3Xii). [40 C.P.R
. § 71.9(1) ] 

### J. Failure of t he Permittee to pay fees in a time l y manner shall subject the Permittee to assessment of penalties and in terest in accordance with 40 C.P.R.§ 71.9ffi
. J. When notified by the EPA ofunderpa)1nent offees, the Pen nittee shall remit full payment within 30 days of receipt of notification. [ 40 C.F.R. § 7 1. 9(jXI) and (2)] K. A Permittee who believes that the EPA assessed fee is in error and who wishes to cbaUen ge s uch 

### fee shaU provide 

### a written explanation ofthe alleged error to the EPA along with full payment of the EPA assessed fee
. [40 C.F.R § 71.9(j)(3)] 4. 3
. COMPLIANCE S TATEMENT (40 C.F.R. 

### § 71.6(a)(6)) (A) Tite Permittee must comply with all conditions of this P art 7 1 permit Any n

oncompliance with this permit constitutes a violation of the CAA a n d is grounds for: [40 C
. P.R.§ 7L6(a)(6)(1)] I
. Enforcement action; 2. Pennit termination, revocation and reissuance, or modification; or 3. Denial of a permit renewal appl ication
. (B) It shall not be a defense for a Perm ittee in an enforcement action that i t wou ld have 

### been necessary to halt or reduce th e permitted activity in order to m ai n tain compliance with t he conditions of thi s permit. [40 C
. P.R.§ 71.6(aX6)(ii )] 4.4. COMJ>LIANCE CERTIFICATIONS [ 40 C.F.R 

### § 71
. 6( c) (S)J T h e Permittee shall submit to EPA a certification ofcompliance with all permit tem1s and conditions, including emission limitations, standards, or work pract ices, each calendar year for the reporting period from January I to December 31, except the first reporting period shall b egin on tbe effective date of thi s permit and end on December 31. All



### VES009242Veo l ia ES Teclmical Sol utio n s, LL.C. Pennit No.: V-!L-17 1 6300103

- 2014-10 Issuance Da t e: DRAFT E

xpira tion Date: DRAFT Page 1 66 of 172
reports s hall be submitted to the EPA and shall be postmarked by the 

### 30 ' h day following the end of the reporting period. The compliance certification shall be · certified as to truth, accuracy, and completeness by a responsible officia l in accordance with condition 4. 8(A) oft h is permit. The c e rtificat ion shall include the following: (A) I dentification of each penn it tenn or condition t hat i s the basis of the certifica t ion ; (B) Identification of the method(s) or o ther means used for determining the com pliance status ofeach term a n d co n dition duri ng the certification period , and whether s uch metltods or other means provide continuous or intennittent data
. Ifn ecessary , the Permittee also shall ident ify any other material information t hat must be included in the certification to comply wit h section 113(c) (2) of the CAA, which prohibits knowingly making 

### a false certifica t ion or omitting material infonnation; (C) The compliance status ofeach term and conditio n of the permit, including whether monitor i ng data is cont inuous and wh ether that data or any other credible ev i dence shows the compliance is cont inuous. Th e certitica t ion shall identifY eac h deviat i o n and take it into account in the compl iance certification; and (D) 

### A Statement indicating the compliance status of the source with any applicable monitoring and compliance certification requirements of the CAA
. 4.5
. S CHEDULE OF C OMPLI ANCE (40 C
. F.R. 

### §§ 7 1.6 (c)( 3 ) and 7 1.5(c )(8 ) (iii)) (A) The Permittee will comply with aU requiremen ts of the permit. (B) For applicable requiremen ts that will become effect ive during the permit term, the Pennittee shall timely comply with such requ irements. 

### 4
. 6. D U

TY TO P RO V IDE AND S UPPLEl\fEN T INFORM A

TION (40 C.F
. R. 

### §§ 7 1.6(a ) (6)(v) and 71
. 5(b) ) (A) The P ennittee shall fumish to the EPA, within a reasonable t im e, any information that the EPA may request i n writing t o dete rmine whether cause exists fo r modifYing , revoking and reissuing, or terminat ing litis permit or to detemtine compliance with t h is penni t. Upon request, the Permittee shall also furn i sh to EPA copies of records that are required to 

### be kept pursuant to the t erms of thi s p erm it, including i n formation claimed to be confidential. lnfomtation c l aimed to be confidential should be accompanied by a claim of confide ntiality according to the provis ions of 40 C
. P.R. Part 2, Subpart B. (B) 11te Permittee, upon becoming aware that any relevant fac ts were om itted or inco1Tect information was su bmitted in t h e pen u it application, s h all promptly submi t such supplementary fac t. s or corrected information. 11t e Pemtittee shall a l so p rovi d e



### VES 009243Veol ia ES Techni cal Solutions, L
. L.C. Penni ! N o. : V-IL- 17 16300 103

- 201 4- 10 Issuance Date: DRAfT Expirnt ion Date: DRAFT Page 167 of 172

additional information as necessary to address a ny requirements that become applicable to the facility after this permi t is is s ued. 4
. 7. E NFORCEABILITY (40 C
. F.R. § 71
. 6(b) J All tenns and conditions i n th is permit, including aoy prov i sions design ated to limit the source's potential to emit , are enforceable by the EPA and ci tizens in accordance with the CAA. 4
. 8
. SUBMIS S IONS (40 C.F
. R. §§ 71
. 5(d ) , 7 1.6 a nd 71.9( (A) A responsible offic. i al of the Permittee shall cert i fy as to the truth , accuracy , and completeness of any document required to be submitted by this penn i t. Such certifications shall state that based on information and belief fonned after reasonable i nq uiry, the statements a nd infonnation in the document are true, accurate, and complet e. Except as otherwise noted, the Penuittee sha ll submit all docume nt s required to be submitted by this penuit to: Air E n f or cem e nt and Compli a n ce Ass urance Branch ( AE- 17J) Air and R a dia ti on Di visi on EPA RegionS 77 West Ja c k s on Boulevard C hiu g o , Illinoi s 60604 (B) The Permittee shall submit pemtit applications, applicat i ons for pennit amendments , aod o t her applicable pennit information, which includes but is not limited to installation ofcontrol equipment. rep l acemen t of an emissions uuit, fee calculation worksheets, and applicati ons for rene wals an d permit modifications , to: Air P ermits S ection Air P rogra ms Br a n ch (AR

- l8J) EPA Re g ionS 7 7 W es t Jackson Boulev ard C hi ug o , Illinoi s 60604 4
. 9
. SE VERABILITY C LAUS E (40 C
. F
. R. 

### § 71.6( a)( S )) The pr ovisions of thi s permi t are severabl e, and i n the even t of a ny challenge to any portion ofthis permit, or if aoy portion is held inv a lid, the remaining permi t conditions shall remain valid aod in force. 4
. 10. PERMIT ACTIO NS (40 C
. F
. R. § 71.6(a)( 6)(iii)J The EPA may modify, r evoke, reopen and reissue this pennit, or terminate i t for ca u se. The fili ng of a reque;t by the Permittee for a permit modification, revocatio n and



### VES 0092 44Vcolia ES Techni c al Solutions , L .L .C. Pelltli t No.: V · ll ·17 1 63001 03 · 20 14 ·1 0 Issuance Date: DRAFT Expiration Date: DRAFT Page 168 of 172
reissuance, or terminatio n , or ofa notification of planned changes or anticipa ted noncompliance does not stay any permit condition. 4
. 11
. 

### ADMINI STRATIVE PERMIT AMENDMENTS [ 40 

### C.F .R. § 71.7(d)) The Permittee may request the use of administrative penn it amendment procedures for a permit revis i on in accordance with 40 C.F.R. 

### § 71.7(d). 

### 4.12. MIN OR PE RI\-UT MODIFI CATIO NS (40 

### C.F.R. § 71
. 7(e) (l) ] The Pennittee may request the use of minor permi t modification procedures for those modifications that meet the r equirements contained in 40 C.P.R
. § 71
. 7(e)(l ). 

### 4
. 1 3. SIG N IFICANT PER..'\1IT MODIFICATIONS ( 40 

### C.F .R. § 71 .7(e)(3)) The Pennittee must request the use of significant pennit modification procedures for those modifications tha t meet the requirements contained in 40 

### C.P.R. § 71. 7( e)(3). 4
. 14
. REOPEN ING 

### FOR CAUSE (40 C. F.R. 

### § 71.7(1)) The EPA shall reopen and revise the permit prior to expiration under any of the following circumstances: (A) Additional applicable requirements under the CAA become applicable to th is source if

the remaining permit tenn is 3 or more years. (B) The EPA detenuines d1at the permit contains a material mistake or that inaccurate statements were made in e stablis hing the emissions standards or other terms or conditions of the permit. (C) The EPA determines that the permit mus t be revised or revoked to assure compl iance with the applicable requirements. 4
. 15
. 

### P ROPERTY RI G HT S (40 

### C.F.R. § 71.6(a)(6)(iv)) This pem1it does no t convey any property rights of any sort, or any ex cl usive privilege. 4.16. 

### INSPECTION AND 

### ENTRY (4 0 

### C. F
. R. § 7 1 .6 (c )( 2 )) Upon presentation of credential s and other documents as may be required by law , the Pen n ittee shall allow EPA or an authorized representative to perform the f ollowing as authorized by the CAA:



### VES009245Veo l iA ES Technic al SoiUiions, L.L.C. Pem it No.: V-JL-17 1 6300 1 03

- 20 1 4 -1 0 Issuanc e Date: DRAFT Expir ation Dille: DRAFT Page 1 69 of 1 72


### (A) 

### Enter upon the Pennittee's prem i ses where the Part 71 

### source is located or e

mi ss ions-related activity is condu c t ed, or where records are kept rmder the conditions ofd1e permit ; (B) 

### Have access to and copy, at reasonable times, any records that must be kept u nder the conditions of the permit; (C) 

### Inspect at rea s onable times any facilities , equipment (i ncl u d ing monitoring and air pollution control equi pm ent), practices, or operations reg ul ated or required u nder the pennit; and (D) 

### Sample or monitor at reasonable times substances or parameters for the purpo se of assuring compliance with the permit or applicable requirements. 4 .17. EMERGENCY PROV ISIO NS [ 40 C
. F.R
. 

### § 7 1.6(g)) (A) In addition to any emergency or upset provision contained in an y applicable requirement, the Pennittee may seek to establish that noncompliance with a technology-based emiss ion limitation under this perm it was due to an emergency . To do so, the Permittee shaH demo ns trate the affrrmative defense ofemergency thr ough p rop er ly signed , contem poraneous operating logs , or other relevant evidence tha t I. An emergency occurred a nd that the Pennittee can identify the cause(s) of the emergency; 2. The permitted facility was at the time bein g properly operated ; 3
. D uring the period ofthe emergency the Permittee t ook a ll reasonable steps to min i mize levels of emissions that exceeded the e mission s s tandards , or other requirements in 

### thi s perm it; and 4. TI1 e Pem 1 ittee submitted not ice o f t

he emergency t o EPA within 2 workin g days o f the time when emission limitations were exceeded due to tl1e emergency . This notice must contain a description of the emergency, any steps taken to mi ti gate e

miss i ons, and corrective actions taken. This notice fulfills the requirements of condition 3.2(B ) of this permit, concerning prompt notification ofdeviations
. (B) I n any enforcement proceeding, the Pem1ittee attempting to establish the occun-ence of an emergency has the burden of proof. (C) 

### An**emergency~** 

### means any situation arisi n g fr om s udden and reasonab ly u nfores e eable e ventS beyond the co n trol of the source, inc l u ding acts of God, which situation requires i mmediate corrective action t o re store normal operation, and that causes t h

e source to 

### exceed a t echnology-based emission limitation under the permit



### VES009246Veol ia ES Technica l Solutions, L L.C. Penn i ! No
. : V

- l l- 1 716300 103

- 201 4

- 10 Issuance Date: DRAFT Expiration Da te : DRAFT Poge 17 0 of 172

due to unavoidable increases in emissions attributable to the emergency . An emergency shall not include noncompliance to the extent caused by i mproperl y des i gned equipment, Jack of preventive maintenance , carel ess or imp r oper operation , or operator error. 4.18
. OFF P ERMIT C HANGES 

### 1 40 C
. F

-R. 

### § 71.6(a){ l 2)) The Permittee is allowed to make certain changes withou t a penni! revision, provided that the following requirements are met: (A) Each change is not addressed or prohibited by this pennit; (B) Each change must comply w i th all applicable requirements and may not violate any ex i sting pennit tenn o r condition; (C) Changes under this provision may not inc l u de changes subject t o any requirement of 40 C.F.R. Parts 72 through 78 or modifications under any provision of Ti tle I o f the CAA; (D) The Pennittee must provide contemporaneous written notice to EPA ofeach change, except for changes that qualify as insignificant activit ie s w 1de r 40 C.F.R. § 7I.S(c)( l l )
. The written n otice must describe each c h ange, dte date oft he change, any change in emissions, pollutants emitt ed, an d any applicable require ments t hat would apply as a resu l t of the change; (E) The pennit shield does not apply to change s made under this provision; and (F) The Permittee must keep a record descr i bing all cha ng es tllat result in em i ssions of any r egulated air pollutant subject to any applicable requirement not otherwise regulated under this permit, and t he emissions resulting from those changes. 4

- 19
. PERMIT EXPIRATION AND RENEWAL ( 40 C
. F
. R. §§ 7 1.S (a)( J)(iii) , 71.6(a)(ll) , 7 L7(b) , 71-7(c)(l)(i) and (ii), 71.8(d ) l (A) Except as provided in con ditions 4. 19(C) an d (D), below, this perm it shall expi r e five years fi'om the effect i ve date. (B) Expiration of this pennit terminates the Pennittee ' s right to operate unless the Pemlittee bas submitted a timely and complete pennit renewal application to the permitting authority at l eas t 6 calendar months, but not more than 

### 18 calendar months, prior to the date of expiration of this penni!. (C) If the Pemlittee submits a timely and compl et e pem1 it a p plication for renewal , consistent with 40 C_F.R
. § 71.5(a)(l) and (2) and condition 4.19( 8 ) , above, but the pennitting authority fails to issue or deny the renewal pennit, then this permit shall



### VE S 00 9247Veo l ia ES Techni cal Solu t ions, L L .C. Pennit No.: V

- IL-1 7163 00 103

- 20 1 4 -1 0 

### Is s uanc e Date: DRAFT Exp iration Dat e : DRAFT Page 17 1 of 1 72



### not expire u ntil the pennitting authority h as issued or denied a renewal permit Any permit shield granted under condition 4.21 ofthis permit may be extended during the period that the permitting authority fails to act on the renewal applicat ion. (D) If the Pemtittee has submitted a timely and complete application for renewal consistent with 40 C
. F.R. § 

### 71.5(a)(l) and (2) and condition 4. 1 9(B) , above , the P

ermittee's failure to have a Part 71 permit is not a violation of Part 71 or the CAA until the pennitting authority takes fmal action on the permi t renewal application. This protection shall cease to apply if, 

### subsequent to the completeness determination, the P emtit t ee fails to s u bmit any additional informat ion identified as being needed to process the application by the deadline specified in writing by the pennitting authority. (E) 

### Renewal of this permit is subject to the same procedural requirements that apply to initial p ermit i ssuance, including those for p u blic participat ion and affected state and tribal review. (F) The app lication for re new al shall include the current permit num ber, description of permit revisions and off

- permit changes that occurred d uring the permit term, any applicable requirements that were promulgated and not incorporated into the permit during t h e pen u it t et m , and other infon u ation required by the application form. 4.20
. OPERATIONAL FLEXIBILITY [ 40 C.F .R
. 

### § 7t
. 6(a) ( J 3) ) The Permittee may make c hanges within the permitted facility without a permit revi sion, including the addition of a new generator or replacement of an existing generator, provided t he following conditions a re met: (A) TI1e changes are no t mod ifica t ions u n

der any provision of T itle I of the CAA; (B) The changes do not exceed the emi ssions allowed under this permit (whether expressed therein as a rate of emissions or in terms of total emissions) ; a n d (C) 

### TI1e Permittee no t ities the EPA at least 7 days iu 

### a d vanc e ofthe proposed changes. The written notification shall include a brief description of the change within the permitted facility, the date on which the change will occur, any change in emissions, a

nd any permit t erm or condition that is no longer applicable as a result ofthe c

h ange. 

### 4
.

21
. PERMIT S HIELD (40 C
. F
. R. 

### § 71
. 6(1)) (A) Except as noted in condit i ons 4
. 21 (A)( I) and ( 2 } , be l ow , compliance with th e conditions of this penn i t shall b e deemed compliance, as of the date ofpennit iss u ance , with any applicable requirements that are specifically identified and



### VES009248Veol ia ES Tecluucal Solutions, L L.C. Penni t No
. : V- IL-17 1 6300 103 -20 14-10 Issuance Date: DRAFT Expiration Date: DRAFT Pnge 172of 172

i ncluded in this permit or that are specifically identified in this permit as not app lyin g to the facility. 1. Compliance with this permit shall not be deemed to be compliance with any requirement of40 

### C.P.R. Part 63, Subpart 

### BEE, (including the appendix and any requirement of the General P rovisions (40 

### C
. F.R. Part 

### 63, Subpart A) identified i n Table 

### I as applicable to 40 

### C.P.R. Part 

### 63, Subpart EEE). 2. The permit shield shall not apply, and comp li ance with this permjt shall no t be deemed to be compliance with, Parts C and D ofTitle 1 oftlte CAA , or any requirements of the lllinois SIP , or federal or sta te regulations th at govern the pemtitting of ma j or modifications to sources of air emissions. (B) Nothing in this permit shall alter or 

### affect the following: I. The liability ofthe Pemlittee for any viol ation of applicable requirements prior to or at tlte time ofpemtit issuance ; 2. The ability of EPA to obtain information under Section 114 of the CAA; 3. The applicable require ments of the ac i d rai n program , consistent w i dt section 408(a) of the CAA; or 4. The p rovisions of section 303 of the CAA (emergency orders), including the authority ofthe Administra tor under t hat section. 4.2 2. CREDffiLE E V IDEN CE (62 Fed. R eg. 8314 (Fe bruary 24, 1997); 42 U.S.C. § 7 41 3 ) Notwiths tandi ng the conditions ofthis permit specifying compliance practices for applicable requirem ents, any person (i n cl uding the Permittee) may a l so use other credible evidence to establish compliance or noncompliance with applicable requirements
.



### VES009249

## VES009250
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