Illinois EPA Bureau of Air Expands Availability of General Operating Permits

A general permit is a permit that covers a specific category of facilities/ sources that have similar operations and types of emissions. Individual permits are unique to each facility based on the facility's operations, type and amount of emissions, equipment, and other factors. Because individual permits for some categories of sources can contain very similar or, in many cases, identical emission limitations and requirements, their standard contents have been compiled into one pre-approved permit that can be applied to certain categories of sources. This is a general permit.

 In effort to streamline permitting as required under Section 39.10 of the Illinois Environmental Protection Act (Act), the Illinois EPA is providing general permits for two new categories of true minor sources: portable material (non-waste) crushing plants and soil/groundwater remediation systems. In addition, the Illinois EPA is updating and expanding the general permits for stationary concrete batch plants from the existing six to twelve and adding four new general  permits for portable concrete batch plants.

With these additions, available general permits from the Bureau of Air include:

• two remediation system (ASSVE/Air Stripper) permits,

• two portable crushing plant permits,

• four portable concrete batch plant permits, and

• twelve non-portable concrete batch plant permits

 Once a source has a general operating permit they can add or modify emission units without having to obtain a construction permit or revised operating permit up to the number of emission units allowed by the general operating permit they are requesting coverage by. This saves the source time and money since they do not have to prepare a construction and operating permit application, pay the construction permit application fee, and wait for their permit to be issued each time they want to add or modify an emission unit as long as they can comply with the general operating permit limits. This increases efficiency for the Bureau of Air as it reduces the number of permit applications reviewed and issued for true minor sources of pollution so more resources can be allocated to reviewing and permitting larger sources of air emissions.

In order to obtain coverage by the general  permits being provided pursuant to Section 39.10 of the Act, the source must complete and submit a Notice of Intent to be Covered Form and the appropriate construction permit application fee if they are a new source or portable source requesting coverage by a joint general construction and lifetime operating permit. If the source is an existing non-portable source, then just the appropriate Notice of Intent to be Covered Form would need to be completed and submitted in order to obtain coverage by one of the lifetime general operating permits.

Upon review of the Notice of Intent to be Covered Form by the Bureau of Air Permit Section, the appropriate general permit would be issued and a copy sent to the applicant or the applicant would be notified of deficiencies with their Notice of Intent to be Covered Form. If the noted deficiencies are rectified then the appropriate permit would be issued and a copy sent to the applicant.

It is important to note that only true minor sources of emissions are eligible for general permits. Air pollution sources whose potential to emit (PTE) is less than the major source annual emission thresholds are considered minor sources. Potential to Emit (PTE) is defined at Section 39.5 of the Illinois Environmental Protection Act and is used to predict the release of air contaminants from an emission source operating at its maximum rate capacity, 24 hours per day, 365 days a year. A true minor air pollution source is one that, even operating at its maximum capacity and continuously, cannot exceed the major source annual emission threshold levels. A true minor source should not be confused with a synthetic minor source which is an air pollution source that has a Federally Enforceable State Operating Permit (FESOP) with conditions that legally restrict its PTE to below the threshold levels.

A major source is defined as any stationary source (or any group of stationary sources that are located on one or more contiguous or adjacent properties, and are under common control of the same person or persons) belonging to a single major industrial grouping and is described in one of the following:

• potential to emit 100 tons per year ("T/yr") or more of any air pollutant, i.e., particulate matter(PM-10), sulfur dioxide (SO2), nitrogen oxides (N0x), carbon monoxide (CO), or volatile organic material (VOM).

• potential to emit 10 T/yr or more of any one of the 187 Hazardous Air Pollutants (HAPs) listed pursuant to section 112(b) of the Clean Air Act, or

• potential to emit 25 T/yr or more of any combination of HAPS

• potential to emit 100,000 T/yr or more of carbon dioxide equivalents (CO2e) of greenhouse gases(GHG) but only if potential to emit is major for one of the above also}

{Potential to emit is the maximum capacity of a stationary source to emit any air pollutant under its physical and operational design without any reduction by air pollution control devices unless it is specifically required by regulation or federally enforceable permit condition. . Note that this is calculated considering the maximum capacity of the equipment (use 8760 operating hours per year).}

The following general permits' Notice of Intent to be Covered forms can be found at http://www.epa.state.il.us/air/forms/general-permits/index.html

• Truck Mix Concrete Batch Plant (APC 660)

• Central Mix Concrete Batch Plant (APC 661)

• Portable Truck Mix Concrete Batch Plant (APC 662)

• Portable Central Mix Concrete Batch Plant (APC 663)

• Portable Crushing Plant (APC 664)

• Remediation System (APC 665)
   

Prior to the new provisions for general permitting (Section 39.10 of the Act), the Illinois EPA Bureau of Air issued lifetime general operating permits to concrete batch plants, grain elevators and aggregate plants/quarries. Unlike the new general permits being issued pursuant to Section 39.10, the previously approved lifetime general operating permits require the applicant to submit the APC-629 Application for a Permit to Operate and other applicable forms. These pre-Section 39.10 lifetime general operating permits for grain elevators and aggregate plants/quarries will continue to be issued in this manner and remain available; however, pre-Section 39.10 lifetime general operating permits and application procedures for the concrete industry are no longer available and are now replaced with new general permits and the Notice of Intent to be Covered Form discussed above. Both the new general permits and the Lifetime General Operating Permits do not expire as long as site fees are paid annually. Existing sources with permits issued prior to Section 39.10 of the Act will continue to operate under their Lifetime General Operating Permit. However, a source may apply if they would like to be covered by the new general permits.

 If you have questions regarding the general permits please contact Charlie Zeal at 217-785-1715 or Charlie.zeal@illinois.gov.

Illinois EPA Requesting Comments Concerning Distillate and Residual Fuel oil

 The Illinois EPA Bureau of Air is in the process of reducing sulfur dioxide (SO2) emissions in the state to help attain and maintain the 2010 1-hour SO2 National Ambient Air Quality Standard (NAAQS). One of the impacts is to reduce the amount of sulfur used in fuels, especially distillate and residual oil (a.k.a. fuel oils 1, 2, 4, 5, and 6). The Illinois EPA is proposing to limit the use of fuel oils in the state by only allowing the use of fuels that are considered ultra-low sulfur fuels. This means that for fuel oils 1 and 2, distillate fuels, the amount of sulfur allowed in the fuels will be 15 ppm or less, and the amount of sulfur allowed in the residual fuel oils 4, 5, and 6, will be 1000 ppm or less.

The Illinois EPA is requesting comments on the impacts of this rule, and if there is a need for any exclusion, for example, used oils. Please send any comments via email to Ash Gelaidos at: Ash.Gelaidos@illinois.gov or Rory Davis at Rory.Davis@illinois.gov by August 22, 2014.

If you would like to mail in a response, please mail to either of the above at Illinois EPA, Bureau of Air, Air Quality Planning Section, 1021 N. Grand Avenue East, Springfield, IL 62794-9276.

Illinois EPA Bureau of Air is also holding a public informational meeting on August 14th in the Sangamo Room at the Illinois EPA Springfield office.  The primary purpose of the meeting is to share the 1-hour SO2 NAAQS nonattainment area modeling results with stakeholders and others interested in the Agency's SIP development efforts. Modeling input and output files, together with source-specific contribution spreadsheets, will be made available electronically upon request.  Currently sources in the Lemont and Pekin areas are impacted since these areas have been designated as nonattainment for the 2010 1-hour SO2 standard.  For more information concerning the outreach meeting or to request documents, please contact Jeff Sprague at Jeff.Sprague@illinois.gov.

 Portable units

I have a portable unit that is registered in ROSS. How do I let the Illinois Environmental Protection Agency know that I plan to move that unit to a new location?

Facilities that have a registered portable unit can use the APC 208 form to let the IEPA know they are going to move to a new location.

Site fee due dates

I registered in ROSS last year, when should I pay my site fee bill?

Site fee billing dates are specific to each facility. If you had a permit prior to registering with ROSS then there is no change to your site fee billing date. If you are a new source then your site fee will be due on the anniversary of your registration in ROSS.

Questions regarding the ROSS Program? Contact the Illinois Small Business Environmental Assistance Program at 800-252-3998.