Veolia ES Technical Solutions, L.L.C. 

Pennit No.: V-IL·1 716300103·2014·10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 123 of 172 

(f) A list of cost-effective energy conservation measures that are within the 

facility's control; 

(g) A list of the energy savings potential of the energy conservation measures 

identified; and 

(h) A comprehensive report detailing the ways to improve efficiency, the cost 

of specific improvements, benefits, and the time frame for recouping those 

investments. 

[40 C.F.R. § 63.7500 and Appendix to 40 C.F .R. Part 63, Subpart DDDDD, 

Table 3 (Item 4)] 

5. At all times, the Permittee must operate and maintain Boiler #1, including any 

associated air pollution control equipment and monitoting equipment, in a 

manner consistent with safety and good air pollution control practices for 

minimizing emissions. Determination of whether such operation and 

maintenance procedures are being used will be based on information available to 

the Administrator that may include, but is not limited to, monitoring results, 

review of operation and maintenance procedures, review of operation and 

maintenance records, and inspection of the source. [40 C.P.R.§ 63.7500(a)(3)) 

(D) Monitoring and Testing (40 C.F.R. § 7l.6(a)(3)) 

I. The Pennittee shall perform an annual Method 9 test to ensure compliance with 

the opacity limit. [40 C.F.R. § 71.6(a)(3)(i)(B)) 

2. The Penmittee must conduct an annual tune-up of Boiler# I to demonstrate 

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 

necessary. The Permittee may delay the burner inspection until the next 

scheduled unit shutdown; (40 C.P.R.§ 63.7540(a)(lO)(i)) 

(b) Inspect the flame pattern, and adjust the burner as necessary to optimize the 

flame pattern. The adjustment should be consistent with the 

manufucturer's specifications, if available; [ 40 C.F.R. § 63.7540(aXlO)(ii)) 

(c) Tnspect the system controlling the air-to-fuel ratio, and ensure that it is 

correctly calibrated and functioning 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 consistent 

with the manufacturer's specifications, if available, and with any NOx 

VES009200 
Veolia ES Technical Solutions, L.L.C. 

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

Issuance Date: DRAFT 

Expiration Date: DRAFT 

requirement to which Boiler #I is subject; and (40 C.P.R. 

§ 63.7540(a)(IO)(iv)] 

Page 124 of 172 

(e) Measure the concentrations in the effluent stream of CO and NOx 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. If Boiler #I is not operating on the required date for a tune-up, the tune-up must 

be conducted within 30 calendar days of startup. (40 C.F.R- § 63.7540(a)(l3)) 

4. The Permittee must conduct performance tests for CO and NOx from the 

affected boiler at a frequency of no less than once every 5 years to demonstrate 

compliance with the CO and NOx emission limits in condition 2.7(A)(2). Each 

perfomtance test must be conducted between 48 and 60 months after the 

previous perfonnance test. The Permittee must do the following during the 

perfortnance tests: 

(a) Select the sampling ports location and the number of traverse points using 

Method I in 40 C.FK Part 60, Appendix A; 

(b) Determine oxygen and carbon dioxide concentrations of the stack gas using 

Method 3A or 38 in 40 C.F R. Part 60, Appendix A, or ASTM 06522- 00 

(ffiR,see40C.F.R. § 63.14(b)), or ASMEPTC 19, Part 10 (1981) (IBR, 

see 40 C.F.R. § 63.14(i)); 

(c) Measure the moisture content of the stack gas using Method 4 in 40 C.F.R. 

Part 60, Appendix A; 

(d) Measure the NOx emission concentration using Method 7 or 7E in 

Appendix 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 fttel is natural gas. 

[40 C.F.R. § 71 .6(a)(3)(i)(B)] 

(E) Recordkeeping and Reporting (40 C.F.R § 71.6(a)(3)] 

I. The Pennittee must record and maintain onsite: 

VES009201 
Veolia ES Technical Solutions, L.L.C. 

Pertnit No.: V-IL-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); 

[Construction 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 load, before and after the tune-up of the 

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 submit annually a compliance report which contains: 

(a) Company name and address; 

(b) Statement by a responsible official with that official's name, title, and 

signature, certif)~ng the tmth, accuracy, and completeness of the content of 

dte report; 

(c) Date of report and beginning and ending dates of the reporting period; 

(d) A summary of the results of the annual tune-ups, including the date of the 

most recent burner inspection if it was not done annually and was delayed 

until the next scheduled or unscheduled unit shutdown. The Pennittee shall 

make actual tune-up results available to tl1e Administrator upon request; 

(e) A summary of the results of performance tests conducted during the 

reponing period. The Pennittee shall make actual test results available to 

the Administrator upon request; 

(1) The hours of operation for the boiler for each calendar month within the 

reporting period; 

(g) The amount of natural gas used during the reporting period (million 

standard cubic feet per year); and 

(h) If the boiler had a startup, shutdown, or malfunction during the reporting 

period and the Pennittee took actions consistent with the SSMP, the 

VES009202 
Voolia BS Technical Solutions, L.L.C. 

Pcnnit No.: V-!L-1716300 103-2014-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

compliance report must 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. § 71.6(a)(3){i)(B)) 

Page 126 of 172 

3. The Pennittee shall notify the IEPA prior to any change in tl1e types of fuel used 

in the boiler. [Construction Permit 95080025] 

2.8 EMER<..'ENCY GENERATORS 

(A) Emission Limitations and Standards (40 C.F.R. § 71.6(a)(l)) 

The two diesel fuel-fired emergency generators, each with a site rating ofless than 

112 HP, are subject to the NESHAP for Stationary Reciprocating Internal 

Combustion Engines (RICE), 40 C.P.R. Part 63, Subpart ZZZZ. However, there are 

no numerical emission limitations that apply. [40 C.P.R.§§ 63.6585, 63.6602) 

(B) Nonapplicable Regulations (40 C.F.R. § 71.6(1)(1)) 

I. The emergency generators are not subject to !he Standards of Performance for 

Stationary Compression Ignition Internal Combustion Engines, 40 C.P.R. 

Part 60, Subpart Illl, because construction of the emergency generator engines 

did not commence, as defined at 40 C.P.R. § 60.4200(a), after July I I, 2005 and 

the engines have 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 

Stationary Spark Ignition Internal Combustion Engines, 40 C.F .R. Part 60, 

Subpart JJJJ, because the emergency generator engines are not spark ignition 

engines as defined at 40 C.P.R.§ 60.4248. [40 C.F.R. § 60.4230) 

3. The emergency generators are not subject to 40 C.F.R. Prut 64, Compliance 

Assurance Monitoring, because tbe emergency generators 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 Practice and Operational Requirements (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 nonemergency situations for 50 hours per year, as described in condition 2.8(C)(2), 

below, is prohibited. lf the Pennittee does not operate the engine according to 

the requirements in condition 2.8(C)(2), below, the engine will not be considered 

VES009203 
Veolia ES Tcclwical Solutions, W...C. 

Pennit No.: V .JL. J716300103·2014· 10 

Issuance Date: DRAFT 

Expiration Date: DRAfT 

Page 127 of 172 

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) There 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 non-emergency situations as 

allowed by condition 2.8(C)(2)(c), below, counts as part of the 100 hours 

per calendar year. 

(i) The Permittee 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 authority and transmission operator, or the 

insurance c.ompany associated with the engine. The Permittee may 

petition the Administrator for approval of additional 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 the 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 determined by the Reliability Coordinator, has 

declared an Energy Emergency Alert Level 2 as defined in the 

NERC Reliability Standard 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 up to 50 hours 

per calendar year in non-emergency situations. The 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 demand response 

provided in condition 2.8(C)(2)(b ), above. The 50 hours per year for nonVES009204 
Veolia ES Technical Solutions, LL.C. 

Permit No.: V-!L-17 16300103-2014-1 0 

lssuanoe Dale: DRAFI' 

Expiration Date: DRAFT 

Page 128 of 172 

emergency situations cannot be used for peak shaving or non-emergency 

demand response, or to generate income for a facility to supply power to an 

electric grid or otherwise supply power as part of a financial arrangement 

with another entity. (40 C.F.R. § 63.6640(0(3)] 

3. The Permittee shall perform the following work practices for each emergency 

generator except during periods of startup. The 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 option to utilize an oil analysis program 

as described in condition 2.8(C)(6), below. 

(b) Inspect air cleaner every 1,000 hours of operation or annually, whichever 

comes first, and replace as necessary. 

(c) Inspect all hoses and belts every 500 hours of operation or annually, 

whichever comes first, and replace as necessary. 

[Table 2c, Item 1, to 40 C.P.R. Part 63, Subpart ZZZZ] 

4. During periods of startup, the Perminee minimize the engine's time spent at idle 

and min.imize the engine's startup time at startup to a period needed for 

appropriate and safe loading of the engine, not to exceed 30 minutes, atrer which 

time the non-startup emission limitations apply. The Pemtittee can petition the 

Administrator pursuant to 40 C.F.R § 63.6(g) for alternative work practices. 

[Table 2c, Item I, to 40 C.F.R. Part 63, Subpart ZZZZ] 

5. If an emergency engine is operating during an emergency and it is not possible to 

shut down the engine in order to perform the work practice requirements on the 

schedule required io condition 2.8(C)(3), above, or if performing the work 

practice on the required schedule would otherwise pose an unacceptable risk 

under federal, state, or local law, the work practice can be delayed until the 

emergency is over or the unacceptable risk under federal, state, or local law has 

abated. The work practice should be performed as soon as practicable after the 

emergency has ended or the unacceptable risk under federal, state, or local law 

has abated. [Table 2c to 40 C.F.R. Part 63, Subpart ZZZZ, footnote I] 

6. The Permittee has the option of utilizing an oil analysis program in order to 

extend the specified oil change requirement in condition 2.8(C)(3), above. The 

oil analysis must be perfonued at the same frequency specified for changing the 

oil in condition 2.ll(C)(3), above. The analysis program must at a minimum 

analyze the following three parameters: Total Base Number, viscosity, and 

percent water content. The condemning limits for these parameters are as 

follows: Total Base Nwuber is less than 30 percent of the Total Base Number of 

VES009205 
Voolia ES Technical Solutions, LL.C. 

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

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 129 of 172 

the oil when new; viscosity of lhe oil has changed by more than 20 percent from 

the viscosity of the oil when new; or percent water content (by volwne) is greater 

than 0.5. If all of these condemning limits are not ex.ceeded,lhe Permittee is not 

required to change the oil. If any of lhe limits are exceeded, the Permittee must 

change the oil within 2 business days of receiving the results of the analysis; if 

lhe engine is not in operation when the results of the analysis are received, the 

Permittee must change lhe oil within 2 business days or before 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 Pennittee shall operate and maintain each emergency generator and aftertreatment control device (if any) according to tbe manufacturer's emissionrelated operation and maintenance instructions; 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 

pollution control practice for minimizing 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, 

operating limitations, and other requirements in 40 C.P.R. Part 63, 

Subpart ZZZZ, at aU times. [40 C.F.R. § 63.6605(a)] 

9. At all times the Permittee must operate and maintain each emergency generator, 

including associated air pollution control equipment and monitoring equipment 

(if any), in a manner consistent 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 include, but is not limited 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 January I, 2015, the Permittee must use diesel fuel that meets tbe 

following requirements of 40 C.F.R. § 80.510(b) for nonroad diesel fuel, except 

tbat any existing diesel fuel purchased (or otherwise obtained) prior to January 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 minimum cetane index of 40; or 

VES009206 
Veolia ES Technical Solutions, U .C. 

Pennit No.: V ·lL-1716300103·2014·1 0 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

(ii) A maximum aromatic content of 35 volume percent. 

[40 C.P.R.§ 63.6604(b)] 

Page 130 ofl72 

II. The Permittee 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 times otber tban startup apply. (40 C.F.R. 

§ 63.6625(h)] 

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)J 

I. The Permittee must install a non-resettable hour meter on each emergency 

generator if one is not already installed. (40 C.F .R. § 63.6625(£)] 

2. Except for monitor malfunctions, associated repairs, required performance 

evaluations, and required quality assurance or control activities, the Pennittee 

must operate any required monitors continuously at all times that the emergency 

generator is operating. A monitoring malfunction is any sudden, infrequent, not 

reasonably preventable failure of the monitoring to provide valid data. 

Monitoring failures that are caused in part by poor maintenance or careless 

operation are not malfunctions. [40 C.F.R. § 63.6635{b)] 

3. The Permittee may not use data recorded during monitoring malfunctions, 

associated repairs, and required quality assurance or control activities in data 

averages and calculations used to report emission or operating levels. The 

Penuittee must, however, use all the valid data collected during all other periods. 

[40 C.P.R.§ 63.6635(c)] 

(E) Recordkeeping and Reporting [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 where the engine is located. 

{b) Date of the report and bet:tinning and en<ling dates of the reporting period. 

(c) Engine site rating and model year. 

(d) Latitude and longitude of the engine in decimal degrees reported to the fifth 

decimal place. 

VES009207 
Veolia ES Technic"! Solutions, L.L.C. 

Pennit No.: Y -IL-1716300 I 03-201 4-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 131 of 172 

(e) Hours operated for the 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) Number ofholU's the engine is contractually obligated to be available for 

the pwposes specified in conditions 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 dispatched the engine and the 

situation that necessitated the dispatch 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 

deviations from the fuel requirements during the reporting period. 

(i) Tfthere were deviations from the fitel requirements in 40 C.F.R. § 63.6604 

that apply to the engine (if any), information on the number, duration, and 

cause of deviations, and the corrective action taken. 

(40 C.F.R. § 63.6650(h)(l); Table 7, Item 4, to 40 C.P.R. Part 63, Subpart ZZZZ] 

2. The first annual report, for purposes of condition 2.8(E)(J), above, must cover 

the calendar year 2015 and must be submitted no later than March 31, 2016, to 

the Administrator at the address in condition 4.8(A). Subsequent 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 Permittee must report each instance in which the Permittee did not meet 

each operating limitation in condition 2.8(C), above, and the applicable 

requirements in Table 8 of 40 C.F .R. Part 63, Subpart ZZZZ. These instances 

are deviations from the emission and operating limitations in 40 C.P.R. Part 63, 

Subpart ZZZZ. The Permittee must report such deviations according to 

condition 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 following information: 

(a) A copy of each notification and report dtat the Permittee submitted to EPA 

to comply with 40 C.P.R. Part 63, Subpart ZZZZ, including all 

documentation supporting any Initial Notification or Notification of 

Compliance Status that the Permittee submitted, according to the 

requirement in 40 C.P.R. § 63.10(b)(2)(xiv). [40 C.P.R.§ 63.6655(a)(l)] 

VES009208 
Veolia 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 Permittee's 

own maintenance plan that provides to the extent practicable for the 

maintenance and operation of the engine in a manner consistent 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 engine 

and after-treatment control device (if any) according to the Permittee's 

maintenance plan. (40 C.F.R. § 63.6655(e)] 

(d) Records of all required maintenance performed on the air pollution control 

and monitoring equipment [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 must document how many hours are spent for 

emergency operation, including what classified the operation as emergency 

and how many hours are spent for non-emergency operation. If the engine 

is used for the purposes specified 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 records of the 

notification of the emergency situation, and the date, start tinte, and end 

time of engine operation for these purposes. [40 C.P.R. § 63.6655(!)] 

(f) Records of the occurrence and duration of each malfunction of operation 

(i.e., process 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 to minimize 

emissions in accordance with 40 C.F.R. § 63.6605(b), including corrective 

actions to restore malfunctioning process and air pollution control and 

monitoring equipment to its normal or usual manner of operation. 

[40 C.F.R. § 63.6655(aX5)] 

5. The Permittee must report according to condition 3.2(B) any failure to perform 

the work practices on the schedule required in condition 2.8(C)(3) as a result of 

the circumstances specified in condition 2.8(C)(5) and tbe federal, state or local 

law under which the risk was deemed unacceptable. [Table 2c to 40 C.F.R. 

Part 63, Subpart ZZZZ, footnote I] 

6. The Permittee must keep each record readily accessible in hard copy or 

electronic form for at least 5 years after the date of each occurrence, 

measurement, maintenance, corrective action, report, or record. [ 40 C.F.R. 

§ 63.6660] 

VES009209 
Vcolia ES Technical Solutions, L.L.C. 

Pennit No.: V·IL· l7 16300103·2014· 10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

2.9 FUGITIVE EMISSIONS 

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(l)) 

Page 133 of l72 

I. Any leaking equipment is subject 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 in) of VOL with vapor pressure of I 7.24 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 in any 15 minute period at standard 

conditions. 

(b) Vapor Blowdowo: (35 lAC 219. 143] 

The Permittee shall not cause or allow the emission of organic material into 

the 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 equipment approved by the !EPA 

according to provisions of351AC 201 and further processed 

consistent with 35 lAC 219. I 08. 

2. National Emissions Standards for Equipment Leaks (40 C.F.R. Part 61, 

Subparts J and V] 

Any affected equipment that is a source of fugitive emissions of benzene or other 

volatile hazardous air pollutants (leaking equipment) is subject to 40 C.F.R. 

Part 61, Subparts V and J. The Permittee shall comply with the standards and 

requirements of 40 C.F.R. Part 61, Subpart V, for pumps, compressors, pressure 

relief devices, sampling coonection systems, open-ended valves or lines, valves, 

connectors, smge control vessels, bottoms 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)] 

VES009210 
Vcolia ES Tccbuical Solufions.l..L.C. 

Permit No.: V-IL·1716300103·2014·10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

(B) Nonapplicable Regulations (40 C.F.R. § 71.6(1)(1)) 

Page 134 of 172 

I. The leaking equipment is not subject to the New Source Performance Standards 

(NSPS) for the Synthetic Organic Chemicals Manufacturing Industry, 40 C.F .R 

Part 60, Subparts VV, m, NNN, and RRR; and the NESHAP for the Synthetic 

Organic Chemicals Manufacturing Industry, 40 C.F.R. Part 63, Subparts F, G, H, 

and I, because it is not associated with the manufacture or production of the 

affected organic chemicals. [40 C.F.R. §§ 60.480; 60.610; 60.660; 60.700; 

63.100; 63.1 10; 63.160] 

2. The leaking equipment is not subject to 40 C.F.R. Part 64, Compliance 

Assurance Monitoring, because the it does not use add-on control devices to 

achieve compliance with an emission limitation or standard. [40 C.F.R. 

§ 64.2(a)] 

(C) Work Practice and Operational Requirements (40 C.F.R. § 71.6(a)(l )( 

The Permittee shall comply with tbe following standards of 40 C.F.R. Part 61, 

Subpart V: 

I. General: [40 C.F .R § 6 1.242-1] 

(a) The Permittee shall demonstrate compliance with the requirements of 

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) Compliance with 40 C.F.R. Part 61, Subpart V, will be determined by 

review of records, review of performance test results, and inspection using 

the methods and procedures specified in 40 C.F.R. § 61.245. 

(c) The Pem1ittee 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 distinguished 

readily from other pieces of equipment. 

2. Pumps: [40 C.P.R.§ 61.242-2) 

(a) The Permittee shall monitor each pump monthly to detect 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) and (g). 

(b) The Permittee shall check each pump by visual inspection each calendar 

week for indications of liquids dripping from the ptunp seal. 

VES009211 
Vcolia ES Tcclwical Solutions, L.L.C. 

Permit No.: v .JL- 1716300103·2014· 10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 135 of 172 

(c) !fan instrument reading of 10,000 ppm or greater is measured, a leak is 

detected. 

(d) If there are indications ofliquids dripping from the pump seal, a leak is 

detected. 

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

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

40 C.F.R. § 61.242- 10. 

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

days after each leak is detected. 

(g) Each pump equipped with a dual mechanical seal system that includes a 

barrier fluid system is exempt from the requirements of conditions 

2.8(C)(2)(a) through (d) of this permit, provided the following 

requirements are met: 

(i) Each dual mechanical seal system is: 

A. Operated with the barrier fluid at a pressure that is at all times 

greater than the pump stuffing box pressure; or 

B. Equipped with a banier fluid degassing reservoir that is routed 

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

system to a control device that complies with the requirements 

of 40 C.F.R. § 61.242-1 1; or 

C. Equipped with a system that purges the banier fluid into a 

process stream with zero volatile hazardous air pollutant 

(VHAP) emissions to atmosphere. 

(ii) The barrier fluid is not in VHAP service and, if the pump is covered 

by standards under 40 C.P.R. Part 60, is not in VOC service. 

(iii) Each banier fluid system is equipped with a sensor that will detect 

failure of the seal system, the banier fluid system, or both. 

(iv) Each pump is checked by visual inspection each calendar week for 

indications ofliquids dripping from the pump seal. 

A. If there are indications of liquid drippi ng from the pump seal at 

the time of the weekly inspection, the Permittee shall monitor 

the pump as specified in 40 C.F.R. § 61 .245 to determine the 

presence ofVOC and VHAP in the banier fluid. 

VES009212 
VeoUa ES Technical Solutions. L.L.C. 

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

Issuance Date: DRAFT 

Page 136 of 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 of this paragraph, the monitor may be 

calibrated with VHAP, or may employ a gas chromatography 

column to limit the response of the monitor to VHAP, at the 

option of the Penninee. 

C. !fan instrument reading of 10,000 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.242-2{d}{3) daily unless it is equipped with an audible alarm. 

(vi) The Pennittee must determine, based on design considerations and 

operating experience, criteria applicable to the presence and 

frequency of drips and to the sensor that indicates failure of the seal 

system, the banier fluid system, or both. 

(vii) If indications of liquids dripping from the pump seal exceed the 

criteria established in condition 2.8(C}(2)(g)(vi) of this pennit, or if, 

based on the criteria established in condition 2.8(C)(2)(g)(vi) of this 

permit, the sensor indicates failure of the seal system, the barrier 

fluid system, or both, a leak is detected. 

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

practicable, but no later than I 5 calendar days after it is detected, 

except as provided in40 C.F.R. § 61.242-10. 

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

calendar days a fter each leak is detected. 

(x) Any pump that is designated, as described in 40 C.F.R. 

§ 6 1.246( e )(2), for no detectable emissions, as indicated by an 

instrument reading of less than 500 ppm above background, is 

exempt !Tom the requirements of paragraphs (a), (c), and (d) if the 

pump: 

A. Has no externally actuated shaft penetrating the pump housing; 

B. Is demonstrated to be operating 'vith no detectable emissions, 

as indicated by an instrument reading of less than 500 ppm 

above background, as measured by the method specified in 

40 C.P.R. § 61.245(c); and 

VES009213 
Veolia ES Tcclwical Solut.ions. Ll..C. 

Pennit No.: V-IL·1116300103·2014··10 

Issuance Date: DRAFT 

Page 137 of 172 

Expiration Dare: DRAFT 

C. Is tested for compliance with paragraph 40 C.F.R. § 6l.242-

2(eX2) initially upon designation, annually, 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 seals to a 

process or fuel gas system or to a control device that complies with 

d1e requirements of 40 C.F.R. § 61.242-1 1, it is exempt from the 

requirements of 40 C.F.R. § 61.242-2(a) through (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 exempt from the 

monitoriug and inspe<."'ion requirements of 40 C.F.R. § 61.242-2(a) 

and (d)(4) through (6) if: 

A. The Pennittee demonstrates that the pump is unsafe to monitor 

because monitoring personnel would be exposed to an 

immediate danger as a consequence of complying with 

40 C.F.R. § 61.242-2(a); and 

B. The Pennittee has a written plan that requires monitoring of the 

pump as frequently as practicable during safe-to-monitor times 

but not more frequently than the periodic monitoring schedule 

otherwise applicable, and repair of the equipment according to 

the procedures in 40 C.F.R § 61.242-2(c) if a leak is detected. 

(xiii) Any pump that is located within the boundary of an unmanned plant 

site is exempt from the weekly visual inspection requirement of 

40 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 that the Pennittee visually 

inspects each pump as often as practicable and at least monthly. 

3. Compressors: (40 C.F.R. § 61.242-3) 

(a) Each compressor shall be equipped with a seal system that includes a 

barrier fluid system and that prevents leakage of process fluid to 

atmosphere, except as provided in 40 C.F.R §§ 61.242-l(c) and 61.242-

3(h) and (i). 

(b) Each compressor seal system required in paragraph 2.8(C)(3Xa), above, 

shall be: 

(i) Operated with the barrier fluid at a pressure that is greater than the 

compressor stuffing box pressure; or 

VES009214 
Veolia ES Technical Solutions, W..C. 

Pemtit No.: V-IL·I716300103· 2014· 10 

Issuance Date: DRAFT 

Page 138 of l72 

Expiration Date: DRAFT 

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

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

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

C.F.R. § 61.242-11; or 

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

stream with zero VHAP emissions to atmosphere. 

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

covered by standards under 40 C.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. § 61.242-3(a)-(c) with a sensor that will detect failure of the seal 

system, barrier fluid system, or both. 

(e) The Permittee shall check each sensor as required in40 C.F.R. § 61.242-

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

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

(I) The Pemtittee shall dete.mine, based on design considerations and 

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

the barrier fluid system, or both. 

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

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

§ 61.242-3, a leak is detected. 

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

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

40 C.P.R. § 61.242-10. 

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

days after each leak is detected. 

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

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

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

system or to a control device that cQmplies with the requirements 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 

reading ofless than 500 ppm above background is exempt from the 

requirements of 40 C.P.R.§ 61.242-3(a)-(h) if the compressor: 

VES00921 5 
Veolia BS Tecbnical Solution~ L.L.C. 

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

Issuance Da<e: DRAFT 

Page 139 of 172 

Expiration Date: DRAFT 

(i) Is demonstrated to be operating with no detectable emissions, as 

indicated by an instrUment reading of Jess than 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 

requested 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 the open end at all 

times except during operations requiring process fluid flow through the 

open-ended valve or line. 

(c) The Petmittee shall operate each open-ended valve 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 valves or Jines in an emergency shutdown system which are 

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

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

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

autocatalytically polymerize or would present an explosion, serious 

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

block and bleed system as specified in40 C.F.R. § 61.242-6(a) through (c) 

are exempt from the requirements of 40 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 by the 

method specified iu40 C.P.R. § 61.245(b) and shall comply with 40 C.F.R. 

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

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

(b) If an instrument reading of I 0,000 ppm or greater is measured, a leak is 

detected. 

VES009216 
Veo~a ES Technical Solutions, L.L.C. 

Pennit No.: Y·IL-1716300103·2014· 10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 140 of 172 

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

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

quarter, until a leak is detected. 

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

leak is not detected for 2 successive months. 

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

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

provided in 4() C.F .R. § 61.242-10. 

(t) The Pemtittee shall make a first attempt at repair no later than five calendar 

days after each leak is detected. 

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

practices where practicable: 

(i) Tightening of bonnet bolts; 

(ii) Replacement of bonnet bolts; 

(iii) Tightening of packing gland nuts; and 

(iv) Injection of lubricant into lubricated packing. 

(h) Any valve dtat is designated. as described in 40 C.F.R § 61.246(eX2), for 

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

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

§ 61.242-7(a) if the valve: 

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

fluid; 

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

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

(iii) Is tested for compliance with 40 C.F.R § 61.242-7(1)(2) initially 

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

Administrator. 

(i) Any valve that is designated, as described in 40 C.F.R. § 6 1.246(f)( I), as an 

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

§ 61.242· 7(a) if: 

VES009217 
Veolia ES Tc<lmical Solutious, J...L.C. 

Pennit No.: V-JL-1716300103·2014·10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 141 of 172 

(i) The Pennittee demonstrates that the valve is unsafe to 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 plan that requires monitoring of the 

valve as frequent as practicable during saf(}-to-monitor times. 

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

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

of 40 C.F.R. § 61 .242-7 if: 

(i) The Pennittee demonstrates that the valve catmot be monitored 

without elevating the monitoring personnel more than 2 meters 

above a support surface; 

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

process unit; and 

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

valve at least once per calendar year. 

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

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

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

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

percent. 

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

with an allowable percentage of valves leaking: 

(i) The Permittee must notif:Y the Administrator that it has elected to 

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

percentage of valves leaking before implementing this alternative 

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

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

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

requested by the Administrator. 

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

with 40 C.P.R.§ 61.242-7(d) and (e). 

(c) The Permittee shall conduct perfonnance tests in the following manner: 

VES009218 
Veolia ES Techoical Solutions. L.L.C. 

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

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 142 of 172 

(i) The Permittee 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 greater is measured, a leak 

is detected. 

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

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

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

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

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

percent. 

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

Permittee must notify the Administrator in writing that it \viii follow the 

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

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

(a) Tite Permittee may elect tor all valves within a process unit to comply with 

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

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

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

the alternative work practices, as specified in 40 C.P.R. § 61 .247(d). 

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

described in 40 C.F .R. § 61.242-7. 

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

of valves leaking equal to or Jess than 2.0, tbe Permittee may begin to skip 

one of the quarterly Je.ak detection periods tor the valves in VHAP service. 

(e) After five consecutive quarterly leak detection periods \\~th the percentage 

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

th.ree of the quarterly leak detection periods for the valves in VHAP 

service. 

(f) lf the percentage of valves leaking is greater than 2 .0, the Permittee shall 

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

may again elect to use 40 C.P.R. § 61.243-2. 

VES009219 
Vc:olia EST ecbnical Solut.ions, L.L.C. 

Pennit No.: V-IL· 1716300103·2014·10 

Issuance Date: DRAFT 

Page 143 of 172 

Expiration Date: DRAFT 

(D) Monitoring and Testing (40 C.F.R. § 71.6(a)(3)(1)(A)) 

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

requirements of 40 C.P.R.§ 61.245: 

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

61.244, and 61.135, as follows: 

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

Part 60, Appendix A. 

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

Method 21. 

(iii) TI1e instrument shall be calibrated before use on each day of its use 

by the procedures specified in Method 21. 

(iv) Calibration gases shall be: 

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

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

approximately, but Jess than, I 0,000 ppm methane or n·bexane. 

(v) The instrument probe shall be tmversed armmd all potential leak 

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

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

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

detectable emissions, the Permittee shall comply with the following 

requirements: 

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

§ 61.245(b)(l) through (4). 

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

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

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

interfaces as close to tl1e interface as possible as described in Method 

21 of40 C.F.R. Part 60, Appendix A. 

(iv) The arithmetic difference between the maximum concentration 

indicated by the instrument and the background level is compared 

with 500 ppm for determining compliance. 

VES009220 
Veolia ES Tedmical Solutions, L.L.C. 

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

Issuance Dare: DRAFT 

Expiration Dote: DRAFT 

Page 144 of 172 

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

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

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

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

determined that the percent VHAP content can be reasonably expected 

never to exceed I 0 percent by weight For purposes of determining the 

percent VHAP content of the process fluid that is contained in or contacts 

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

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

in 40 C.P.R.§ 61.18). 

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

40 C.P.R. § 6!.245(d)(l) to demonstrate that the percent VHAP content 

does not exceed I 0 percent by weight, provided that the engineering 

judgment demonstrates that the VHAP content clearly does not exceed 10 

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

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

Permittee shall use the procedures in 40 C.P.R. § 61.245(d)(l). 

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

the determination can be revised only after following the procedures in 

paragraph 40 C.P.R. § 61.245( d)(l ). 

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

representative of the process fluid that is contained 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 

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

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

by each process unit. 

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

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

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

identification, marked with the equipment identification number, to 

the leaking equipment. 

(ii) The Pem1ittee may remove the identification on a valve after it has 

monitored the valve for 2 successive months as specified in 40 

VES00922l 
Veolia ES Technical Solurions, L.L.C. 

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

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 145of 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 equipment, 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. 

§§ 61.242-2, 61.242-3, 61.242-7, 61.242-8, and 61.135, the Pennittee shall 

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

2 years in a readily accessible location: 

(i) The instrument and operator identification numbers and the 

equipment identification number; 

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

the leak; 

(iii) Repair methods applied in eac.h attempt to repair the leak; 

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

the methods specified in 4() C.P.R.§ 61.245(a) after each repair 

attempt is equal to or greater than I 0,000 ppm; 

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

"~thin 15 calendar days after discovery of the leak; 

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

repair could not be affected 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 unit shutdowns that occur while the equipment is 

unrepaired; and 

(ix) The date of successful repair of the leak. 

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

the following infom1ation pertaining to all equipment to which a standard 

applies: 

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

fittings) subject to the requirements of 40 C.F.R. Part 61, Subpart V; 

VES009222 
Veolia ES Technical Solutions, LL.C. 

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

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 146 of 172 

(ii) A Jist of identification numbers for equipment that the Permittee 

elects to designate for no detectable emissions as indicated by an 

instrument reading of less than 500 ppm above background; 

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

be signed by a responsible official; 

(iv) The dates of each 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 level measured during each compliance test; and 

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

each compliance test. 

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

the following information pertaining to all valves subject to the 

requirements of40 C.F.R. § 6!.242-7(g) and (h) and to all pumps subject to 

the requirements of40 C.F.R. § 61.242-2(g): 

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

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

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

plan for monitoring each valve or pump; and 

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

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

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

each valve. 

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

following information: 

(i) Design criterion required in40 C.F.R. §§ 61.242-2(d)(5) and 61.242-

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

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

(g) Hours of operation of each component. 

(h) Emissions ofVOC. 

(E) Recordkeeplng and Reporting [40 C.F.It § 71.6(a)(3)) 

VES009223 
Veolia ES Teclulical Solutions, L.L.C. 

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

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 147 of 172 

I. The Permittee shall promptly notify the permitting authority of deviations of the 

affected leaking equipment from the permit requirements. Reports shall describe 

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

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

2. Requirements of40 C.F.R. § 61.247: 

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

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

§§ 61.242, 61.245, 61.246, and 61.247. 

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

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

statement to the Administrator along with the information required under 

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

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

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

the Administrator. 

(c) The Pennittee must include the following infonnation for each source in 

the statement: 

(i) Equipment identification number and process unit identification; 

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

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

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

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

leak detection and repair" or "equipped with dual mechanical 

seals"). 

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

starting 6 months after the initial report required in 40 C.F.R. § 6 1.247(a), 

that includes the following information: 

(i) Process unit identification; 

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

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

in 40 C.P.R.§§ 61.242-7(b) or 61.243-2; 

VES009224 
Veolia ES Tcchoical Solutions, I..L.C. 

Pennit No.: V-JL-1716300103-2014-10 

Issuance Date: DRAFT 

Jlxpiration Date: DRAFT 

Page 148 of l72 

B. Number of valves for which 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 of pumps 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 of compressors for which leaks were not repaired as 

required in 40 C.F.R. § 61.242-3(g); and 

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

appropriate, why a process unit shutdown was technically 

infeasible. 

2.10 INSIGNIFICANT EMISSION UNITS AND ACTIVITIES 

(A) List of Insignificant Emission Units and Activities (40 C.F.R. § 7l.S(c)(ll)) 

The following are insignificant 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 tanks; 

4. Ash handling; 

5. Handling of spent dry scrubber solids; 

6. Lime unloading and proportioning; 

7. Gasoline storage and dispensing; 

8. Use of absort>ent material; 

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

handling); 

10. Laboratory (chemical and physical analysis); 

11. Piping and storage system for natural gas; 

12. Non-halogenated cold cleaning de~:,'re-<~sers; 

13. Internal combustion engines of motor vehicles; and 

14. Storage and handling of closed drums. 

VES009225 
Veolia ES Technical Solutions. L.L.C. 

PennitNo.: V-IJ.A716300103·2014·10 

Issuance Date: DRAFT 

Expiration Dote: DRAFT 

(B) Applicable Requirements (40 C.F.R. § 71.6(a)(l)( 

Page 149 of 172 

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

with the applicable particulate matter emission limit of351AC 212.321 or 

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

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

emission unit's process weight rate is I 00 pounds per hour or less, pursuant 10 35 

lAC 266.110. (35 lAC 212.321 or 212.322 and 35 lAC Part 266] 

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

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

limit of35 lAC 215.301, which requires that organic material emissions no! 

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

photochemically reactive material as defined in 35 lAC 211.4690. (35 lAC 

215.301) 

3. For each open burning activity, the Permittee shaU comply with 35 lAC Part 237, 

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

35 lAC 237.201, if necessary. (35 lAC Part 237] 

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

I. The Pemtittee shall keep cun-ent a fi le for the affected insignificant emission 

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

maintenance and repair log, and other information necessary to demonstrate 

compliance with the applicable requirements and classification of the units as 

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

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

conducted on the affected emission units. [40 C.F.R. § 71 .6(a)(3)(i)(B)] 

VES009226 
Veolia ES Technical Solutions, L.t..C. 

Pennit No.: V-IL-17 16300103-2014-10 

Issuance Date: DRAFT 

Page ISO of 172 

Expiration Date: DRAFT 

3.0 FACILITY-WIDE PERMIT REQUIREMENTS 

3.1. GENERAL PART 71 RECORD KEEPING 

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

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

following: 

I. The date, place, 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 such analyses; and 

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

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

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

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

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

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

recordinb>S for continuous monitoring instrumentation, and copies of all reports 

required by this pe1mit. 

(C) Emissions Calculation Methodology [40 C.F.R. § 71.6(a)(3)(1)(B)) 

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

specific methodology for calculating emissions, the Permittee must follow the 

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

methodology for calculating emissions: 

(a) CEM data from the stationary source; 

(b) Performance test data from the stationary source; 

(c) Manufacturer's emissions perfonnance b'llarantee; 

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

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

(f) Industry-derived emission factors; 

VES009227 
Voolia ES Technical Snlut.ions, L.L.C. 

Pcnnit No.: V-IL-1116300103·2014·10 

Issuance Date: DRAFT 

Expiration Dale: DRAFT 

(g) Emission factors published in the latest version of EPA's Compilation of 

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

factors being considered before the lower rated emission factors; 

(b) Engineeringjudgment. 

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

3.l(C)(I), above, before selecting the emissions calculation methodology 

including a demonstration of the selected emission factors' appropriateness for 

the specific emission units from which emissions are being calculated. 

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

condition 3.J(C)(J), above, does not preclude any person, such as EPA, the 

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

establish compliance or noncompliance 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 semi-annual reports of all required 

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

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

postmarked by the 30th day following the end of the reporting period. AU 

instances of deviations from permit requirements must be clearly identified in 

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

consistent with condition4.8(A){I) of this permit. [40 C.F.R. 

§ 71.6(a)(3)(iii)(A)] 

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

following: 

(a) The company name and address; 

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

(c) The emissions unit or activity being monitored; 

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

and limitations (such as parameter ranges), specified in t11e pem1it for 

which compliance is being monitored; 

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

by referenced test method, monitoring, or through any other credible 

VES009228 
Veolia ES Tecltoical Solutions, L.L.C. 

Pennit No.: Y·IL· l716300t03·2014·10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 152 of 172 

evidence, including those attributable to upset conditions as defined in this 

permit, and the date on which each deviation occurred; 

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

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

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

deviations; 

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

the applicable requirement; and 

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

to the 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) Deviations 

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

penn it tenn or condition. A deviation is not always 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 

limited to, any of the following: (40 C.P.R. § 71.6(a)(3)(iii)(C)] 

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

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

indicate that an emission limitation or standard 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. TI1e Permittee shall promptly report to the EPA deviations from permit 

requirements, including those attributed to malfunction, emergency or other 

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

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

(40 C.F.R. § 71.6(a)(3)(iii)(B)] 

VES009229 
Ve<:>Ua ES Technical Solutions, L.L.C. 

Permit No.: V-J.L-1716300103-2014-10 

lssuruwe 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 

permit); or 

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

provide a time frame for reporting deviations, reports of deviations will be 

submitted based on the following schedule: 

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

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

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

within 24 hours of the occurrence. 

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

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

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

within 48 hours. 

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

submitted with the semi-annual monitoring report required in 

condition 3.2(A)(l} of this permit 

3. lfany of the requirements in condition 3.2(B)(l)(a) through (c), above, are met, 

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

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

submitted within I 0 working days of the occurrence. All deviations reported 

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

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

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

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

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

(B) Safe sampling platform(s); 

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

(D) Utilities for sampling and testing equipment. 

VES009230 
Veolia ES Technical SoluliOI!S_ L.l.C. 

Penni! No.: V-!L-1716300103-2014-10 

Issuance Dale: DRAFT 

Expiration Da1e: DRAFT 

3.4. FACILITY-WIDE APPLICABLE REQUffiEMENTS 

(A) Fugitive Particulate Matter Restrictions [35 lAC 212.301) 

Page !54 ofl72 

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

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

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

line of the emission source. 

(B) Open Burning Prohibitions [35 1AC 2 37.102) 

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

35 lAC 237. 

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

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

purpose of disposing of the class of refuse being burned. 

(C) Visible Emissions [35 1AC 212.123(a)] 

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

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

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

212.122, except as allowed by 351AC 212. 123(b) and 35 lAC 212. 124. 

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

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

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

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

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

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

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

appliances must comply with the standards for recycling and recovery equipment 

pursuant to 40 C.F.R. § 82.158. 

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

be certified by an approved technician certification program pursuant to 40 

C.F.R. § 82.161. 

VES009231 
Veolia ES Technical Solutions, L.L.C. 

Permit No.: V-l!J.l716300103-2014-IO 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 155 of 172 

(E) Risk Management Plan (RMP) [40 C.F.R. § 68.21S(a)(2)(1) and (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 submit the items below: 

I. A compliance schedule for meeting the requirements of 40 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, including the registration and submission of the RMP, as part 

of the annual compliance certification. 

(F) Episode Action Plans [35 lAC 244, Subpart CJ 

The Permittee shall maintain at the source and have on ftle with the !EPA a written 

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

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

shall contain the information specified in 35 IAC244. 144 and is incorporated by 

reference into this permit. 

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

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

by the following procedure: 

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 I 0 percent water, on a 

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

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

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

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

procedures specified in 40 C.F.R.. § 6l.355(b). 

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

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

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

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

annual average benzene concentration. 

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

together the annual benzene quantity for each waste stream generated 

VES009232 
Veolia ES Technical Solutions, LL.C. 

Pennit No.: V-JL-1716300103-2014·10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 156 of 172 

during 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 

10 megagramper year (11 ton/yr), then thePemUttee shall comply with the 

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

(H) General Prohibition on Air Pollution (35 lAC 201.141) 

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

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

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

Illinois, or so as to violate the provisions of35 lAC, Subtitle B, Chapter I, or so as to 

prevent the attainment or maintenance of any applicable ambient air quality 

standard. [35 lAC 201.141] 

(I) Faclllty-wlde Testing [40 C.F.R. § 71.6(aX3)(i)] 

I. Testing Required by 35 lAC 201.282. 

Every emission source and all air pollution c<~ntrol equipment shall be subject to 

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

quantities of specified air contaminant emissions and for the purpose of 

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

(a) Testing by the Permittee. The !EPA may require the Permittee to conduct 

tests in accordance with procedures adopted by the IEP A, 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 testing. Such procedures and formats, 

and revisions 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 be 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 of such tests. 

(b) Testing 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 IEP A. the Permittee 

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

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

excluding instruments and sensing devices, as may be necessary. 

VES009233 
Veolin ES Technical Solutions, L.L.C. 

Pennit No.: V-JL..1716300103-2014-IO 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 157 of 172 

2. Determination of annual 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 using the methods and 

procedures established iu 40 C.F.R. § 61.355 along with the following: 

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

Pennittee shall detenniue the flow-weighted annual average benzene 

concentration in a manner that meets the requirements given in 40 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 detennination 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) Knowledge of the waste. The Permittee shall provide sufficient 

information to document the flow-weighted annual average benzene 

concentration of each waste stream. Examples of information that 

could constilllte knowledge include material balances, records of 

chemicals purchases, or previous test results provided the results are 

still relevant to tl1e current waste stream conditions. If test data are 

used, then the Permittee shall provide documentation describing the 

testiug protocol and the means by which sampling variability and 

analytical variability were accounted for iu the determination of the 

flow-weighted aruma( average benzene concentration for the waste 

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

determinations of the flow-weighted annual average benzene 

concentration based on knowledge of the waste, the procedures 

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

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

accordance with the following procedures: 

A. Collect a minimum of three representative samples from each 

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

enclosed pipe prior to the waste being exposed to the 

atmosphere. 

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

used: 

VES009234 
Veo~a ES Technical Solutions, L l.C. Page ISS of 172 

Pem1it No.: V-JL-17 16300103·2014·10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

I. Samples shall be collected prior to the waste being 

exposed to the atmosphere in order to minimize the loss 

of benzene prior to sampling. 

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

a by-pass line unless the Penniltee demonstrates that 

installation of a static mixer in the line is not necessary 

to accurately determine the benzene concentration of the 

waste stream. 

ill. The sampling tap shall be located within two pipe 

diameters of the static mixer outlet. 

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

cooling coil shall be purged with at least four volumes of 

waste. 

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

sample container and the tip of the sampling tube shall 

be kept below the surface of the waste during sampling 

to minimize contact with the atmosphere. 

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

cooling coil is able to maintain a waste temperature less 

than 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 sample containers shall immediately be cooled and 

maintained at a temperature below I 0°C (50°F) for 

transfer to the laboratory. 

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

minimum oftl1ree representative samples shall be collected in a 

manner to minimize exposure of the sample to the atmosphere 

and loss of benzene prior to sampling. 

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

following test methods for detennining the benzene 

concentration in a waste stream: 

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

Methods for Evaluating Solid Wa~'te, Physical/Chemical 

VES009235 
Veolia ES Technical Solutions, L.l..C. 

Pennit No.: V-IL-1716300103-2014· 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 Method 8021, Volatile Organic Compounds in Water by 

Purge and Trap Capillary Column Gas Chromatography 

with Photoionization and Electrolytic Conductivity 

Detectors in Series, in "Test Methods for Evaluating 

Solid Waste, Physical/Chemical Med1ods," EPA 

Publication No. SW-846 (incorporation by reference as 

specified in 40 C.P.R. § 61.18); 

111. Method 8240, Gas Chromatography/Mass Spectrometry 

for Volatile Organics, in "Test Methods for Evaluating 

Solid Waste, Physical/Chemical Methods," EPA 

Publication No. SW-846 (incorporation by reference as 

specified in 40 C.P.R. § 61.18); 

IV. Method 8260, Gas Chromatography/Mass Spectrometry 

for Volatile Organics: Capillary Column Technique, in 

"Test Methods for Evaluating Solid Waste, 

PhysicaVChemical Methods," EPA Publication No. SW846 (incorporated by reference as specified in 40 C.F.R. 

§ 6l.J8); 

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

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

Analysis of Organic Pollutants, for wastewaters for 

which this is an approved EPA methods; or 

Vl. Method 624, Purgeables, as described in 40 C.P.R. Part 

136, Appendix A, Test Procedures for Analysis of 

Organic Pollutants, for wastewaters for which this is an 

approved EPA method. 

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

benzene concentration by averaging the results of the sample 

analyses as follows: 

Where: 

VES009236 
Veolia ES Techuical Solutions, l.L.C. 

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

Issuance O.tc: DRAFT 

E.'piration Date: DRAFT 

Page I60ofl72 

C = Flow-weighted annual average benzene concentration 

for waste stream, ppmw. 

Q, = Total annual waste quantity for waste stream, kglyr 

(lb/yr). 

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

Q; = Atmual waste quantity for waste stream represented 

by Ci, kglyr (lb/yr). 

C; = Measured concentration of benzene in waste sample i, 

ppmw. 

(J) Facility-wide Recordkeeping [40 .C.F.R § 71.6(a)(3)(i)(B)J 

I. If 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 61, Subpart FF: (40 

C.F.R. § 61.357] 

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

10 Mgiyr (I I tonlyr), then the Permittee shall submit to the Administrator the 

following reports: 

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

updates the information listed 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 to 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 waste determined in 

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

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

stream will be controlled for benzene emissions in accordance with 

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

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

emissions in accordance with the requirements of 40 C.P.R. Part 61, 

VES009237 
Veotin ES Technical Snlutions, LL.C. 

Pcnnit No.: V-IL· 171 6300103·2014·l0 

Issuance Date: DRAFT 

Page 161 of 172 

Expirlltion Date: DRAFT 

Subpart FF, the Permittee shall add the foUowing information to the 

table: 

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

than I 0 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 concentrations for the waste stream; 

E. Annual average flow-weighted benzene concentration for the 

waste stream; and 

F. Annual benzene quantity for the waste stream. 

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

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

40 C.F .R. § 61.357(d)(l), the Pemtittee shall submit quarterly to the 

Administrator a certification that all of the required inspections have been 

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

Subpart FF. 

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

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

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

the Administrator that includes: 

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

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

period of operation during which the concentration of benzene in the 

monitored waste stream exiting the wtit is equal to or greater than I 0 

parts per million by weight. 

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

monitored in accordance with 40 C.F.R. § 6 1.354(a)(2), then each 3-

hour period of operdtion during which the averdge value of the 

monitored parameter is outside the range of acceptable values or 

during which the unit is not operating as designed. 

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

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

period of operation during which the flow-weighted annual average 

VES009238 
Veolia ES Technical Solutions, L.L.C. 

Penni! No.: V-1L- 1716300103-201 4-10 

Issuance Da<e: DRAFT 

Pa&e 162 of172 

Expiration Date: DRAFT 

concentration of benzene in tbe monitored waste stream entering the 

unit is equal to or greater than I 0 ppmw and/or the total annual 

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

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

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

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

applicable to tbe control device. 

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

C.F.R. § 61.354(g), the Pennittee shall submit a report quarterly to 

the Administrator that identifies any period in 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 

smnmatizes all inspections required by 40 C.F.R. §§ 61.342 through 61.354 

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

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

including information about the repairs or corrective action taken. 

VES009239 
Veolia ES Technical Solutions, I.. I... C. 

Permit No.: V-!L-1716300103-2014-10 

Issuance Date: DRAFT 

Expiration Dille: DRAFT 

4.0 GENERAL PART 71 REQUIREMENTS 

4.1. DEFINITIONS [40 C.F.R § 71.21 .

Page 163 ofl72 

Tenns and conditions not othenvise defined in this permit have the me31Jing assigned to 

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

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

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

outlined below. (40 C.P.R. § 71.9(a)] 

B. The Permittee shall 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 Permittee shall submit the annual report and pay the 

annual penn it fee each year on or before tl1e anniversary date (3 months from the 

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

The Pe.rmittee shall submit the annual report to: 

Air Permits Section (AR- 18J) 

Air and Radiation Division 

EPA Region S 

77 West Jackson Boulevard 

Chicago, DUnois 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. Emironmental Protection Agency 

FOIA and l\Uscellaneous Payments, 

Cincinnati Finance Center, 

P.O. Box 979078, 

St. Louis, MO 63197-9000 

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

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

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

condition 4.8(B) of thi~ permit. (The Permittee should note that an annual emissions 

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

§ 7 I .9(h), has been incorporated into the fee calculation worksheet form as a 

convenience.) 

VES009240 
Veolia ES TeclUiical Solutions, LL.C. 

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

Issuance Date: DRAFT 

E.xpiration Date: DRAFT 

F. Basis for calculating annual fee: 

Page 164 of 172 

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

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

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

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

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

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

source over the preceding calendar year. Actual emissions shall be 

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

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

or combusted during the preceding calendar year. (40 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 data. 

[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 other federally recognized procedures. 

[40 C.F.R. § 71.9(e)(2)) 

(d) The term "regulated pollutant (for fee calculation)" is defined in 40 C.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 shall exclude the following emissions from the calculation of fees: 

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

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

(40 C.F.R. § 71.9(c)(5){I)] 

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

included in the fee calculation; [40 C.F.R. § 71.9(cX5)(ii)] and 

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

activities [defined in 40 C.P.R.§ 71.5(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){Jl){ii)). [40 C.P.R. 

§ 71.9(c)(5){iii)] 

VES009241 
Vcolia ES Tedmical Solutions, LL.C. 

Pennit No.: V-IL-1716300103·2014·10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 165 of 172 

G. Fee calculation worksheets shall be certified as to truth, accuracy, and completeness 

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

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

responsibility.) 

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

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

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

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

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

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

C.F.R. § 71.6(aX3Xii). [40 C.P.R. § 71.9(1)] 

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

assessment of penalties and interest in accordance with 40 C.P.R.§ 71.9ffi. 

J. When notified by the EPA of underpa)1nent of fees, the Pennittee shall remit full 

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

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

cbaUenge such fee shaU provide a written explanation of the 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 STATEMENT (40 C.F.R. § 71.6(a)(6)) 

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

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

for: [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 application. 

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

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

compliance with the conditions of this permit. [40 C.P.R.§ 71.6(aX6)(ii)] 

4.4. COMJ>LIANCE CERTIFICATIONS [40 C.F.R § 71.6(c)(S)J 

The Permittee shall submit to EPA a certification of compliance with all permit tem1s and 

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

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

period shall begin on tbe effective date of this permit and end on December 31. All 

VES009242 
Veolia ES Teclmical Solutions, LL.C. 

Pennit No.: V-!L-1716300103-2014-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 166 of 172 

reports shall 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 official in accordance with condition 4.8(A) 

of this permit. The certification shall include the following: 

(A) Identification of each penn it tenn or condition that is the basis of the certification; 

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

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

metltods or other means provide continuous or intennittent data. If necessary, the 

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

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

knowingly making a false certification or omitting material infonnation; 

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

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

shows the compliance is continuous. The certitication shall identifY each deviation 

and take it into account in the compliance certification; and 

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

monitoring and compliance certification requirements of the CAA. 

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

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

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

Pennittee shall timely comply with such requirements. 

4.6. DUTY TO PROVIDE AND SUPPLEl\fENT INFORMATION 

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

(A) The Pennittee shall fumish to the EPA, within a reasonable time, any information 

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

modifYing, revoking and reissuing, or terminating litis permit or to detemtine 

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

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

including information claimed to be confidential. lnfomtation claimed to be 

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

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

(B) 11te Permittee, upon becoming aware that any relevant facts were omitted or 

inco1Tect information was submitted in the penuit application, shall promptly submit 

such supplementary fact.s or corrected information. 11te Pemtittee shall also provide 

VES009243 
Veolia ES Technical Solutions, L.L.C. 

Penni! No.: V-IL-17 16300103-2014-10 

Issuance Date: DRAfT 

Expirntion Date: DRAFT 

Page 167 of 172 

additional information as necessary to address any requirements that become 

applicable to the facility after this permit is issued. 

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

All tenns and conditions in this permit, including aoy provisions designated to limit the 

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

CAA. 

4.8. SUBMISSIONS (40 C.F.R. §§ 71.5(d), 71.6 a nd 71.9( 

(A) A responsible offic.ial of the Permittee shall certify as to the truth, accuracy, and 

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

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

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

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

required to be submitted by this penuit to: 

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

Air and Radiation Division 

EPA RegionS 

77 West Jackson Boulevard 

Chiu go, Illinois 60604 

(B) The Permittee shall submit pemtit applications, applications for pennit amendments, 

aod other applicable penn it information, which includes but is not limited to 

installation of control equipment. replacement of an emissions uuit, fee calculation 

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

Air Permits Section 

Air Programs Bra n ch (AR-l8J) 

EPA RegionS 

77 West Jackson Boulevard 

Chiugo, Illinois 60604 

4.9. SEVERABILITY CLAUSE (40 C.F.R. § 71.6(a)(S)) 

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

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

shall remain valid aod in force. 

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

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

The filing of a reque;t by the Permittee for a permit modification, revocation and 

VES009244 
Vcolia ES Technical Solutions, L.L.C. 

Pelltlit No.: V ·ll·17163001 03·2014·10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 168 of 172 

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

noncompliance does not stay any permit condition. 

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

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

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

4.12. MINOR PERI\-UT MODIFICATIONS (40 C.F.R. § 71.7(e)(l)] 

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

modifications that meet the requirements contained in 40 C.P.R. § 71 .7(e)(l ). 

4.13. SIGNIFICANT 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 that meet the requirements contained in 40 C.P.R. § 71. 7( e)(3 ). 

4.14. REOPENING 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 this 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 establishing the emissions standards or other terms or 

conditions of the permit. 

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

compliance with the applicable requirements. 

4.15. PROPERTY RIGHTS (40 C.F.R. § 71.6(a)(6)(iv)) 

This pem1it does not convey any property rights of any sort, or any exclusive privilege. 

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

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

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

authorized by the CAA: 

VES009245 
VeoliA ES Technical SoiUiions, L.L.C. 

Pemit No.: V-JL-1716300103-2014-10 

Issuance Date: DRAFT 

Expiration Dille: DRAFT 

Page 169 of 172 

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

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

conditions of d1e permit; 

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

the conditions of the permit; 

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

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

pennit; and 

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

assuring compliance with the permit or applicable requirements. 

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

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

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

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

To do so, the Permittee shaH demonstrate the affrrmative defense of emergency 

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

that 

I. An emergency occurred and that the Pennittee can identify the cause(s) of the 

emergency; 

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

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

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

requirements in this permit; and 

4. TI1e Pem1ittee submitted notice of the emergency to EPA within 2 working days 

of the time when emission limitations were exceeded due to tl1e emergency. This 

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

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

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

(B) In any enforcement proceeding, the Pem1ittee attempting to establish the occun-ence 

of an emergency has the burden of proof. 

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

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

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

causes the source to exceed a technology-based emission limitation under the permit 

VES009246 
Veolia ES Technical Solutions, L L.C. 

Penni! No.: V-ll-1716300103-201 4-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Poge 170 of 172 

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

emergency shall not include noncompliance to the extent caused by improperly 

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

or operator error. 

4.18. OFF PERMIT CHANGES 140 C.F-R. § 71.6(a){l 2)) 

The Permittee is allowed to make certain changes without 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 with all applicable requirements and may not violate any 

existing pennit tenn or condition; 

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

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

CAA; 

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

except for changes that qualify as insignificant activities w1der 40 C.F.R. 

§ 7I.S(c)(l l ). The written notice must describe each change, dte date of the change, 

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

would apply as a result of the change; 

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

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

any regulated air pollutant subject to any applicable requirement not otherwise 

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

4-19. PERMIT EXPIRATION AND RENEWAL (40 C.F.R. §§ 71.S(a)(J)(iii), 71.6(a)(ll), 

7L7(b), 71-7(c)(l)(i) and (ii), 71.8(d)l 

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

five years fi'om the effective 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 least 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 complete pem1it application 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 

VES009247 
Veolia ES Technical Solutions, L L.C. 

Pennit No.: V-IL-1716300103-2014-1 0 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Page 171 of 172 

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

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

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

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

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

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

until the pennitting authority takes fmal action on the permit renewal application. 

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

determination, the Pemtittee fails to submit any additional information 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 permit issuance, including those for public participation and affected state and 

tribal review. 

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

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

applicable requirements that were promulgated and not incorporated into the permit 

during the penuit tetm, and other infonuation required by the application form. 

4.20. OPERATIONAL FLEXIBILITY [40 C.F.R. § 7t.6(a)(J3)) 

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

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

provided the following conditions are met: 

(A) TI1e changes are not modifications under any provision of Title I of the CAA; 

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

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

(C) TI1e Permittee notities the EPA at least 7 days iu advance of the proposed changes. 

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

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

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

change. 

4.21. PERMIT SHIELD (40 C.F.R. § 71.6(1)) 

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

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

issuance, with any applicable requirements that are specifically identified and 

VES009248 
Veolia ES Tecluucal Solutions, L L.C. 

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

Issuance Date: DRAFT 

Expiration Date: DRAFT 

Pnge 172of 172 

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

applying to the facility. 

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

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

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

in Table I as applicable to 40 C.P.R. Part 63, Subpart EEE). 

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

deemed to be compliance with, Parts C and D of Title 1 oftlte CAA, or any 

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

pemtitting of major modifications to sources of air emissions. 

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

I. The liability of the Pemlittee for any violation of applicable requirements prior to 

or at tlte time of pemtit issuance; 

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

3. The applicable requirements of the acid rain program, consistent widt section 

408(a) of the CAA; or 

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

authority of the Administrator under that section. 

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

Notwithstanding the conditions of this permit specifying compliance practices for 

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

evidence to establish compliance or noncompliance with applicable requirements. 

VES009249 
VES009250. pdf