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Ed Bakowski, Permit Section Division of Air Pollution Control
Illinois EPA
Critical Air Permitting Critical Air Permitting Developments 2012Developments 2012
1
OverviewOverview
Legislative and Regulatory Changes
Greenhouse Gases (GHGs)
2
P A 097-0095 (House Bill 1297)P A 097-0095 (House Bill 1297)signed by Governor on 7/12/2011signed by Governor on 7/12/2011
1. Permit Streamlining
2. Increased Operating Fees
3. Sales Tax Revenue
4. GHG Provisions
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Permit StreamliningPermit Streamlining Registration of Smaller Sources (ROSS)
Registration rather than permits
Fee same as Small sources
Mandatory
As many as 3850 out of 6400 total permits
4
Permit StreamliningPermit Streamlining
General Permits Authorizes Illinois EPA to issue general permits for
construction, installation, or operation of categories of facilities. Within 6 months of the effective date of bill, Illinois EPA, in consultation with regulated community, will identify types of permits for which general permitting would be appropriate, including but not limited to, permits for nonhazardous solid waste activities, discharge of stormwater from landfills, and discharges of hydrostatic test waters.
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BOA – General PermitsBOA – General Permits
Concrete Batch Plants (stationary & portable) Concrete Batch Plants (stationary & portable)
• • Petroleum Dry CleanersPetroleum Dry Cleaners
• • Material (non-waste) crushers (portable only) Material (non-waste) crushers (portable only)
• • Soil vapor extraction/Air strippers (alone or at true Soil vapor extraction/Air strippers (alone or at true minor sources) minor sources)
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Permit StreamliningPermit Streamlining
Permits by Rule Authorizes IPCB to adopt permits by rule for classes of
facilities. Within 1 year of effective date of bill, Illinois EPA, in consultation with regulated community, will identify types of permits for which permitting by rule would be appropriate, including but not limited to, permits for open burning, certain package boilers and heaters using only natural gas or refinery gas, and certain internal combustion engines.
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Permit StreamliningPermit Streamlining Expedited Permits Permit applicant wishing expedited review can request for a fee equal
to 4 times standard permit fee, not to exceed $100,000. For recurring permit fees (annual fees, operating fees, or discharge fees), fee shall be 4 times the recurring permit fee each time the applicant requests recurring permit be expedited. Where no standard fee is required for a permit, expedited permit fee is negotiated between permit applicant and Agency. All such expedited permit fees would be in addition to required standard permit fees.
Time period required to review the permit is negotiated between the permit applicant and Agency. Should Illinois EPA fail to complete review within time period set forth, Illinois EPA required to refund expedited permit fee on prorated basis as mutually agreed upon by permit applicant and Agency.
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Permit StreamliningPermit Streamlining Web Portal (initial launch by end of 2011)
Checklists and guidance relating to completion of permit applications
By July 1, 2013 Online Application Forms
User friendly forms that can be saved electronically and submitted to Agency electronically
Online Tracking Review status of pending applications, including name
and contact information of permit analyst. Until this system is up and running (within 2 years) Illinois EPA required to post tracking reports on its website that include timeframes for permit issuance and reasons for delays.
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Permit StreamliningPermit Streamlining Notification of Assigned Analyst
Upon request of applicant, Agency shall notify applicant of permit analyst assigned to the application upon its receipt.
Permit Guidance Agency authorized to prepare and distribute guidance
documents relating to its administration of its permitting program and procedural rules implementing permit issuance procedures. Guidance documents prepared shall not be considered rules and shall not be subject to the Illinois Administrative Procedure Act. Such guidance shall not be binding on any party.
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Permit StreamliningPermit Streamlining Draft Permit Submittal
Permit applicants may include with application suggested permit language for Agency consideration. Agency is not obligated to use suggested language or any portion thereof in its permitting decision. If requested by permit applicant, Agency shall meet with applicant to discuss the suggested language.
Draft Permit Review If requested by permit applicant, Agency shall provide a
copy of the draft permit prior to any public review period. If requested by permit applicant, Agency shall provide a
copy of the final permit prior to its issuance.
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Increased Operating FeesIncreased Operating Fees No increase to construction permit fees
BEGINNING JANUARY 1, 2012 Title V
From $18/ton to $21.50/ton Maximum fee from $250,000 to $294,000
FESOP Minimum (< 25 tons/yr) $200 to $235 25 to 100 tons/yr sources: $1,800 to $2,150 Maximum (> 100 tons/yr) from $3,500 to $4,112
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Increased FeesIncreased Fees
Lifetime Minimum (< 25 tons/yr) $200 to $235 25 to 100 tons/yr sources: $1,800 to $2,150 Maximum (> 100 tons/yr) from $3,500 to $4,112
Revenue from all 3 permit categories could bring in additional $1 - $3.2 million per year
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Sales Tax RevenueSales Tax Revenue Revenue from Sorbent Sales Partially Diverted
to Fund Air Permit Program
Beginning July 1, 2011, each month the Department of Revenue shall pay into the Clean Air Act (CAA) Permit Fund 80% of the net revenue realized for the preceding month from the 6.25% general rate on the selling price of sorbents used in Illinois in the process of sorbent injection as used to comply with the Environmental Protection Act or the federal Clean Air Act, but the total payment into the Clean Air Act (CAA) Permit Fund shall not exceed $2,000,000 in any fiscal year.
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Rulemaking RequiredRulemaking Required
Regulations:
1. Part 251 – State Fee Rules
2. Part 201 – Permit by Rule
3. Part 270 – CAAPP – Raise GHG Thresholds
4. 254 – Add GHG Reporting Requirements
5. Part 201.175 - New Rules for Registration of Smaller Sources (ROSS)
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GHGsGHGs
PA 097-0095 – Ties State GHG Permitting to Federal Requirements
Permitting of GHGs is here - Final Tailoring Rule issued May 13, 2010
Tailoring Rule “adjusts” Title V and Prevention of Significant Deterioration (PSD) requirements
16Jim Ross 16
GHGs GHGs Regulated Air Pollutants and Subject to Regulation
consistent with federal GHG tailoring rule (i.e., same thresholds, timing, and definitions).
Establishes a permit exemption for sources of GHG emissions that are not subject to Tailoring Rule.
If federal Tailoring Rule or ability to regulate GHGs is preempted due to federal legislation, judicial, or presidential action then the GHG provisions of Illinois legislation are likewise preempted.
No fee charged for GHG emissions.
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GHG Tailoring RuleGHG Tailoring Rule Step 1 (January 2, 2011 – July 1, 2011)
PSD only for “already subject anyway” sources New sources or existing sources with increase > 75,000 tons/yr CO2e
Title V only for “already subject anyway” Can’t be subject to PSD or Title V solely due to GHGs
Step 2 (July 1, 2011 to June 30, 2013) Continue Step 1 sources plus other large GHG sources Can now be subject to PSD and Title V due only to GHGs
PSD: major = 100,000 tons/yr CO2e, significant increase = 75,000 tons/yr CO2e
Title V: major = 100,000 tons/yr CO2e
Step 3 (2011 to July 1, 2013 and beyond) New Rule to be proposed in 2011. Final rule by July 1, 2012. Effective on
July 1, 2013. Possibly (likely) go to 50,000 tons/yr CO2e for PSD and Title V – can’t go
lower than 50,000 tons/yr CO2e until at least 2016
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Tailoring Rule ImpactTailoring Rule Impact Evaluated at all levels – numbers below for
50,000 tons/yr CO2e
Title V sources: Potential emissions = 196 sources Actual emissions = 90 sources
PSD: New major sources per year = 24 Major modifications = 2
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ROSS ProgramROSS ProgramJackie Sims & Annette FulgenziJackie Sims & Annette Fulgenzi
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www.ienconnect.com/enviro
800/252-3998
ROSS ProgramROSS Program Eligibility Requirements (1) the source must not be (1) the source must not be required to obtain a permitrequired to obtain a permit
pursuant to the Illinois Clean Air Act Permit Program or pursuant to the Illinois Clean Air Act Permit Program or Federally Enforceable State Operating Permit program, Federally Enforceable State Operating Permit program, or under regulations promulgated pursuant to Section 111 or under regulations promulgated pursuant to Section 111 ((i.e., New Source Performance Standards - NSPSi.e., New Source Performance Standards - NSPS) or ) or 112 (112 (e.g., National Emission Standards of Hazardous Air e.g., National Emission Standards of Hazardous Air Pollutants-NESHAP-Part 63Pollutants-NESHAP-Part 63) of the Clean Air Act;) of the Clean Air Act;
(2) the USEPA has not otherwise determined that a (2) the USEPA has not otherwise determined that a permit is required;permit is required;
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ROSS ProgramROSS Program Eligibility Requirements (continued) (3) the source emits less than an actual 5 tons per year of (3) the source emits less than an actual 5 tons per year of
combined particulate matter (PM), carbon monoxide (CO), combined particulate matter (PM), carbon monoxide (CO), nitrogen oxides (NOx), sulfur dioxide (SO2), and volatile nitrogen oxides (NOx), sulfur dioxide (SO2), and volatile organic material (VOM) air pollutant emissions; (organic material (VOM) air pollutant emissions; ( these are these are emissions from permitted units – excludes units that do not emissions from permitted units – excludes units that do not require a permit)require a permit)
Example – Rock QuarryExample – Rock Quarry:: Crushing 0 .2 tons PMCrushing 0 .2 tons PM Screening 0.2 tons PMScreening 0.2 tons PM Gas Generator 1.0 tons NOxGas Generator 1.0 tons NOx Gas Generator Gas Generator 0.2 tons CO0.2 tons CO
Total 1.6 tons < 5.0 tpy = ROSS Total 1.6 tons < 5.0 tpy = ROSS Eligible Eligible
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ROSS ProgramROSS Program
Eligibility Requirements (continued) (4) the source emits less than an actual 0.5 tons per (4) the source emits less than an actual 0.5 tons per
year of combined hazardous air pollutant emissions;year of combined hazardous air pollutant emissions;
(5) the source emits less than an actual 0.05 tons (5) the source emits less than an actual 0.05 tons per year of lead air emissions; per year of lead air emissions;
(6) the source emits less than an actual 0.05 tons per (6) the source emits less than an actual 0.05 tons per year of mercury air emissions, and:year of mercury air emissions, and:
Example – same as before – total for all units; Example – same as before – total for all units; excluding exempt units.excluding exempt units.
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ROSS ProgramROSS Program Eligibility Requirements (continued)
(7) the source does not have an emission unit (7) the source does not have an emission unit subject to a subject to a standard standard pursuant to 40 CFR Part 61 Maximum Achievable pursuant to 40 CFR Part 61 Maximum Achievable Control Technology (MACT), or 40 CFR Part 63 National Control Technology (MACT), or 40 CFR Part 63 National Emissions Standards for Hazardous Air Pollutants Emissions Standards for Hazardous Air Pollutants (NESHAP)other than those regulations that the USEPA has (NESHAP)other than those regulations that the USEPA has categorized as "area source”.categorized as "area source”. (some categories of NESHAP are for both major and (some categories of NESHAP are for both major and
area source, e.g., Reciprocating Internal Combustion area source, e.g., Reciprocating Internal Combustion Engines -RICE)Engines -RICE)
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ROSS ProgramROSS Program
Eligibility Requirements (continued) (8) Emission units at the source are not used as (8) Emission units at the source are not used as
thermal desorption systems pursuant to 35 Ill. Adm. thermal desorption systems pursuant to 35 Ill. Adm. Code 728 Table F or as an incineratorCode 728 Table F or as an incinerator
(9) The source is not subject to local siting review (9) The source is not subject to local siting review under Section 39.2 of the Actunder Section 39.2 of the Act
Mandatory Program Mandatory Program - if you meet the applicability - if you meet the applicability requirements, then you need to registerrequirements, then you need to register
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ROSS Registration DeadlinesROSS Registration Deadlines Sources holding Sources holding a permit a permit must register must register no later than their no later than their
annual fee payment dateannual fee payment date in state fiscal year 2013 (July in state fiscal year 2013 (July 1, 2012 through June 30, 2013). 1, 2012 through June 30, 2013). The registration fee is The registration fee is due by this date also. due by this date also. ((Must be current on fees!)Must be current on fees!)
The owner or operator of an operating source The owner or operator of an operating source notnot
holding a permitholding a permit shall register no later than shall register no later than July 1, 2012 July 1, 2012 and payment of the and payment of the fee is due at the time of registration.fee is due at the time of registration.
The owner or operator of a The owner or operator of a new source new source shall register at shall register at least 10 days before commencing construction or least 10 days before commencing construction or operationoperation and may commence construction or operation and may commence construction or operation 10 days after submittal to the Agency. Fee payment is 10 days after submittal to the Agency. Fee payment is due at the time of registration.due at the time of registration.
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ROSS RenewalsROSS Renewals Verify that facility meets eligibility requirementsVerify that facility meets eligibility requirements
Combine the sum of all actual emissions of PM, CO, Combine the sum of all actual emissions of PM, CO, NOx, SO2, and VOM from all non-exempt units from NOx, SO2, and VOM from all non-exempt units from prior calendar yearprior calendar year
Must be Must be < < 7.0 tons, or 7.0 tons, or Sum of all from prior two calendar years Sum of all from prior two calendar years << 10 tons. 10 tons. note: First year < 5.0 tonsnote: First year < 5.0 tons
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ROSS RenewalsROSS Renewals
Sum all actual emissions of HAPs, mercury and lead Sum all actual emissions of HAPs, mercury and lead from all non exempt units from prior calendar yearfrom all non exempt units from prior calendar year
HAPs must be HAPs must be << 0.50 tons 0.50 tons Mercury must be Mercury must be << 0.05 tons 0.05 tons Lead must be Lead must be << 0.05 tons 0.05 tons
Renewals are verified through the annual site feeRenewals are verified through the annual site fee If ownership, phone number, or address changes, submit If ownership, phone number, or address changes, submit
information to Permit Section within 45 days of change-information to Permit Section within 45 days of change-include ID numberinclude ID number
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ROSS RenewalsROSS Renewals If actual emissions exceeds ROSS eligibility If actual emissions exceeds ROSS eligibility
Notify Permit SectionNotify Permit Section If never had a permit – must apply for permit within If never had a permit – must apply for permit within
90 days of annual fee payment date90 days of annual fee payment date If not constructed or operated during initial If not constructed or operated during initial
registration and exceeds eligibility within first registration and exceeds eligibility within first two years – must also pay avoided construction two years – must also pay avoided construction fees.fees.
If existing source (had permit prior to ROSS) must If existing source (had permit prior to ROSS) must notify Permit Section of change in status from notify Permit Section of change in status from ROSS to Permit by annual site fee date ROSS to Permit by annual site fee date
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ROSS RenewalsROSS Renewals
Actual emissions exceed ROSS (continued)Actual emissions exceed ROSS (continued) If units have changed since last permit – must update If units have changed since last permit – must update
permit within 90 days of annual site fee datepermit within 90 days of annual site fee date Once actual emissions meet ROSS eligibility Once actual emissions meet ROSS eligibility
requirements – go back to ROSSrequirements – go back to ROSS If there is a change in a regulation or a new regulation If there is a change in a regulation or a new regulation
that impacts a ROSS source that causes the source to that impacts a ROSS source that causes the source to no longer be eligible for ROSS, the source must apply no longer be eligible for ROSS, the source must apply for a permit or go back to existing permit for a permit or go back to existing permit
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ROSS RecordkeepingROSS Recordkeeping Maintain records on siteMaintain records on site
Description of emission units and controlsDescription of emission units and controls Description of control efficiency or emission rates Description of control efficiency or emission rates
used to be eligible for ROSSused to be eligible for ROSS Documentation of emission calculations – may use Documentation of emission calculations – may use
material usage or emission ratesmaterial usage or emission rates Copy of initial registrationCopy of initial registration Copy of last most recent five annual fee paymentsCopy of last most recent five annual fee payments Any other records that are required by any State or Any other records that are required by any State or
Federal regulationFederal regulation..
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ROSS ReportingROSS Reporting
ROSS sources that are impacted by a State or Federal ROSS sources that are impacted by a State or Federal regulations that require reporting, e.g., semi-annual regulations that require reporting, e.g., semi-annual reports, notification of compliance status, initial reports, notification of compliance status, initial notifications, etc., notifications, etc., MUST stillMUST still submit the reports to Illinois submit the reports to Illinois EPA or USEPA as required.EPA or USEPA as required. Example:Example: ROSS source with boilers or engines that ROSS source with boilers or engines that
fall under an area source NESHAP (40 CFR 63 fall under an area source NESHAP (40 CFR 63 Subpart JJJJJJ or Subpart ZZZZ, respectively) would Subpart JJJJJJ or Subpart ZZZZ, respectively) would still be required to comply with regulations and still be required to comply with regulations and maintain and submit all reports and tests required. maintain and submit all reports and tests required.
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BOA FAQ’sBOA FAQ’s
Annual Emission ReportsAnnual Emission Reports
If I’m a ROSS eligible source, do I have to submit If I’m a ROSS eligible source, do I have to submit my 2011 AER that is due May 1? my 2011 AER that is due May 1? No, once a source is ROSS eligible and are no No, once a source is ROSS eligible and are no
longer required to have a permit, they do not longer required to have a permit, they do not have to submit the AER for 2011 and in the have to submit the AER for 2011 and in the future.future.
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ROSS FAQ’S ROSS FAQ’S
NSPS & NESHAPNSPS & NESHAP If I’m covered by rules under If I’m covered by rules under regulations promulgated regulations promulgated
pursuant to Section 111 or 112 of the Clean Air Act, does pursuant to Section 111 or 112 of the Clean Air Act, does that mean I am ineligible for ROSS? that mean I am ineligible for ROSS? No, if the NESHAP does not require the source to No, if the NESHAP does not require the source to
have a permit have a permit the source could still be eligible for the source could still be eligible for ROSSROSS Actual emissions must meet eligibility criteriaActual emissions must meet eligibility criteria Example: RICE (Reciprocating Internal Example: RICE (Reciprocating Internal
Combustion Engine) NESHAPCombustion Engine) NESHAP
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ROSS FAQ’s ROSS FAQ’s Initial Eligibility Initial Eligibility
If I have 5.02 or 5.3 tons of actual combined pollutants but If I have 5.02 or 5.3 tons of actual combined pollutants but have been 3.6 tons and 3.0 tons the past few years, is have been 3.6 tons and 3.0 tons the past few years, is their any consideration of our historical emissions? their any consideration of our historical emissions?
1.1. NoNo, for , for initial registration initial registration it is a firm emission criteria of 5 it is a firm emission criteria of 5 tons.tons.
2.2. However for However for renewalrenewal: the total sum of actual emissions of : the total sum of actual emissions of combined air pollutant emissions for the combined air pollutant emissions for the prior calendar prior calendar year must be less than or equal to 7 tonsyear must be less than or equal to 7 tons, and, and the total the total sum of actual emissions from the prior two calendar years sum of actual emissions from the prior two calendar years must be less than or equal to 10 tons.must be less than or equal to 10 tons.
(Summed emissions of HAPs, mercury or lead must be (Summed emissions of HAPs, mercury or lead must be less than or equal to 0.5 tons per year, 0.05 tons per year, less than or equal to 0.5 tons per year, 0.05 tons per year, or 0.05 tons per year, for the prior calendar year, or 0.05 tons per year, for the prior calendar year, respectively.)respectively.)
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ROSS FAQ’sROSS FAQ’sExceeding ROSS Criteria: Now Need PermitExceeding ROSS Criteria: Now Need PermitIf I am a ROSS source and I believe my actual emissions If I am a ROSS source and I believe my actual emissions
will push me out of the program into permits, how long do will push me out of the program into permits, how long do I have to notify the agency? I have to notify the agency? Existing sources who previously were covered by a permit Existing sources who previously were covered by a permit
must notify the agency within must notify the agency within 90 days of their site fee due 90 days of their site fee due datedate that they wish to reinstate their permit and will comply that they wish to reinstate their permit and will comply with its terms and/or modify their permit.with its terms and/or modify their permit.
ROSS sources not previously covered by a permit must ROSS sources not previously covered by a permit must apply for a permit 90 days priorapply for a permit 90 days prior to annual site fee renewal. to annual site fee renewal.
(Note: the renewal criteria allows for emissions up to 7 tons for the prior (Note: the renewal criteria allows for emissions up to 7 tons for the prior year or two year combined total of 10 tons or less)year or two year combined total of 10 tons or less)
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ROSS FAQCircumventionCircumvention
Can I apply for ROSS for our new facility startup since our Can I apply for ROSS for our new facility startup since our first year we expect our actual emissions to be low?first year we expect our actual emissions to be low?
If a If a new source new source was not constructed at the time of was not constructed at the time of initial registration and exceed the initial actual emission initial registration and exceed the initial actual emission eligibility criteria in the eligibility criteria in the firstfirst or or second yearsecond year, the ROSS , the ROSS source must apply for an operating permit and pay source must apply for an operating permit and pay applicable construction permit application feesapplicable construction permit application fees..
If an If an existing ROSS source existing ROSS source constructs several constructs several emission units through the years and then exceeds the emission units through the years and then exceeds the ROSS eligibility requirement, then they must ROSS eligibility requirement, then they must only apply only apply for a construction permit for the last emission unitfor a construction permit for the last emission unit that that put them back into a permit and pay applicable fees.put them back into a permit and pay applicable fees.
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ROSS FAQ’sROSS FAQ’s
Green House Gas (GHG)EmissionsGreen House Gas (GHG)Emissions
Do GHG emissions determine my ROSS eligibility? Do GHG emissions determine my ROSS eligibility? No, GHG emissions as well as emissions from No, GHG emissions as well as emissions from
exempt activities or equipment are not exempt activities or equipment are not considered in determining eligibilityconsidered in determining eligibility
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ROSS FAQ’SROSS FAQ’S
PENDING PERMIT APPLICATIONSPENDING PERMIT APPLICATIONSWhat if I have already submitted my permit application What if I have already submitted my permit application
to the BOA and I now qualify for ROSS?to the BOA and I now qualify for ROSS? The source will be notified by permits that they The source will be notified by permits that they
must register under the ROSS program instead of must register under the ROSS program instead of acquiring a permit. The source will receive a acquiring a permit. The source will receive a refund for construction fees and they can be refund for construction fees and they can be given a credit towards registration or a refund for given a credit towards registration or a refund for the $235. the $235.
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ROSS FAQ’sROSS FAQ’s
PORTABLE UNITSPORTABLE UNITS How will portable units be handled under ROSS? How will portable units be handled under ROSS?
portable units that emit less than 5 tpy in portable units that emit less than 5 tpy in aggregate at all locations need to register aggregate at all locations need to register
portable units pay one annual site fee of $235portable units pay one annual site fee of $235 when a portable is being moved, the company when a portable is being moved, the company
must submit new location information (use must submit new location information (use APC208 FormAPC208 Form))
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ROSS FAQROSS FAQ
Will I receive notification that I am a registered Will I receive notification that I am a registered ROSS source?ROSS source?
Yes, sources will receive a confirmation letter that Yes, sources will receive a confirmation letter that they are registered and those are going soon after they are registered and those are going soon after received, generally within a week.received, generally within a week.
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ROSS FAQ’SROSS FAQ’S
REASONS FOR REJECTIONREASONS FOR REJECTION Common errors include:Common errors include:
Not marking the certification checkboxNot marking the certification checkbox Lack of signatureLack of signature No payment with a new sourceNo payment with a new source Non-payment of past site fees for existing Non-payment of past site fees for existing
sourcessources applications are being checked against inventory applications are being checked against inventory
for 2010 and may call those who do not appear to for 2010 and may call those who do not appear to be eligiblebe eligible
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ROSS Information & ContactsROSS Information & Contacts General ROSS Questions & Assistance General ROSS Questions & Assistance concerning concerning
ROSS: SBEAP 800-252-3998ROSS: SBEAP 800-252-3998 ROSS Administrative issuesROSS Administrative issues: IEPA 217/785-1720: IEPA 217/785-1720 General Site Fee QuestionsGeneral Site Fee Questions: IEPA 217/782-7437: IEPA 217/782-7437 Registration Forms can be sent electronically to: Registration Forms can be sent electronically to:
[email protected] Electronic Payment via Illinois E-Pay coming soonElectronic Payment via Illinois E-Pay coming soon
ROSS Information, Forms & Updates at:ROSS Information, Forms & Updates at:
www.ienconnect.com/enviro
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REMEMBERREMEMBER
ROSS only eliminates the ROSS only eliminates the requirement for a permit (& AER) requirement for a permit (& AER) only, you must still comply with all only, you must still comply with all
applicable environmental applicable environmental
requirementsrequirements..
ALLALL 38593859 POTENTIAL ROSS SOURCES = POTENTIAL ROSS SOURCES = LESS THAN LESS THAN 1% 1% OF TOTAL EMISSIONS IN ILLINOISOF TOTAL EMISSIONS IN ILLINOIS
Thank YouThank You
Any Questions?
Ed BakowskiEd Bakowski Manager, Permit SectionManager, Permit Section
Division of Air Pollution Division of Air Pollution ControlControl
Bureau of Air, Illinois EPABureau of Air, Illinois EPA (217) 782-2113 (217) 782-2113 [email protected]
Annette FulgenziAnnette Fulgenzi Project Mgr, IL SBEAPProject Mgr, IL SBEAP IL Dept of Commerce & IL Dept of Commerce &
Economic OpportunityEconomic Opportunity (217)524-5199(217)524-5199 annette.fulgenzi@illinois.
gov
Jackie SimsJackie Sims IEPA (217)782-9333IEPA (217)782-9333
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