AIR EMISSION PERMIT NO. 12300054- 002 IS ISSUED TO Rexam ...€¦ · Title I Condition: Monitoring for Limit to avoid classification as major modification under 40 CFR 52.21 and Minn

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- 002

IS ISSUED TO

Rexam Beverage Can Company

Rexam Beverage Can Company - St. Paul (Eva) 139 Eva Street

St. Paul, Ramsey County, MN 551071412 The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Action Number Application Date Issue Date Total Facility Operating Permit 001 04/14/1995 12/11/2001 Major Amendment 002 06/19/2002 See below This permit authorizes the Permittee to operate and construct 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. Permit Type: Federal; Pt 70/NSR Authorization Issue Date: 12/16/2002 Expiration: 12/11/2006 All Title I Conditions do not expire. Ann M. Foss Major Facilities Section Manager Majors and Remediation Division for Karen A. Studders Commissioner Minnesota Pollution Control Agency

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Appendix: Appendix I - Insignificant Activities

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 manufactures two-piece aluminum cans. There are three can lines, each of which contains a can-forming area, a printing/oven area and an inside spray area with oven. The facility is major source, according to the New Source Review Program, of Volatile Organic Compound (VOC) emissions, which emanate mostly from the printing and spray operations. The printer/ovens are subject to the New Source Performance Standard for Beverage Can Coating. MAJOR AMENDMENT DESCRIPTION: There are two Cuppers at the facility that produces cups, from which the cans are made. These Cuppers are the bottleneck to the other processes following. Cuppers are not considered as emission units. The Permittee proposes to remove an existing Cupper and replace it with a refurbished Cupper, and be able to produce more cups than before. Maximum capacity of cups produced: 4,380 cups/minute Maximum Printer/Oven capacity: 1,450 cans/minute from Lines 1, 2, and 3 individually Maximum Spray Machine capacity: 1,500 cans/minute from Lines 1, 2, and 3 individually This is a Synthetic Minor Modification (involves debottlenecking) to the existing Major facility under Prevention of Significant Deterioration. The VOC emissions increase from the proposed modification is less than 40 tons per year.

TABLE A: LIMITS AND OTHER REQUIREMENTS 12/16/02

Rexam Beverage Can Co - St Paul (Eva)

12300054 - 002

Facility Name:

Permit Number:

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 itVolatile 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: Limit to avoid classification as majormodification under 40 CFR Section 52.21 and Minn. R.7007.3000

Maximum capacity (to limit emissions change due to debottlenecking and to avoidmaking a physical modification to process equipment):

Cups produced: 4,380 cups per minute (two Cuppers)Lines 1, 2, and 3:Printer/Oven (each): 1,450 cans per minuteSpray Machine (each): 1,500 cans per minute


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

Material Usage Recordkeeping.

For overvarnish and ink materials used in the printers: On each day of operation,the Permittee shall record and maintain the total quantity of cans processed byeach printer/oven. This shall be based on written production logs and meterreadings.

For other VOC-containing materials (including clean-up solvents): The Permitteeshall record and maintain monthly usage records showing the quantity of eachmaterial used. This shall be based on either written usage logs, orpurchase/delivery records.

Title I Condition: Monitoring for Limit to avoidclassification as major modification under 40 CFR52.21 and Minn. R. 7007.3000, Minn. R. 7007.0800.subp. 4 and 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 monthusing the daily usage records. This record shall also include the VOC and solidscontents of each material as determined by the Material Content requirement of thispermit.2) The VOC emissions for the previous month using the formulas 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, subp. 4 and 5

Monthly VOC Emissions CalculationThe Permittee shall calculate VOC emissions using the following equations:

VOC (tons/month) = V - WV = (A1 x B1) + (A2 x B2) + (A3 x B3) + .....W = (C1 x D1) + (C2 x D2) + (C3 x D3) + .....

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;W = the amount of VOC shipped in waste, in tons/month;C# = amount, in tons/month, of each VOC containing waste material shipped. Ifthe Permittee chooses to not take credit for waste shipments, this parameter wouldbe zero; andD# = weight percent of VOC in C#, as a fraction.

Minn. R. 7007.0800, subp. 4 and 5

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12300054 - 002

Facility Name:

Permit Number:

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 shall include a preventativemaintenance program for that equipment, a description of (the minimum but notnecessarily the only) corrective actions to be taken to restore the equipment toproper operation to meet applicable permit conditions, a description of theemployee training program for proper operation and maintenance of the controlequipment, and the records kept to demonstrate plan implementation.

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

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

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as specified by Minn. R. 7017.2025 followingformal review of a subsequent performance test on the same unit.

Minn. R. 7017.2025

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See TableB 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

Minn. R. 7017.2030, subp. 1-4 and Minn. R.7017.2035, subp. 1-2

Monitoring Equipment: Install or make needed repairs to monitoring equipmentwithin 60 days of issuance of the permit if monitoring equipment is not installed andoperational on the date the permit is issued.

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

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately 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)

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

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

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

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12300054 - 002

Facility Name:

Permit Number:

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

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

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated, unlessotherwise noted in Table A.

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

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

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 through Minn. R. 7007.1500

Application for Permit Reissuance: due 180 days before expiration of existingpermit.

Minn. R. 7007.0400, subp. 3

Extension Requests: The Permittee may apply for an Administrative Amendmentto extend 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)

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007. 1250, subp. 3) or changes contravening permit terms(as required by Minn. R. 7007.1350 subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007. 0800, subp. 5(B)

Record keeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal recordings for continuous monitoring instrumentation, and copies of allreports required by the permit. Records must conform to the requirements listed inMinn. R. 7007.0800, subp. 5(A).

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

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

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

Minn. R. 7007.0800, subp. 16

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)

Emission Inventory Report: due 91 days after end of each calendar year followingpermit issuance (April 1). To be submitted on a form approved by theCommissioner.

Minn. R. 7019.3000 through Minn. R. 7019.3010

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

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12300054 - 002

Facility Name:

Permit Number:

Subject Item: GP 001 Direct-Heating Equipment (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 itTotal 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)

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity.

Minn. R. 7011.0610, subp. 1(A)(2)

A-4



12300054 - 002

Facility Name:

Permit Number:

Subject Item: GP 002 Printer/Ovens

Associated Items: EU 001 Printer/Oven - Line 1

EU 004 Printer/Oven - Line 2

EU 007 Printer/Oven - Line 3

What to do Why to do itLIMITS 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

Volatile Organic Compounds: less than or equal to 82 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. This limit is forGP002 emission units only.



RECORDKEEPING hdr


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


For overvarnish and ink materials used in the printers: On each day of operation,the Permittee shall record and maintain the total quantity of cans processed byeach printer/oven. This shall be based on written production logs and meterreadings.


Title I Condition: Monitoring for Limit to avoidclassification as major modification under 40 CFR52.21 and Minn. R. 7007.3000, Minn. R. 7007.0800.subp. 4 and 5


Minn. R. 7007.0800, subp. 4 and 5

CALCULATION METHOD hdr

A-5



12300054 - 002

Facility Name:

Permit Number:




Minn. R. 7007.0800, subp. 4 and 5

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)

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)

REPORTING hdr

Deviations Report: Due 30 days after end of each calendar quarter starting12/11/2001 for VOC content. Each Permittee shall identify, record, and submitquarterly reports to the Administrator of each instance in which thevolume-weighted average of the total mass of VOC per volume of coating solids, isgreater than the limit. If no such instances occur during a particular quarter, areport stating this shall be submitted to the Administrator annually.

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

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

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12300054 - 002

Facility Name:

Permit Number:

Subject Item: GP 003 Spray Machines

Associated Items: EU 002 Spray Machine - Line 1

EU 005 Spray Machine - Line 2

EU 008 Spray Machine - Line 3

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. This limit appliesto GP003 emission units only. The VOC limit for the entire facility is less than orequal to 224 tons/year.



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)

RECORDKEEPING AND REPORTING hdr


Minn. R. 7007.0800, subp. 4 and 5


For coating materials used in the spray machinges: On each day of operation, thePermittee shall record and maintain the total quantity of cans processed by eachspray machine. This shall be based on written production logs and meter readings.




Minn. R. 7007.0800, subp. 4 and 5

CALCULATION METHOD hdr




Minn. R. 7007.0800, subp. 4 and 5

A-7

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

Permit Number: 12300054 - 002

12/16/02

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 any application for a permit or permit amendment to:

Permit Technical AdvisorPermit SectionAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

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.

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

SupervisorCompliance Determination UnitAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

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

Mr. George CzerniakAir and Radiation BranchEPA Region V77 West Jackson BoulevardChicago, Illinois 60604

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

U.S. Environmental Protection AgencyClean Air Markets Division1200 Pennsylvania Avenue NW (6204N)Washington, D.C. 20460

B-1

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

Permit Number: 12300054 - 002

12/16/02

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

half-year starting 12/11/2001 . If thevolume-weighted average of the total mass ofVOC per volume of coating solids is notgreater than the limit, then a report stating thisshall be submitted to the Administratorsemiannually.

GP002

Semiannual Deviations Report due 30 days after end of each calendarhalf-year starting 12/11/2001 . 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 occured, the Permittee shall submit thereport stating no deviations.

Total Facility

Compliance Certification due 30 days after end of each calendar yearstarting 12/11/2001 (for the previous calendaryear). To be submitted on a form approvedby the Commissioner <, both to theCommissioner, and to the U.S. EPA regionaloffice in Chicago. This report covers alldeviations experienced during the calendaryear. The EPA copy shall be sent to: Mr.George Czerniak, Chief, Air Enforcement andCompliance Assurance Branch, Air andRadiation Division, EPA Region V, 77 WestJackson Boulevard, Chicago, Illinois 60604.

Total Facility

B-2

APPENDIX MATERIAL Facility Name: Rexam Beverage Can Company – St. Paul (Eva) Permit Number: 12300054-002

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(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)

5. blueprint copiers and photographic processes; Minn. R. 7011.0110 (opacity)

8. cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners.

Minn. R. 7011.0610 + 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 hot-water heaters and approximately 2 natural-gas-fired space heaters and 2 make-up air units. These are

Tanks: Minn. R. 7011.2300 (VOCs, HAPs); Fuel-burning: Minn. R. 7011.0510/0515 (PM and opacity)

Minn. R. 7007.1300,


General Applicable

Requirement(s)

each considered an insignificant source.

Under Minn. R. 7007.1250, subp. 1(A), the Permittee may add insignificant activities to the stationary source throughout the term of the permit without getting permit amendments. Certain exclusions apply and are listed in Minn. R. 7007.1250, subp. 2. In addition, this permit specifically prohibits the Permittee from making any modifications that would make the source major under NSR. The following table is a listing of the insignificant activities that the Permittee is somewhat likely to add and their associated applicable requirements.

Minn. R. 7007.1300,


General Applicable

Requirement(s)

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

Minn. R. 7011.0510/0515 (PM and opacity)

3(B)(1) Furnaces, boilers, and incinerators:

1. infrared electric ovens; and Minn. R. 7011.0110 (opacity)

3(H) Miscellaneous:

4. brazing, soldering or welding equipment; Minn. R. 7011.0715 (PM and opacity)

5. blueprint copiers and photographic processes; Minn. R. 7011.0110 (opacity)

8. cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners.

Minn. R. 7011.0610; Minn. R. 7011.0715 (PM and opacity)

3(J) Fugitive Emissions from unpaved roads and parking lots. Minn. R. 7011.0150 (PM)

3(K) Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source, such as spray painting of buildings, machinery, vehicles, and other supporting equipment.

Minn. R. 7011.0710/0715 (VOC)

TECHNICAL SUPPORT DOCUMENT For

DRAFT AIR EMISSION PERMIT NO. 12300054-002 This technical support document is for all the interested parties of the draft permit. The purpose of this document is to set forth the legal and factual basis for the draft permit conditions, including references to the applicable statutory or regulatory provisions. 1. General Information 1.1. Applicant and Stationary Source Location:

Facility Address and contact (SIC Code: 3411)

Rexam Beverage Can Company 139 Eva Street

St. Paul Ramsey County

David Birkemeier (651) 227-7211 1.2. Description Of The Facility This facility produces two-piece aluminum cans. There are three can production lines, each of which consists of a can forming section, a printing area and oven, and an inside spray area and oven. This facility is a major source under the Prevention of Significant Deterioration program for volatile organic compound (VOC) emissions from printing and inside spray operations. The printer/ovens are subject to the New Source Performance Standards (NSPS) for Beverage Can Coating. The Spray machines are not subject to NSPS. 1.3 Description of the Activities Allowed By This Permit Action The primary purpose of this amendment was to increase the amount of aluminum cans produced per minute from 3,600 (current maximum capacity) to 4,380 from all three lines. Replacing an existing Cupper with a refurbished Cupper would facilitate the projected increase in aluminum can production. This project is considered “Debottlenecking”. Even though the Cupper is not an emission unit, plant-wide VOC emissions increase (Printer/Ovens and Spray Machines) is evaluated as a result of the proposed modification. For calculating the emissions change resulting from the modification and debottlenecked units, U.S. Environmental Protection Agency (EPA) requires that the emissions change from these units be based on their allowable emissions after the change minus their current actual emissions. This permit amendment also revises GP 001 in the permit to include other emission units subject to Direct Heating Equipment (EU 011 through EU 020). This is a major amendment to the existing Part 70 permit with Title I Conditions to make a Synthetic Minor Modification.

Permit Action Number: 12300054-002 Date: 2/18/2004

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1.4. Facility Emissions:

Emissions Associated With the Modification – Tons Per Year

Limited Potential to Emit after modification = 224.0 tons per year of VOCs Current Actual Emissions (average for years 2000 and 2001) = 185.3 tons per year of VOCs Significant Emissions Increase from the proposed project: 224.0 – 185.3 = 38.7 tpy of VOCs

Table 1. Total Facility Potential to Emit Summary

Total Facility – Including Modification

PM tpy

PM10 tpy

SO2 tpy

NOx tpy

CO tpy

VOC tpy

Pb tpy

Single HAP tpy

All HAPs

tpy Limited Potential Emissions (per Title V permit – except VOC)

30.7 30.7 0.1 17.0 3.6 224.0 0.0 42.6 65.6

Actual Emissions* 0.53 0.53 0.04 6.97 5.9 183.4 0.0 NR NR * Per the 2001 Emissions Inventory Summary NR – Not Reportable

Table 2. Permit Action Classification

Classification (put x in appropriate

box) Major/Affected

Source *Synthetic Minor *Minor

PSD (list pollutant)

VOC PM, PM10, SO2, NOx, CO, HAPs

NAAR (list pollutant) None None None Part 70 Permit Program (list pollutant) VOC PM, PM10,

SO2, NOx, CO, HAPs

* Refers to potential emissions that are less than those specified as major by 40 CFR 52.21, 40 CFR pt. 51 Appendix S, and 40 CFR pt. 70. 2. Regulatory and/or Statutory Basis Summary Regulatory and/or Statutory Basis of the Emission or operational Limit Regulatory Overview of Units Affected by the Modification


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Table 3. Regulatory Overview

Total Facility/

GP

Applicable Regulations

Comments

TF 40 CFR Section 52.21 and Minn. R. 7007.3000

Title I Condition: Limit taken to avoid a major modification for VOCs. The new total facility limit for VOCs is less than or equal to 224.0 tons per year, calculated using 12-month Rolling Sum.

TF 40 CFR Section 52.21 and Minn. R. 7007.3000

Title I Condition: Limit taken to avoid a major modification for VOCs. Maximum capacity without making physical change or debottlenecking in the future: 4,380 cups per minute (two Cuppers combined) 1,450 cans per minute (each Printer/Oven) 1,500 cans per minute (each Spray Machine)

GP001 Minn. R. 7011.0610 Direct-heating equipment rule – applies to ovens GP003 40 CFR Section

52.21 and Minn. R. 7007.3000

Title I Condition: Limit taken to avoid a major modification for VOCs. GP003 previous VOC limit was 255 tons per year. This limit was revised to reflect the new total facility VOC limit of less than or equal to 224.0 tons per year.

3. Technical Information Rexam Beverage Can Company – St. Paul currently operates with two Cuppers, each of 1,860 cups per minute capacity. This facility is proposing to replace one of the cuppers with a cupper of higher capacity (2,520 cups per minute). After the proposed replacement is done, Rexam can produce 4,380 cups per minute. The permit amendment application as submitted on June 19, 2002, requested authorization to install a new short stroke cupper, to be able to produce 4,060 cans/minute. The Permittee anticipated the maximum potential increase in VOC emissions of 36 tons per year, and that the proposed project would have been a minor amendment to the total facility permit. Debottlenecking: This project of replacing an existing Cupper (which is a bottleneck in the process) with an increase capacity constitutes debottlenecking. Per EPA memo dated November 23, 1998, EPA provided guidance on “What constitutes debottlenecking, and how are the emission increases from debottlenecked units calculated?” According to EPA, when calculating the emissions change resulting from the modification and debottlednecked units, EPA requires that the emissions change from the debottlenecked units be based on their allowable emissions after the change minus their current actual emissions (emitted during the 2-year period which precedes the change. For Rexam facility it’s the average of 2000 and 2001 VOC emissions. Cuppers are not considered as emission units. Further, the maximum emissions after the change are based on the future amount of cans that can be processed through the printer/ovens and spray machines.


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Total facility VOC limit: The MPCA staff evaluated different options to provide flexibility as the Permittee requested to be able to produce maximum amount of cans per year and also to be able to keep this modification as a Synthetic Minor modification under PSD. Per EPA guidance on calculating emissions for debottlenecked emission units, and to keep the VOC emissions increase from the modification less than 40 tons per year, a new VOC limit is established in the permit for VOC emissions less than or equal to 224.0 tons per year. The Permittee is proposing lower VOCs for the coatings. The future potential (limited) of the facility is kept at 224.0 tons per year, while the past actual emissions were at 185.0 tons per year of VOCs. Note: The VOC limits for GP002 (printers) in this permit was retained from the previous permit action. However, the VOC limit for GP003 (spray machines) in this permit was lowered from 255 tons per year (established in the previous permit actions) to 224 tons per year, and this VOC limit is also the limited allowable VOC emissions for the entire facility (224 tons per year). The Permittee has the flexibility to increase or decrease VOC emissions from GP002 or GP003 in order that the limited allowable VOC emissions for the entire facility are below 224 tons per year. Maximum capacity of Cuppers, Printer/Ovens, and Spray Machines: Based on the information provided by the Permittee and not to authorize any future debottlenecking or physical modifications without proper permit amendments and or New Source Review, this permit amendment limits the maximum capacity of Cuppers, Printers/Ovens and Spray Machines. EAW/EIS applicability: The proposed replacement of Cupper, which results in an increase of 39 tons per year of VOCs is not subject to Environmental Review process. NSPS: Only GP002 emission units are subject to 40 CFR 60, subp. WW CAM: There is no pollution control equipment at this facility and hence CAM is not applicable. NESHAPs: This facility is a major source HAPs and therefore is subject to future MACT Subpart KKKK Metal Can (Surface Coating). 112(g) Applicability: Not applicable. The new Cupper is not considered an emission unit and hence this modification is not considered construction or reconstruction of an emission source for HAPs. Periodic Monitoring – similar to the requirements under Title V program 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. To achieve this objective, EPA issued guidance (September 15, 1998), memorandum Periodic Monitoring Guidance for Title V Operating Permits Programs on periodic monitoring requirements for permitted sources.


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In evaluating the monitoring included in the permit, the MPCA considered the following as per the September 15, 1998 guidance: • The likelihood of violating the applicable requirement • Whether add-on controls are necessary to meet the emission limit • 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 • The kind of monitoring found on similar units The following table summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate:

Emission Units Subject to Periodic Monitoring Facility/GP Emission Limit Additional

Monitoring Discussion

Total Facility VOC usage limit <= 224.0 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.

GP002 - printers VOC content None NSPS-required monitoring is adequate. VOC usage limit = 82 tpy on

a 12-month rolling sum Daily recordkeeping of usage; on-going MSDS records of coating contents; monthly calculation


GP003 – spray machines

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

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


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 92%. The PTE of the spray operations are 2.18 lb/hr each.

Public Comments: There were no comments received during the 30-day public comment period 4. Conclusion


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Based on the information provided by Rexam Beverage Can Company – St. Paul, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 12300054-002 and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: John Chikkala, Robert Berg Attachment: Emission calculation spreadsheets and MSDS information

Documents

AIR EMISSION PERMIT NO. 12300054- 002 IS ISSUED TO Rexam ...€¦ · Title I Condition: Monitoring for Limit to avoid classification as major modification under 40 CFR 52.21 and Minn