February 2, 1995

Donald Sutton, Manager
Permit Section
Bureau of Air
Illinois Environmental Protection Agency
P.O. Box 19276
2200 Churchill Road
Springfield, Illinois 62794-9276

Dear Mr. Sutton:

The purpose of this letter is to respond to Illinois Environmental Protection Agency's January 10, 1995, request for interpretation of stationary source applicability to Color Communications, Inc. located in Chicago, Illinois.

A stationary source, as defined in 40 CFR 52.21, is any building, structure, facility, or installation having common ownership or control, belonging to the same industrial grouping, and located on one or more contiguous or adjacent properties. The two Color Communication facilities clearly meet the common ownership and same industrial grouping criteria. It is also the United States Environmental Protection Agency's (USEPA) opinion the Color Communications meets the adjacency criteria. Therefore, USEPA believes that Color Communications meets the definition of a stationary source.

The preamble of the August 7, 1980, Federal Register (page 52695) states that buildings can be separated by a physical distance and still be one source.

Since the two facilities act as one unit in that a substantial amount of the final product is partially completed at one facility and finished at another facility, USEPA considers the two facilities to be one source regardless of the block separating the two buildings.

An example of a USEPA determination of a similar situation occurred with a General Motors Corporation facility in Michigan in June 1981. USEPA determined that the facilities were functionally equivalent to one source.

I have enclosed copies of the correspondence determining that the General Motors facility is one source, for your reference.

As always, we are available to assist you in permitting this source. If you have any questions in regards to this letter, please contact Genevieve Nearmyer at (312) 353-4761.

Sincerely yours,


Stephen Rothblatt, Chief
Regulation Development Branch


cc: Bharat Mathur, Chief
Bureau of Air
Illinois Environmental Protection Agency

Robb Layman
Division of Legal Counsel
Illinois Environmental Protection Agency