Air Emission Permit No. 12300054-003 Is Issued to Rexam Beverage Can Co - St Paul (EVA)€¦ ·...

TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

AIR EMISSION PERMIT NO. 12300054-003 Total Facility Operating Permit - Reissuance

IS ISSUED TO

Rexam Beverage Can Company

REXAM BEVERAGE CAN COMPANY - ST PAUL (EVA)

139 Eva Street St. Paul, Ramsey County, MN 55107

The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the Permit Applications Table. This permit reissuance supersedes Air Emission Permit No. 12300054002, and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR § 52.1220, and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Permit Type: Federal Permit; Part 70/Limits to Avoid NSR

Operating Permit Issue Date: August 19, 2010

Expiration Date: August 19, 2015 – All Title I Conditions do not expire. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for Paul Eger Commissioner Minnesota Pollution Control Agency

Permit Applications Table

Permit Type Application Date Permit Action Total Facility Operating Permit Reissuance June 8, 2006 003 Total Facility Operating Permit Reissuance – Revised and Updated April 16, 2010 003

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Appendices

NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area 651-296-6300 Outside Metro Area 1-800-657-3864 TTY 651-282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, 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. FACILITY DESCRIPTION: This facility produces two-piece aluminum cans. At the beginning of the production line, cuppers form the can. The cuppers act as a bottleneck for the facility, the maximum capacity of the cuppers is 4444 cans/minute. The cuppers feed into three can lines, each of which include a printing area and oven, and an inside spray area and oven. The maximum capacity of each individual line is 1500 cans/minute. This facility has accepted limit of 224 tons/year on Volatile Organic Compound (VOC) emissions to avoid major source status under the Prevention of Significant Deterioration program. The printer/ovens are subject to the New Source Performance Standards (NSPS) for Beverage Can Coating. The Spray machines are not subject to a NSPS, however, the Permittee only uses NSPS-compliant coatings at their facility.

TABLE A: LIMITS AND OTHER REQUIREMENTS 08/19/10

Rexam Beverage Can Co - St Paul (Eva)

12300054 - 003

Facility Name:

Permit Number:

A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column ofthe table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you musttake and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it)lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facilityrequirements.

Subject Item: Total Facility

What to do Why to do itSOURCE-SPECIFIC REQUIREMENTS hdr

Permit Appendices: This permit contains 2 appendices as listed in the permit Tableof Contents. The Permittee shall comply with all requirements contained in theappendices.

Minn. R. 7007.0800, subp. 2

OPERATIONAL REQUIREMENTS hdr

The Permittee shall comply with National Primary and Secondary Ambient AirQuality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air QualityStandards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstratedupon written request by the MPCA.

40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn.R. 7007.0800, subps. 1, 2 & 4; Minn. R.7009.0010-7009.0080

Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution control rule,without reducing the total amount of pollutant emitted.

Minn. R. 7011.0020

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,subp. 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation.

Minn. R. 7007.0800, subps. 14 and 16(J)

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shallimmediately take all practical steps to modify operations to reduce the emission ofany regulated air pollutant. The Commissioner may require feasible and practicalmodifications in the operation to reduce emissions of air pollutants. No emissionsunits that have an unreasonable shutdown or breakdown frequency of process orcontrol equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4

Fugitive Emissions: Do not cause or permit the handling, use, transporting, orstorage of any material in a manner which may allow avoidable amounts ofparticulate matter to become airborne. Comply with all other requirements listed inMinn. R. 7011.0150.

Minn. R. 7011.0150

Noise: The Permittee shall comply with the noise standards set forth in Minn. R.7030.0010 to 7030.0080 at all times during the operation of any emission units.This is a state only requirement and is not enforceable by the EPA Administrator orcitizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures andrequirements as found in Minn. R. 7007.0800, subp. 9(A).

Minn. R. 7007.0800, subp. 9(A)

The Permittee shall comply with the General Conditions listed in Minn. R.7007.0800, subp. 16.

Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING hdr

Performance Testing: Conduct all performance tests in accordance with Minn. R.ch. 7017 unless otherwise noted in Tables A, B, and/or C.

Minn. R. ch. 7017



12300054 - 003

Facility Name:

Permit Number:

A-2

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Table A of the permit.See Table B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy: due 105 days after each PerformanceTest

The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.

Minn. R. 7017.2018; Minn. R. 7017.2030, subps. 1-4,Minn. R. 7017.2035, subps. 1-2

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as stated in the MPCA's Notice of Complianceletter granting preliminary approval. Preliminary approval is based on formal reviewof a subsequent performance test on the same unit as specified by Minn. R.7017.2025, subp. 3. The limit is final upon issuance of a permit amendmentincorporating the change.

Minn. R. 7017.2025, subp. 3

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: The Permittee shall calibrate all requiredmonitoring equipment at least once every 12 months (any requirements applying tocontinuous emission monitors are listed separately in this permit).

Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D)

RECORDKEEPING hdr

Recordkeeping: Retain all records at the stationary source, unless otherwisespecified within this permit, for a period of five (5) years from the date of monitoring,sample, measurement, or report. Records which must be retained at this locationinclude all calibration and maintenance records, all original recordings forcontinuous monitoring instrumentation, and copies of all reports required by thepermit. Records must conform to the requirements listed in Minn. R. 7007.0800,subp. 5(A).

Minn. R. 7007.0800, subp. 5(C)

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (asrequired by Minn. R. 7007.1350, subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007.0800, subp. 5(B)

If the Permittee determines that no permit amendment or notification is requiredprior to making a change, the Permittee must retain records of all calculationsrequired under Minn. R. 7007.1200. These records shall be kept for a period of fiveyears from the date the change was made or until permit reissuance, whichever islonger. The records shall be kept at the stationary source for the current calendaryear of operation and may be kept at the stationary source or office of thestationary source for all other years. The records may be maintained in eitherelectronic or paper format.

Minn. R. 7007.1200, subp. 4

REPORTING/SUBMITTALS hdr

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of aplanned shutdown of any control equipment or process equipment if the shutdownwould cause any increase in the emissions of any regulated air pollutant. If theowner or operator does not have advance knowledge of the shutdown, notificationshall be made to the Commissioner as soon as possible after the shutdown.However, notification is not required in the circumstances outlined in Items A, Band C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner ofthe cause of the shutdown and the estimated duration. The owner or operator shallnotify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3



12300054 - 003

Facility Name:

Permit Number:

A-3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

Application for Permit Amendment: If a permit amendment is needed, submit anapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

Minn. R. 7007.1150 - 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendment toextend a deadline in a permit by no more than 120 days, provided the proposeddeadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

Minn. R. 7007.1400, subp. 1(H)

Emission Inventory Report: due on or before April 1 of each calendar year followingpermit issuance, to be submitted on a form approved by the Commissioner.

Minn. R. 7019.3000 - 7019.3100

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 - 7002.0095



12300054 - 003

Facility Name:

Permit Number:

A-4

Subject Item: GP 001 Direct-Heating Equipment (Combustion from Ovens)

Associated Items: EU 003 Inside Bake Oven - Line 1

EU 006 Inside Bake Oven - Line 2

EU 009 Inside Bake Oven - Line 3

EU 010 Washer 1 - Oven

EU 011 Washer 2 - Oven

EU 012 Washer 1- Fire Tube Stage 1

EU 013 Washer 1 - Fire Tube Stage 2





EU 018 Printer Oven combustion - Line 1



What to do Why to do itEMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735.

Minn. R. 7011.0610, subp. 1(A)(1) and Minn. R.7011.0715, subp. 3

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0610, subp. 1(A)(2)



12300054 - 003

Facility Name:

Permit Number:

A-5

Subject Item: GP 002 Printer Lines, NSPS applies

Associated Items: EU 001 Printer/Oven - Line 1

EU 004 Printer/Oven - Line 2


What to do Why to do itOPERATIONAL LIMIT hdr

VOC emissions to the atmosphere shall not exceed the following volume-weightedcalendar-month average emissions:

0.46kg of VOC per litre of coating solids (3.84 lb/gal of coating solids) from eachtwo-piece can clear base coating operation and from each overvarnish coatingoperation.

40 CFR Section 60.492(b), Minn. R. 7011.2575

RECORDKEEPING hdr

Material Content: The VOC content in coating materials shall be determined byformulation data supplied by the manufacturer or the supplier, or by an anlaysis ofeach coating, as received, using Reference Method 24 or an equivalent oralternative method. If a material content range is given in the formulation data, thehighest number in the range shall be used in all compliance calculations. TheCommissioner reserves the right to require the Permittee to determine the VOCcontents of any material, according to EPA or ASTM reference methods. If an EPAor ASTM reference method is used for material content determination, the dataobtained shall supersede the MSDS.

Minn. R. 7007.0800, subp. 4 and 5

Recordkeeping: Maintain a file of all measurements, maintenance, reports andrecords for at least five years.

40 CFR Section 60.7(f); Minn. R. 7019.0100, subp. 1

CALCULATION METHOD hdr

Monthly calculation of total mass of VOC per volume of coating solids.

The Permittee shall calculate the mass of VOC used each calendar month for eachaffected printer operation in accordance with 40 CFR 60.493(b)(1)(i), unless eachof the coatings used is individually compliant as stated in the following requirement.

M = LDW

M = mass consumedL = volume of coating used, including any added solventsD = density of coatingW = proportion of VOC in coating by weight

This calculation shall be used for each coating and solvent used. The mass ofVOC used will be the sum of the individual calculations.

40 CFR Section 60.493(b)(1)(i); Minn. R. 7011.2575

If each individual coating used has a VOC content equal to or less than 0.46 kgVOC/liter (3.84 lb VOC/gal), the affected facility is in compliance provided no VOCsolvents are added to the coating during distribution of application.

40 CFR Section 60.493(b)(1)(iv); Minn. R. 7011.2575

REPORTING hdr

Deviations Report: Due 30 days after end of each calendar quarter for VOCcontent. Each Permittee shall identify, record, and submit quarterly reports to theAdministrator of each instance in which the volume-weighted average of the totalmass of VOC per volume of coating solids, is greater than the limit. If no suchinstances occur during a particular quarter, a report stating this shall be submittedto the Administrator annually.

40 CFR Section 60.495, Minn. R. 7011.2575

Semiannual Continuous Compliance Report: due 30 days after end of eachcalendar half-year. If the volume-weighted average of the total mass of VOC pervolume of coating solids is not greater than the limit, then a report stating this shallbe submitted to the Administrator semiannually.

40 CFR Section 60.495, Minn. R. 7011.2575

NOTIFICATIONS hdr

Notification of any physical or operational change which increases emission rate:due 60 days (or as soon as practical) before the change is commenced within 180days of completion of any physical or operational change subject to the controlmeasures specified in 60.14(a), compliance with all applicable standards must beachieved.

40 CFR Section 60.7(a)(4); Minn. R. 7019.0100, subp.1



12300054 - 003

Facility Name:

Permit Number:

A-6

No owner or operator shall build, erect, install, or use any article, machine,equipment or process, the use of which conceals an emission which wouldotherwise constitute a violation of an applicable standard.

40 CFR Section 60.12; Minn. R. 7019.0100, subp. 1



12300054 - 003

Facility Name:

Permit Number:

A-7

Subject Item: GP 003 Spray Machines

Associated Items: EU 002 Spray Machine - Line 1

EU 005 Spray Machine - Line 2


What to do Why to do itEMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735.

Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)



12300054 - 003

Facility Name:

Permit Number:

A-8

Subject Item: GP 004 VOC Limit

Associated Items: EU 001 Printer/Oven - Line 1






What to do Why to do itLIMIT hdr

Volatile Organic Compounds: less than or equal to 224 tons/year using 12-monthRolling Sum to be calculated by the 15th day of each month for the previous12-month period using the Calculation Method described below.

VOC contents for each VOC-containing material shall be determined as describedunder the Material Content requirement.

Title I Condition: To avoid classification as majorsource and modification under 40 CFR Section 52.21& Minn. R. 7007.3000

RECORDKEEPING hdr

Daily Material Usage Recordkeeping.

On each day of operation, the Permittee shall record and maintain records of thetotal quantity of cans processed. This shall be based on written production logsand meter readings.

Title I Condition: To avoid classification as majorsource and modification under 40 CFR Section 52.21& Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4and 5

Monthly Recordkeeping -- VOC Emissions.By the 15th of the month, the Permittee shall calculate and record the following:

1) The total usage of VOC-containing materials for the previous calendar month.This record shall also include the VOC and solids contents of each material asdetermined by the Material Content requirement of this permit.2) The VOC emissions for the previous month using the formula specified in thispermit.3) The 12-month rolling sum VOC emissions for the previous 12-month period bysumming the monthly VOC emissions data for the previous 12 months.

Minn. R. 7007.0800, subps. 4 and 5

Material Content: The VOC content in coating materials shall be determined byformulation data supplied by the manufacturer or the supplier for each materialused, by the Material Safety Data Sheet (MSDS) provided by the supplier for eachmaterial used, or by an anlaysis of each coating, as received, using ReferenceMethod 24 or an equivalent or alternative method. If a material content range isgiven in the formulation data or on the MSDS, the highest number in the range shallbe used in all compliance calculations. The Commissioner reserves the right torequire the Permittee to determine the VOC contents of any material, according toEPA or ASTM reference methods. If an EPA or ASTM reference method is usedfor material content determination, the data obtained shall supersede the MSDS.

Minn. R. 7007.0800, subps. 4 and 5

Maximum Contents of Materials: The Permittee assumed certain worst-casecontents of materials when determining the short term potential to emit of units inGP004. These assumptions are listed in Appendix II of this permit. Changing to amaterial that has a higher content of any of the given pollutants is considered achange in method of operation that must be evaluated under Minn. R. 7007.1200,subp. 3 to determine if a permit amendment or notification is required under Minn.R. 7007.1150.

Minn. R. 7005.0100, subp. 35a

CALCULATION METHOD hdr

Monthly VOC Emissions Calculation

The Permittee shall calculate VOC emissions using the following equation:

VOC (tons/month) = VV = (A1 x B1) + (A2 x B2) + (A3 x B3) + .....

where:V = total VOC used in tons/month;A# = amount of each VOC containing material used, in tons/month;B# = weight percent VOC in A#, as a fraction;

Minn. R. 7007.0800, subps. 4 and 5

TABLE B: SUBMITTALSFacility Name: Rexam Beverage Can Co - St Paul (Eva)

Permit Number: 12300054 - 003

08/19/10B-1

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- changes that contravene a permit term.

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table Aor, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately listone-time only and recurrent submittal requirements.

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Send any application for a permit or permit amendment to:

AQ Permit Technical Advisor Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Rexam Beverage Can Co - St Paul (Eva)


08/19/10B-2

What to send When to send Portion of Facility AffectedApplication for Permit Reissuance due 180 days before expiration of Existing

PermitTotal Facility

TABLE B: RECURRENT SUBMITTALSFacility Name: Rexam Beverage Can Co - St Paul (Eva)


08/19/10B-3

What to send When to send Portion of Facility AffectedSemiannual Deviations Report due 30 days after end of each calendar

half-year following Permit Issuance. The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occurred, the Permittee shall submit thereport stating no deviations.

Total Facility

Compliance Certification due 31 days after end of each calendar yearfollowing Permit Issuance (for the previouscalendar year). The Permittee shall submitthis on a form approved by the Commissioner,both to the Commissioner and to the US EPAregional office in Chicago. This report coversall deviations experienced during the calendaryear.

Total Facility

APPENDIX MATERIAL Facility Name: Rexam Beverage Can Company – St. Paul (Eva) Permit Number: 12300054-003

APPENDIX I

Insignificant Activities and General Applicable Requirements

The table below lists the insignificant activities that are currently at the facility and their associated general applicable requirements.

Minn. R. 7007.1300,

subp. Rule Description of the Activity

General Applicable

Requirement(s)

3(A) Fuel Use: space heaters fueled by kerosene, natural gas, or propane.

The facility has 6 space heaters.

Minn. R. 7011.0610 and Minn. R. 7011.0715, subp. 3

(PM and Opacity)

3(D) Processing Operations:

2. equipment venting PM inside a building (i.e. drilling, machining, routing, sanding, grinding) provided that emissions from the equipment are

a) filtered through an air cleaning system; and

b) vented inside of the building 100 percent of the time.

The facility has a machine shop (grinding, welding) and a small woodshop (radial arm saw and table saw) vented internally.

Minn. R. 7011.0715 (PM and opacity)

3(H) Miscellaneous:

3. brazing, soldering or welding equipment;

There is a machine shop at the facility.

Minn. R. 7011.0715 (PM and opacity)

4(B)&(C) B. Potential emissions of 2.28 pounds per hours or actual emissions of one ton per year for particulate matter, particulate matter less than ten microns, nitrogen oxide, sulfur dioxide, and VOCs; and

C. For hazardous air pollutants, emissions units with potential emissions of 25% or less of the HAP thresholds listed in part 7007.1251 (for glycol ethers = 5 tpy).

There are 6 tanks at the facility which are considered insignificant sources. The combined PTE of these tanks is less than 1 tpy of VOCs and HAPs

There are 3 hot-water heaters 2 make-up air units. These are each considered an insignificant source.

The facility uses ~188 gallons per year of Safety Kleen in their parts cleaner (0.09 tons/year of VOC)

Tanks: Minn. R. 7011.2300 (VOCs, HAPs); Fuel-burning: Minn. R. 7011.0610 and Minn. R. 7011.0715, subp. 3

(PM and opacity)

APPENDIX MATERIAL Facility Name: Rexam Beverage Can Company – St. Paul (Eva) Permit Number: 12300054-003

APPENDIX II

Maximum Contents of Materials All contents are “as applied”.

Emissions Unit VOC Content (lb/gal)

Solids Content (lb VOC/gal solid)

INSIDE SPRAY (EU002, EU005, EU008))

Inside Spray 3.5 6.8 PRINTER LINE

(EU001, EU004, EU007)

Overvarnish 2.1 2.8 Bottom Varnish 2.1 2.9

Technical Support Document, Permit Action Number: 12300054-003 Date: 8/26/2010

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 12300054-003 This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit.

1. General Information

1.1 Applicant and Stationary Source Location:

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address (SIC Code: 3411)

Rexam Beverage Can Company 139 Eva Street St. Paul, MN 55155

Rexam Beverage Can Company 139 Eva St St. Paul, Minnesota Ramsey County

Chris Karpovich, Plant Manager 651-223-9552 [email protected]

1.2 Facility Description

This facility produces two-piece aluminum cans. At the beginning of the production line, cuppers form the can. The cuppers act as a bottleneck for the facility, the maximum capacity of the cuppers is 4444 cans/minute. The cuppers feed into three can lines, each of which include a printing area and oven, and an inside spray area and oven. The maximum capacity of each individual line is 1500 cans/minute. This facility has accepted limit of 224 tons/year on volatile organic compound (VOC) emissions to avoid major source status under the Prevention of Significant Deterioration program. The printer/ovens are subject to the New Source Performance Standards (NSPS) for Beverage Can Coating. The Spray machines are not subject to a NSPS, however, the Permittee only uses NSPS-compliant coatings at their facility.


1.3 Description of any Changes Allowed with this Permit Issuance

• Removed VOC limits contained within GP002 and GP003 that were set during previous

modifications to avoid exceeding the major modification threshold for VOCs under New Source Review. The Permittee has subsequently changed coatings (lower VOC content) and has accepted a VOC limit of 224 tons per year such that the facility is no longer considered a major source under 40 CFR Section 52.21.

• Relocated the 224 tons per year limit from the Total Facility level to GP004, and

specifically identified which emission units are subject to the limit, along with appropriate recordkeeping and reporting requirements.

• Added Appendix II to the permit to document the Material Contents of Coatings, and

maximum production numbers used in calculations to determine hourly PTE.

• Added Safety Kleen-based parts washers to the list of Insignificant Activities

• Updated citations

• Updated calculations to reflect coatings currently in use at the facility.

1.4 Description of All Amendments Issued Since the Issuance of the Last Total Facility Permit and to be Included in the Part 70 Permit

Permit Number and Issuance Date

Action Authorized

12300054-002 Installation of new cupper. Debottlenecked facility, allowing increase in maximum can production to 4380 cans/minute.


1.5 Facility Emissions:

Table 2. Total Facility Potential to Emit Summary

PM tpy

PM10 tpy

PM2.5 tpy

SO2 tpy

NOx tpy

CO tpy

VOC tpy

SingleHAP tpy

All HAPs

tpy GP001 (ovens) .99 .99 .99 0.08 13.01 14.28 0.72 EU001 17.7 EU002 0.64 0.64 0.64 72.2 EU004 17.7 EU005 0.64 0.64 0.64 72.2 EU007 17.7 EU008 0.64 0.64 0.64 72.2 EU021 3.13 GP004 224 5.62 10.27 Total Facility Limited Potential Emissions

2.91 2.91 2.91 0.08 13.01 14.28 227.85* 5.62 10.27

*Limited VOC = GP004 (EU001, 002, 004,005, 007, 008) limit of 224 tpy + GP001 + EU021 Total Facility Actual Emissions (2008)

0.47 0.47 0.47 0.04 6.12 5.14 197.64 HAPs not reported in emission inventory

Table 3. Facility Classification

Classification Major/Affected Source

Synthetic Minor Minor

PSD - VOC CO, NOx, SOx, Pb, PM/PM10/PM2.5, HAPs

Part 70 Permit Program VOC - CO, NOx, SOx, Pb, PM/PM10/PM2.5, HAPs

Part 63 NESHAP - - HAPs


2. Regulatory and/or Statutory Basis

New Source Review

The facility has accepted limits on VOC emissions to avoid classification as a major source under New Source Review regulations.

Part 70 Permit Program

The facility is a major source under the Part 70 permit program.

New Source Performance Standards (NSPS)

GP002 emission units, the printers are subject to Standards of Performance for Beverage Can Coating (40 CFR pt. 60, subp. WW). The standard requires use of VOC –compliant coatings.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

The Facility is considered an area source of HAPs under 40 CFR pt. 63. Thus, no major source NESHAPs apply. There are no area source NESHAPs that apply to this Facility.

Background Information regarding 40 CFR § 63, subp. KKKK. November 10, 2004, the Permittee submitted Initial Notification to EPA regarding their plan to be in compliance with 40 CFR § 63, subp. KKKK. At the time when the Initial Notification was submitted, EPA was in the final stage of delisting Ethylene Glycol Monobutyl Ether (EGBE also known as Butyl Cellosolve), which was previously defined as a HAP. On November 18, 2004, EPA delisted EGBE. This action changed the status of this Facility from a major source of HAPs to an area source of HAPs. 40 CFR § 63, subp. KKKK, became effective November 13, 2006, after the Facility became reclassified as an area source of HAPs.

Compliance Assurance Monitoring (CAM)

The facility does not have any pollution control equipment, therefore none of the units are subject to CAM.

Environmental Review & AERA

The facility is not constructing any new sources of emissions, therefore this permit action is not subject to environmental review, i.e. an Environmental Assessment Worksheet (EAW,) and is not required to perform an Air Emissions Risk Analysis (AERA).

Minnesota State Rules

Portions of the facility are subject to the following Minnesota Standards of Performance: • Minn. R. 7011.0610 Standards of Performance for Fossil-Fuel-Burning Direct Heating

Equipment • Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process

Equipment


Table 4. Regulatory Overview of Facility

EU or GP #

Applicable Regulations Comments:

GP001 (ovens)

Minn. R. 7011.0610, subp. 1Minn. R. 7011.0715, subp. 3

Standards of Performance for new Direct-heating equipment – applies to ovens. PM and Opacity limits, met by equipment design while burning natural gas.

GP002 (NSPS)

40 CFR Pt. 60, subp. WW

Standards of Performance for Beverage Can Coating. Requires VOC content limit in coatings.

GP003 (spray)

Minn. R. 7011.0710 Standards of Performance for new Industrial Process Equipment- applies to spray machines. PM and Opacity limits, met by equipment and process design.

GP004 Limits to avoid classification as major source and modification under 40 CFR § 52.21

VOC limit of 224 tons/year for emission units within group (printers and spray machines, material usage).

3. Technical Information Calculations of Potential to Emit Attachment 1 to this TSD contains Form GI-07, which summarizes the PTE of the Facility, while Attachment 2 contains detailed spreadsheets and supporting information prepared by the MPCA and the Permittee. The following sections include additional discussion on the emission units at the facility that is not included with the attached calculations. Group 002: Printer Lines EU001, 004, 007 Historical Background: These printer/ovens were modified in 1991/92. The facility was classified as an existing major source. A source-wide netting analysis was conducted at the time. The unit that was considered modified is the printer and oven as one emission unit, as 90% of the VOC are emitted from the oven stack. Since analysis results were very close to the 40 tpy threshold for VOC emissions, a VOC limit was set to avoid a major modification for PSD. Current Permit Action: The facility has accepted limits on VOC emissions such that they are no longer considered a major source for NSR. This was enabled by the continuing pursuit of lower-VOC containing coatings to use in their process. Also, their major source of HAPs at the facility, Butyl Cellosolve, was delisted. PM Emissions: This is an offset printing operation which is considered an overvarnish coating operation. Therefore, there are no associated PM emissions. NSPS, 40 CFR, Subp. WW – Beverage Can Surface Coating. The NSPS for Beverage Cans does apply to this unit as they were installed after Aug. 25, 1983 (promulgation date of standard).


• Limit of 3.84 lb of VOC per gallon of coating solids, as a volume weighted calendar month average. Calculated in accordance with 40 CFR 60.493(b)(1)(i).

Group 003: Spray Machines EU002, 005, 008 Discussion of Transfer Efficiency: PTE PM EMISSIONS(from calculations)

MATERIAL TYPE NAME USAGE DENSITY USAGE Gallons Pounds

I/S SPRAY 20Q53AP 353,309 8.43 2,978,393

WEIGHT % SOLIDS SOLIDS

EMISSION FACTOR PM, PM 10 , PM2.5

lbs lbs/lbs RELEASED lbs 21.1% 628,441 6.0% 37,706

Total PM Emissions: 1.89 ton /year for all 3 lines LB/HR CALCULATION ton for each line = 0.64 lb/hr for each line = 0.15

lb/hr PTE is calculated by scaling maximum capacity for all 3 lines (4444 cans/minute) to maximum capacity of can line (1500 cans/minute)

(i.e. 1.89 ton/yr * 1500 can/min / 4444 can min, convert to lb/hr)

6% of inside spray is oversprayed

90% of that is agglomerated on overspray sleeves. 33,936 Lb/yr10% of PM is emitted through inside spray machine stacks

3,771 Lb/yr Transfer efficiency for process is 99.4% overall. No control. 3771(lb of solids released)/628441(lb of solids applied) x 100 = 0.6 % 2009 Verification of Transfer Efficiency The Permittee conducted an additional analysis of PM emissions (to verify the original determination that was made in 1994) from the spray machines based upon current production data. The following analysis is based upon the 2009 emission year. When the Permittee applies the inside spray coating to the inside


of a can body, most of the coating is distributed very efficiently inside the can body; however, a very small amount of coating is over sprayed which is accumulated on cardboard sleeves. The amount of overspray is minimized by checking and adjusting the coating spray nozzles as required by our quality control procedures to minimize spray waste. The cardboard sleeves containing the inside spray waste are shipped out as a special waste handled by the certified waste disposal companies. The waste manifest containing the quantity shipped in pounds are maintained at the facility. 2009 PM emission analysis is as follows:

• The actual 2009 Inside Spray coating usage from our monthly calculation spreadsheet: 2,275,788 Pounds

• Total can production in 2009: 1,726,139,000 Cans

• Using actual production and film weight coating applied to cans in 2009: 2,248,085 Pounds

• The difference is the amount of overspray that accumulated on cardboard sleeves: 27,703 Pounds

• Total amount of Inside Spray waste shipped in 2009: 24,865 Pounds

• 24865/27703 x 100 = 90%

• The difference is the PM Emissions: 2,838 Pounds OR 1.42 Tons

Allowable PM per Industrial Process Equipment rule: Each of 3 has exhaust flow of 6917 acfm @ 80F • 6917 (460+68/460+80) = 6763 scfm • 0.1 x 6763 x 60/7000 = 5.8 lb/hr = 25.4 tpy each = 76.2 tpy PM allowable for all 3 > 5.67 tpy

PM PTE O.K. • compliance with state rule is PTE of equipment NSPS, 40 CFR, Subp. WW – Beverage Can Surface Coating. The NSPS for Beverage Cans does not apply to this unit as they were installed prior to Aug. 25, 1983 (promulgation date of standard). Existing Permit limits. In 1992, source-wide netting analysis results were very close to the 40 tpy threshold for VOC emissions. Therefore, two limits (VOC usage < 255 tpy, and VOC content < 7.42 lb/gal) were set in the permit to ensure that they did not unknowingly violate PSD in the future by changing materials to one with a higher VOC content. The facility has subsequently accepted limits so that the facility is a nonmajor source for NSR, so these limits are no longer necessary.


Periodic Monitoring

In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements.

In evaluating the monitoring included in the permit, the MPCA considers the following:

• The likelihood of violating the applicable requirements; • Whether add-on controls are necessary to meet the emission limits; • The variability of emissions over time; • The type of monitoring, process, maintenance, or control equipment data already

available for the emission unit; • The technical and economic feasibility of possible periodic monitoring methods; and

Table 4 summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate

Table 5. Periodic Monitoring

EU/GP Emission Limit Additional Monitoring

Discussion

GP001 – direct-heating equipment

Direct-heating equipment rule: PM: <or= 0.3 grains/dry standard cubic foot Opacity: <or= 20%

None All units use natural gas and therefore the likelihood of violating either of the emissions limits is very small. The Permittee can demonstrate that these units will continue to operate such that emissions are well below the emission limits by only burning natural gas. Since this is a permit condition, the semi-annual deviations report will document any deviations from this condition.

GP002 - printers VOC content <or= 3.84 lb/gal of coating solids

Use of compliant coatings

NSPS-required monitoring is adequate. Only compliant materials are used at the facility

GP003 – spray machines

Industrial Process equipment rule: PM: <or= 5.8 lb/hr/unit Opacity: <or= 20%

None The transfer efficiency of the inside spray operation is at least 99.4%. This is inherent to the process. The PTE of the spray operations are 0.43 lb/hr each. Opacity limits are met by equipment design. There is no pollution control equipment associated with this unit.

GP004 VOC usage limit <or= 224 tpy on a 12-month rolling sum

Daily recordkeeping of usage; on-going MSDS records of coating contents; monthly calculation

Records are generated daily based upon usage (production logs) and maintained in a database.


3.2 Insignificant Activities

Rexam has several operations which are classified as insignificant activities. These are listed in Appendix I to the permit.

The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities.

Table 6. Insignificant Activities

Insignificant Activity

General Applicable

Emission limit

Discussion

Fuel use: space heaters fueled by, kerosene, natural gas, or propane

The facility has 6 natural-gas-fired space heaters

PM < 0.6 or 0.4 lb/MMBtu, depending on year constructedOpacity < 20% with exceptions

Minn. R. 7011.0610/0615

For these units, based on the fuels used and EPA published emissions factors, it is highly unlikely that it could violate the applicable requirement. In addition, these types of units are typically operated and vented inside a building, so testing for PM or opacity is not feasible.

Processing Operations:

2. equipment venting PM /PM10 inside a building provided that emissions from the equipment are

a. filtered through an air cleaning system; and

b. vented inside of the building 100% of the time. The facility has a machine shop (grinding, welding) and a small woodshop (radial arm saw and table saw) vented internally

PM, variable depending on airflow Opacity < 20%

Minn. R. 7011.0710/715

For these units, based upon EPA published emission factors, it is highly unlikely that they could violate the applicable requirements. In addition, these units are vented internally, so testing for PM or opacity is not feasible.


Brazing, soldering or welding equipment There is a machine shop at the facility.

PM, variable depending on airflow Opacity < 20%

Minn. R. 7011.0710/715

For these units, based on EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, these units are typically operated and vented inside a building, so testing for PM or opacity is not feasible.

Individual units with actual emissions less than 2000 lb/year of certain pollutants

There are 6 tanks at the facility which are considered insignificant sources. The combined PTE of these tanks is less than 1 tpy of VOCs and HAPs.

There are 3 hot-water heaters and approximately and 2 make-up air units. These are each considered an insignificant source.

The facility uses ~188 gallons per year of Safety Kleen in their parts cleaner (0.09 tons/year of VOC)

Tanks:

VOCs, HAPs Minn. R. 7011.2300

Fuel-burning:

PM, variable depending on airflow Opacity < 20% (with exceptions) Minn. R. 7011.0610/0615 (Minn. R.

For the natural gas units and the tanks, based on the fuels used and stored and EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, all of these units are operated and vented inside a building, so testing for PM or opacity is not feasible.

Tanks (Installed 9/20/93): Tank emissions are considered insignificant sources. Minn. R. 7011.1505 Standard of Performance for Storage Vessels • Subp. 3, B: Post-June 11, 1973 vessels greater than 2,000 gal and less than 40,000 gal.

Equip the storage vessel with a permanent submerged fill pipe. 9/20/93 Inside Spray Tank 6400 gal Overvarnish Tank 6400 gal Hydraulic Oil Tank 6400 gal Body Maker Tank 6400 gal Oily Waste Tank 6400 gal


3.3 Permit Organization

In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be tracked (e.g., limits, submittals, etc.), should be in Table A or B. The main reason is that the appendices are word processing sections and are not part of the tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these.

3.4 Comments Received

Public Notice Period: June 15, 2010 – July 14, 2010 EPA 45-day Review Period: June 15, 2010 – July 29

Comments were not received from the public during the public notice period. No changes were made to the draft/proposed permit during the public notice/review period.

4. Permit Fee Assessment

This permit action is the reissuance of an individual Part 70; therefore, no application fees apply under Minn. R. 7002.0016, subp. 1.

5. Conclusion

Based on the information provided by Rexam Beverage Can Company, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 12300054-003 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Bonnie Nelson (permit writer/engineer) Steve Palzkill (enforcement) Jessica Forsberg (peer reviewer)

AQ File No. 1200C; DQ 1116 Attachments: 1. PTE Summary

2. Calculation Spreadsheets 3. Facility Description and CD-01 Forms

Air Emission Permit No. 12300054-003 Is Issued to Rexam Beverage Can Co - St Paul (EVA)€¦ ·...

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