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Home My WebLink About20181902.tiffCOLORADO Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 June 13, 2018 Dear Sir or Madam: On June 14, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Carestream Health, Inc. - Carestream Health Colorado. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., John W. Hickenlooper, Governor pu.�1is Review D(o-d5- l8 Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer cc . PLCTPI Iu NO) Et -L( , 'PIN (ER/CI+ISMICk) 64,- 19-18 2018-1902 Air Pollution Control Division Notice Of A Proposed Renewal Title V Operating Permit Warranting Public Comment Website Title: Carestream Health, Inc. - Carestream Health Colorado - Weld County Notice Period Begins: June 14, 2018 NOTICE is hereby given that an application to renew an Operating Permit has been submitted to the Colorado Air Pollution Control Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for the following source of air pollution: Applicant: Carestream Health, Inc. 2000 Howard Smith Ave West Windsor, CO 80550 Facility: Carestream Health Colorado 2000 Howard Smith Ave West Windsor, CO 80550 Carestream Health, Inc. has applied to renew the Operating Permit for the Carestream Health Colorado in Weld County, CO. This facility is a manufacturer of photographic supplies. This modification will add a Coating Assessment Laboratory, two boilers 206 mmBtu/hr each, five corona treater units, and address a calculation error. This modification will result in an increase in VOC of 8.12 tpy, an increase in PM of 7.86 tpy, an increase in PM10 of 7.82 tpy, an increase in ozone of 7 tpy, an increase in NOx of 133.4 tpy, and an increase of CO of 96.5 tpy. A copy of the application, including supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit 06OPWE228 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. The Division has made a preliminary determination of approval of the application. Based on the information submitted by the applicant, the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Ramazan Spencer of the Division at (303) 692-3201 to obtain additional information. Any interested person may submit written comments to the Division concerning 1) the sufficiency of the preliminary analysis, 2) whether the permit application should be approved or denied, 3) the ability of the proposed activity to comply with applicable requirements, 4) the air quality impacts of, alternatives to, and control technology required on the source or modification, and 5) any other appropriate air quality considerations. Any interested person may submit a written request to the Division for a public comment hearing before the Colorado Air Quality Control Commission (Commission) to receive comments regarding the concerns listed above as well as the sufficiency of the preliminary analysis and whether the Division should approve or deny the permit application. If requested, the hearing will be held before the Commission within 60 days of its receipt of the request for a hearing unless a longer time period is agreed upon by the Division and the applicant. The hearing request must: 1) identify the individual or group requesting the hearing, 2) state his or her address and phone number, and 3) state the reason(s) for the request, the manner in which the person is affected by the proceedings, and an explanation of why the person's interests are not already adequately represented. The Division will receive and consider the written public comments and requests for any hearing for thirty calendar days after the date of this Notice. COLORA.00 114 Colorado Department of Public Health and Environment OPERATING PERMIT Carestream Health, Inc. First Issued: September 1, 1999 Renewed: DRAFT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: FACILITY ID: RENEWED: EXPIRATION DATE: MODIFICATIONS: Carestream Health Colorado 123/6350 DRAFT DRAFT See Appendix F of Permit OPERATING PERMIT NUMBER 06OPWE288 Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et seq Supp. and applicable rules and regulations. ISSUED TO: Carestream Health, Inc. 2000 Howard Smith Ave West Windsor, CO 80550 INFORMATION RELIED UPON Operating Permit Renewal Application Received: And Additional Information Received: Nature of Business: Primary SIC: PLANT SITE LOCATION: 2000 Howard Smith Ave West Windsor, CO 80550 Weld County October 29, 2008 April 24, 2009, May 27, 2009, May 11, 2010, June 6, 2014, December 8, 2017, & April 18, 2018 Manufacturer of photographic supplies 3861 RESPONSIBLE OFFICIAL Name: Christopher L. Schmachtenberger Title: Site Manager Carestream Health, Inc. Phone: (970)304-4712 FACILITY CONTACT PERSON Name:. Laura Jackson Pales Title: Environmental Engineer Carestream Health, Inc. Phone: (970) 304-4768 SUBMITTAL DEADLINES First Semi -Annual Monitoring Period:. Subsequent Semi -Annual Monitoring Periods: Semi -Annual Monitoring Reports: First Annual Compliance'Per7iod: Subsequent!. Annual Compliance Periods:'. Annual Compliance Cern cation: October l 2010 — December 31, 2010 January I June 30, July 1 December 31 Due February 1, 2011 & August 1, 2011 & subsequent years October 1.2010 - December, 1, 201 a anuary , December °31 tie February 1, 2011 & subsequent years Note that the Semi -Annual Monitoring Reports and Annual Compliance Certifications must be received at the Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the purposes of determining the timely receipt of those reports/certifications. TABLE OF CONTENTS: SECTION I - General Activities and Summary 1 1. Permitted Activities 1 2. Nonattainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 2 3. Accidental Release Prevention Program (112(r)) 3 4. Summary of Emission Units 3 5. Alternate Operating Scenarios 3 6. Compliance Assurance Monitoring (CAM) 4 SECTION II - Specific Permit Terms 5 1. Sensitizing Complex and Support Manufacturing (AIRS# 001, 002, and 003) 5 2. Coating Assessment Laboratory (CAL). (AIRS# 005) 12 3. S070 - Two Natural Gas and Diesel Fueled Boilers (206 mmBtu/hr each, AIRS# 004)18 4. Degreasing Units (C-15, C-20, C-41, C-48, C-50, C-70) 30 SECTION III - Permit Shield 32 1. Specific Non -Applicable Requirements 32 2. General Conditions 33 3. Stream -lined Conditions 33 SECTION IV - General Permit Conditions (Ver. 5/22/12) 34 1. Administrative Changes 34 2. Certification Requirements 34 3. Common Provisions 35 4. Compliance Requirements 39 5. Emergency Provisions 40 6. Emission Controls for Asbestos 41 7. Emissions Trading, Marketable Permits, Economic Incentives 41 8. Fee Payment 41 9. Fugitive Particulate Emissions 41 10. Inspection and Entry 41 11. Minor Permit Modifications 42 12. New Source Review 42 13. No Property Rights Conveyed 42 14. Odor 42 15. Off -Permit Changes to the Source 43 16. Opacity 43 17. Open Burning 43 18. Ozone Depleting Compounds 43 19. Permit Expiration and Renewal 43 20. Portable Sources 44 21. Prompt Deviation Reporting 44 22. Record Keeping and Reporting Requirements 45 23. Reopenings for Cause 46 24. Section 502(b)(10) Changes 46 TABLE OF CONTENTS: 25. Severability Clause 46 26. Significant Permit Modifications 47 27. Special Provisions Concerning the Acid Rain Program 47 28. Transfer or Assignment of Ownership 47 29. Volatile Organic Compounds 47 30. Wood Stoves and Wood burning Appliances 48 APPENDIX A Inspection Information 50 Directions to Plant: 50 Safety Equipment Required: 50 Facility Plot Plan- 50 List of Insignificant Activities: 50 APPENDIX B Reporting Requirements and Definitions 54 APPENDIX C Required Format for Annual Compliance Certification Reports 62 APPENDIX D Notification Addresses 65 APPENDIX E Permit Acronyms 66 APPENDIX F Permit Modifications 68 APPENDIX G Equipment List 69 APPENDIX H Operating and Maintenance Plan 70 Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 1 1. Permitted Activities 1.1 SECTION I - General Activities and Summary Carestream Health, Inc. Colorado (CHC) is a paper and web manufacturing and coating facility located at 2000 Howard Smith Avenue West, Windsor, CO 80550 in Weld County. The facility is located approximately two miles southeast of Windsor. The campus consists of multiple buildings containing a variety of equipment used in the manufacturing processes. A polyester film support base is produced for X-ray products in Building C-50 — Innovative Polyester Manufacturing (IPM). IPM produces a flexible thermoplastic polyester film from polyester pellets. This process involves heating the plastic using heat transfer fluid and friction. The polyester is extruded and allowed to cool and harden. The plastic is then reheated, processed, coated with several sublayers, cooled, and wound into large rolls. C-50 also houses mechanical shops that support the process and cleaning services to ensure quality. Medical x-ray film, color photographic paper, and contract manufacturing products are produced in the Sensitizing Complex (Buildings C-40, C-41, C-42, and C-43). Light sensitive emulsions consisting of silver halide and other chemicals are applied to a support to produce photographic film and paper. This process involves mixing raw chemicals together into solutions and dispersions. These solutions and dispersions are mixed with gels and coated onto plastic or paper. The coating is dried and rolled onto master rolls. The Sensitizing Complex also houses mechanical shops to support the process, labs to provide quality control and new product testing, and cleaning services to ensure quality. In addition, C- 43 also houses the Coating Assessment Laboratory, which provides quality assessments of new coatings and substrate configurations. Building C-46 houses a high efficiency silver recovery operation, which results in a concentrated silver mud recovered from coating formulation waste streams. The mud is shipped offsite for metal recovery. CHC leases space in Building C-15, where CHC operates a paper finishing process. This process includes slitting the paper and chopping it into retail dimensions. This paper is packaged and prepared for retail distribution. Building C-20 is the warehousing and distribution facility. It also includes a machine shop and forklift shop to support the entire campus. The process includes receiving raw materials and products, onsite storage, and national/international distribution of products. The machine shop produces custom parts and equipment for operations. The forklift shop maintains mobile equipment for the facility. Building C-70 houses the main central utilities operations including two boilers, each rated at 206 mmBtu/hour, that supply steam for the site. Natural gas is used as primary fuel and No. 2 fuel oil is used as back up fuel. Utilities support operations occur in Buildings C-48, C-59, C-61, and C-63. Utilities include steam production, chilled and cooling water production, compressed air service, industrial wastewater and service water treatment. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 2 Buildings C-80, C-81, and C-82 are associated with the onsite industrial wastewater treatment plant. The facility is located in Weld County, near Windsor. This facility is located in an area classified as attainment for all pollutants except ozone. It is classified as nonattainment for the 8 -hr ozone standard and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. Wyoming is an affected state within 50 miles of the plant. The following Federal Class I designated areas are within 100 kilometers of the plant: Rocky Mountain National Park and Rawah National Wilderness Area. 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. This Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet the applicable substantive New Source Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3, Part C shall become new applicable requirements for purposes of this operating permit and shall survive reissuance. This permit incorporates the applicable requirements from the following construction permit: 96WE473, 10WE1575, 13WE1752 1.3 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State -only enforceable conditions are: Permit Condition Number(s): Section IV — 3.g (last paragraph), 14, & 18 (as noted). 1.4 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit. 2. Nonattainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 2.1 This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC or NOx > 100 Tons/Year (TPY)). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) for VOC or NOx or a modification which is major by itself (Potential to Emit of > 100 TPY of either VOC or NOx) may result in the application of the NANSR review requirements. 2.2 Based on the information provided by the applicant, this source is categorized as a minor stationary source for PSD as of the issue date of this permit. Any future modification which is major by itself (Potential to Emit > 250 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. The boilers are a listed source for PSD purposes and therefore are categorized as a major source for PSD Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 3 purposes (PTE > 100 tons/year). (Colorado Regulation No. 3, Part B, Section IV.D.3). Future modifications related to the boilers resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) or a modification which is major by itself (Potential to Emit of > 100 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. 2.3 There are no other Operating Permits associated with this facility. 3. Accidental Release Prevention Program (112(r)) Based on the information provided by the applicant, this facility is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act). 4. Summary of Emission Units 4.1 The emissions units regulated by this permit are the following: AIRS ID" Facility Identifier Description Pollution Control Device Construction Permit 001 SO40 Sensitizing Complex, Buildings C-40, C-41, C- 42, C-43, C-46 j 96WE473 002 S050 Support Manufacturing, Building C-50 Railroad Car Unloading / Thy Chemical Weighing Room / PET unloading HEPA filter 003 S040 Five corona treaters used in web coating operations. (sensitizing) ' _ 13WE1752 005 S040 Coating Assessment Laboratory 004 S070 Two 206 mmBtu/hr boilers 10WE1575 r ,.<„mac � Degreasing Units (C-15, C-20, C-41, C-48, C - 50, C -70(x2)) Appendix G lists specific equipment in each of the Buildings and associated MRS Identification Numbers. 4.2 Equipment Replacement This permit covers only the specific existing equipment listed in Appendix G of this permit. 5. Alternate Operating Scenarios 5.1 The permittee shall be allowed to make the following changes to method of operation without applying for a revision of this permit. This only applies to the Coating Assessment Laboratory. See Section II for specific permit terms applicable to these scenarios. 5.1.1 The Coating Assessment Laboratory may perform metal coil surface coating operations to evaluate quality and commercial production feasibility. This operation is subject to New Source Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 4 Performance Standards Subpart TT. Reference Section II, Condition 2.3 for applicable requirements. 5.1.2 The Coating Assessment Laboratory may perform flexible vinyl and urethane coating and printing operations to evaluate quality and commercial production feasibility. This operation is subject to New Source Performance Standards Subpart FFF. Reference Section II, Condition 2.4 for applicable requirements. 5.1.3 The Coating Assessment Laboratory may perform polymeric coating operations to evaluate quality and commercial production feasibility. This operation is subject to New Source Performance Standards Subpart VVV. Reference Section H, Condition 2.5 for applicable requirements. 5.1.4 The permittee shall notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation that would trigger additional applicable subparts. The notification shall be submitted in form of a letter. The letter shall include; reason for submittal, reference to permit, specification of the operational changes, the applicable subpart(s), date subpart(s) became applicable, and applicable requirements. 5.1.5 Within one hundred and eighty days (180) after commencement of any Alternate Operating Scenario, compliance with the newly applicable conditions shall be demonstrated to the Division. It is the permittee's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit or enforcement action by the Division. (Colorado Regulation No. 3, Part B, III.G.2). 5.1.6 All emission limits in this operating permit shall be met. Emissions shall be estimated as set forth in Section II, Condition 2.1. 5.1.7 The permittee shall, contemporaneously with making a change from one operating scenario to another, record in a log at the permitted facility a record of the scenario under which it is operating. (Colorado Regulation No. 3, Part A, IV.A.1, as referred to in Part C, V.C.14). This log shall be made available to the Division for inspection upon request. 6. Compliance Assurance Monitoring (CAM) 6.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre -control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64 as adopted by reference into Colorado Regulation No. 3, Part C, Section XIV: None. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 5 SECTION II - Specific Permit Terms 1. Sensitizing Complex and Support Manufacturing (AIRS# 001, 002, and 003) Parameter Condition Number Limitation Compliance Emission Factor Monitoring Method Interval VOC 1.1 48.3Tons/Yr See Condition 1.1 Recordkeeping Calculation Monthly PM 15.0 Tons/Yr PMIo 15.0 Tons/Yr Ozone (O3) 7.0 Tons/Yr Opacity 1.2 Not to exceed 20%, except as provided for below Nature of the Processes Annually Certain Operating Conditions - Not to exceed 30%, for a period or periods aggregating more than six (6) minutes in any 60 consecutive minutes Consumption 1.3 See Condition 1.3 Recordkeeping Monthly Use of corona treaters 1.4 191,780 kW -hr per year Recordkeeping Monthly MACT Subpart JJJJ 1 6 No more than 5% of the organic HAP applied for each month (95% reduction) OR No more than 4 % of the mass of coating materials applied for each month OR No more than 20 % of the mass of coating solids applied for each month Calculation Monthly Reg 7, Section IX 1.7 2.9 lb/gc (pounds of solvent VOC per gallon of coating minus water and "exempt" solvents) See Condition 1.7.1 Recordkeeping and Calculation Daily See Condition 1.7.7.1 Note: See Equipment List, Appendix G 1.1 Emissions shall not exceed the rates listed in the above Table 1(Construction Permit 96WE473 as modified under the provisions of Section I, Condition 1.3). Compliance with annual limits shall be determined on a rolling twelve month total. By the 45th day after the close of each month a new twelve month total shall be calculated using the previous twelve months' data. The permit holder shall calculate monthly emissions using the procedures described below and keep a compliance record on site for Division review. 1.1.1 VOC Emissions shall be calculated as follows: Building C-40, C-41, C-42, C-43, & C-46: Except for the separately listed chemicals, mass balance shall be used to estimate emissions using the following equation: VOC tons tons = VOC consumption month month Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 6 1.1.1.2 Building C-50: Mass balance shall be used to estimate emissions using the following equation: VOC tons tons = VOC consumption month month For thermal degradation byproducts in extruded material: tons lbs VOC Million lbs 1 ton VOC month= 64 Million lbs extruded x Extruder Throughput month x 2000 lbs For pre -polymer byproducts removed by molecular sieve regenerations: tons lbs VOC Regenerations 1 ton VOC month= 3.5 Regeneration x month x 2000 lbs 1.1.2 O3 Emissions shall be calculated as follows: 1.1.2.1 Building C-40: Corona Discharge Treaters: tons lbs 03 kWhr 1 ton 03 month = 0.073 kWhr x Energy Consumption month x 2000 lbs 1.1.3 PM/PMio Emissions shall be calculated as follows: 1.1.3.1 Building C-50 : Railroad Car PET Powder Unloading: tons gr hr min 1 lb 1 ton PM/PM10 month= = 0.01 dscf x 888 dscfm x Usage month x 60 hr x 7000 gr x 2000 lbs Railroad Car PET Pellet Unloading : tons lb lb PM 1 ton PM/PM10 month= PET month x (1 0.97) x 3.47E-6 lb PET x 2000 lbs Three Pellet Grinders (total): PM/PM10 tom = PET Pellets Extruded x 2.9E lbs_5 lb pm x 1 ton month month lb pellet extruded 2000 lbs Chemical Weighing Hood: tons gr hr min 1 lb 1 ton PM/PM10 yr = 0.04 dscf x 8500 dscfm x 365—yr x 60 hr x 7000 gr x 2000 lbs Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 7 501 Machine: tons lbs 1 ton PM/PM.° month= Resorcinol Consumed month x 2000 lbs The permittee shall maintain emission calculation records on site for Division inspection upon request. 1.2 Except as provided in Colorado Regulation No. 1, Section II.A.4, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement on which these standards are based is EPA Method 9 (40 CFR Part 60, Appendix A (July 1992)) in all subsections of Section II of Regulation No. 1. (Construction Permit 96WE473, and Colorado Regulation No 1, Section II.A.1). No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment, which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.4). The PM emission sources located at this facility are the chemical making, polymer unloading, pellet unloading, three pellet grinders, chemical melting kettles, and chemical weighing processes. When operated in their current configuration and method, no opacity is generated. By certifying compliance with this Condition 1.2, the source is certifying that no changes have been made to the equipment, process, or operation such that opacity is generated. In addition, the building C-50 Rail Car Polymer Unloading, and Dry chemical Weighing Room HEPA filters shall be replaced at least annually. The HEPA filter associated with the C-50 pellet unloading shall be replaced at least annually, unless the process is not used during the previous year. In which case, the HEPA filter shall be replaced just prior to startup of any pellet unloading activities. The dust collector associated with the C-50 grinders shall be operated and maintained in accordance with manufacturer's recommendations. Such recommendations and practices shall be in written format and made available for Division inspection upon request. 1.3 The permittee shall maintain records of the monthly consumption of VOC containing materials, including throughput data, in -process inventory, material safety data sheets, number of Building C-50 molecular sieve regenerations, and off -site waste shipment information, as necessary in order to estimate emissions as set forth in Section II, Condition 1.1. In addition, the permittee shall maintain records of Resorcinol consumption. These records shall be kept on site for Division inspection upon request. (Colorado Regulation No. 3, Part B, III.A.4 and IV.E, and Construction Permit 90WE0466.) 1.4 Total operation of the corona treaters shall not exceed 191,780 kW -hr per year (as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part B, Section III.A.6, and Part C, Section X based on maximum rate identified in an APEN filed by the source dated 4/22/2009). A twelve-month rolling total shall be maintained for demonstration of compliance with the annual limitation. By the end of each month a new twelve-month total shall be calculated using the previous twelve months' data. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 8 1.5 The permittee shall comply with the provisions of Regulation No. 3 concerning APEN reporting. Emission factors and/or other emission estimating methods that are specified within this permit. cannot be adjusted without requiring a permit modification. Emission factors and/or other emission estimating methods used to comply with the reporting requirements of Regulation No. 3, Part A, Section II can be updated and modified as specified in that Section. These changes by themselves do not require any permitting activities though the resulting emission estimate may trigger permitting activities. 1.6 The coating line is subject to 40 CFR Part 63, Subpart JJJJ — National Emission Standards for Hazardous Air Pollutants: Paper and Other Web Coating, as adopted by reference in Colorado Regulation No. 8, Part E, Section III, as follows: [The requirements below reflect the current rule language of 40 CFR Part 63 Subpart JJJJ published in the Federal Register on 12/04/2002. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63, Subpart JJJJ.] 1.6.1 If you own or operate any affected source that is subject to the requirements of Subpart JJJJ, you must comply with these requirements on and after the compliance dates as specified in §63.3330 (§ 63.3320(a)). This unit is an existing source and its compliance date was December 5, 2005 per § 63.3330(a). 1.6.2 You must limit organic HAP emissions to the level specified in Conditions 1.6.2.1, 1.6.2.2 or 1.6.2.3 below: 1.6.2.1 No more than 5 percent of the organic HAP applied for each month (95 percent reduction) (§ 63.3320(b)(1)); or 1.6.2.2 No more than 4 percent of the mass of coating materials applied for each month at existing affected sources (§ 63.3320(b)(2)); or 1.6.2.3 No more than 20 percent of the mass of coating solids applied for each month (§ 63.3320(b)(3)). The source must indicate one of the three emission limit options that will be used and notify the Division of that choice in the notification of compliance status and must monitor and report compliance results accordingly. If a source decides to change to other emission limit options, the Division must be notified in the semi-annual reports specified in Condition 1.6.5. The permittee has previously indicated that they would meet the limitation in Condition 1.6.2.2. 1.6.3 The organic HAP content, volatile organic and coating solids content and volatile matter retained in the coated web or otherwise not emitted to the atmosphere shall be determined using the procedures specified in §§ 63.3360(c), (d) and (g), respectively (§ 63.3360(a)(1)). Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 9 1.6.4 Demonstrate that the monthly average as -applied organic HAP content of all coating materials applied at an existing affected source is less than 0.04 kg organic HAP per kg of coating material applied, and all coating materials applied at a new affected source are less than 0.016 kg organic HAP per kg of coating material applied, as determined by Equation 4 of § 63.3370 (§ 63.3370(c)(3). 1.6.5 The permittee shall submit semi-annual compliance reports as required by § 63.3400(c) and startup, shutdown and malfunction reports as required by § 63.3400(g). 1.6.6 The permittee shall retain records as specified in §§ 63.3410(a) and (b). 1.6.7 Table 2 to Subpart JJJJ specifies the provisions of Subpart A of 40 CFR Part 63 that apply if you are subject to Subpart JJJJ, such as startup, shutdown, and malfunction plans (SSMP) in §63.6(e)(3) for affected sources using a control device to comply with the emission standards (§ 63.3340). The general provisions that apply to this source, include but are not limited to the following: 1.6.7.1 Prohibited activities in 40 CFR Part 63 Subpart A § 63.4. 1.6.7.2 Operation and maintenance requirements in 40 CFR Part 63 Subpart A § 63.6(e)(1). 1.6.7.3 Startup, shutdown and malfunction plan requirements in 40 CFR Part 63 Subpart A § 63.6(e)(3). 1.6.7.4 Performance test requirements in 40 CFR Part 63 Subpart A § 63.7. 1.6.7.5 Monitoring requirements in 40 CFR Part 63 Subpart A § 63.8. 1.6.7.6 Notification requirements in 40 CFR Part 63 Subpart A § 63.9. 1.6.7.7 Recordkeeping requirements in 40 CFR Part 63 Subpart A § 63.10. 1.7 Volatile Organic Compound (VOC) emissions from coating operations are subject to the requirements in Colorado Regulation No. 7, Section IX, as follows: 1.7.1 VOC emissions from coating operations shall not exceed 2.9 lb/gc. Lb/gc is the abbreviation for (avoirdupois) pounds of solvent VOC per gallon of coating (minus water and "exempt" solvents, as defined in Section II.B.). (Colorado Regulation No. 7, Section IX.I and IX.J) 1.7.2 Test Methods and Procedures 1.7.2.1 The owner or operator of any VOC source required to comply with Colorado Regulation No. 7, Section IX.A.3.a shall, at their own expense, demonstrate compliance using EPA reference method 24 of 40 CFR Part 60 for surface coatings, and reference method 25 and reference methods 1 through 4 for add-on controls. (Colorado Regulation No. 7, Section IX.A.3.a) 1.7.2.2 The test protocol should be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No test shall be Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 10 conducted without prior approval from the Division. (Colorado Regulation No. 7, Section IX.A. 3.b) 1.7.2.3 The Division may use independent tests to verify test data submitted by the source operator or owner. The test methods shall be those listed in Condition 1.7.2.1 above and the Division test results shall take precedence. (Colorado Regulation No. 7, Section IX.A. 3.c) 1.7.2.4 The Division may accept, instead of the testing required in this subsection, a certification by the manufacturer of the composition of the coatings if supported by actual batch formulation records. The owner or operator of the VOC source required to comply with Colorado Regulation No. 7, Section IX.A. 3.d shall obtain certification from the coating manufacturer(s) that the test method(s) used for determination of VOC content meet the requirements specified in Subsection IX.A.3.a. The owner or operator shall have this certification readily available to Division personnel, in order to allow the results to be used in the daily compliance calculations specified in Subsection IX.A.10. (Colorado Regulation No. 7, Section IX.A. 3.d) 1.7.3 To determine compliance with applicable surface coating standards, samples shall be taken from the coating as freshly delivered to the reservoir of the coating applicator. (Colorado Regulation No. 7, Section IX.A.4) 1.7.4 Fugitive emission control 1.7.4.1 Control techniques and work practices shall be implemented at all times to reduce VOC emissions from fugitive sources. Control techniques and work practices include, but are not limited to (Colorado Regulation No. 7, Section IX.A.7.a): a tight -fitting covers for open tanks; b covered containers for solvent wiping cloths; c proper disposal of dirty cleanup solvent. 1.7.4.2 Emissions of organic material released during clean-up operations, disposal, and other fugitive emissions shall be included when determining total emissions, unless the source owner or operator documents that the VOCs are collected and disposed of in a manner that prevents evaporation to the atmosphere. (Colorado Regulation No. 7, Section IX.A.7.b) 1.7.5 Recordkeeping procedures shall follow the guidance in "Recordkeeping Guidance Document for Surface Coating Operations and the Graphic Arts Industry," July 1989, EPA 340/1-88-003. (Colorado Regulation No. 7, Section IX.A.8.c) 1.7.6 No owner or operator of a source of VOCs subject to Regulation No. 7, Section IX.A.9.a.(1) shall operate, cause, allow or permit the operation of the source, unless: For each category of surface coating as specified in Sections IX.B through IX.M, the owner or operator of a surface coating line or facility subject to that section does not cause, allow or permit the discharge into the atmosphere of any VOCs in excess of the specified emission limit, calculated as delivered to Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 11 the coating applicator or as applied to the substrate, whichever is greater. (Colorado Regulation No. 7, Section IX.A.9.a.(1)) 1.7.7 Compliance Calculation Procedures 1.7.7.1 Compliance with the emission limitations shall be determined on a daily basis. Sources may request a revision of the State Implementation Plan for longer times for compliance determination. (Colorado Regulation No. 7, Section IX.A.10.a) The permittee shall record material usage on a daily basis. However, daily compliance calculations for a given month may be conducted prior to the end of the subsequent month. 1.7.7.2 Compliance calculation procedures shall follow the guidance in "Procedure for Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink, and Other Coatings," EPA -450/3-84/019. In addition, for add-on controls or other compliance alternatives, calculation procedures shall follow the guidance of Section IX.A.5.f of this regulation. (Colorado Regulation No. 7, Section IX.A.10.b) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 12 2. Coating Assessment Laboratory (CAL). (AIRS# 005) Parameter Condition Number Limitations Monitoring Method Interval VOC Emissions 2.1 4.8 tons/yr Recordkeeping Calculation Monthly Alternate Operating Scenarios NSPS Subpart TT 2.3 0.28 kilogram VOC per liter of coating solids applied NSPS Subpart FFF 2.4 Use inks with a weighted average VOC content less than 1.0 kilogram VOC per kilogram ink solids NSPS Subpart VVV 2.5 Recordkeeping Calculation Monthly Note: The NSPS Subparts listed in Table 2 above provide emission limit options that require either partial or constant use of a control device. Since the CAL does not currently have the capability to accommodate such device, emission limit options utilizing a control device were not included in the Permit. 2.1 Emissions of VOC from the CAL shall not exceed the limits listed in the table above. Mass balance shall be used to estimate emissions using the following equation: tons VOC tons = VOC consumption month month Compliance with the annual limits shall be monitored on a rolling (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly emissions and process rates, and keep a compliance record on site for Division review. (Construction Permit 13WE1752 as modified under the provisions of Section I, Condition 1.3) 2.2 The permit holder shall conduct and record inspection and maintenance on the Dixon Coating Line as indicated in the O&M plan approved by the Division. Note: O&M plan approved on January 30, 2014. See Appendix H 2.3 In the event that the Coating Assessment Laboratory performs metal coil surface coating this source will be subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart TT, Standards of Performance for Metal Coil Surface Coating, 40 C.F.R. Part 60 (July 1, 1998), and as amended on October 17, 2000 (65 FR 61744), including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart TT published in the Federal Register on 10/17/2000. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60, Subpart TT.] Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 13 2.3.1 On and after the date on which §60.8 requires a performance test to be completed, each owner or operator subject to Subpart TT shall not cause to be discharged into the atmosphere more than: (60.462(a)) 2.3.1.1 0.28 kilogram VOC per liter (kg VOC/l) of coating solids applied for each calendar month for each affected facility that does not use an emission control device(s). (60.462(a)(1)) 2.3.2 The owner or operator of an affected facility shall conduct an initial performance test as required under §60.8(a) and thereafter a performance test for each calendar month for each affected facility according to the procedures in §60.463. (60.463(b)) 2.3.3 The owner or operator shall use the following procedures for determining monthly volume - weighted average emissions of VOC's in kg/1 of coating solids applied. (60.463(c)) 2.3.3.1 An owner or operator shall use the following procedures for each affected facility that does not use a capture system and control device to comply with the emission limit specified under §60.462(a)(1). The owner or operator shall determine the composition of the coatings by formulation data supplied by the manufacturer of the coating or by an analysis of each coating, as received, using Method 24. The Administrator may require the owner or operator who uses formulation data supplied by the manufacturer of the coatings to determine the VOC content of coatings using Method 24 or an equivalent or alternative method. The owner or operator shall determine the volume of coating and the mass of VOC-solvent added to coatings from company records on a monthly basis. If a common coating distribution system serves more than one affected facility or serves both affected and existing facilities, the owner or operator shall estimate the volume of coating used at each affected facility by using the average dry weight of coating and the surface area coated by each affected and existing facility or by other procedures acceptable to the Administrator. (60.463(c)(1)) 2.3.4 Where compliance with the numerical limit specified in §60.462(a) (1) is achieved through the use of low VOC-content coatings without the use of emission control devices, the owner or operator shall compute and record the average VOC content of coatings applied during each calendar month for each affected facility, according to the equations provided in §60.463. (60.464(a)) 2.3.5 Where compliance with the numerical limit specified in §60.462(a) (1) is achieved through the use of low VOC-content coatings without emission control devices, each owner or operator subject to the provisions of Subpart TT shall include in the initial compliance report required by §60.8 the weighted average of the VOC content of coatings used during a period of one calendar month for each affected facility.(60.465(a)) 2.3.6 Following the initial performance test, the owner or operator of an affected facility shall identify, record, and submit a written report to the Administrator every calendar quarter of each instance in which the volume -weighted average of the local mass of VOC's emitted to the atmosphere per volume of applied coating solids (N) is greater than the limit specified under §60.462. If no such Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 14 instances have occurred during a particular quarter, a report stating this shall be submitted to the Administrator semiannually.(60.465(d)) 2.3.7 Each owner or operator subject to the provisions of this subpart shall maintain at the source, for a period of at least 2 years, records of all data and calculations used to determine monthly VOC emissions from each affected facility and to determine the monthly emission limit, where applicable.(60.465 (e)) 2.3.8 The reference methods in appendix A to 40 CFR Part 60, except as provided under §60.8(b), shall be used to determine compliance with §60.462 as follows: (60.466(a)) 2.3.8.1 Method 24, or data provided by the formulator of the coating, shall be used for determining the VOC content of each coating as applied to the surface of the metal coil. In the event of a dispute, Method 24 shall be the reference method. When VOC content of waterborne coatings, determined by Method 24, is used to determine compliance of affected facilities, the results of the Method 24 analysis shall be adjusted as described in Section 12.6 of Method 24; (60.466(a)(1)) 2.3.9 For Method 24, the coating sample must be at least a 1 -liter sample taken at a point where the sample will be representative of the coating as applied to the surface of the metal coil. (60.466(b)) 2.4 " In the event that the Coating Assessment Laboratory performs flexible vinyl and urethane coating and printing this source will be subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart FFF, Standards of Performance for Flexible Vinyl and Urethane Coating and Printing, 40 C.F.R. Part 60 (July 1, 1998), and as amended on October 17, 2000 (65 FR 61744), including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart FFF published in the Federal Register on 10/17/2000. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60, Subpart FFF.] 2.4.1 On and after the date on which the performance test required by §60.8 has been completed, each owner or operator subject to Subpart FFF shall: (60.582(a)) 2.4.1.1 Use inks with a weighted average VOC content less than 1.0 kilogram VOC per kilogram ink solids at each affected facility (60.582(a)(1)) 2.4.2 Methods in appendix A of 40 CFR Part 60, except as provided under §60.8(b), shall be used to determine compliance with §60.582(a) as follows: (60.583(a)) 2.4.2.1 Method 24 for analysis of inks. If nonphotochemically reactive solvents are used in the inks, standard gas chromatographic techniques may be used to identify and quantify these solvents. The results of Method 24 may be adjusted to subtract these solvents from the measured VOC content. (60.583(a)(1)) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 15 2.4.3 To demonstrate compliance with §60.582(a)(1), the owner or operator of an affected facility shall determine the weighted average VOC content of the inks according to the following procedures: (60.583(b)) 2.4.3.1 Determine and record the VOC content and amount of each ink used at the print head, including the VOC content and amount of diluent solvent, for any time periods when VOC emission control equipment is not used. (60.583(b)(1)) 2.4.3.2 Compute the weighted average VOC content by the following equation: (60.583(b)(2)) E +' i(WoiMci) E 1(WojMdj) G _ E 1(MciWsi) 2.4.3.3 The weighted average VOC content of the inks shall be calculated over a period that does not exceed one calendar month, or four consecutive weeks. A facility that uses an accounting system based on quarters consisting of two 28 calendar day periods and one 35 calendar day period may use an averaging period of 35 calendar days four times per year, provided the use of such an accounting system is documented in the initial performance test. (60.583(b)(3)) 2.4.3.4 Each determination of the weighted average VOC content shall constitute a performance test for any period when VOC emission control equipment is not used. Results of the initial performance test must be reported to the Administrator. Method 24 or ink manufacturers' formulation data along with plant blending records (if plant blending is done) may be used to determine VOC content. The Administrator may require the use of Method 24 if there is a question concerning the accuracy of the ink manufacturer's data or plant blending records. (60.583(b)(4)) 2.4.3.5 If, during the time periods when emission control equipment is not used, all inks used contain less than 1.0 kilogram VOC per kilogram ink solids, the owner or operator is not required to calculate the weighted average VOC content, but must verify and record the VOC content of each ink (including any added dilution solvent) used as determined by Method 24, ink manufacturers' formulation data, or plant blending records. (60.583(b(5))) 2.4.4 To demonstrate compliance with §60.582(a)(1), the owner or operator may determine the weighted average VOC content using an inventory system. (60.583(c)) 2.4.4.1 The inventory system shall accurately account to the nearest kilogram for the VOC content of all inks and dilution solvent used, recycled, and discarded for each affected facility during the averaging period. Separate records must be kept for each affected facility. (60.583(c)(1)) 2.4.4.2 To determine VOC content of inks and dilution solvent used or recycled, Method 24 or ink manufacturers' formulation data must be used in combination with plant blending records (if plant blending is done) or inventory records or purchase records Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 16 for new inks or dilution solvent. (60.583(c)(2)) 2.4.4.3 For inks to be discarded, only Method 24 shall be used to determine the VOC content. Inks to be discarded may be combined prior to measurement of volume or weight and testing by Method 24. (60.583(c)(3)) 2.4.4.4 The Administrator may require the use of Method 24 if there is a question concerning the accuracy of the ink manufacturer's data or plant records. (60.583(c)(4)) 2.4.4.5 The Administrator shall approve the inventory system of accounting for VOC content prior to the initial performance test. (60.583(c)(5)) 2.4.5 For all affected facilities subject to compliance with §60.582, the performance test data and results from the performance test shall be submitted to the Administrator as specified in §60.8(a). (60.585(a)) 2.4.6 The owner or operator of each affected facility shall submit semiannual reports to the Administrator of occurrences of the following: (60.585(b)) 2.4.6.1 Exceedances of the weighted average VOC content specified in §60.582(a)(1). (60.585(b)(1)) 2.4.7 The reports required under paragraph (b) shall be postmarked within 30 days following the end of the second and fourth calendar quarters. (60.585(c)) 2.5 In the event that the Coating Assessment Laboratory performs polymeric coating this source will be subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart VVV, Standards of Performance for Standards of Performance for Polymeric Coating of Supporting Substrates Facilities, §§60.744(b), 60.747(b), and 60.747(c), including, but not limited to, the following: [The requirements below reflect the current rule language of 40 CFR Part 60 Subpart VVV published in the Federal Register on 9/11/1989. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60, Subpart VVV.] 2.5.1 Any affected facility for which the amount of VOC used is less than 95 Mg per 12 -month period is subject only to the requirements of §§60.744(b), 60.747(b), and 60.747(c). If the amount of VOC used is 95 Mg or greater per 12 -month period, the facility is subject to all the requirements of Subpart VVV. Once a facility has become subject to the requirements of Subpart VVV, it will remain subject to those requirements regardless of changes in annual VOC use. (60.740(b)) 2.5.2 Each owner or operator of an affected facility that uses less than 95 Mg of VOC per year and each owner or operator of an affected facility subject to the provisions specified in §60.742(c)(3) shall: (60.744(b)) 2.5.2.1 Make semiannual estimates of the projected annual amount of VOC to be used for the manufacture of polymeric coated substrate at the affected coating operation in Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 17 that year; and (60.744(b)(1)) 2.5.2.2 Maintain records of actual VOC use. (60.744(b)(2)) 2.5.3 Each owner or operator of an affected facility subject to the provisions of §60.742(c)(3) and initially using less than 130 Mg of VOC per year and each owner or operator of an affected facility initially using less than 95 Mg of VOC per year shall: (60.747(c)) 2.5.3.1 Record semiannual estimates of projected VOC use and actual 12 -month VOC use; (60.747(c)(1)) 2.5.3.2 Report the first semiannual estimate in which projected annual VOC use exceeds the applicable cutoff; and (60.747(c)(2)) 2.5.3.3 Report the first 12 -month period in which the actual VOC use exceeds the applicable cutoff. (60.747(c)(3)) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 18 3. S070 - Two Natural Gas and Diesel Fueled Boilers (206 mmBtu/hr each, AIRS# 004). Parameter Condition Number Limitation Compliance Emission Factor Monitoring Natural Gas I Diesel Fuel Method Interval PM Fuel Use 3.1 3.2 0.5 (FI)-°26 lbs/mmBtu Natural Gas: 1203.7 mmscf/year Diesel Fuel: 82,500 gallons/year Opacity 3.3 Not to exceed 20%, except as provided for in 3.3 SO2 3.4 1.5 lbs/1NIlVIBtu 7.6 lbs/mmscf 2 lbs/1000 gal Analysis and Recordkeeping Calculation Recordkeeping Semiannual Calculation Monthly EPA Method 9 Fuel Restriction Record keeping and calculation As needed PM PM10 NOx VOC CO 3.5 4.66 Tons/Yr 4.62 Tons/Yr 7.6 lbs/mmscf 1 lbs/1000 gal 133.40 Tons/Yr 220 lbs/mmscf 24 lbs/1000 gal 3.32 Tons/Yr 5.5 lbs/mmscf 0.2 lbs/1000 gal 96.50 Tons/Yr 160 lbs/mmscf 5 lbs/1000 gal Recordkeeping Calculation Monthly Applicable Only if Actual NOx Emissions from Boilers Exceed 5 Tons/Year. Reg. 7, Section XVI 3.6 Conduct Annual Combustion Process Adjustment OR Conduct Combustion Process Adjustment According to Manufacturer Schedule & Procedure OR Comply With Tune up Procedure of MACT DDDDD MACT Subpart DDDDD Reg. 7, Section XIX 3.7 3.9 Tune-up every 5 years. One -Time Facility Energy Assessment. Fuel oil can only be burned during periods of gas curtailment, gas supply emergencies, or periodic testing. Periodic testing is limited to 48 hours per calendar year. Submit RACT Analysis See Conditions 3.6 See Conditions 3.7 See Conditions 3.8 See Conditions 3.9 Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 19 3.1 PM emissions shall not exceed the limitation as stated in the above equation (Colorado Regulation No. 1, Section II.A.1.b). In this equation, PE = the particulate limit (lbs/mmBtu) and FI = fuel input (mmBtu/hour). 3.1.1 In the absence of credible evidence to the contrary, compliance with the particulate matter standard shall be presumed whenever natural gas is used as fuel for this boiler. 3-.1.2 In the absence of credible evidence to the contrary, compliance with the particulate matter standard shall be presumed whenever No. 2 Fuel Oil is used as fuel for this boiler. 3.2 This source shall be limited to a maximum raw material process rate or fuel use rate as listed below and all other activities, operational rates and numbers of equipment as stated in the application. Monthly records of the actual consumption rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, Section II.A.4.) Consumption of natural gas fuel for both boilers together shall not exceed 1,203.7 MMscf per year. Consumption of No. 2 fuel oil for both boilers together shall not exceed 82,500 gallons per year. Compliance with the annual consumption limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months data. 3.3 The boilers are subject to the following opacity requirements: 3.3.1 Except as provided for in Condition 3.3.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). This opacity standard applies to each boiler. 3.3.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from start-up which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Construction Permit 10WE1575 and Colorado Regulation No. 1, Section II.A.4). This opacity standard applies to each boiler. Compliance with the opacity requirements will be monitored as follows: 3.3.3 When Burning Natural Gas: In the absence of credible evidence to the contrary, compliance with above opacity requirements shall be presumed whenever natural gas is used as fuel for these boilers. 3.3.4 When Burning No. 2 Fuel Oil: Compliance with the opacity requirements shall be monitored as follows: 3.3.4.1 Compliance with the opacity standard in Condition 3.3.2 shall be monitored by conducting a visible emission observation in accordance with EPA Reference Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 20 Method 9, once per year. This annual observation shall be taken within one (1) hour of the commencement of startup during daylight hours on No. 2 fuel oil and every 24 hours thereafter until startup is completed. A visible emission observation is not required for any annual period where no No. 2, fuel oil has been burned. 3.3.4.2 Compliance with the opacity standard in Condition 3.3.1 shall be monitored by conducting visible emission observations in accordance with EPA Method 9, once per quarter. Such observation shall be conducted within 24 hours of completion of startup on No. 2 fuel oil, if applicable. If No. 2 fuel oil is burned continuously for seven (7) days, a visible emission observation shall be conducted on the seventh day. Subsequent observations shall be taken every seven (7) days thereafter, provided that No. 2 fuel oil is burned continuously. If No. 2 fuel oil is not burned during the quarter, then no visible emission observations are required. 3.3.4.3 Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the opacity limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 3.3.4.4 Results of Method 9 readings and a copy of the certified Method 9 observer's certification shall be made available to the Division upon request. 3.4 Existing oil -fired sources of sulfur dioxide shall not emit sulfur dioxide in excess of 1.5 pounds of sulfur dioxide per million Btu of heating input. (Heat input rates shall be the manufacturer's guaranteed maximum heat input rates) (Reference: Regulation No. 1, VI.A.3.b.(i)) In the absence of credible evidence to the contrary, compliance with the emission standard for distillate fuel combustion may be demonstrated by maintaining a record of a calculation demonstrating the combination of the emission factor and fuel heat content precludes non-compliance. A copy of the calculation shall be made available for Division review upon request. 3.5 Compliance with annual limits shall be determined on a rolling twelve month total. By the 45th day after the close of each month a new twelve month total shall be calculated using the previous twelve months' data. The permit holder shall calculate monthly emissions using the procedures described below and keep a compliance record on site for Division review. tons lb mmscf 1 ton VOC month_ 5.5 mmscf x Natural Gas Use month x 2000 lbs tons lb mmscf 1 ton PM/PM10 month= 7.6 mmscf x Natural Gas Use month x 2000 lbs Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 tons lb mmscf 1 ton CO month_ 160 mmscf x Natural Gas Use month x 2000 lbs tons lb mmscf 1 ton NOx = 280 x Natural Gas Use x month mmscf month 2000 lbs Carestream Health, Inc. Page 21 The permittee shall maintain emission calculation records on site for Division inspection upon request. 3.6 Applicable only IF actual NOx emissions from boilers exceed 5 tons/ year. The S070 Boilers are subject to the requirements in Colorado Regulation No. 7, Section XVI, as follows: 3.6.1 When burning the fuel that provides the majority of the heat input since the last combustion process adjustment and when operating at a firing rate typical of normal operation, the owner or operator must conduct the following inspections and adjustments of boilers and process heaters, as applicable: (Colorado Regulation No. 7, Section XVI.D.2.a) 3.6.1.1 Inspect the burner and combustion controls and clean or replace components as necessary. (Colorado Regulation No. 7, Section XVI.D.2.a.(i)) 3.6.1.2 Inspect the flame pattern and adjust the burner or combustion controls as necessary to optimize the flame pattern. (Colorado Regulation No. 7, Section XVI.D.2.a.(ii)) 3.6.1.3 Inspect the system controlling the air -to -fuel ratio and ensure that it is correctly calibrated and functioning properly. (Colorado Regulation No. 7, Section XVI.D.2.a.(iii)) 3.6.1.4 Measure the concentration in the effluent stream of carbon monoxide and nitrogen oxide in ppm, by volume, before and after the adjustments in Sections XVI.D.2.a.(i)- (iii). Measurements may be taken using a portable analyzer. (Colorado Regulation No. 7, Section XVI.D.2.a.(iv)) 3.6.2 The owner or operator must operate and maintain the boiler, duct burner, process heater, stationary combustion turbine, or stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (Colorado Regulation No. 7, Section XVI.D.2.e) 3.6.3 The owner or operator must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (Colorado Regulation No. 7, Section XVI.D.2.f.(i)) 3.6.4 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections XVI.D.4.a. or XVI.D.4.b of Colorado Regulation No. 7. (Colorado Regulation No. 7, Section XVI.D.2.f.(ii)) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 22 3.6.5 The owner or operator must create a report once every calendar year identifying the combustion equipment at the facility subject to Section XVI.D. and including for each combustion equipment: (Colorado Regulation No. 7, Section XVI.D.3.a) 3.6.5.1 The date of the adjustment; (Colorado Regulation No. 7, Section XVI.D.3.a.(i)) 3.6.5.2 Whether the combustion process adjustment under Sections XVI.D.2.a.-e. was followed, and what procedures were performed; (Colorado Regulation No. 7, Section XVI.D.3.a.(ii)) 3.6.5.3 Whether a combustion process adjustment under XVI.D.4.a.-b. was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any; and (Colorado Regulation No. 7, Section XVI.D.3.a.(iii)) 3.6.5.4 A description of any corrective action taken. (Colorado Regulation No. 7, Section XVI.D.3.a.(iv)) 3.6.5.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (Colorado Regulation No. 7, Section XVI.D.3.a.(v)) 3.6.5.6 If multiple fuels are used, the type of fuel burned and heat input provided by each fuel. (Colorado Regulation No. 7, Section XVI.D.3.a.(vi)) 3.6.6 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under Section XVI.D.4.a. for the life of the equipment, and make available to the Division upon request. (Colorado Regulation No. 7, Section XVI.D.3.b) 3.6.7 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under Section XVI.D.4.a. for the life of the equipment, and make available to the Division upon request. (Colorado Regulation No. 7, Section XVI.D.3.c) 3.6.8 As an alternative to the requirements described in Sections XVI.D.2.a.-e. and XVI.D.3.a.: (Colorado Regulation No. 7, Section XVI.D.4) 3.6.8.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule; or (Colorado Regulation No. 7, Section XVI.D.4.a) 3.6.8.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 or 40 CFR Part 63. (Colorado Regulation No. 7, Section XVI.D.4.b) 3.6.8.3 The owner or operator may comply with applicable recordkeeping requirements Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 23 related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63. (Colorado Regulation No. 7, Section XVI.D.4.c) 3.7 These boilers are subject to the National Emissions Standards for Hazardous air pollutants from Industrial, Commercial and Institutional Boilers and Process Heaters, 40 CFR Part 63 Subpart DDDDD. Specifically, these boilers are subject to the following requirements: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart DDDDD published in the Federal Register on 11/05/2015. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63, Subpart DDDDD.] 3.7.1 If you have an existing boiler or process heater, you must comply with Subpart DDDDD no later than January 31, 2016, except as provided in §63.6(i). (63.7495(b)) 3.7.2 You must meet the notification requirements in. §63.7545 according to the schedule in §63.7545 and in subpart A of 40 CFR Part 63. Some of the notifications must be submitted before you are required to comply with the emission limits and work practice standards in Subpart DDDDD. (63.7495(d)) 3.7.3 You must meet the requirements in paragraphs (a)(1) through (3) of §63.7500, except as provided in paragraphs (b), through (e) of §63.7500. You must meet these requirements at all times the affected unit is operating, except as provided in paragraph (f) of §63.7500. (63.7500(a)) Note: The requirements in § 63.7500(a)(2) do not apply to these boilers and have not been included in the permit. 3.7.3.1 You must meet each emission limit and work practice standard in Tables 1 through 3, and 11 through 13 to Subpart DDDDD that applies to your boiler or process heater, for each boiler or process heater at your source, except as provided under §63.7522. The output -based emission limits, in units of pounds per million Btu of steam output, in Tables 1 or 2 to Subpart DDDDD are an alternative applicable only to boilers and process heaters that generate either steam, cogenerate steam with electricity, or both. The output -based emission limits, in units of pounds per megawatt -hour, in. Tables 1 or 2 to Subpart DDDDD are an alternative applicable only to boilers that generate only electricity. Boilers that perform multiple functions (cogeneration and electricity generation) or supply steam to common headers would calculate a total steam energy output using equation 21 of §63.7575 to demonstrate compliance with the output -based emission limits, in units of pounds per million Btu of steam output, in Tables 1 or 2 to Subpart DDDDD. If you operate a new boiler or process heater, you can choose to comply with alternative limits as discussed in paragraphs (a)(1)(i) through (iii) of §63.7500, but on or after January 31, 2016, you must comply with the emission limits in Table 1 to §63.7500. (63.7500(a)(1)) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 24 3.7.3.2 A new or existing boiler or process heater with a continuous oxygen trim system that maintains an optimum air to fuel ratio must conduct a tune-up of the boiler or process heater every 5 years as specified in §63.7540. (40 CFR Part 63 Subpart DDDDD, Table 3, Item 1) 3.7.3.3 An existing boiler or process heater located at a major source facility, not including limited use units must have a one-time energy assessment performed by a qualified energy assessor. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in this table, satisfies the energy assessment requirement. A facility that operated under an energy management program developed according to the ENERGY STAR guidelines for energy management or compatible with ISO 50001 for at least one year between January 1, 2008 and the compliance date specified in §63.7495 that includes the affected units also satisfies the energy assessment requirement. The energy assessment must include the following with extent of the evaluation for items a. to e. appropriate for the on -site' technical hours listed in §63.7575: (40 CFR Part 63 Subpart DDDDD, Table 3, Item 4) Note: This requirement has been fulfilled as per Notification of Compliance received February 5, 2016. a A visual inspection of the boiler or process heater system. b An evaluation of operating characteristics of the boiler orprocess heater systems, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints. c An inventory of major energy use systems consuming energy from affected boilers and process heaters and which are under the control of the boiler/process heater owner/operator. d A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage. e A review of the facility's energy management program and provide recommendations for improvements consistent with the definition of energy management program, if identified. f A list of cost-effective energy conservation measures that are within the facility's control. g A list of the energy savings potential of the energy conservation measures identified. h A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments. 3.7.3.4 At all times, you must operate and maintain any affected source (as defined in Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 ..................__......_....... Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 25 §63.7490), including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (63.7500(a)(3)) 3.7.4 As provided in §63.6(g), EPA may approve use of an alternative to the work practice standards in §63.7500. (63.7500(b)) 3.7.5 For existing affected sources (as defined in §63.7490), you must complete an initial tune-up by following the procedures described in §63.7540(a)(10)(i) through (vi) no later than the compliance date specified in §63.7495, except as specified in paragraph (j) of §63.7510. You must complete the one-time energy assessment specified in Table 3 to §63.7510 no later than the compliance date specified in §63.7495. (63.7510(e)) 3.7.6 If you are required to meet an applicable tune-up work practice standard, you must conduct an annual, biennial, or 5 -year performance tune-up according to §63.7540(a)(10), (11), or (12), respectively. Each annual tune-up specified in §63.7540(a)(10) must be no more than 13 months after the previous tune-up. Each biennial tune-up specified in §63.7540(a)(11) must be conducted no more than 25 months after the previous tune-up. Each 5 -year tune-up specified in §63.7540(a)(12) must be conducted no more than 61 months after the previous tune-up. (63.7515(d)) 3.7.7 You must include with the Notification of Compliance Status a signed certification that either the energy assessment was completed according to Table 3 to Subpart DDDDD, and that the assessment is an accurate depiction of your facility at the time of the assessment, or that the maximum number of on -site technical hours specified in the definition of energy assessment applicable to the facility has been expended. (63.7530(e)) 3.7.8 You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in §63.7545(e). (63.7530(f)) 3.7.9 If your boiler or process heater has a continuous oxygen trim system that maintains an optimum air to fuel ratio, or a heat input capacity of less than or equal to 5 million Btu per hour and the unit is in the units designed to burn gas 1; units designed to burn gas 2 (other); or units designed to burn light liquid subcategories, or meets the definition of limited -use boiler or process heater in §63.7575, you must conduct a tune-up of the boiler or process heater every 5 years as specified in paragraphs (a)(10)(i) through (vi) of this section to demonstrate continuous compliance. You may delay the burner inspection specified in paragraph (a)(10)(i) of this section until the next scheduled or unscheduled unit shutdown, but you must inspect each burner at least once every 72 months. If an oxygen trim system is utilized on a unit without emission standards to reduce the tune-up frequency to once every 5 years, set the oxygen level no lower than the oxygen concentration measured during the most recent tune-up. (63.7540(a)(12)) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 26 3.7.9.1 As applicable, inspect the burner, and clean or replace any components of the burner as necessary (you may perform the burner inspection any time prior to the tune-up or delay the burner inspection until the next scheduled unit shutdown). Units that produce electricity for sale may delay the burner inspection until the first outage, not to exceed 36 months from the previous inspection. At units where entry into a piece of process equipment or into a storage vessel is required to complete the tune-up inspections, inspections are required only during planned entries into the storage vessel or process equipment; (63.7540(a)(10)(i)) 3.7.9.2 Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available; (63.7540(a)(10)(ii)) 3.7.9.3 Inspect the system controlling the air -to -fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly (you may delay the inspection until the next scheduled unit shutdown). Units that produce electricity for sale may delay the inspection until the first outage, not to exceed 36 months from the previous inspection; (63.7540(a)(10)(iii)) 3.7.9.4 Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any NOx requirement to which the unit is subject; (63.7540(a)(10)(iv)) 3.7.9.5 Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer; and (63.7540(a)(10)(v)) 3.7.9.6 Maintain on -site and submit, if requested by the Administrator, a report containing the information in paragraphs (a)(10)(vi)(A) through (C) of §63.7540. (63 .7540(a)(10)(vi)) 3.7.10 If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar days of startup. (63.7540(a)(13)) 3.7.11 You must submit to the Division the initial notification (§ 63.9(b)) and the notification of compliance status (§ 63.9(h)) by the dates specified. (63.7545(a)) 3.7.12 As specified in §63.9(b)(2), if you startup your affected source before January 31, 2013, you must submit an Initial Notification not later than 120 days after January 31, 2013. (63.7545(b)) 3.7.13 If you are required to conduct an initial compliance demonstration as specified in §63.7530, you must submit a Notification of Compliance Status according to §63.9(h)(2)(ii). For the initial compliance demonstration for each boiler or process heater, you must submit the Notification of Compliance Status, including all performance test results and fuel analyses, before the close of business on the 60th day following the completion of all performance test and/or other initial compliance demonstrations for all boiler or process heaters at the facility according to §63.10(d)(2). The Notification of Compliance Status report must contain all the information Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 27 specified in paragraphs (e)(1) through (8) of §63.7545, as applicable. The Notification of Compliance Status for the affected sources at this facility shall include the information specified in paragraphs (e)(1), (6), (7) and (8) of §63.7545. (63.7545(e)) 3.7.14 If you operate a unit designed to burn natural gas, refinery gas, or other gas 1 fuels that is subject to Subpart DDDDD, and you intend to use a fuel other than natural gas, refinery gas, gaseous fuel subject to another subpart of 40 CFR Part 63, part 60, 61, or 65, or other gas 1 fuel to fire the affected unit during a period of natural gas curtailment or supply interruption, as defined in §63.7575, you must submit a notification of alternative fuel use within 48 hours of the declaration of each period of natural gas curtailment or supply interruption, as defined in §63.7575. The notification must include the information specified in paragraphs (f)(1) through (5) of §63.7545. (63.7545(f)) 3.7.15 You must submit each report in Table 9 to Subpart DDDDD that applies to you. (63.7550(a)) 3.7.15.1 You must submit a compliance report containing information required in §63.7550(c)(1) through (5); and (40 CFR Part 63 Subpart DDDDD, Table 9, Item 1(a)) 3.7.15.2 If there are no deviations from any emission limitation (emission limit and operating limit) that applies to you and there are no deviations from the requirements for work practice standards for periods of startup and shutdown in Table 3 to Subpart DDDDD that apply to you, a statement that there were no deviations from the emission limitations and work practice standards during the reporting period. If there were no periods during which the CMSs, including continuous emissions monitoring system, continuous opacity monitoring system, and operating parameter monitoring systems, were out -of -control as specified in §63.8(c)(7), a statement that there were no periods during which the CMSs were out -of -control during the reporting period; and (40 CFR Part 63 Subpart DDDDD, Table 9, Item 1(b)) 3.7.15.3 If you have a deviation from any emission limitation (emission limit and operating limit) where you are not using a CMS to comply with that emission limit or operating limit, or a deviation from a work practice standard for periods of startup and shutdown, during the reporting period, the report must contain the information in §63.7550(d); and (40 CFR Part 63 Subpart DDDDD, Table 9, Item 1(c)) 3.7.15.4 If there were periods during which the CMSs, including continuous emissions monitoring system, continuous opacity monitoring system, and operating parameter monitoring systems, were out -of -control as specified in §63.8(c)(7), or otherwise not operating, the report must contain the information in §63.7550(e). (40 CFR Part 63 Subpart DDDDD, Table 9, Item 1(3)) 3.7.15.5 You must submit the report semiannually, annually, biennially, or every 5 years according to the requirements in §63.7550(b). (40 CFR Part 63 Subpart DDDDD, Table 9, Item 1(a)) 3.7.16 For units that are subject only to a requirement to conduct subsequent annual, biennial, or 5 -year tune-up according to §63.7540(a)(10), (11), or (12), respectively, and not subject to emission Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 28 limits or Table 4 operating limits, you may submit only an annual, biennial, or 5 -year compliance report, as applicable, as specified in paragraphs (b)(1) through (4) of this section, instead of a semi-annual compliance report. (63.7550(b)) 3.7.17 A compliance report must contain the following information depending on how the facility chooses to comply with the limits set in this rule. (63.7550(c)) 3.7.17.1 If the facility is subject to the requirements of a tune up you must submit a compliance report with the information in paragraphs (c)(5)(i) through (iii), (xiv), and (xvii) of §63.7550. (63.7550(c)(1)) 3.7.18 You must keep the following records: 3.7.18.1 A copy of each notification and report that you submitted to comply with Subpart DDDDD, including all documentation supporting any Initial Notification or Notification of Compliance Status or semiannual compliance report that you submitted, according to the requirements in §63.10(b)(2)(xiv). (63.7555(a)(1)) 3.7.18.2 Records of performance tests, fuel analyses, or other compliance demonstrations and performance evaluations as required in § 63.10(b)(2)(viii). (63.7555(a)(2)) 3.7.19 If you operate a unit in the unit designed to burn gas 1 subcategory that is subject to Subpart DDDDD, and you use an alternative fuel other than natural gas, refinery gas, gaseous fuel subject to another subpart under 40 CFR Part 63, other gas 1 fuel, or gaseous fuel subject to another subpart of 40 CFR Part 63 or Part 60, 61, or 65, you must keep records of the total hours per calendar year that alternative fuel is burned and the total hours per calendar year that the unit operated during periods of gas curtailment or gas supply emergencies. (63.7555(h)) 3.7.20 Records shall be kept in the form and for the duration specified in § 63.7560. 3.7.21 Table 10 of 40 CFR Part 63 Subpart DDDDD shows which parts of the General Provisions in §§ 63.1 through 63.15 apply to you. (63.7565) These requirements include but are not limited to the following: 3.7.21.1 Prohibited activities in § 63.4. 3.7.21.2 Compliance with Standards and Maintenance Requirements in §63.6(a), (b)(1) - (b)(5), (b)(7), (c) 3.7.21.3 Notification requirements in § 63.9. 3.8 In accordance with the requirements in 40 CFR Part 63 Subpart DDDDD, boilers designed to burn gas 1 subcategory fuels, are subject to the requirements listed above. A "unit designed to burn gas 1 subcategory" is defined in 40 CFR Part 63 Subpart DDDDD § 63.7575, "includes any boiler or process heater that burns only natural gas, refinery gas, and/or other gas 1 fuels. Gaseous fuel boilers and process heaters that burn liquid fuel for periodic testing of liquid fuel, maintenance, or operator training, not to exceed a combined total of 48 hours during any calendar year, are included in this definition. Gaseous fuel boilers and process heaters that burn liquid fuel during periods of gas curtailment or gas supply interruptions of any duration are also included in this definition." The permittee shall retain Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 29 records for each unit documenting the reason for burning fuel oil and the hours that fuel oil is burned. In the event that fuel oil is burned in any boiler for reasons other than periodic testing of liquid fuel, maintenance, or operator training or if periodic testing and/or training exceeds 48 hours during a calendar year, additional provision in 40 CFR Part 63 Subpart DDDDD apply to that boiler. Within 60 days of triggering additional requirements in 40 CFR Part 63 Subpart DDDDD, the permittee shall submit an application to revise this permit to include the appropriate requirements. 3.9 The S070 Boilers are subject to the requirements in Colorado Regulation No. 7, Section XIX, as follows: 3.9.1 Owners or operators of the following major sources must submit a RACT analysis for the facility or specified emission points to the Division. Approved RACT determinations will be addressed in the relevant source permit or through rule revisions, as appropriate. (Colorado Regulation No. 7, Section XIX.B) 3.9.1.1 Carestream Health (123-6250) — boilers (pt 004) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE28$ Carestream Health, Inc. Page 30 4. Degreasing Units (C-15, C-20, C-41, C-48, C-50, C-70) Parameter Condition Number Limitation Monitoring Method Interval Reg 7, Section X.A — Transfer and Storage of Waste & Solvents 4.1 & 4.2 See Conditions 4.1 & 4.2 Certification Annually Reg 7, Section X.B — Control Standards 4.3 — 4.8 See Conditions 4.3 - 4.8 Certification Annually Note that this emission unit is exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction permit requirements in Regulation No. 3, Part B. 4.1 In any disposal or transfer of waste or used solvent, at least 80 percent by weight of the solvent/waste liquid shall be retained (i.e., no more than 20 percent of the liquid solvent/solute mixture shall evaporate or otherwise be lost during transfers). (Colorado Regulation No. 7, Section X.A.3) 4.2 Waste or used solvent shall be stored in closed containers unless otherwise required by law. (Colorado Regulation No. 7, Section X.A.4) 4.3 All cold -cleaners shall have a properly fitting cover. (Colorado Regulation No. 7, Section X.B.1.a(i)) ,-- 4.3.1 Covers shall be designed to be easily operable with one hand under any of the following conditions (Colorado Regulation No. 7, Section X.B.1.a(ii)): 4.3.1.1 Solvent true vapor pressure is greater than 15 ton (0.3 psia) at 38°C (100°F). (Colorado Regulation No. 7, Section X.B.1.a(ii)(A)) 4.3.1.2 The solvent is agitated by an agitating mechanism. (Colorado Regulation No. 7, Section X.B.1.a(ii)(B)) 4.3.1.3 The solvent is heated. (Colorado Regulation No. 7, Section X.B.1.a(ii)(C)) 4.4 All cold -cleaners shall have a drainage facility that captures the drained liquid solvent from the cleaned parts. (Colorado Regulation No. 7, Section X.B.1.b(i)). For cold -cleaners using solvent which has a vapor pressure greater than 32 torr (0.62 psia) measured at 38°C (100°F) either: 4.4.1 There shall be an internal drainage facility within the confines of the cold -cleaner, so that parts are enclosed under the (closed) cover to drain after cleaning, or if such a facility will not fit within; (Colorado Regulation No. 7, Section X.B.1.b(ii)(A)) 4.4.2 An enclosed, external drainage facility that captures the drained solvent liquid from the cleaned parts. (Colorado Regulation No. 7, Section X.B.1.b(ii)(B)) 4.5 A permanent, clearly visible sign shall be mounted on or next to the cold -cleaner. The sign shall list the operating requirements. (Colorado Regulation No. 7, Section X.B.1.c) 4.6 Solvent spray apparatus shall not have a splashing, fine atomizing, or shower type action but rather should produce a solid, cohesive stream. Solvent spray shall be used at a pressure that does not cause excessive splashing. (Colorado Regulation No. 7, Section X.B.1.d) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 31 For solvents with a true vapor pressure above 32 ton (0.62 psia) at 38°C (100°F), or, for solvents heated above 50°C (120°F), one of the following techniques shall be used: 4.6.1 A freeboard ratio greater than or equal to 0.7. (Colorado Regulation No. 7, Section X.B.1.d(i)) 4.6.2 A water or a non-volatile liquid cover. The cover liquid shall not be soluble in the solvent and shall not be more dense than the solvent and the depth of the cover liquid shall be sufficient to prevent the escape of solvent vapors. (Colorado Regulation No. 7, Section X.B.1.d(ii)) 4.7 The cold -cleaner cover shall be closed whenever parts are not being handled within the cleaner confines. (Colorado Regulation No. 7, Section X.B.2.a) 4.8 Cleaned parts shall be drained for at least 15 seconds and/or until dripping ceases. Any pools of solvent shall be tipped out off the clean part back into the tank. (Colorado Regulation No. 7, Section X.B.2.b) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 32 SECTION III - Permit Shield Regulation No. 3, 5 CCR 1001-5, Part C, I.A.4, V.D. & XIII.B; & 25-7-114.4(3)(a), C.R.S. 1. Specific Non -Applicable Requirements Based on the information available to the Division and supplied by the applicant, the following parameters and requirements have been specifically identified as non -applicable to the facility to which this permit has been issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit issuance. In addition, this shield does not protect the source from any violations that occur as a result of any modification or reconstruction on which construction commenced prior to permit issuance. Emission Unit Description &Number Applicable Requirement Justification Facility Wide 40 CFR Parts 9 and 63, Subpart JJ, as adopted by reference in Colorado Regulation No. 8, Part E Permitee maintains records of coating and adhesive use to demonstrate they are an incidental wood product manufacturer 40 CFR Part 63, Subpart U, as adopted by reference in Colorado Regulation No. 8, Part E Permitee does not manufacture as a primary product any of the elastomer products listed in this regulation 40 CFR Part 63, Subpart W, as adopted by reference in Colorado Regulation No. 8, Part E Permitee is not an existing, new, or reconstructed manufacturer of epoxy resins or wet strength resins 40 CFR Part 63, Subpart V, as adopted by reference in Colorado Regulation No. 8, Part E Permitee purchases low molecular weight PET from an offsite source 40 CFR Part 61 Facility is not subject to listed NESHAPS 40 CFR Part 9 and Part 63, Subpart Q Facility does not use chromium in its industrial cooling towers 40 CFR Part 82, Subpart E Product does not contain or is not made with ozone depleting compounds Colorado Regulation No. 18, 40 CFR Part 72 and General Condition 26 of this permit There are no affected units subject to the acid rain provisions at this facility Colorado Regulation No. 8, Parts A and C Facility is not subject to listed NESHAPS and is not a stationary source of lead. General Condition 20 of this permit There are no portable sources associated with this facility. General Condition 30 of this permit This facility does not advertise, sell, install, or use wood stoves or wood burning appliances 40 CFR Part 63, Subpart JJJ, as adopted by reference in Colorado Regulation No. 8 This facility does not produce any thermoplastic product listed in the Group IV polymers MACT. 40 CFR Part 63, Subpart EEEE, as adopted by reference in Colorado Regulation No. 8 This facility does not fit the definition of affected source under 40 CFR Part, Subpart EEEE. 40 CFR Part 63, Subpart FFFF, as adopted by reference in Colorado Regulation No. 8 This facility is subject to MACT JJJJ and therefore exempt from MACT FFFF as per §63.2435(c)(3). C-40 40 CFR Part 60, Subpart Kb, as adopted by reference in Colorado Regulation No. 6, Part A All VOL storage tanks are less than 40 m3 in size Colorado Regulation No. 3, Part B 1.A Chemical Weigh Station, Gelatin Weigh Station, and Silver Recovery received grandfathered status Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 2. General Conditions Carestream Health, Inc. Page 33 Compliance with this Operating Permit shall be deemed compliance with all applicable requirements specifically identified in the permit and1other requirements specifically identified in the permit as not applicable to the source. This permit shield shall not alter or affect the following: 2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement in cases of emergency; 2.2 The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; 2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the federal act; 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to § 25-7- 111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the federal act; 2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to Regulation No. 3, Part C, § XIII. 2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to permit issuance. 3. Stream -lined Conditions The following applicable requirements have been subsumed within this operating permit using the pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed requirements. No applicable requirements were streamlined out of this permit. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 34 SECTION IV - General Permit Conditions (Ver. 5/22/12) 1. Administrative Changes Regulation No. 3, 5 CCR 1001-5, Part A, § III. The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes that are described in Regulation No. 3, Part A, § I.B.1. The permittee may immediately make the change upon submission of the application to the Division. 2. Certification Requirements Regulation No. 3, 5 CCR 1001-5, Part C, &§ III.B.9., V.C.16.a.& e. and V.C.17. a. Any application, report, document and compliance certification submitted to the Air Pollution Control Division pursuant to Regulation No. 3 or the Operating Permit shall contain a certification by a responsible official of the truth, accuracy and completeness of such form, report or certification stating that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate and complete. b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the Division in the Operating Permit. c. Compliance certifications shall contain: (i) the identification of each permit term and condition that is the basis of the certification; (ii) the compliance status of the source; (iii) whether compliance was continuous or intermittent; (iv) method(s) used for determining the compliance status of the source, currently and over the reporting period; and (v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the source. d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r) of the federal act, the permittee shall certify its compliance with that requirement; the Operating Permit shall not incorporate the contents of the risk management plan as a permit term or condition. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 35 3. Common Provisions Common Provisions Regulation, 5 CCR 1001-2 $& II.A., II.B., II.C., II.E., II.F., II.I, and II.J a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line, such emissions shall not cause the air quality standards of the receiving State to be exceeded, provided reciprocal action is taken by the receiving State. b. Emission Monitoring Requirements The Division may require owners or operators of stationary air pollution sources to install, maintain, and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. c. Performance Testing The owner or operator of any air pollution source shall, upon request of the Division, conduct performance test(s) and furnish the Division a written report of the results of such test(s) in order to determine compliance with applicable emission control regulations. Performance test(s) shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves, in specific cases, the use of a test method with minor changes in methodology; (ii) approves the use of an.equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance; or (iv) waives the requirement for performance test(s) because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes, Title 25, Article 7, and pursuant to regulations promulgated by the Commission. Compliance test(s) shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility. The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s). Operations during period of startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s) unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 36 are made for earlier testing. The owner or operator of an affected facility shall provide, or cause to be provided, performance testing facilities as follows: (i) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s); and (iv) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be conducted for the time and under theconditions specified in the applicable standard. For the purpose of determining compliance with an applicable standard, the arithmetic mean of results of at least three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances beyond the owner or operator's control, compliance may, upon the Division's approval, be determined using the arithmetic mean of the results of the two other runs. Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted. d. Affirmative Defense Provision for Excess Emissions during Malfunctions An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that: (i) The excess emissions were caused by a sudden, unavoidable breakdown of equipment, or a sudden, unavoidable failure of a process to operate in the normal or usual manner, beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided, or planned for, and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions (including any bypass) were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation (if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 37 (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or maintenance; (ix) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This section is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement; and (x) During the period of excess emissions, there were no exceedances of the relevant ambient air quality standards established in the Commissions' Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards or emission limits, including, but not limited to, new source performance standards and national emission standards for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip) limits or permit limits that have been set taking into account potential emissions during malfunctions, including, but not necessarily limited to, certain limits with 30 -day or longer averaging times, limits that indicate they apply during malfunctions, and limits that indicate they apply at all times or without exception. e. Circumvention Clause A person shall not build, erect, install, or use any article, machine, equipment, condition, or any contrivance, the use of which, without resulting in a reduction in the total release of air pollutants to the atmosphere, reduces or conceals an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. f. Compliance Certifications For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in the Colorado State Implementation Plan, nothing in the Colorado State Implementation Plan shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. Evidence that has the effect of making any relevant standard or permit term more stringent shall not be credible for proving a violation of the standard or permit term. When compliance or non-compliance is demonstrated by a test or procedure provided by permit or Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 38 g. other applicable requirement, the owner or operator shall be presumed to be in compliance or non- compliance unless other relevant credible evidence overcomes that presumption. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of the evidence that: (i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and could not have been prevented through careful planning and design; (ii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation or maintenance; (iii) If the excess emissions were caused by a bypass (an intentional diversion of control equipment), then the bypass was unavoidable to prevent loss of life, personal injury, or severe property damage; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation (if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; and, (viii) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the division verbally as soon as possible, but no later than two (2) hours after the start of the next working day, and shall submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that derive from new source performance standards or national emissions standards for hazardous air pollutants, or any other federally enforceable performance standard or emission limit with an averaging time greater than twenty-four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of Significant Deterioration (PSD) increments. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 .................... _........._. Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 39 In making any determination whether a source established an affirmative defense, the division shall consider the information within the notification required above and any other information the division deems necessary, which may include, but is not limited to, physical inspection of the facility and review of documentation pertaining to the maintenance and operation of process and air pollution control equipment. 4. Compliance Requirements Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.C.9., V.C.I 1. & 16.d. and § 25-7-122.1(2), C.R.S. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally -enforceable terms or conditions constitutes a violation of the federal act, as well as the state act and Regulation No. 3. Any permit noncompliance relating to state -only terms or conditions constitutes a violation of the state act and Regulation No. 3, shall be enforceable pursuant to state law, and shall not be enforceable by citizens under § 304 of the federal act. Any such violation of the federal act, the state act or regulations implementing either statute is grounds for enforcement action, for permit termination, revocation and reissuance or modification or for denial of a permit renewal application. b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination, revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of any request by the permittee for a permit modification, revocation and reissuance, or termination, or any notification of planned changes or anticipated noncompliance does not stay any permit condition, except as provided in §§ X. and XI. of Regulation No. 3, Part C. d. The permittee shall furnish to the Air Pollution Control Division, within a reasonable time as specified by the Division, any information that the Division may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Division copies of records required to be kept by the permittee, including information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental, and shall not sanction noncompliance with, the applicable requirements on which it is based. f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of permit issuance, the permittee shall submit, at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division, Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 40 g. progress reports which contain the following: (i) (ii) dates for achieving the activities, milestones, or compliance required in the schedule for compliance, and dates when such activities, milestones, or compliance were achieved; and an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventive or corrective measures adopted. The permittee shall not knowingly falsify, tamper with, or render inaccurate any monitoring device or method required to be maintained or followed under the terms and conditions of the Operating Permit. 5. Emergency Provisions Regulation No. 3, 5 CCR 1001-5, Part C, § VII.E An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed the technology -based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology -based emission limitation if the permittee demonstrates, through properly signed, contemporaneous operating logs, or other relevant evidence that: a. b. c. d. an emergency occurred and that the permittee can identify the cause(s) of the emergency; the permitted facility was at the time being properly operated; during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in the permit; and the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency, and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 41 6. Emission Controls for Asbestos Regulation No. 8, 5 CCR 1001-10. Part B The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No. 8, Part B, "asbestos control." 7. Emissions Trading, Marketable Permits, Economic Incentives Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.13. No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are specifically provided for in the permit. 8. Fee Payment C.R.S §§ 25-7-114.1(6) and 25-7-114.7 a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. § 25-7- 114.7. A 1% per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the date of invoice, unless a permittee has filed a timely protest to the invoice amount. b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7- 114.7. If the Division estimates that processing of the permit will take more than 30 hours, it will notify the permittee of its estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit. c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. § 25-7-114.1(6) for each APEN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. 1, 5 CCR 1001-3, $ III.D.1. The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, § III.D.1. 10. Inspection and Entry Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.16.b. Upon presentation of credentials and other documents as may be required by law, the permittee shall Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 ..........................._._....... Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 42 allow the Air Pollution Control Division, or any authorized representative, to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located, or emissions - related activity is conducted, or where records must be kept under the terms of the permit; b. have access to, and copy, at reasonable times, any records that must be kept under the conditions of the permit; c. inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the Operating Permit; d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or applicable requirements, any substances or parameters. 11. Minor Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, $& X. & XI. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. 12. New Source Review Regulation No. 3, 5 CCR 1001-5, Part B The permittee shall not commence construction or modification of a source required to be reviewed under the New Source Review provisions of Regulation No. 3, Part B, without first receiving a construction permit. 13. No Property Rights Conveyed Regulation No. 3, 5 CCR 1001-5, Part C, & V.C.11.d. This permit does not convey any property rights of any sort, or any exclusive privilege. 14. Odor Regulation No. 2, 5 CCR 1001-4, Part A As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous emissions. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 43 15. Off -Permit Changes to the Source Regulation No. 3, 5 CCR 1001-5, Part C, XII.B. The permittee shall record any off -permit change to the source that causes the emissions of a regulated pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from the change, including any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off -permit change. 16. Opacity Regulation No. 1, 5 CCR 1001-3, $§ I., II. The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ L- II. 17. Open Burning Regulation No. 9, 5 CCR 1001-11 The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions of Regulation No. 9. 18. Ozone Depleting Compounds Regulation No. 15, 5 CCR 1001-17 The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds. Sections I., II.C., II.D., III. IV., and V. of Regulation No. 15 shall be enforced as a matter of state law only. 19. Permit Expiration and Renewal Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.B.6., IV.C., V.C.2. a. The permit term shall be five (5) years. The permit shall expire at the end of its term. Permit expiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted. b. Applications for renewal shall be submitted at least twelve months, but not more than 18 months, prior to the expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit that require revision, supplementing, or deletion, incorporating the remaining permit terms by reference from the previous permit. A copy of any materials incorporated Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 44 by reference must be included with the application. 20. Portable Sources Regulation No. 3, 5 CCR 1001-5, Part C, II.D. Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location. 21. Prompt Deviation Reporting Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.7.b. The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. "Prompt" is defined as follows: a. Any definition of "prompt" or a specific timeframe for reporting deviations provided in an underlying applicable requirement as identified in this permit; or b. Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of deviations will be submitted based on the following schedule: (i) For emissions of a hazardous air pollutant or a toxic air pollutant (as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements, the report shall be made within 24 hours of the occurrence; (ii) For emissions of any regulated air pollutant, excluding a hazardous air pollutant or a toxic air pollutant that continue for more than two hours in excess of permit requirements, the report shall be made within 48 hours; and (iii) For all other deviations from permit requirements, the report shall be submitted every six (6) months, except as otherwise specified by the Division in the permit in accordance with paragraph 22.d. below. c. If any of the conditions in paragraphs b.i or b.ii above are met, the source shall notify the Division by telephone (303-692-3155) or facsimile (303-782-0278) based on the timetables listed above. [Explanatory note: Notification by telephone or facsimile must sped that this notification is a deviation report for an Operating Permit.] A written notice, certified consistent with General Condition 2.a. above (Certification Requirements), shall be submitted within 10 working days of the occurrence. All deviations reported under this section shall also be identified in the 6 -month report required above. "Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of avoiding enforcement actions. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 ............... _...._............... Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 45 22. Record Keeping and Reporting Requirements Regulation No. 3, 5 CCR 1001-5, Part A, § II.; Part C, §§ V.C.6., V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit, the permittee shall maintain compliance monitoring records that include the following information: (i) date, place as defined in the Operating Permit, and time of sampling or measurements; (ii) date(s) on which analyses were performed; (iii) the company or entity that performed the analysis; (iv) the analytical techniques or methods used; (v) the results of such analysis; and (vi) the operating conditions at the time of sampling or measurement. b. The permittee shall retain records of all required monitoring data and support information for a period of at least five (5) years from the date of the monitoring sample, measurement, report or application. Support information, for this purpose, includes all calibration and maintenance records and all original strip -chart recordings for continuous monitoring instrumentation, and copies of all reports required by the Operating Permit. With prior approval of the Air Pollution Control Division, the permittee may maintain any of the above records in a computerized form. c. Permittees must retain records of all required monitoring data and support information for the most recent twelve (12) month period, as well as compliance certifications for the past five (5) years on - site at all times. A permittee shall make available for the Air Pollution Control Division's review all other records of required monitoring data and support information required to be retained by the permittee upon 48 hours advance notice by the Division. d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every six (6) months, unless an applicable requirement, the compliance assurance monitoring rule, or the Division requires submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly identified in such reports. e. The permittee shall file an Air Pollutant Emissions Notice ("APEN") prior to constructing, modifying, or altering any facility, process, activity which constitutes a stationary source from which air pollutants are or are to be emitted, unless such source is exempt from the APEN filing requirements of Regulation No. 3, Part A, § II.D. A revised APEN shall be filed annually whenever a significant change in emissions, as defined in Regulation No. 3, Part A, § II.C.2., occurs; whenever there is a change in owner or operator of any facility, process, or activity; whenever new control equipment is installed; whenever a different type of control equipment replaces an existing type of control equipment; whenever a permit limitation must be modified; or before the APEN expires. An APEN is valid for a period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires. Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by April 30 of the following year. Where a permit revision is required, the revised APEN must be filed along with a request for permit revision. APENs Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 46 for changes in control equipment must be submitted before the change occurs. Annual fees are based on the most recent APEN on file with the Division. 23. Reopenings for Cause Regulation No. 3, 5 CCR 1001-5, Part C, XIII. a. The Air Pollution Control Division shall reopen, revise, and reissue Operating Permits; permit reopenings and reissuance shall be processed using the procedures set forth in Regulation No. 3, Part C, § III., except that proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists. b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major source with a remaining permit term of three or more years, unless the effective date of the requirements is later than the date on which the permit expires, or unless a general permit is obtained to address the new requirements; whenever additional requirements (including excess emissions requirements) become applicable to an affected source under the acid rain program; whenever the Division determines the permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit; or whenever the Division determines that the permit must be revised or revoked to assure compliance with an applicable requirement. c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit, except that a shorter notice may be provided in the case of an emergency. d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and reissuance procedure. 24. Section 502(b)(10) Changes Regulation No. 3, 5 CCR 1001-5, Part C, $ XII.A. The permittee shall provide a minimum 7 -day advance notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of each such notice given to its Operating Permit. 25. Severability Clause Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.10. In the event of a challenge to any portion of the permit, all emissions limits, specific and general conditions, monitoring, record keeping and reporting requirements of the permit, except those being challenged, remain valid and enforceable. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 47 26. Significant Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, §III.B.2. The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B ("Construction Permit" requirements) without first receiving a construction permit. The permittee shall submit a complete Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve months of commencing operation, to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating Permit must be received prior to commencing construction of the new or modified source. 27. Special Provisions Concerning the Acid Rain Program Regulation No. 3, 5 CCR 1001-5, Part C, §§ V.C.1.b. & 8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act, 40 Code of Federal Regulations (CFR) Part 72, both provisions shall be incorporated into the permit and shall be federally enforceable. b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the regulations promulgated thereunder, 40 CFR Part 72, are expressly prohibited. 28. Transfer or Assignment of Ownership Regulation No. 3, 5 CCR 1001-5, Part C, II.C. No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or operator applies to the Air Pollution Control Division on Division -supplied Administrative Permit Amendment forms, for reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner or operator has been submitted to the Division. 29. Volatile Organic Compounds Regulation No. 7, 5 CCR 1001-9, §§ III & V. The requirements in paragraphs a, b and e apply to sources located in an ozone nonattainment area or the Denver 1 -hour ozone attainment/maintenance area. The requirements in paragraphs c and d apply statewide. a. All storage tank gauging devices, anti -rotation devices, accesses, seals, hatches, roof drainage systems, support structures, and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened, actuated, or used for necessary and proper activities (e.g. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 48 maintenance). Such opening, actuation, or use shall be limited so as to minimize vapor loss. Detectable vapor loss shall be determined visually, by touch, by presence of odor, or using a portable hydrocarbon analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm. Testing shall be conducted as in Regulation No. 7, Section VIII.C.3. b. Except when otherwise provided by Regulation No. 7, all volatile organic compounds, excluding petroleum liquids, transferred to any tank, container, or vehicle compartment with a capacity exceeding 212 liters (56 gallons), shall be transferred using submerged or bottom filling equipment. For top loading, the fill tube shall reach within six inches of the bottom of the tank compartment. For bottom -fill operations, the inlet shall be flush with the tank bottom. c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably Available Control Technology (RACT) is utilized. d. No owner or operator of a bulk gasoline terminal, bulk gasoline plant, or gasoline dispensing facility as defined in Colorado Regulation No. 7, Section VI, shall permit gasoline to be intentionally spilled, discarded in sewers, stored in open containers, or disposed of in any other manner that would result in evaporation. e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b, above. 30. Wood Stoves and Wood burning Appliances Regulation No. 4, 5 CCR 1001-6 The permittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use of wood stoves and wood burning appliances. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - REPORTING REQUIREMENTS AND DEFINITIONS C - COMPLIANCE CERTIFICATION REPORT FORMAT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - PERMIT MODIFICATIONS G- EQUIPMENT LIST *DISCLAIMER: None of the information found in these Appendices shall be considered to be State or Federally enforceable, except as otherwise provided in the permit, and is presented to assist the source, permitting authority, inspectors, and citizens. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 50 APPENDIX A Inspection Information Directions to Plant: The plant is located in Northern Colorado near the town of Windsor. From Denver, take I-25 North approximately 60 miles and take the Windsor exit East. Follow Highway 392 through the town of Windsor and turn right on Highway 257. After about 1.5 miles, turn left to access the Health Group facility. Safety Equipment Required: - Eye Protection - Safety Shoes - Conductive Shoes - Hearing Protection Facility Plot Plan: Figure 1 (following page) shows the plot plan as submitted on November 30, 2016. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list, activities may have changed since the last filing. This list is current as of April 2018. Insignificant activities and/or sources of emissions as submitted in the application are as follows: Building C-20 Distribution Center Building C-40, C-41, C-42, C-43, C-46, and C-48 C-41 — Welding Booth C-40 — Quality Control and Process Support Labs C-43 — Chemical Storage Areas C-43 — Dry Chemical Weight Station C-46 — Wet Scrubber C-48 — Cooling Towers East of C-48 Building C-50 C-50 — Quality Lab C-50 — Regeneration of Molecular Sieve Adsorber C-50 — Prepolymer Silos and Conveyance Equipment C-50 — Polymer Silos and Conveyance Equipment Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 51 C-50 — PET Reuse Process Building C-15 Color Paper Manufacturing: Slitting, spooling, and packaging of Color Media Testing film for quality Exemption: Regulation 3 Part C, Section II.E.3.i (QA/QC/R&D labs) QA/QC labs located in the following buildings: C-40, C-42, C-43, C-50, C-61, C-70, and the wastewater treatment plant. Exemption: Regulation 3 Part C, Section II.E.3.aaa/ fff (Diesel Fuel/Lubricating Oil Storage Tanks) Location Storage Capacity (Gallons) Contents C70, UST Day Tank 30,000 No. 2 diesel for back up boiler fuel C20 & C50 Mobile Fuel 200 Diesel Fuel C48, Transformers (2) 1,206 Enviro-Temp FR3 C48, Inside Drum Storage 385 Gear, Lube, Hydraulic, Waste C50, Inside Drum Storage 165 Gear, Lube, Hydraulic, Waste C40's, Inside Drum Storage 275 Gear, Lube, Hydraulic, Waste C15, Inside Drum Storage 55 Gear, Lube, Hydraulic, Waste C20, Inside Drum Storage 370 Gear, Lube, Hydraulic, Waste C43, Slitter 120 Hydraulic, Inside tank C70, Turbine Lube Oil 1,400 Lube Oil, Inside tank C70, Inside Drum Storage 550 Gear, Lube, Hydraulic, Waste C46, Inside Drum Storage 110 Gear, Lube, Hydraulic, Waste C61, Inside Drum Storage 385 Gear, Lube, Hydraulic, Waste Exemption: Regulation 3 Part C, Section II.E.3.eeee (Sulfuric Acid & Caustic Tanks <10,500 Gal) Location Storage Capacity (Gallons) Quantity Contents West of Building C-61 2,050 1 sulfuric acid 10,000 1 sodium hydroxide Exemption: Regulation 3 Part C, Section II.E.3. k (Fuel Burning Equipment ≤ 5 mmbtu/hr) Equipment Rating Quantity Toro Power Shift 824 snow blower 5120 BTU/hr 1 Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 52 Other Insignificant Activities: Exemption: Landscaping/Grounds Keeping Activities Regulation 3 Part C, Section II.E.3.bb/cc/dd/qq HVAC Regulation 3 Part C, Section II.E.3.c Aerosol can usage Regulation 3 Part C, Section II.E.3.0 Non -product adhesive use Regulation 3 Part C, Section II.E.3.y Non -product related caulking operations Regulation 3 Part C, Section II.E.3.aa Smoking Rooms Regulation 3 Part C, Section II.E.3.gg Plastic pipe welding Regulation 3 Part C, Section II.E.3.hh Housekeeping / Janitorial / Office Activities Regulation 3 Part C, Section II.E.3.pp/tt Forklifts Regulation 3 Part C, Section II.E.3.kkk Steam vents Regulation 3 Part C, Section II.E.3.aaaa Natural gas venting during maintenance of boilers Regulation 3 Part C, Section II.E.3.dddd Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 53 rr HE=.LTH LE= is E ?'E RT'y Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 54 APPENDIX B Reporting Requirements and Definitions with codes ver 8/20/14 Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement, representation, or certification in, or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either filed or maintained (whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report #1: Monitoring Deviation Report (due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit, monitoring means any condition determined by observation, by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel analyses, and operational or control device parameter monitoring. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 55 Report #2: Permit Deviation Report (must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from permit requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of such deviations, and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit are required to be summarized or referenced in the annual compliance certification. For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions. Additional discussion on these conditions is provided later in this Appendix. For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern. For example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1, Section IV. In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes of this operating permit are any of the following: (1) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; (3) A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. (only if the emission point is subject to CAM) For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation Report. All deviations shall be reported using the following codes: 1 = Standard: 2 = Process: 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: 8 = CAM: 9 = Other: When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is recordkeeping When the requirement is reporting A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. When the deviation is not covered by any of the above categories Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 56 Report #3: Compliance Certification (annually, as defined in the permit) Submission of compliance certifications with terms and conditions in the permit, including emission limitations, standards, or work practices, is required not less than annually. Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other material information (i.e. information beyond required monitoring that has been specifically assessed in relation to how the information potentially affects compliance status), that information must be identified and addressed in the compliance certification. The compliance certification must include the following: • The identification of each term or condition of the permit that is the basis of the certification; • Whether or not the method(s) used by the owner or operator for determining the compliance status with each permit term and condition during the certification period was the method(s) specified in the permit. Such methods and other means shall include, at a minimum, the methods and means required in the permit. If necessary, the owner or operator also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Federal Clean Air Act, which prohibits knowingly making a false certification or omitting material information; • The status of compliance with the terms and conditions of the permit, and whether compliance was continuous or intermittent. The certification shall identify each deviation and take it into account in the compliance certification. Note that not all deviations are considered violations.1 • Such other facts as the Division may require, consistent with the applicable requirements to which the source is subject, to determine the compliance status of the source. The Certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. (only for emission points subject to CAM) Note the requirement that the certification shall identify each deviation and take it into account in the compliance certification. Previously submitted deviation reports, including the deviation report submitted at the time of the annual certification, may be referenced in the compliance certification. 1 For example, given the various emissions limitations and monitoring requirements to which a source may be subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an exception and/or special circumstances relating to that same event. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 57 Startup, Shutdown, Malfunctions and Emergencies, Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important in both the deviation reports and the annual compliance certifications. Startup, Shutdown, and Malfunctions Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or standards often do not apply unless specifically stated in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and would still be noted in the deviation report. In regard to compliance certifications, the permittee should be confident of the information related to those deviations when making compliance determinations since they are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available Control Technology (BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources. Emergency Provisions Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense against enforcement action if they are properly reported. DEFINITIONS Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily caused by poor maintenance, careless operation, or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions. Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology -based emission limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 58 APPENDIX B: Monitoring and Permit Deviation Report - Part I 1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety. FACILITY NAME: Carestream Health, Inc. OPERATING PERMIT NO: 06OPWE288 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) AIRS ID Unit Description Deviations noted During Period?1 Deviation Code 2 Malfunction/Emergency Condition Reported During Period? YES NO 4 YES NO 001 Sensitizing Complex, Buildings C-40, C-41, C-42, C- 43, C-46 002 Support Manufacturing, Building C-50 003 Five corona treaters used in web coating operations. 005 Coating Assessment Laboratory 004 Boilers Degreasing Units Facility Wide General Conditions Insignificant Activities ' See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information. 2 Use the following entries, as appropriate 1 = Standard: 2 = Process: 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: 8=CAM: 9 = Other: When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is recordkeeping When the requirement is reporting A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. When the deviation is not covered by any of the above categories Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 59 APPENDIX B: Monitoring and Permit Deviation Report - Part II FACILITY NAME: Carestream Health, Inc. OPERATING PERMIT NO: 06OPWE288 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration (start/stop date & time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Malfunctions/Emergencies Reported (if applicable) Deviation Code Division Code QA: SEE EXAMPLE ON THE NEXT PAGE Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 60 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: Emergency Malfunction XX N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control - Unit XXX Operating Permit Condition Number Citation Section II, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Slurry Line Feed Plugged Duration START- 1730 4/10/06 END- 1800 4/10/06 Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Malfunction/Emergencies Reported (if applicable) 5/30/06 to A. Einstein, APCD Deviation Code Division Code QA: Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAT" _ I' Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 61 APPENDIX B: Monitoring and Permit Deviation Report - Part III REPORT CERTIFICATION SOURCE NAME: Carestream Health, Inc. FACILITY IDENTIFICATION NUMBER: 1236350 PERMIT NUMBER: 06OPWE288 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) All information for the Title V Semi -Annual Deviation Reports must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. STATEMENT OF COMPLETENESS I have reviewed the information being submitted in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this submittal are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub -Section 18- 1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of Sub -Section 25-7 122.1, C.R.S. Printed or Typed Name Title Signature of Responsible Official Date Signed Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit. No copies need be sent to the U.S. EPA. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix C Page 62 APPENDIX C Required Format for Annual Compliance Certification Reports Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: Carestream Health, Inc OPERATING PERMIT NO: 06OPWE288 REPORTING PERIOD: I. Facility Status During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/are the method(s) specified in the Permit. With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The method used to determine compliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. AIRS ID Unit Description Deviations Reported' Monitoring Method per Permit?2 Was compliance continuous or intermittent?3 Previous Current YES NO Continuous Intermittent 001 Sensitizing Complex, Buildings C-40, C-41, C- 42, C-43, C-46 002 Support Manufacturing, Building C-50 003 Five corona treaters 005 Coating Assessment Laboratory 004 Boilers Degreasing Units Facility Wide General Conditions Insignificant Activities 4 Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 .................................... Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix C Page 63 ' If deviations were noted in a previous deviation report , put an "X" under "previous". If deviations were noted in the current deviation report (i.e. for the last six months of the annual reporting period), put an "X" under "current". Mark both columns if both apply. 2 Note whether the method(s) used to determine the compliance status with each term and condition was the method(s) specified in the permit. If it was not, mark "no" and attach additional information/explanation. 3 Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent Compliance" can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. NOTE: The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not indicate non-compliance, and if 3) the Responsible Official is not aware of any credible evidence that indicates non- compliance, then the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time period. 4 Compliance status for these sources shall be based on a reasonable inquiry using readily available information. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix C Page 64 II. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act) B. If subject: The facility requirements of section 112(r). is is not in compliance with all the 1. A Risk Management Plan will be has been submitted to the appropriate authority and/or the designated central location by the required date. III. Certification All information for the Annual Compliance Certification must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix D Page 62 APPENDIX D Notification Addresses 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-S S -B 1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Matt Burgett 2. United States Environmental Protection Agency Compliance Notifications: Office of Enforcement, Compliance and Environmental Justice Mail Code 8ENF-AT U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 502(b)(10) Changes, Off Permit Changes: Office of Partnerships and Regulatory Assistance Mail Code 8P -AR U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAT I Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 66 APPENDIX E Permit Acronyms Listed Alphabetically: AIRS - Aerometric Information Retrieval System AP -42 - EPA Document Compiling Air Pollutant Emission Factors APEN - Air Pollution Emission Notice (State of Colorado) APCD - Air Pollution Control Division (State of Colorado) ASTM - American Society for Testing and Materials BACT - Best Available Control Technology BTU - British Thermal Unit CAA - Clean Air Act (CAAA = Clean Air Act Amendments) CCR - Colorado Code of Regulations CEM - Continuous Emissions Monitor CF - Cubic Feet (SCF = Standard Cubic Feet) CFR - Code of Federal Regulations CO - Carbon Monoxide COM - Continuous Opacity Monitor CRS - Colorado Revised Statute EF - Emission Factor EPA - Environmental Protection Agency FI - Fuel Input Rate in MMBtu/hr FR Federal Register G - Grams Gal - Gallon GPM - Gallons per Minute HAPs - Hazardous Air Pollutants HP - Horsepower HP -HR - Horsepower Hour (G/HP-HR = Grams per Horsepower Hour) LAER - Lowest Achievable Emission Rate LBS - Pounds M - Thousand MM - Million MMscf - Million Standard Cubic Feet MMscfd Million Standard Cubic Feet per Day N/A or NA - Not Applicable NOx - Nitrogen Oxides NESHAP - National Emission Standards for Hazardous Air Pollutants NSPS - New Source Performance Standards P - Process Weight Rate in Tons/Hr PE - Particulate Emissions Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed. DRAFT Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 67 PM - PMio - PSD - PTE - RACT- SCC - SCF - SIC - SO2 - TPY - TSP - VOC- Particulate Matter Particulate Matter Under 10 Microns Prevention of Significant Deterioration Potential To Emit Reasonably Available Control Technology Source Classification Code Standard Cubic Feet Standard Industrial Classification Sulfur Dioxide. Tons Per Year Total Suspended Particulate Volatile Organic Compounds Operating Permit Number: 060PWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix F Page 68 APPENDIX F Permit Modifications Date Of Revision Section Number, Condition Number Description Of Revision Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix G Page 69 APPENDIX G Equipment List Building Location I AIRS ID Description C-40, 41, 42, and 43 (Sensitizing Complex) C-40 001 Coating and Drying Equipment (001 Machine) Sensitizing Complex Process Vessels and Ancillary Equipment C-50 (Innovative Polyester Manufacturing) Polymer Area 002 Railcar Unloading System (HEPA Filter) Polymer Area PET Grinding System Polymer Area Grinding System Dust Collector (DF-50) Polymer Area Powdered Polymer Transfer System (HEPA Filter) Polymer Area Molecular Sieve Adsorbers Extruder Room East/West Extruders C-50 Dornier Heavy Duty Transverse Film Stretching Machine Coating and Exhaust Systems (501 Machine) Chem Weigh Room Dry Chemical Weighing Hood (HEPA Filter) IPM Complex Process Vessels and Ancillary Equipment IPM Complex Fugitive Emissions C-40 001 Machine 003 Five Corona Treaters (CT1 — CT5) C-70 Boiler House 004 Two Natural Gas and Diesel Fueled Boilers Rated at 206 mmBtu/hr Each C-43 Coating Assessment Laboratory 005 Dixon Coater Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix H Page 70 APPENDIX H Operating and Maintenance Plan OPERATING AND MAINTENANCE PLAN Coating Assessment Laboratory State of Colorado Construction Permit 13WE1752 Careatrearn Health_ Incorporated 2000 Howard Smith Ave. West VVindstar, CO 84550 Prepared by: Gadder Asseaies Inc 28©9, East Hatmcny Road Suite 340 Fort Onti�ns, CO Bt}623 September 2013 1340848 Golder Associates vas:: Ga,xa:nt-. .a:ex a-,4 It* as itd* n aew releenexa Con.,41,,s Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix H Page 71 abet 2013 Table of Contents PURPOSE OF THE OEM PLAN ..... .. ............ 2.0 EMISSION CALCULATIONS AND RECORDKEEPING.- _ ............. 2,t Emissions Calculations.. 2�2 Recontkeeping .. ....«< . 3�Lt PREVENTTATiVE MAINTENANCE... 4.0 MANUFACTURER'S OPERATION RECOMMENDATIONS of Append►tes Appendix A Appendix B Appendix C Appendix O Appendix E Appendix F Appendix G Solvent Usage Spreadsheet Solvent Usage for MontrtYear Solvent Usage Spreadsheet —SOS Solvent Service Solvent Usage Spreadsheet SSM Records Solvent Usage Spreadsheet Charge Card Records Scale Preventative Maintenance Procedure Dryer Pressure Switch Preventative Maintenance Procedure CAL Operating Procedure 2 3 Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Colorado Department of Public Health and Environment OPERATING PERMIT Carestream Health, Inc. First Issued: September 1, 1999 Renewed: DRAFT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: Carestream Health Colorado FACILITY ID: 123/6350 RENEWED: EXPIRATION DATE: MODIFICATIONS: DRAFT DRAFT See Appendix F of Permit OPERATING PERMIT NUMBER 06OPWE288 Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et seq Supp. and applicable rules and regulations. ISSUED TO: Carestream Health, Inc. 2000 Howard Smith Ave West Windsor, CO 80550 INFORMATION RELIED UPON Operating Permit Renewal Application Received: And Additional Information Received: Nature of Business: Primary SIC: PLANT SITE LOCATION: 2000 Howard Smith Ave West Windsor, CO 80550 Weld County October 29, 2008 April 24, 2009, May 27, 2009, May 11, 2010, June 6, 2014, December 8, 2017, & April 18, 2018 Manufacturer of photographic supplies 3861 RESPONSIBLE OFFICIAL Name: Christopher L. Schmachtenberger Title: Site Manager Carestream Health, Inc. Phone: (970)304-4712 FACILITY CONTACT PERSON Name: Laura Jackson Pales Title: Environmental Engineer Carestream Health, Inc. Phone: (970) 304-4768 SUBMITTAL DEADLINES First Semi -Annual Monitoring Period: Subsequent Semi -Annual Monitoring Periods: Semi -Annual Monitoring Reports: First Annual' Compliance Period: Subsequent Annual Compliance Pei Annual Compliance Certification: Note that the Semi -Annual Monitoring Reports and Annual Compliance Certifications must be received at the Division office by 5:00 p.m on the due date. Postmarked dates will not be accepted for the purposes of determining the timely receipt of those reports/certifications. October 1, 2010 —December 31, 2010 January 1- June 30, July 1 -December 31 Due February_1, 2011 & August 1, 2011 & subsequent years October J, 2010 - December 31, 2010 January 1 December 31 Due February 1, 2011 & subsequent years TABLE OF CONTENTS: SECTION I - General Activities and Summary 1 1. Permitted Activities 1 2. Nonattainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 2 3. Accidental Release Prevention Program (112(r)) 3 4. Summary of Emission Units 3 5. Alternate Operating Scenarios 3 6. Compliance Assurance Monitoring (CAM) 4 SECTION II - Specific Permit Terms 5 1. Sensitizing Complex and Support Manufacturing (AIRS# 001, 002, and 003) 5 2. Coating Assessment Laboratory (CAL). (AIRS# 005) 12 3. S070 - Two Natural Gas and Diesel Fueled Boilers (206 mmBtu/hr each, AIRS# 004)18 4. Degreasing Units (C-15, C-20, C-41, C-48, C-50, C-70) 30 SECTION III - Permit Shield 32 1. Specific Non -Applicable Requirements 32 2. General Conditions 33 3. Stream -lined Conditions 33 SECTION IV - General Permit Conditions (Ver. 5/22/12) 34 1. Administrative Changes 34 2. Certification Requirements 34 3. Common Provisions 35 4. Compliance Requirements 39 5. Emergency Provisions 40 6. Emission Controls for Asbestos 41 7. Emissions Trading, Marketable Permits, Economic Incentives 41 8. Fee Payment 41 9. Fugitive Particulate Emissions 41 10. Inspection and Entry 41 11. Minor Permit Modifications 42 12. New Source Review 42 13. No Property Rights Conveyed 42 14. Odor 42 15. Off -Permit Changes to the Source 43 16. Opacity 43 17. Open Burning 43 18. Ozone Depleting Compounds 43 19. Permit Expiration and Renewal 43 20. Portable Sources 44 21. Prompt Deviation Reporting 44 22. Record Keeping and Reporting Requirements 45 23. Reopenings for Cause 46 24. Section 502(b)(10) Changes 46 TABLE OF CONTENTS: 25. Severability Clause 46 26. Significant Permit Modifications 47 27. Special Provisions Concerning the Acid Rain Program 47 28. Transfer or Assignment of Ownership 47 29. Volatile Organic Compounds 47 30. Wood Stoves and Wood burning Appliances 48 APPENDIX A Inspection Information 50 Directions to Plant: 50 Safety Equipment Required: 50 Facility Plot Plan. 50 List of Insignificant Activities: 50 APPENDIX B Reporting Requirements and Definitions 54 APPENDIX C Required Format for Annual Compliance Certification Reports 62 APPENDIX D Notification Addresses 65 APPENDIX E Permit Acronyms 66 APPENDIX F Permit Modifications 68 APPENDIX G Equipment List 69 APPENDIX H Operating and Maintenance Plan 70 Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 1 1. Permitted Activities 1.1 SECTION I - General Activities and Summary Carestream Health, Inc. Colorado (CHC) is a paper and web manufacturing and coating facility located at 2000 Howard Smith Avenue West, Windsor, CO 80550 in Weld County. The facility is located approximately two miles southeast of Windsor. The campus consists of multiple buildings containing a variety of equipment used in the manufacturing processes. A polyester film support base is produced for X-ray products in Building C-50 - Innovative Polyester Manufacturing (IPM). IPM produces a flexible thermoplastic polyester film from polyester pellets. This process involves heating the plastic using heat transfer fluid and friction. The polyester is extruded and allowed to cool and harden. The plastic is then reheated, processed, coated with several sublayers, cooled, and wound into large rolls. C-50 also houses mechanical shops that support the process and cleaning services to ensure quality. Medical x-ray film, color photographic paper, and contract manufacturing products are produced in the Sensitizing Complex (Buildings C-40, C-41, C-42, and C-43). Light sensitive emulsions consisting of silver halide and other chemicals are applied to a support to produce photographic film and paper. This process involves mixing raw chemicals together into solutions and dispersions. These solutions and dispersions are mixed with gels and coated onto plastic or paper. The coating is dried and rolled onto master rolls. The Sensitizing Complex also houses mechanical shops to support the process, labs to provide quality control and new product testing, and cleaning services to ensure quality. In addition, C- 43 also houses the Coating Assessment Laboratory, which provides quality assessments of new coatings and substrate configurations. Building C-46 houses a high efficiency silver recovery operation, which results in a concentrated silver mud recovered from coating formulation waste streams. The mud is shipped offsite for metal recovery. CHC leases space in Building C-15, where CHC operates a paper finishing process. This process includes slitting the paper and chopping it into retail dimensions. This paper is packaged and prepared for retail distribution. Building C-20 is the warehousing and distribution facility. It also includes a machine shop and forklift shop to support the entire campus. The process includes receiving raw materials and products, onsite storage, and national/international distribution of products. The machine shop produces custom parts and equipment for operations. The forklift shop maintains mobile equipment for the facility. Building C-70 houses the main central utilities operations including two boilers, each rated at 206 mmBtu/hour, that supply steam for the site. Natural gas is used as primary fuel and No. 2 fuel oil is used as back up fuel. Utilities support operations occur in Buildings C-48, C-59, C-61, and C-63. Utilities include steam production, chilled and cooling water production, compressed air service, industrial wastewater and service water treatment. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 ..... . .............................. Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 2 Buildings C-80, C-81, and C-82 are associated with the onsite industrial wastewater treatment plant. The facility is located in Weld County, near Windsor. This facility is located in an area classified as attainment for all pollutants except ozone. It is classified as nonattainment for the 8 -hr ozone standard and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. Wyoming is an affected state within 50 miles of the plant. The following Federal Class I designated areas are within 100 kilometers of the plant: Rocky Mountain National Park and Rawah National Wilderness Area. 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. This Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet the applicable substantive New Source Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3, Part C shall become new applicable requirements for purposes of this operating permit and shall survive reissuance. This permit incorporates the applicable requirements from the following construction permit: 96WE473, 10WE1575, 13WE1752 1.3 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State -only enforceable conditions are: Permit Condition Number(s): Section IV — 3.g (last paragraph), 14, & 18 (as noted). 1.4 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit. 2. Nonattainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 2.1 This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC or NOx > 100 Tons/Year (TPY)). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) for VOC or NOx or a modification which is major by itself (Potential to Emit of > 100 TPY of either VOC or NOx) may result in the application of the NANSR review requirements. 2.2 Based on the information provided by the applicant, this source is categorized as a minor stationary source for PSD as of the issue date of this permit. Any future modification which is major by itself (Potential to Emit > 250 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. The boilers are a listed source for PSD purposes and therefore are categorized as a major source for PSD Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 3 purposes (PTE > 100 tons/year). (Colorado Regulation No. 3, Part B, Section IV.D.3). Future modifications related to the boilers resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) or a modification which is major by itself (Potential to Emit of > 100 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. 2.3 There are no other Operating Permits associated with this facility. 3. Accidental Release Prevention Program (112(r)) Based on the information provided by the applicant, this facility is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act). 4. Summary of Emission Units 4.1 The emissions units regulated by this permit are the following: AIRS ID` Facility Identifier Description Pollution Control Device Construction Permit 001 SO40 Sensitizing Complex, Buildings C-40, C-41, C 42, C-43, C-46 N rl �yE \�� ' , �,,.... 96WE473 002 S050. Support Manufacturing, Building C-50 Railroad Car Unloading / Dry Chemical Weighing Room / PET unloading HEPA filter 003 SO40 Five corona treaters used in web coating operations. (sensitizing) ? y3 , 005 S040 Coating Assessment Laboratory ,' .illf y: r " i 13WE1752 004 S070 Two 206 mmBtu/hr boilers 10WE1575 Degreasing Units (C-15, C-20, C-41, C-48, C� 50, C -70(x2)) Appendix G lists specific equipment in each of the Buildings and associated AIRS Identification Numbers. 4.2 Equipment Replacement This permit covers only the specific existing equipment listed in Appendix G of this permit. 5. Alternate Operating Scenarios 5.1 The permittee shall be allowed to make the following changes to method of operation without applying for a revision of this permit. This only applies to the Coating Assessment Laboratory. See Section II for specific permit terms applicable to these scenarios. 5.1.1 The Coating Assessment Laboratory may perform metal coil surface coating operations to evaluate quality and commercial production feasibility. This operation is subject to New Source Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 4 Performance Standards Subpart TT. Reference Section II, Condition 2.3 for applicable requirements. 5.1.2 The Coating Assessment Laboratory may perform flexible vinyl and urethane coating and printing operations to evaluate quality and commercial production feasibility. This operation is subject to New Source Performance Standards Subpart FFF. Reference Section II, Condition 2.4 for applicable requirements. 5.1.3 The Coating Assessment Laboratory may perform polymeric coating operations to evaluate quality and commercial production feasibility. This operation is subject to New Source Performance Standards Subpart VVV. Reference Section II, Condition 2.5 for applicable requirements. 5.1.4 The permittee shall notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation that would trigger additional applicable subparts. The notification shall be submitted in form of a letter. The letter shall include; reason for submittal, reference to permit, specification of the operational changes, the applicable subpart(s), date subpart(s) became applicable, and applicable requirements. 5.1.5 Within one hundred and eighty days (180) after commencement of any Alternate Operating Scenario, compliance with the newly applicable conditions shall be demonstrated to the Division. It is the permittee's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit or enforcement action by the Division. (Colorado Regulation No. 3, Part B, IlI.G.2). 5.1.6 All emission limits in this operating permit shall be met. Emissions shall be estimated as set forth in Section II, Condition 2.1. 5.1.7 The permittee shall, contemporaneously with making a change from one operating scenario to another, record in a log at the permitted facility a record of the scenario under which it is operating. (Colorado Regulation No. 3, Part A, IV.A.1, as referred to in Part C, V.C.14). This log shall be made available to the Division for inspection upon request. 6. Compliance Assurance Monitoring (CAM) 6.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre -control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64 as adopted by reference into Colorado Regulation No. 3, Part C, Section XIV: None. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 5 SECTION II - Specific Permit Terms 1. Sensitizing Complex and Support Manufacturing (AIRS# 001, 002, and 003) Parameter Condition Number Limitation Compliance Emission Factor Monitoring Method Interval VOC 1.1 48.3Tons/Yr See Condition 1.1 Recordkeeping Calculation Monthly PM 15.0 Tons/Yr PM:o 15.0 Tons/Yr Ozone (O3) 7.0 Tons/Yr Opacity 1.2 Not to exceed 20%, except as provided for below Nature of the Processes Annually Certain Operating Conditions - Not to exceed 30%, for a period or periods aggregating more than six (6) minutes in any 60 consecutive minutes Consumption 1.3 See Condition 1.3 Recordkeeping Monthly Use of corona treaters 1.4 191,780 kW -hr per year Recordkeeping Monthly MACT Subpart JJJJ 1 6 No more than 5% of the organic HAP applied for each month (95% reduction) OR No more than 4 % of the mass of coating materials applied for each month OR No more than 20 % of the mass of coating solids applied for each month Calculation Monthly Reg 7, Section IX 1.7 2.9 lb/gc (pounds of solvent VOC per gallon of coating minus water and "exempt" solvents) See Condition 1.7.1 Recordkeeping and Calculation Daily See Condition 1.7.7.1 Note: See Equipment List, Appendix G 1.1 Emissions shall not exceed the rates listed in the above Table 1(Construction Permit 96WE473 as modified under the provisions of Section I, Condition 1.3). Compliance with annual limits shall be determined on a rolling twelve month total. By the 45th day after the close of each month a new twelve month total shall be calculated using the previous twelve months' data. The permit holder shall calculate monthly emissions using the procedures described below and keep a compliance record on site for Division review. 1.1.1 VOC Emissions shall be calculated as follows: Building C-40, C-41, C-42, C-43, & C-46: Except for the separately listed chemicals, mass balance shall be used to estimate emissions using the following equation: VOC tons tons = VOC consumption month month Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 6 1.1.1.2 Building C-50: Mass balance shall be used to estimate emissions using the following equation: tons tons VOC month= VOC consumption month For thermal degradation byproducts in extruded material: tons _ lbs VOC Million lbs 1 ton VOC month 64 Million lbs extruded x Extruder Throughput month x 2000 lbs For pre -polymer byproducts removed by molecular sieve regenerations: VOC tons lbs VOC x Regenerations 1 ton month = 3.5 Regeneration month x 2000 lbs 1.1.2 O3 Emissions shall be calculated as follows: 1.1.2.1 Building C-40: Corona Discharge Treaters: tons = lbs 03 kWhr 1 ton 03 month0.073 kWhr x Energy Consumption month x 2000 lbs 1.1.3 PM/PM10 Emissions shall be calculated as follows: 1.1.3.1 Building C-50 : Railroad Car PET Powder Unloading: tons gr hr min 1 lb 1 ton PM/PM10 month= 0.01 dscf x 888 dscfm x Usage month x 60 hr x 7000 gr x 2000 lbs Railroad Car PET Pellet Unloading : tons _ lb lb PM 1 ton PM/PM10 month= PET month x (1 — 0.97) x 3.47E-6 lb PET x 2000 lbs Three Pellet Grinders (total): PM/Ptons M10 month lbs= PET Pellets Extruded on lb pm 1 ton x 2.9E —5 x month lb pellet extruded 2000 lbs Chemical Weighing Hood: tons gr hr min 1 lb 1 ton PM/PM10 yr = 0.04 dscf x 8500 dscfm x 365- x 60 hr x 7000 gr x 2000 lbs Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 7 501 Machine: tons lbs 1 ton PM/PMlo = Resorcinol Consumed x month month 2000 lbs The permittee shall maintain emission calculation records on site for Division inspection upon request. 1.2 Except as provided in Colorado Regulation No. 1, Section II.A.4, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement on which these standards are based is EPA Method 9 (40 CFR Part 60, Appendix A (July 1992)) in all subsections of Section II of Regulation No. 1. (Construction Permit 96WE473, and Colorado Regulation No 1, Section II.A.1). No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment, which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.4). The PM emission sources located at this facility are the chemical making, polymer unloading, pellet unloading, three pellet grinders, chemical melting kettles, and chemical weighing processes. When operated in their current configuration and method, no opacity is generated. By certifying compliance with this Condition 1.2, the source is certifying that no changes have been made to the equipment, process, or operation such that opacity is generated. In addition, the building C-50 Rail Car Polymer Unloading, and Dry chemical Weighing Room HEPA filters shall be replaced at least annually. The HEPA filter associated with the C-50 pellet unloading shall be replaced at least annually, unless the process is not used during the previous year. In which case, the HEPA filter shall be replaced just prior to startup of any pellet unloading activities. The dust collector associated with the C-50 grinders shall be operated and maintained in accordance with manufacturer's recommendations. Such recommendations and practices shall be in written format and made available for Division inspection upon request. 1.3 The permittee shall maintain records of the monthly consumption of VOC containing materials, including throughput data, in -process inventory, material safety data sheets, number of Building C-50 molecular sieve regenerations, and off -site waste shipment information, as necessary in order to estimate emissions as set forth in Section IL Condition 1.1. In addition, the permittee shall maintain records of Resorcinol consumption. These records shall be kept on site for Division inspection upon request. (Colorado Regulation No. 3, Part B, III.A.4 and IV.E, and Construction Permit 90WE0466.) 1.4 Total operation of the corona treaters shall not exceed 191,780 kW -hr per year (as provided for under the provisions of Section I, Condition. 1.3 and Colorado Regulation No. 3, Part B, Section III.A.6, and Part C, Section X based on maximum rate identified in an APEN filed by the source dated 4/22/2009). A twelve-month rolling total shall be maintained for demonstration of compliance with the annual limitation. By the end of each month a new twelve-month total shall be calculated using the previous twelve months' data. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 8 1.5 The permittee shall comply with the provisions of Regulation No. 3 concerning APEN reporting. Emission factors and/or other emission estimating methods that are specified within this permit cannot be adjusted without requiring a permit modification. Emission factors and/or other emission estimating methods used to comply with the reporting requirements of Regulation No. 3, Part A, Section II can be updated and modified as specified in that Section. These changes by themselves do not require any permitting activities though the resulting emission estimate may trigger permitting activities. 1.6 The coating line is subject to 40 CFR Part 63, Subpart JJJJ — National Emission Standards for Hazardous Air Pollutants: Paper and Other Web Coating, as adopted by reference in Colorado Regulation No. 8, Part E, Section III, as follows: [The requirements below reflect the current rule language of 40 CFR Part 63 Subpart JJJJ published in the Federal Register on 12/04/2002. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63, Subpart JJJJ.] 1.6.1 If you own or operate any affected source that is subject to the requirements of Subpart JJJJ, you must comply with these requirements on and after the compliance dates as specified in §63.3330 (§ 63.3320(a)). This unit is an existing source and its compliance date was December 5, 2005 per § 63.3330(a). 1.6.2 You must limit organic HAP emissions to the level specified in Conditions 1.6.2.1, 1.6.2.2 or 1.6.2.3 below: 1.6.2.1 No more than 5 percent of the organic HAP applied for each month (95 percent reduction) (§ 63.3320(b)(1)); or 1.6.2.2 No more than 4 percent of the mass of coating materials applied for each month at existing affected sources (§ 63.3320(b)(2)); or 1.6.2.3 No more than 20 percent of the mass of coating solids applied for each month (§ 63.3320(b)(3)). The source must indicate one of the three emission limit options that will be used and notify the Division of that choice in the notification of compliance status and must monitor and report compliance results accordingly. If a source decides to change to other emission limit options, the Division must be notified in the semi-annual reports specified in Condition 1.6.5. The permittee has previously indicated that they would meet the limitation in Condition 1.6.2.2. 1.6.3 The organic HAP content, volatile organic and coating solids content and volatile matter retained in the coated web or otherwise not emitted to the atmosphere shall be determined using the procedures specified in §§ 63.3360(c), (d) and (g), respectively (§ 63.3360(a)(1)). Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 9 1.6.4 Demonstrate that the monthly average as -applied organic HAP content of all coating materials applied at an existing affected source is less than 0.04 kg organic HAP per kg of coating material applied, and all coating materials applied at a new affected source are less than 0.016 kg organic HAP per kg of coating material applied, as determined by Equation 4 of § 63.3370 (§ 63.3370(c)(3). 1.6.5 The permittee shall submit semi-annual compliance reports as required by § 63.3400(c) and startup, shutdown and malfunction reports as required by § 63.3400(g). 1.6.6 The permittee shall retain records as specified in §§ 63.3410(a) and (b). 1.6.7 Table 2 to Subpart JJJJ specifies the provisions of Subpart A of 40 CFR Part 63 that apply if you are subject to Subpart JJJJ, such as startup, shutdown, and malfunction plans (SSMP) in §63.6(e)(3) for affected sources using a control device to comply with the emission standards (§ 63.3340). The general provisions that apply to this source, include but are not limited to the following: 1.6.7.1 Prohibited activities in 40 CFR Part 63 Subpart A § 63.4. 1.6.7.2 Operation and maintenance requirements in 40 CFR Part 63 Subpart A § 63.6(e)(1). 1.6.7.3 Startup, shutdown and malfunction plan requirements in 40 CFR Part 63 Subpart A § 63.6(e)(3). 1.6.7.4 Performance test requirements in 40 CFR Part 63 Subpart A § 63.7. 1.6.7.5 Monitoring requirements in 40 CFR Part 63 Subpart A § 63.8. 1.6.7.6 Notification requirements in 40 CFR Part 63 Subpart A § 63.9. 1.6.7.7 Recordkeeping requirements in 40 CFR Part 63 Subpart A § 63.10. 1.7 Volatile Organic Compound (VOC) emissions from coating operations are subject to the requirements in Colorado Regulation No. 7, Section IX, as follows: 1.7.1 VOC emissions from coating operations shall not exceed 2.9 lb/gc. Lb/gc is the abbreviation for (avoirdupois) pounds of solvent VOC per gallon of coating (minus water and "exempt" solvents, as defined in Section II.B.). (Colorado Regulation No. 7, Section IX.I and IX.J) 1.7.2 Test Methods and Procedures 1.7.2.1 The owner or operator of any VOC source required to comply with Colorado Regulation No. 7, Section IX.A.3.a shall, at their own expense, demonstrate compliance using EPA reference method 24 of 40 CFR Part 60 for surface coatings, and reference method 25 and reference methods 1 through 4 for add-on controls. (Colorado Regulation No. 7, Section IX.A.3.a) 1.7.2.2 The test protocol should be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No test shall be Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 10 conducted without prior approval from the Division. (Colorado Regulation No. 7, Section IX.A. 3.b) 1.7.2.3 The Division may use independent tests to verify test data submitted by the source operator or owner. The test methods shall be those listed in Condition 1.7.2.1 above and the Division test results shall take precedence. (Colorado Regulation No. 7, Section IX.A. 3.c) 1.7.2.4 The Division may accept, instead of the testing required in this subsection, a certification by the manufacturer of the composition of the coatings if supported by actual batch formulation records. The owner or operator of the VOC source required to comply with Colorado Regulation No. 7, Section IX.A. 3.d shall obtain certification from the coating manufacturer(s) that the test method(s) used for determination of VOC content meet the requirements specified in Subsection IX.A.3.a. The owner or operator shall have this certification readily available to Division personnel, in order to allow the results to be used in the daily compliance calculations specified in Subsection IX.A.10. (Colorado Regulation No. 7, Section IX.A. 3.d) 1.7.3 To determine compliance with applicable surface coating standards, samples shall be taken from the coating as freshly delivered to the reservoir of the coating applicator. (Colorado Regulation No. 7, Section IX.A.4) 1.7.4 Fugitive emission control 1.7.4.1 Control techniques and work practices shall be implemented at all times to reduce VOC emissions from fugitive sources. Control techniques and work practices include, but are not limited to (Colorado Regulation No. 7, Section IX.A.7.a): a tight -fitting covers for open tanks; b covered containers for solvent wiping cloths; c proper disposal of dirty cleanup solvent. 1.7.4.2 Emissions of organic material released during clean-up operations, disposal, and other fugitive emissions shall be included when determining total emissions, unless the source owner or operator documents that the VOCs are collected and disposed of in a manner that prevents evaporation to the atmosphere. (Colorado Regulation No. 7, Section IX.A.7.b) 1.7.5 Recordkeeping procedures shall follow the guidance in "Recordkeeping Guidance Document for Surface Coating Operations and the Graphic Arts Industry," July 1989, EPA 340/1-88-003. (Colorado Regulation No. 7, Section IX.A.8.c) 1.7.6 No owner or operator of a source of VOCs subject to Regulation No. 7, Section IX.A.9.a.(1) shall operate, cause, allow or permit the operation of the source, unless: For each category of surface coating as specified in Sections IX.B through IX.M, the owner or operator of a surface coating line or facility subject to that section does not cause, allow or permit the discharge into the atmosphere of any VOCs in excess of the specified emission limit, calculated as delivered to Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 11 the coating applicator or as applied to the substrate, whichever is greater. (Colorado Regulation No. 7, Section IX.A.9.a.(1)) 1.7.7 Compliance Calculation Procedures 1.7.7.1 Compliance with the emission limitations shall be determined on a daily basis. Sources may request a revision of the State Implementation Plan for longer times for compliance determination. (Colorado Regulation No. 7, Section IX.A.10.a) The permittee shall record material usage on a daily basis. However, daily compliance calculations for a given month may be conducted prior to the end of the subsequent month. 1.7.7.2 Compliance calculation procedures shall follow the guidance in "Procedure for Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink, and Other Coatings," EPA -450/3-84/019. In addition, for add-on controls or other compliance alternatives, calculation procedures shall follow the guidance of Section IX.A.5.f of this regulation. (Colorado Regulation No. 7, Section IX.A.10.b) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 2. Coating Assessment Laboratory (CAL). (AIRS# 005) Carestream Health, Inc. Page 12 Parameter Condition Number Limitations Monitoring Method Interval VOC Emissions 2.1 4.8 tons/yr Recordkeeping Calculation Monthly Alternate Operating Scenarios NSPS Subpart TT 2.3 0.28 kilogram VOC per liter of coating solids applied NSPS Subpart FFF 2.4 Use inks with a weighted average VOC content less than 1.0 kilogram VOC per kilogram ink solids NSPS Subpart VVV 2.5 Recordkeeping Calculation Monthly Note: The NSPS Subparts listed in Table 2 above provide emission limit options that require either partial or constant use of a control device. Since the CAL does not currently have the capability to accommodate such device, emission limit options utilizing a control device were not included in the Permit. 2.1 Emissions of VOC from the CAL shall not exceed the limits listed in the table above. Mass balance shall be used to estimate emissions using the following equation: tons VOC month = VOC consumption month Compliance with the annual limits shall be monitored on a rolling (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly emissions and process rates, and keep a compliance record on site for Division review. (Construction Permit 13WE1752 as modified under the provisions of Section I, Condition 1.3) 2.2 The permit holder shall conduct and record inspection and maintenance on the Dixon Coating Line as indicated in the O&M plan approved by the Division. Note: O&M plan approved on January 30, 2014. See Appendix H. 2.3 In the event that the Coating Assessment Laboratory performs metal coil surface coating this source will be subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart TT, Standards of Performance for Metal Coil Surface Coating, 40 C.F.R. Part 60 (July 1, 1998), and as amended on October 17, 2000 (65 FR 61744), including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart TT published in the Federal Register on 10/17/2000. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60, Subpart TT.] Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 13 2.3.1 On and after the date on which §60.8 requires a performance test to be completed, each owner or operator subject to Subpart TT shall not cause to be discharged into the atmosphere more than: (60.462(a)) 2.3.1.1 0.28 kilogram VOC per liter (kg VOC/l) of coating solids applied for each calendar month for each affected facility that does not use an emission control device(s). (60.462(a)(1)) 2.3.2 The owner or operator of an affected facility shall conduct an initial performance test as required under §60.8(a) and thereafter a performance test for each calendar month for each affected facility according to the procedures in §60.463. (60.463(b)) 2.3.3 The owner or operator shall use the following procedures for determining monthly volume - weighted average emissions of VOC's in kg/1 of coating solids applied. (60.463(c)) 2.3.3.1 An owner or operator shall use the following procedures for each affected facility that does not use a capture system and control device to comply with the emission limit specified under §60.462(a)(1). The owner or operator shall determine the composition of the coatings by formulation data supplied by the manufacturer of the coating or by an analysis of each coating, as received, using Method 24. The Administrator may require the owner or operator who uses formulation data supplied by the manufacturer of the coatings to determine the VOC content of coatings using Method 24 or an equivalent or alternative method. The owner or operator shall determine the volume of coating and the mass of VOC-solvent added to coatings from company records on a monthly basis. If a common coating distribution system serves more than one affected facility or serves both affected and existing facilities, the owner or operator shall estimate the volume of coating used at each affected facility by using the average dry weight of coating and the surface area coated by each affected and existing facility or by other procedures acceptable to the Administrator. (60.463(c)(1)) 2.3.4 Where compliance with the numerical limit specified in §60.462(a) (1) is achieved through the use of low VOC-content coatings without the use of emission control devices, the owner or operator shall compute and record the average VOC content of coatings applied during each calendar month for each affected facility, according to the equations provided in §60.463. (60.464(a)) 2.3.5 Where compliance with the numerical limit specified in §60.462(a) (1) is achieved through the use of low VOC-content coatings without emission control devices, each owner or operator subject to the provisions of Subpart TT shall include in the initial compliance report required by §60.8 the weighted average of the VOC content of coatings used during a period of one calendar month for each affected facility.(60.465(a)) 2.3.6 Following the initial performance test, the owner or operator of an affected facility shall identify, record, and submit a written report to the Administrator every calendar quarter of each instance in which the volume -weighted average of the local mass of VOC's emitted to the atmosphere per volume of applied coating solids (N) is greater than the limit specified under §60.462. If no such Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 14 instances have occurred during a particular quarter, a report stating this shall be submitted to the Administrator semiannually.(60.465(d)) 2.3.7 Each owner or operator subject to the provisions of this subpart shall maintain at the source, for a period of at least 2 years, records of all data and calculations used to determine monthly VOC emissions from each affected facility and to determine the monthly emission limit, where applicable. (60.465 (e)) 2.3.8 The reference methods in appendix A to 40 CFR Part 60, except as provided under §60.8(b), shall be used to determine compliance with §60.462 as follows: (60.466(a)) 2.3.8.1 Method 24, or data provided by the formulator of the coating, shall be used for determining the VOC content of each coating as applied to the surface of the metal coil. In the event of a dispute, Method 24 shall be the reference method. When VOC content of waterborne coatings, determined by Method 24, is used to determine compliance of affected facilities, the results of the Method 24 analysis shall be adjusted as described in Section 12.6 of Method 24; (60.466(a)(1)) 2.3.9 For Method 24, the coating sample must be at least a 1 -liter sample taken at a point where the sample will be representative of the coating as applied to the surface of the metal coil. (60.466(b)) 2.4 In the event that the Coating Assessment Laboratory performs flexible vinyl and urethane coating and printing this source will be subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart FFF, Standards of Performance for Flexible Vinyl and Urethane Coating and Printing, 40 C.F.R. Part 60 (July 1, 1998), and as amended on October 17, 2000 (65 FR 61744), including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart FFF published in the Federal Register on 10/17/2000. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60, Subpart FFF.] 2.4.1 On and after the date on which the performance test required by §60.8 has been completed, each owner or operator subject to Subpart FFF shall: (60.582(a)) 2.4.1.1 Use inks with a weighted average VOC content less than 1.0 kilogram VOC per kilogram ink solids at each affected facility (60.582(a)(1)) 2.4.2 Methods in appendix A of 40 CFR Part 60, except as provided under §60.8(b), shall be used to determine compliance with §60.582(a) as follows: (60.583(a)) 2.4.2.1 Method 24 for analysis of inks. If nonphotochemically reactive solvents are used in the inks, standard gas chromatographic techniques may be used to identify and quantify these solvents. The results of Method 24 may be adjusted to subtract these solvents from the measured VOC content. (60.583(a)(1)) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 15 2.4.3 To demonstrate compliance with §60.582(a)(1), the owner or operator of an affected facility shall determine the weighted average VOC content of the inks according to the following procedures: (60.583(b)) 2.4.3.1 Determine and record the VOC content and amount of each ink used at the print head, including the VOC content and amount of diluent solvent, for any time periods when VOC emission control equipment is not used. (60.583(b)(1)) 2.4.3.2 Compute the weighted average VOC content by the following equation: (60.583(b)(2)) G = 1�WoiMci) +Ej i(WojMdi) Ei=1(MciWsi) 2.4.3.3 The weighted average VOC content of the inks shall be calculated over a period that does not exceed one calendar month, or four consecutive weeks. A facility that uses an accounting system based on quarters consisting of two 28 calendar day periods and one 35 calendar day period may use an averaging period of 35 calendar days four times per year, provided the use of such an accounting system is documented in the initial performance test. (60.583(b)(3)) 2.4.3.4 Each determination of the weighted average VOC content shall constitute a performance test for any period when VOC emission control equipment is not used. Results of the initial performance test must be reported to the Administrator. Method 24 or ink manufacturers' formulation data along with plant blending records (if plant blending is done) may be used to determine VOC content. The Administrator may require the use of Method 24 if there is a question concerning the accuracy of the ink manufacturer's data or plant blending records. (60.583(b)(4)) 2.4.3.5 If, during the time periods when emission control equipment is not used, all inks used contain less than 1.0 kilogram VOC per kilogram ink solids, the owner or operator is not required to calculate the weighted average VOC content, but must verify and record the VOC content of each ink (including any added dilution solvent) used as determined by Method 24, ink manufacturers' formulation data, or plant blending records. (60.583(b(5))) 2.4.4 To demonstrate compliance with §60.582(a)(1), the owner or operator may determine the weighted average VOC content using an inventory system. (60.583(c)) 2.4.4.1 The inventory system shall accurately account to the nearest kilogram for the VOC content of all inks and dilution solvent used, recycled, and discarded for each affected facility during the averaging period. Separate records must be kept for each affected facility. (60.583(c)(1)) 2.4.4.2 To determine VOC content of inks and dilution solvent used or recycled, Method 24 or ink manufacturers' formulation data must be used in combination with plant blending records (if plant blending is done) or inventory records or purchase records Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 16 for new inks or dilution solvent. (60.583(c)(2)) 2.4.4.3 For inks to be discarded, only Method 24 shall be used to determine the VOC content. Inks to be discarded may be combined prior to measurement of volume or weight and testing by Method 24. (60.583(c)(3)) 2.4.4.4 The Administrator may require the use of Method 24 if there is a question concerning the accuracy of the ink manufacturer's data or plant records. (60.583(c)(4)) 2.4.4.5 The Administrator shall approve the inventory system of accounting for VOC content prior to the initial performance test. (60.583(c)(5)) 2.4.5 For all affected facilities subject to compliance with §60.582, the performance test data and results from the performance test shall be submitted to the Administrator as specified in §60.8(a). (60.585(a)) 2.4.6 The owner or operator of each affected facility shall submit semiannual reports to the Administrator of occurrences of the following: (60.585(b)) 2.4.6.1 Exceedances of the weighted average VOC content specified in §60.582(a)(1). (60.585(b)(1)) 2.4.7 The reports required under paragraph (b) shall be postmarked within 30 days following the end of the second and fourth calendar quarters. (60.585(c)) 2.5 In the event that the Coating Assessment Laboratory performs polymeric coating this source will be subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart VVV, Standards of Performance for Standards of Performance for Polymeric Coating of Supporting Substrates Facilities, §§60.744(b), 60.747(b), and 60.747(c), including, but not limited to, the following: [The requirements below reflect the current rule language of 40 CFR Part 60 Subpart VVV published in the Federal Register on 9/11/1989. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60, Subpart VVV.] 2.5.1 Any affected facility for which the amount of VOC used is less than 95 Mg per 12 -month period is subject only to the requirements of §§60.744(b), 60.747(b), and 60.747(c). If the amount of VOC used is 95 Mg or greater per 12 -month period, the facility is subject to all the requirements of Subpart VVV. Once a facility has become subject to the requirements of Subpart VVV, it will remain subject to those requirements regardless of changes in annual VOC use. (60.740(b)) 2.5.2 Each owner or operator of an affected facility that uses less than 95 Mg of VOC per year and each owner or operator of an affected facility subject to the provisions specified in §60.742(c)(3) shall: (60.744(b)) 2.5.2.1 Make semiannual estimates of the projected annual amount of VOC to be used for the manufacture of polymeric coated substrate at the affected coating operation in Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 17 that year; and (60.744(b)(1)) 2.5.2.2 Maintain records of actual VOC use. (60.744(b)(2)) 2.5.3 Each owner or operator of an affected facility subject to the provisions of §60.742(c)(3) and initially using less than 130 Mg of VOC per year and each owner or operator of an affected facility initially using less than 95 Mg of VOC per year shall: (60.747(c)) 2.5.3.1 Record semiannual estimates of projected VOC use and actual 12 -month VOC use; (60.747(c)(1)) 2.5.3.2 Report the first semiannual estimate in which projected annual VOC use exceeds the applicable cutoff; and (60.747(c)(2)) 2.5.3.3 Report the first 12 -month period in which the actual VOC use exceeds the applicable cutoff. (60.747(c)(3)) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 18 3. S070 - Two Natural Gas and Diesel Fueled Boilers (206 mmBtu/hr each, AIRS# 004). Parameter Condition Number Limitation Compliance Emission Factor Natural Gas Diesel Fuel Monitoring Method Interval PM 3.1 0.5 (FI)-o26 lbs/mmBtu Fuel Use Opacity 3.2 3.3 Natural Gas: 1203.7 mmscf/year Diesel Fuel: 82,500 gallons/year Not to exceed 20%, except as provided for in 3.3 SO2 3.4 1.5 lbs/M1VIBtu 7.6 lbs/mmscf 2 lbs/1000 gal Analysis and Recordkeeping Calculation Recordkeeping Semiannual Calculation Monthly EPA Method 9 Fuel Restriction Record keeping and calculation As needed PM PMto NOx VOC CO 3.5 4.66 Tons/Yr 4.62 Tons/Yr 7.6 lbs/mmscf 1 lbs/1000 gal 133.40 Tons/Yr 220 lbs/mmscf 24 lbs/1000 gal 3.32 Tons/Yr 5.5 lbs/mmscf 0.2 lbs/1000 gal 96.50 Tons/Yr 160 lbs/mmscf 5 lbs/1000 gal Recordkeeping Calculation Monthly Applicable Only if Actual NOx Emissions from Boilers Exceed 5 Tons/Year. Reg. 7, Section XVI 3.6 Conduct Annual Combustion Process Adjustment OR Conduct Combustion Process Adjustment According to Manufacturer Schedule & Procedure OR Comply With Tune up Procedure of MACT DDDDD MACT Subpart DDDDD 3.7 Tune-up every 5 years. One -Time Facility Energy Assessment. Fuel oil can only be burned during periods of gas curtailment, gas supply emergencies, or periodic testing. Periodic testing is limited to 48 hours per calendar year. Reg. 7, Section XIX 3.9 Submit RACT Analysis See Conditions 3.6 See Conditions 3.7 See Conditions 3.8 See Conditions 3.9 Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 19 3.1 PM emissions shall not exceed the limitation as stated in the above equation (Colorado Regulation No. 1, Section II.A.1.b). In this equation, PE = the particulate limit (lbs/mmBtu) and FI = fuel input (mmBtu/hour). 3.1.1 In the absence of credible evidence to the contrary, compliance with the particulate matter standard shall be presumed whenever natural gas is used as fuel for this boiler. 3.1.2 In the absence of credible evidence to the contrary, compliance with the particulate matter standard shall be presumed whenever No. 2 Fuel Oil is used as fuel for this boiler. 3.2 This source shall be limited to a maximum raw material process rate or fuel use rate as listed below and all other activities, operational rates and numbers of equipment as stated in the application. Monthly records of the actual consumption rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, Section II.A.4.) Consumption of natural gas fuel for both boilers together shall not exceed 1,203.7 MMscf per year. Consumption of No. 2 fuel oil for both boilers together shall not exceed 82,500 gallons per year. Compliance with the annual consumption limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months data. 3.3 The boilers are subject to the following opacity requirements: 3.3.1 Except as provided for in Condition 3.3.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.I). This opacity standard applies to each boiler. 3.3.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from start-up which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Construction Permit 10WE1575 and Colorado Regulation No. 1, Section II.A.4). This opacity standard applies to each boiler. Compliance with the opacity requirements will be monitored as follows: 3.3.3 When Burning Natural Gas: In the absence of credible evidence to the contrary, compliance with above opacity requirements shall be presumed whenever natural gas is used as fuel for these boilers. 3.3.4 When Burning No. 2 Fuel Oil: Compliance with the opacity requirements shall be monitored as follows: 3.3.4.1 Compliance with the opacity standard in Condition 3.3.2 shall be monitored by conducting a visible emission observation in accordance with EPA Reference Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 20 Method 9, once per year. This annual observation shall be taken within one (1) hour of the commencement of startup during daylight hours on No. 2 fuel oil and every 24 hours thereafter until startup is completed. A visible emission observation is not required for any annual period where no No. 2 fuel oil has been burned. 3.3.4.2 Compliance with the opacity standard in Condition 3.3.1 shall be monitored by conducting visible emission observations in accordance with EPA Method 9, once per quarter. Such observation shall be conducted within 24 hours of completion of startup on No. 2 fuel oil, if applicable. If No. 2 fuel oil is burned continuously for seven (7) days, a visible emission observation shall be conducted on the seventh day. Subsequent observations shall be taken every seven (7) days thereafter, provided that No. 2 fuel oil is burned continuously. If No. 2 fuel oil is not burned during the quarter, then no visible emission observations are required. 3.3.4.3 Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the opacity limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 3.3.4.4 Results of Method 9 readings and a copy of the certified Method 9 observer's certification shall be made available to the Division upon request. 3.4 Existing oil -fired sources of sulfur dioxide shall not emit sulfur dioxide in excess of 1.5 pounds of sulfur dioxide per million Btu of heating input. (Heat input rates shall be the manufacturer's guaranteed maximum heat input rates) (Reference: Regulation No. 1, VI.A.3.b.(i)) In the absence of credible evidence to the contrary, compliance with the emission standard for distillate fuel combustion may be demonstrated by maintaining a record of a calculation demonstrating the combination of the emission factor and fuel heat content precludes non-compliance. A copy of the calculation shall be made available for Division review upon request. 3.5 Compliance with annual limits shall be determined on a rolling twelve month total. By the 45th day after the close of each month a new twelve month total shall be calculated using the previous twelve months' data. The permit holder shall calculate monthly emissions using the procedures described below and keep a compliance record on site for Division review. tons _ lb mmscf 1 ton VOC month — 5.5 mmscf x Natural Gas Use month x 2000 lbs tons lb mmscf 1 ton PM/PM10 month= 7.6 mmscf x Natural Gas Use month x 2000 lbs Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. tons _ lb mmscf 1 ton CO month= 160 mmscf x Natural Gas Use month x 2000 lbs tons _ lb mmscf 1 ton NOx month — 280 mmscf x Natural Gas Use month x 2000 lbs Page 21 The permittee shall maintain emission calculation records on site for Division inspection upon request. 3.6 Applicable only IF actual NOx emissions from boilers exceed 5 tons/ year. The S070 Boilers are subject to the requirements in Colorado Regulation No. 7, Section XVI, as follows: 3.6.1 When burning the fuel that provides the majority of the heat input since the last combustion process adjustment and when operating at a firing rate typical of normal operation, the owner or operator must conduct the following inspections and adjustments of boilers and process heaters, as applicable: (Colorado Regulation No. 7, Section XVI.D.2.a) 3.6.1.1 Inspect the burner and combustion controls and clean or replace components as necessary. (Colorado Regulation No. 7, Section XVI.D.2.a.(i)) 3.6.1.2 Inspect the flame pattern and adjust the burner or combustion controls as necessary to optimize the flame pattern. (Colorado Regulation No. 7, Section XVI.D.2.a.(ii)) 3.6.1.3 Inspect the system controlling the air -to -fuel ratio and ensure that it is correctly calibrated and functioning properly. (Colorado Regulation No. 7, Section XVI.D.2.a.(iii)) 3.6.1.4 Measure the concentration in the effluent stream of carbon monoxide and nitrogen oxide in ppm, by volume, before and after the adjustments in Sections XVI.D.2.a.(i)- (iii). Measurements may be taken using a portable analyzer. (Colorado Regulation No. 7, Section XVI.D.2.a.(iv)) 3.6.2 The owner or operator must operate and maintain the boiler, duct burner, process heater, stationary combustion turbine, or stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (Colorado Regulation No. 7, Section XVI.D.2.e) 3.6.3 The owner or operator must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (Colorado Regulation No. 7, Section XVI.D.2.f.(i)) 3.6.4 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections XVI.D.4.a. or XVI.D.4.b of Colorado Regulation No. 7. (Colorado Regulation No. 7, Section XVI.D.2.f.(ii)) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 22 3.6.5 The owner or operator must create a report once every calendar year identifying the combustion equipment at the facility subject to Section XVI.D. and including for each combustion equipment: (Colorado Regulation No. 7, Section XVI.D.3.a) 3.6.5.1 The date of the adjustment; (Colorado Regulation No. 7, Section XVI.D.3.a.(i)) 3.6.5.2 Whether the combustion process adjustment under Sections XVI.D.2.a.-e. was followed, and what procedures were performed; (Colorado Regulation No. 7, Section XVI.D.3.a.(ii)) 3.6.5.3 Whether a combustion process adjustment under XVI.D.4.a.-b. was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any; and (Colorado Regulation No. 7, Section XVI.D.3.a.(iii)) 3.6.5.4 A description of any corrective action taken. (Colorado Regulation No. 7, Section XVI.D.3.a.(iv)) 3.6.5.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (Colorado Regulation No. 7, Section XVI.D.3.a.(v)) 3.6.5.6 If multiple fuels are used, the type of fuel burned and heat input provided by each fuel. (Colorado Regulation No. 7, Section XVI.D.3.a.(vi)) 3.6.6 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under Section XVI.D.4.a. for the life of the equipment, and make available to the Division upon request. (Colorado Regulation No. 7, Section XVI.D.3.b) 3.6.7 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under Section XVI.D.4.a. for the life of the equipment, and make available to the Division upon request. (Colorado Regulation No. 7, Section XVI.D.3.c) 3.6.8 As an alternative to the requirements described in Sections XVI.D.2.a.-e. and XVI.D.3.a.: (Colorado Regulation No. 7, Section XVI.D.4) 3.6.8.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule; or (Colorado Regulation No. 7, Section XVI.D.4.a) 3.6.8.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 or 40 CFR Part 63. (Colorado Regulation No. 7, Section XVI.D.4.b) 3.6.8.3 The owner or operator may comply with applicable recordkeeping requirements Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 23 related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63. (Colorado Regulation No. 7, Section XVI.D.4.c) 3.7 These boilers are subject to the National Emissions Standards for Hazardous air pollutants from Industrial, Commercial and Institutional Boilers and Process Heaters, 40 CFR Part 63 Subpart DDDDD. Specifically, these boilers are subject to the following requirements: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart DDDDD published in the Federal Register on 11/05/2015. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63, Subpart DDDDD.] 3.7.1 If you have an existing boiler or process heater, you must comply with Subpart DDDDD no later than January 31, 2016, except as provided in §63.6(i). (63.7495(b)) 3.7.2 You must meet the notification requirements in §63.7545 according to the schedule in §63.7545 and in subpart A of 40 CFR Part 63. Some of the notifications must be submitted before you are required to comply with the emission limits and work practice standards in Subpart DDDDD. (63.7495(d)) 3.7.3 You must meet the requirements in paragraphs (a)(1) through (3) of §63.7500, except as provided in paragraphs (b), through (e) of §63.7500. You must meet these requirements at all times the affected unit is operating, except as provided in paragraph (f) of §63.7500. (63.7500(a)) Note: The requirements in § 63.7500(a) (2) do not apply to these boilers and have not been included in the permit. 3.7.3.1 You must meet each emission limit and work practice standard in Tables 1 through 3, and 11 through 13 to Subpart DDDDD that applies to your boiler or process heater, for each boiler or process heater at your source, except as provided under §63.7522. The output -based emission limits, in units of pounds per million Btu of steam output, in Tables 1 or 2 to Subpart DDDDD are an alternative applicable only to boilers and process heaters that generate either steam, cogenerate steam with electricity, or both. The output -based emission limits, in units of pounds per megawatt -hour, in Tables 1 or 2 to Subpart DDDDD are an alternative applicable only to boilers that generate only electricity. Boilers that perform multiple functions (cogeneration and electricity generation) or supply steam to common headers would calculate a total steam energy output using equation 21 of §63.7575 to demonstrate compliance with the output -based emission limits, in units of pounds per million Btu of steam output, in Tables 1 or 2 to Subpart DDDDD. If you operate a new boiler or process heater, you can choose to comply with alternative limits as discussed in paragraphs (a)(1)(i) through (iii) of §63.7500, but on or after January 31, 2016, you must comply with the emission limits in Table 1 to §63.7500. (63.7500(a)(1)) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: Dl Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 24 3.7.3.2 A new or existing boiler or process heater with a continuous oxygen trim system that maintains an optimum air to fuel ratio must conduct a tune-up of the boiler or process heater every 5 years as specified in §63.7540. (40 CFR Part 63 Subpart DDDDD, Table 3, Item 1) 3.7.3.3 An existing boiler or process heater located at a major source facility, not including limited use units must have a one-time energy assessment performed by a qualified energy assessor. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in this table, satisfies the energy assessment requirement. A facility that operated under an energy management program developed according to the ENERGY STAR guidelines for energy management or compatible with ISO 50001 for at least one year between January 1, 2008 and the compliance date specified in §63.7495 that includes the affected units also satisfies the energy assessment requirement. The energy assessment must include the following with extent of the evaluation for items a. to e. appropriate for the on -site technical hours listed in §63.7575: (40 CFR Part 63 Subpart DDDDD, Table 3, Item 4) Note: This requirement has been fulfilled as per Notification of Compliance received February 5, 2016. a A visual inspection of the boiler or process heater system. b An evaluation of operating characteristics of the boiler or process heater systems, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints. c An inventory of major energy use systems consuming energy from affected boilers and process heaters and which are under the control of the boiler/process heater owner/operator. d A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage. e A review of the facility's energy management program and provide recommendations for improvements consistent with the definition of energy management program, if identified. f A list of cost-effective energy conservation measures that are within the facility's control. g A list of the energy savings potential of the energy conservation measures identified. h A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments. 3.7.3.4 At all times, you must operate and maintain any affected source (as defined in Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 25 §63.7490), including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (63.7500(a)(3)) 3.7.4 As provided in §63.6(g), EPA may approve use of an alternative to the work practice standards in §63.7500. (63.7500(b)) 3.7.5 For existing affected sources (as defined in §63.7490), you must complete an initial tune-up by following the procedures described in §63.7540(a)(10)(i) through (vi) no later than the compliance date specified in §63.7495, except as specified in paragraph (j) of §63.7510. You must complete the one-time energy assessment specified in Table 3 to §63.7510 no later than the compliance date specified in §63.7495. (63.7510(e)) 3.7.6 If you are required to meet an applicable tune-up work practice standard, you must conduct an annual, biennial, or 5 -year performance tune-up according to §63.7540(a)(10), (11), or (12), respectively. Each annual tune-up specified in §63.7540(a)(10) must be no more than 13 months after the previous tune-up. Each biennial tune-up specified in §63.7540(a)(11) must be conducted no more than 25 months after the previous tune-up. Each 5 -year tune-up specified in §63.7540(a)(12) must be conducted no more than 61 months after the previous tune-up. (63.7515(d)) 3.7.7 You must include with the Notification of Compliance Status a signed certification that either the energy assessment was completed according to Table 3 to Subpart DDDDD, and that the assessment is an accurate depiction of your facility at the time of the assessment, or that the maximum number of on -site technical hours specified in the definition of energy assessment applicable to the facility has been expended. (63.7530(e)) 3.7.8 You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in §63.7545(e). (63.7530(f)) 3.7.9 If your boiler or process heater has a continuous oxygen trim system that maintains an optimum air to fuel ratio, or a heat input capacity of less than or equal to 5 million Btu per hour and the unit is in the units designed to burn gas 1; units designed to burn gas 2 (other); or units designed to burn light liquid subcategories, or meets the definition of limited -use boiler or process heater in §63.7575, you must conduct a tune-up of the boiler or process heater every 5 years as specified in paragraphs (a)(10)(i) through (vi) of this section to demonstrate continuous compliance. You may delay the burner inspection specified in paragraph (a)(10)(i) of this section until the next scheduled or unscheduled unit shutdown, but you must inspect each burner at least once every 72 months. If an oxygen trim system is utilized on a unit without emission standards to reduce the tune-up frequency to once every 5 years, set the oxygen level no lower than the oxygen concentration measured during the most recent tune-up. (63.7540(a)(12)) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 26 3.7.9.1 As applicable, inspect the burner, and clean or replace any components of the burner as necessary (you may perform the burner inspection any time prior to the tune-up or delay the burner inspection until the next scheduled unit shutdown). Units that produce electricity for sale may delay the burner inspection until the first outage, not to exceed 36 months from the previous inspection. At units where entry into a piece of process equipment or into a storage vessel is required to complete the tune-up inspections, inspections are required only during planned entries into the storage vessel or process equipment; (63.7540(a)(10)(i)) 3.7.9.2 Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available; (63.7540(a)(10)(ii)) 3.7.9.3 Inspect the system controlling the air -to -fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly (you may delay the inspection until the next scheduled unit shutdown). Units that produce electricity for sale may delay the inspection until the first outage, not to exceed 36 months from the previous inspection; (63.7540(a)(10)(iii)) 3.7.9.4 Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any NOx requirement to which the unit is subject; (63.7540(a)(10)(iv)) 3.7.9.5 Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer; and (63.7540(a)(10)(v)) 3.7.9.6 Maintain on -site and submit, if requested by the Administrator, a report containing the information in paragraphs (a)(10)(vi)(A) through (C) of §63.7540. (63 .7540(a)(10)(vi)) 3.7.10 If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar days of startup. (63.7540(a)(13)) 3.7.11 You must submit to the Division the initial notification (§ 63.9(b)) and the notification of compliance status (§ 63.9(h)) by the dates specified. (63.7545(a)) 3.7.12 As specified in §63.9(b)(2), if you startup your affected source before January 31, 2013, you must submit an Initial Notification not later than 120 days after January 31, 2013. (63.7545(b)) 3.7.13 If you are required to conduct an initial compliance demonstration as specified in §63.7530, you must submit a Notification of Compliance Status according to §63.9(h)(2)(ii). For the initial compliance demonstration for each boiler or process heater, you must submit the Notification of Compliance Status, including all performance test results and fuel analyses, before the close of business on the 60th day following the completion of all performance test and/or other initial compliance demonstrations for all boiler or process heaters at the facility according to §63.10(d)(2). The Notification of Compliance Status report must contain all the information Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 27 specified in paragraphs (e)(1) through (8) of §63.7545, as applicable. The Notification of Compliance Status for the affected sources at this facility shall include the information specified in paragraphs (e)(1), (6), (7) and (8) of §63.7545. (63.7545(e)) 3.7.14 If you operate a unit designed to burn natural gas, refinery gas, or other gas 1 fuels that is subject to Subpart DDDDD, and you intend to use a fuel other than natural gas, refinery gas, gaseous fuel subject to another subpart of 40 CFR Part 63, part 60, 61, or 65, or other gas 1 fuel to fire the affected unit during a period of natural gas curtailment or supply interruption, as defined in §63.7575, you must submit a notification of alternative fuel use within 48 hours of the declaration of each period of natural gas curtailment or supply interruption, as defined in §63.7575. The notification must include the information specified in paragraphs (f)(1) through (5) of §63.7545. (63.7545(f)) 3.7.15 You must submit each report in Table 9 to Subpart DDDDD that applies to you. (63.7550(a)) 3.7.15.1 You must submit a compliance report containing information required in §63.7550(c)(1) through (5); and (40 CFR Part 63 Subpart DDDDD, Table 9, Item 1(a)) 3.7.15.2 If there are no deviations from any emission limitation (emission limit and operating limit) that applies to you and there are no deviations from the requirements for work practice standards for periods of startup and shutdown in Table 3 to Subpart DDDDD that apply to you, a statement that there were no deviations from the emission limitations and work practice standards during the reporting period. If there were no periods during which the CMSs, including continuous emissions monitoring system, continuous opacity monitoring system, and operating parameter monitoring systems, were out -of -control as specified in §63.8(c)(7), a statement that there were no periods during which the CMSs were out -of -control during the reporting period; and (40 CFR Part 63 Subpart DDDDD, Table 9, Item 1(b)) 3.7.15.3 If you have a deviation from any emission limitation (emission limit and operating limit) where you are not using a CMS to comply with that emission limit or operating limit, or a deviation from a work practice standard for periods of startup and shutdown, during the reporting period, the report must contain the information in §63.7550(d); and (40 CFR Part 63 Subpart DDDDD, Table 9, Item 1(c)) 3.7.15.4 If there were periods during which the CMSs, including continuous emissions monitoring system, continuous opacity monitoring system, and operating parameter monitoring systems, were out -of -control as specified in §63.8(c)(7), or otherwise not operating, the report must contain the information in §63.7550(e). (40 CFR Part 63 Subpart DDDDD, Table 9, Item 1(3)) 3.7.15.5 You must submit the report semiannually, annually, biennially, or every 5 years according to the requirements in §63.7550(b). (40 CFR Part 63 Subpart DDDDD, Table 9, Item 1(a)) 3.7.16 For units that are subject only to a requirement to conduct subsequent annual, biennial, or 5 -year tune-up according to §63.7540(a)(10), (11), or (12), respectively, and not subject to emission Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 28 limits or Table 4 operating limits, you may submit only an annual, biennial, or 5 -year compliance report, as applicable, as specified in paragraphs (b)(1) through (4) of this section, instead of a semi-annual compliance report. (63.7550(b)) 3.7.17 A compliance report must contain the following information depending on how the facility chooses to comply with the limits set in this rule. (63.7550(c)) 3.7.17.1 If the facility is subject to the requirements of a tune up you must submit a compliance report with the information in paragraphs (c)(5)(i) through (iii), (xiv), and (xvii) of §63.7550. (63.7550(c)(1)) 3.7.18 You must keep the following records: 3.7.18.1 A copy of each notification and report that you submitted to comply with Subpart DDDDD, including all documentation supporting any Initial Notification or Notification of Compliance Status or semiannual compliance report that you submitted, according to the requirements in §63.10(b)(2)(xiv). (63.7555(a)(1)) 3.7.18.2 Records of performance tests, fuel analyses, or other compliance demonstrations and performance evaluations as required in § 63.10(b)(2)(viii). (63.7555(a)(2)) 3.7.19 If you operate a unit in the unit designed to burn gas 1 subcategory that is subject to Subpart DDDDD, and you use an alternative fuel other than natural gas, refinery gas, gaseous fuel subject to another subpart under 40 CFR Part 63, other gas 1 fuel, or gaseous fuel subject to another subpart of 40 CFR Part 63 or Part 60, 61, or 65, you must keep records of the total hours per calendar year that alternative fuel is burned and the total hours per calendar year that the unit operated during periods of gas curtailment or gas supply emergencies. (63.7555(h)) 3.7.20 Records shall be kept in the form and for the duration specified in § 63.7560. 3.7.21 Table 10 of 40 CFR Part 63 Subpart DDDDD shows which parts of the General Provisions in §§ 63.1 through 63.15 apply to you. (63.7565) These requirements include but are not limited to the following: 3.7.21.1 Prohibited activities in § 63.4. 3.7.21.2 Compliance with Standards and Maintenance Requirements in §63.6(a), (b)(1) - (b)(5), (b)(7), (c) 3.7.21.3 Notification requirements in § 63.9. 3.8 In accordance with the requirements in 40 CFR Part 63 Subpart DDDDD, boilers designed to burn gas 1 subcategory fuels, are subject to the requirements listed above. A "unit designed to burn gas 1 subcategory" is defined in 40 CFR Part 63 Subpart DDDDD § 63.7575, "includes any boiler or process heater that burns only natural gas, refinery gas, and/or other gas 1 fuels. Gaseous fuel boilers and process heaters that burn liquid fuel for periodic testing of liquid fuel, maintenance, or operator training, not to exceed a combined total of 48 hours during any calendar year, are included in this definition. Gaseous fuel boilers and process heaters that burn liquid fuel during periods of gas curtailment or gas supply interruptions of any duration are also included in this definition." The permittee shall retain Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 29 records for each unit documenting the reason for burning fuel oil and the hours that fuel oil is burned. In the event that fuel oil is burned in any boiler for reasons other than periodic testing of liquid fuel, maintenance, or operator training or if periodic testing and/or training exceeds 48 hours during a calendar year, additional provision in 40 CFR Part 63 Subpart DDDDD apply to that boiler. Within 60 days of triggering additional requirements in 40 CFR Part 63 Subpart DDDDD, the permittee shall submit an application to revise this permit to include the appropriate requirements. 3.9 The S070 Boilers are subject to the requirements in Colorado Regulation No. 7, Section XIX, as follows: 3.9.1 Owners or operators of the following major sources must submit a RACT analysis for the facility or specified emission points to the Division. Approved RACT determinations will be addressed in the relevant source permit or through rule revisions, as appropriate. (Colorado Regulation No. 7, Section XIX.B) 3.9.1.1 Carestream Health (123-6250) — boilers (pt 004) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 30 4. Degreasing Units (C-15, C-20, C-41, C-48, C-50, C-70) Parameter Condition Number Limitation Monitoring Method Interval Reg 7, Section X.A — Transfer and Storage of Waste & Solvents 4.1 & 4.2 See Conditions 4.1 & 4.2 Certification Annually Reg 7, Section X.B — Control Standards 4.3 — 4.8 See Conditions 4.3 - 4.8 Certification Annually Note that this emission unit is exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction permit requirements in Regulation No. 3, Part B. 4.1 In any disposal or transfer of waste or used solvent, at least 80 percent by weight of the solvent/waste liquid shall be retained (i.e., no more than 20 percent of the liquid solvent/solute mixture shall evaporate or otherwise be lost during transfers). (Colorado Regulation No. 7, Section X.A.3) 4.2 Waste or used solvent shall be stored in closed containers unless otherwise required by law. (Colorado Regulation No. 7, Section X.A.4) 4.3 All cold -cleaners shall have a properly fitting cover. (Colorado Regulation No. 7, Section X.B.1.a(i)) 4.3.1 Covers shall be designed to be easily operable with one hand under any of the following conditions (Colorado Regulation No. 7, Section X.B.1.a(ii)): 4.3.1.1 Solvent true vapor pressure is greater than 15 torr (0.3 psia) at 38°C (100°F). (Colorado Regulation No. 7, Section X.B.1.a(ii)(A)) 4.3.1.2 The solvent is agitated by an agitating mechanism. (Colorado Regulation No. 7, Section X.B.1.a(ii)(B)) 4.3.1.3 The solvent is heated. (Colorado Regulation No. 7, Section X.B.1.a(ii)(C)) 4.4 All cold -cleaners shall have a drainage facility that captures the drained liquid solvent from the cleaned parts. (Colorado Regulation No. 7, Section X.B.1.b(i)). For cold -cleaners using solvent which has a vapor pressure greater than 32 ton (0.62 psia) measured at 38°C (100°F) either: 4.4.1 There shall be an internal drainage facility within the confines of the cold -cleaner, so that parts are enclosed under the (closed) cover to drain after cleaning, or if such a facility will not fit within; (Colorado Regulation No. 7, Section X.B.1.b(ii)(A)) 4.4.2 An enclosed, external drainage facility that captures the drained solvent liquid from the cleaned parts. (Colorado Regulation No. 7, Section X.B.1.b(ii)(B)) 4.5 A permanent, clearly visible sign shall be mounted on or next to the cold -cleaner. The sign shall list the operating requirements. (Colorado Regulation No. 7, Section X.B.1.c) 4.6 Solvent spray apparatus shall not have a splashing, fine atomizing, or shower type action but rather should produce a solid, cohesive stream. Solvent spray shall be used at a pressure that does not cause excessive splashing. (Colorado Regulation No. 7, Section X.B.1.d) Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: D Air Pollution Control Division Colorado Operating Permit Permit # 060PWE288 Carestream Health, Inc. Page 31 For solvents with a true vapor pressure above 32 torr (0.62 psia) at 38°C (100°F), or, for solvents heated above 50°C (120°F), one of the following techniques shall be used: 4.6.1 A freeboard ratio greater than or equal to 0.7. (Colorado Regulation No. 7, Section X.B.1.d(i)) 4.6.2 A water or a non-volatile liquid cover. The cover liquid shall not be soluble in the solvent and shall not be more dense than the solvent and the depth of the cover liquid shall be sufficient to prevent the escape of solvent vapors. (Colorado Regulation No. 7, Section X.B.1.d(ii)) 4.7 The cold -cleaner cover shall be closed whenever parts are not being handled within the cleaner confines. (Colorado Regulation No. 7, Section X.B.2.a) 4.8 Cleaned parts shall be drained for at least 15 seconds and/or until dripping ceases. Any pools of solvent shall be tipped out off the clean part back into the tank. (Colorado Regulation No. 7, Section X.B.2.b) Operating Permit Number: 060PWE288 First Issued: September 1, 1999 Renewed: enewed DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 32 SECTION III - Permit Shield Regulation No. 3, 5 CCR 1001-5, Part C, I.A.4, V.D. & XIII.B; § 25-7-114.4(3)(a), C.R.S. 1. Specific Non -Applicable Requirements Based on the information available to the Division and supplied by the applicant, the following parameters and requirements have been specifically identified as non -applicable to the facility to which this permit has been issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit issuance. In addition, this shield does not protect the source from any violations that occur as a result of any modification or reconstruction on which construction commenced prior to permit issuance. Emission Unit Description &Number Applicable Requirement Justification Facility Wide 40 CFR Parts 9 and 63, Subpart JJ, as adopted by reference in Colorado Regulation No. 8, Part E Permitee maintains records of coating and adhesive use to demonstrate they are an incidental wood product manufacturer 40 CFR Part 63, Subpart U, as adopted by reference in Colorado Regulation No. 8, Part E Permitee does not manufacture as a primary product any of the elastomer products listed in this regulation 40 CFR Part 63, Subpart W, as adopted by reference in Colorado Regulation No. 8, Part E Permitee is not an existing, new, or reconstructed manufacturer of epoxy resins or wet strength resins 40 CFR Part 63, Subpart V, as adopted by reference in Colorado Regulation No. 8, Part E Permitee purchases low molecular weight PET from an offsite source 40 CFR Part 61 Facility is not subject to listed NESHAPS 40 CFR Part 9 and Part 63, Subpart Q Facility does not use chromium in its industrial cooling towers 40 CFR Part 82, Subpart E Product does not contain or is not made with ozone depleting compounds Colorado Regulation No. 18, 40 CFR Part 72 and General Condition 26 of this permit There are no affected units subject to the acid rain provisions at this facility Colorado Regulation No. 8, Parts A and C Facility is not subject to listed NESHAPS and is not a stationary source of lead. General Condition 20 of this permit There are no portable sources associated with this facility. General Condition 30 of this permit This facility does not advertise, sell, install, or use wood stoves or wood burning appliances 40 CFR Part 63, Subpart JJJ, as adopted by reference in Colorado Regulation No. 8 This facility does not produce any thermoplastic product listed in the Group IV polymers MACT. 40 CFR Part 63, Subpart EEEE, as adopted by reference in Colorado Regulation No. 8 This facility does not fit the definition of affected source under 40 CFR Part, Subpart EEEE. 40 CFR Part 63, Subpart FFFF, as adopted by reference in Colorado Regulation No. 8 This facility is subject to MACT JJJJ and therefore exempt from MACT FFFF as per §63.2435(c)(3). C-40 40 CFR Part 60, Subpart Kb, as adopted by reference in Colorado Regulation No. 6, Part A All VOL storage tanks are less than 40 m3 in size Colorado Regulation No. 3, Part B 1.A Chemical Weigh Station, Gelatin Weigh Station, and Silver Recovery received grandfathered status Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 33 2. General Conditions Compliance with this Operating Permit shall be deemed compliance with all applicable requirements specifically identified in the permit and other requirements specifically identified in the permit as not applicable to the source. This permit shield shall not alter or affect the following: 2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement in cases of emergency; 2.2 The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; 2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the federal act; 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to § 25-7- 111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the federal act; 2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to Regulation No. 3, Part C, § XIII. 2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to permit issuance. 3. Stream -lined Conditions The following applicable requirements have been subsumed within this operating permit using the pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed requirements. No applicable requirements were streamlined out of this permit. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 34 SECTION IV - General Permit Conditions (Ver. 5/22/12) 1. Administrative Changes Regulation No. 3, 5 CCR 1001-5, Part A, 4 III. The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes that are described in Regulation No. 3, Part A, § I.B.1. The permittee may immediately make the change upon submission of the application to the Division. 2. Certification Requirements Regulation No. 3, 5 CCR 1001-5, Part C, &§ III.B.9., V.C.16.a.& e. and V.C.17. a. Any application, report, document and compliance certification submitted to the Air Pollution Control Division pursuant to Regulation No. 3 or the Operating Permit shall contain a certification by a responsible official of the truth, accuracy and completeness of such form, report or certification stating that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate and complete. b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the Division in the Operating Permit. c. Compliance certifications shall contain: (i) the identification of each permit term and condition that is the basis of the certification; (ii) the compliance status of the source; (iii) whether compliance was continuous or intermittent; (iv) method(s) used for determining the compliance status of the source, currently and over the reporting period; and (v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the source. d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r) of the federal act, the permittee shall certify its compliance with that requirement; the Operating Permit shall not incorporate the contents of the risk management plan as a permit term or condition. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 35 3. Common Provisions Common Provisions Regulation, 5 CCR 1001-2 §& II.A., II.B., II.C., II.E., II.F., II.I, and II.J a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line, such emissions shall not cause the air quality standards of the receiving State to be exceeded, provided reciprocal action is taken by the receiving State. b. Emission Monitoring Requirements The Division may require owners or operators of stationary air pollution sources to install, maintain, and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. c. Performance Testing The owner or operator of any air pollution source shall, upon request of the Division, conduct performance test(s) and furnish the Division a written report of the results of such test(s) in order to determine compliance with applicable emission control regulations. Performance test(s) shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves, in specific cases, the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance; or (iv) waives the requirement for performance test(s) because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes, Title 25, Article 7, and pursuant to regulations promulgated by the Commission. Compliance test(s) shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility. The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s). Operations during period of startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s) unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 36 are made for earlier testing. The owner or operator of an affected facility shall provide, or cause to be provided, performance testing facilities as follows: (i) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s); and (iv) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining compliance with an applicable standard, the arithmetic mean of results of at least three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances beyond the owner or operator's control, compliance may, upon the Division's approval, be determined using the arithmetic mean of the results of the two other runs. Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted. d. Affirmative Defense Provision for Excess Emissions during Malfunctions An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that: (i) The excess emissions were caused by a sudden, unavoidable breakdown of equipment, or a sudden, unavoidable failure of a process to operate in the normal or usual manner, beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided, or planned for, and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions (including any bypass) were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation (if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 37 (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or maintenance; (ix) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This section is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement; and (x) During the period of excess emissions, there were no exceedances of the relevant ambient air quality standards established in the Commissions' Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards or emission limits, including, but not limited to, new source performance standards and national emission standards for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip) limits or permit limits that have been set taking into account potential emissions during malfunctions, including, but not necessarily limited to, certain limits with 30 -day or longer averaging times, limits that indicate they apply during malfunctions, and limits that indicate they apply at all times or without exception. e. Circumvention Clause A person shall not build, erect, install, or use any article, machine, equipment, condition, or any contrivance, the use of which, without resulting in a reduction in the total release of air pollutants to the atmosphere, reduces or conceals an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. f. Compliance Certifications For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in the Colorado State Implementation Plan, nothing in the Colorado State Implementation Plan shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. Evidence that has the effect of making any relevant standard or permit term more stringent shall not be credible for proving a violation of the standard or permit term. When compliance or non-compliance is demonstrated by a test or procedure provided by permit or Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 38 g. other applicable requirement, the owner or operator shall be presumed to be in compliance or non- compliance unless other relevant credible evidence overcomes that presumption. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of the evidence that: (i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and could not have been prevented through careful planning and design; (ii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation or maintenance; (iii) If the excess emissions were caused by a bypass (an intentional diversion of control equipment), then the bypass was unavoidable to prevent loss of life, personal injury, or severe property damage; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation (if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; and, (viii) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the division verbally as soon as possible, but no later than two (2) hours after the start of the next working day, and shall submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that derive from new source performance standards or national emissions standards for hazardous air pollutants, or any other federally enforceable performance standard or emission limit with an averaging time greater than twenty-four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of Significant Deterioration (PSD) increments. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 39 In making any determination whether a source established an affirmative defense, the division shall consider the information within the notification required above and any other information the division deems necessary, which may include, but is not limited to, physical inspection of the facility and review of documentation pertaining to the maintenance and operation of process and air pollution control equipment. 4. Compliance Requirements Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.C.9., V.C.11. & 16.d. and § 25-7-122.1(2), C.R.S. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally -enforceable terms or conditions constitutes a violation of the federal act, as well as the state act and Regulation No. 3. Any permit noncompliance relating to state -only terms or conditions constitutes a violation of the state act and Regulation No. 3, shall be enforceable pursuant to state law, and shall not be enforceable by citizens under § 304 of the federal act. Any such violation of the federal act, the state act or regulations implementing either statute is grounds for enforcement action, for permit termination, revocation and reissuance or modification or for denial of a permit renewal application. b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination, revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of any request by the permittee for a permit modification, revocation and reissuance, or termination, or any notification of planned changes or anticipated noncompliance does not stay any permit condition, except as provided in §§ X. and XI. of Regulation No. 3, Part C. d. The permittee shall furnish to the Air Pollution Control Division, within a reasonable time as specified by the Division, any information that the Division may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Division copies of records required to be kept by the permittee, including information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental, and shall not sanction noncompliance with, the applicable requirements on which it is based. f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of permit issuance, the permittee shall submit, at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division, Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed. DRS Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 40 g. progress reports which contain the following: (i) dates for achieving the activities, milestones, or compliance required in the schedule for compliance, and dates when such activities, milestones, or compliance were achieved; and (ii) an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventive or corrective measures adopted. The permittee shall not knowingly falsify, tamper with, or render inaccurate any monitoring device or method required to be maintained or followed under the terms and conditions of the Operating Permit. 5. Emergency Provisions Regulation No. 3, 5 CCR 1001-5, Part C, § VII.E An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed the technology -based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology -based emission limitation if the permittee demonstrates, through properly signed, contemporaneous operating logs, or other relevant evidence that: a. an emergency occurred and that the permittee can identify the cause(s) of the emergency; b. the permitted facility was at the time being properly operated; c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in the permit; and d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency, and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 41 6. Emission Controls for Asbestos Regulation No. 8, 5 CCR 1001-10, Part B The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No. 8, Part B, "asbestos control." 7. Emissions Trading, Marketable Permits, Economic Incentives Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.13. No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are specifically provided for in the permit. 8. Fee Payment C.R.S §§ 25-7-114.1(6) and 25-7-114.7 a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. § 25-7- 114.7. A 1% per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the date of invoice, unless a permittee has filed a timely protest to the invoice amount. b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7- 114.7. If the Division estimates that processing of the permit will take more than 30 hours, it will notify the permittee of its estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit. c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. § 25-7-114.1(6) for each APEN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. 1, 5 CCR 1001-3, a III.D.1. The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, § III.D.1. 10. Inspection and Entry Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.16.b. Upon presentation of credentials and other documents as may be required by law, the permittee shall Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 42 allow the Air Pollution Control Division, or any authorized representative, to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located, or emissions - related activity is conducted, or where records must be kept under the terms of the permit; b. have access to, and copy, at reasonable times, any records that must be kept under the conditions of the permit; c. inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the Operating Permit; d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or applicable requirements, any substances or parameters. 11. Minor Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, $$ X. & XI. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. 12. New Source Review Regulation No. 3, 5 CCR 1001-5, Part B The permittee shall not commence construction or modification of a source required to be reviewed under the New Source Review provisions of Regulation No. 3, Part B, without first receiving a construction permit. 13. No Property Rights Conveyed Regulation No. 3, 5 CCR 1001-5, Part C, & V.C.11.d. This permit does not convey any property rights of any sort, or any exclusive privilege. 14. Odor Regulation No. 2, 5 CCR 1001-4, Part A As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous emissions. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. 15. Off -Permit Changes to the Source Regulation No. 3, 5 CCR 1001-5, Part C, XII.B. Page 43 The permittee shall record any off -permit change to the source that causes the emissions of a regulated pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from the change, including any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off -permit change. 16. Opacity Regulation No. 1, 5 CCR 1001-3, §§ I., II. The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ I.- II. 17. Open Burning Regulation No. 9, 5 CCR 1001-11 The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions of Regulation No. 9. 18. Ozone Depleting Compounds Regulation No. 15, 5 CCR 1001-17 The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds. Sections I., II.C., II.D., III. IV., and V. of Regulation No. 15 shall be enforced as a matter of state law only. 19. Permit Expiration and Renewal Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.B.6., IV.C., V.C.2. a. The permit term shall be five (5) years. The permit shall expire at the end of its term. Permit expiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted. b. Applications for renewal shall be submitted at least twelve months, but not more than 18 months, prior to the expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit that require revision, supplementing, or deletion, incorporating the remaining permit terms by reference from the previous permit. A copy of any materials incorporated Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 44 by reference must be included with the application. 20. Portable Sources Regulation No. 3, 5 CCR 1001-5, Part C, § II.D. Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location. 21. Prompt Deviation Reporting Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.7.b. The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. "Prompt" is defined as follows: a. Any definition of "prompt" or a specific timeframe for reporting deviations provided in an underlying applicable requirement as identified in this permit; or b. Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of deviations will be submitted based on the following schedule: (i) For emissions of a hazardous air pollutant or a toxic air pollutant (as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements, the report shall be made within 24 hours of the occurrence; (ii) For emissions of any regulated air pollutant, excluding a hazardous air pollutant or a toxic air pollutant that continue for more than two hours in excess of permit requirements, the report shall be made within 48 hours; and (iii) For all other deviations from permit requirements, the report shall be submitted every six (6) months, except as otherwise specified by the Division in the permit in accordance with paragraph 22.d. below. c. If any of the conditions in paragraphs b.i or b.ii above are met, the source shall notify the Division by telephone (303-692-3155) or facsimile (303-782-0278) based on the timetables listed above. [Explanatory note: Notification by telephone or facsimile must specify that this notification is a deviation report for an Operating Permit.] A written notice, certified consistent with General Condition 2.a. above (Certification Requirements), shall be submitted within 10 working days of the occurrence. All deviations reported under this section shall also be identified in the 6 -month report required above. "Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of avoiding enforcement actions. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 45 22. Record Keeping and Reporting Requirements Regulation No. 3, 5 CCR 1001-5, Part A, § II.; Part C, §§ V.C.6., V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit, the permittee shall maintain compliance monitoring records that include the following information: (i) date, place as defined in the Operating Permit, and time of sampling or measurements; (ii) date(s) on which analyses were performed; (iii) the company or entity that performed the analysis; (iv) the analytical techniques or methods used; (v) the results of such analysis; and (vi) the operating conditions at the time of sampling or measurement. b. The permittee shall retain records of all required monitoring data and support information for a period of at least five (5) years from the date of the monitoring sample, measurement, report or application. Support information, for this purpose, includes all calibration and maintenance records and all original strip -chart recordings for continuous monitoring instrumentation, and copies of all reports required by the Operating Permit. With prior approval of the Air Pollution Control Division, the permittee may maintain any of the above records in a computerized form. c. Permittees must retain records of all required monitoring data and support information for the most recent twelve (12) month period, as well as compliance certifications for the past five (5) years on - site at all times. A permittee shall make available for the Air Pollution Control Division's review all other records of required monitoring data and support information required to be retained by the permittee upon 48 hours advance notice by the Division. d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every six (6) months, unless an applicable requirement, the compliance assurance monitoring rule, or the Division requires submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly identified in such reports. e. The permittee shall file an Air Pollutant Emissions Notice ("APEN") prior to constructing, modifying, or altering any facility, process, activity which constitutes a stationary source from which air pollutants are or are to be emitted, unless such source is exempt from the APEN filing requirements of Regulation No. 3, Part A, § II.D. A revised APEN shall be filed annually whenever a significant change in emissions, as defined in Regulation No. 3, Part A, § II.C.2., occurs; whenever there is a change in owner or operator of any facility, process, or activity; whenever new control equipment is installed; whenever a different type of control equipment replaces an existing type of control equipment; whenever a permit limitation must be modified; or before the APEN expires. An APEN is valid for a period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires. Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by April 30 of the following year. Where a permit revision is required, the revised APEN must be filed along with a request for permit revision. APENs Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 46 for changes in control equipment must be submitted before the change occurs. Annual fees are based on the most recent APEN on file with the Division. 23. Reopenings for Cause Regulation No. 3, 5 CCR 1001-5, Part C, § XIII. a. The Air Pollution Control Division shall reopen, revise, and reissue Operating Permits; permit reopenings and reissuance shall be processed using the procedures set forth in Regulation No. 3, Part C, § III., except that proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists. b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major source with a remaining permit term of three or more years, unless the effective date of the requirements is later than the date on which the permit expires, or unless a general permit is obtained to address the new requirements; whenever additional requirements (including excess emissions requirements) become applicable to an affected source under the acid rain program; whenever the Division determines the permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit; or whenever the Division determines that the permit must be revised or revoked to assure compliance with an applicable requirement. c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit, except that a shorter notice may be provided in the case of an emergency. d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and reissuance procedure. 24. Section 502(b)(10) Changes Regulation No. 3, 5 CCR 1001-5, Part C, § XII.A. The permittee shall provide a minimum 7 -day advance notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of each such notice given to its Operating Permit. 25. Severability Clause Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.10. In the event of a challenge to any portion of the permit, all emissions limits, specific and general conditions, monitoring, record keeping and reporting requirements of the permit, except those being challenged, remain valid and enforceable. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 47 26. Significant Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, § III.B.2. The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B ("Construction Permit" requirements) without first receiving a construction permit. The permittee shall submit a complete Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve months of commencing operation, to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating Permit must be received prior to commencing construction of the new or modified source. 27. Special Provisions Concerning the Acid Rain Program Regulation No. 3, 5 CCR 1001-5, Part C, §§ V.C.1.b. & 8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act, 40 Code of Federal Regulations (CFR) Part 72, both provisions shall be incorporated into the permit and shall be federally enforceable. b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the regulations promulgated thereunder, 40 CFR Part 72, are expressly prohibited. 28. Transfer or Assignment of Ownership Regulation No. 3, 5 CCR 1001-5, Part C, § II.C. No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or operator applies to the Air Pollution Control Division on Division -supplied Administrative Permit Amendment forms, for reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner or operator has been submitted to the Division. 29. Volatile Organic Compounds Regulation No. 7, 5 CCR 1001-9, §& III & V. The requirements in paragraphs a, b and e apply to sources located in an ozone nonattainment area or the Denver 1 -hour ozone attainment/maintenance area. The requirements in paragraphs c and d apply statewide. a. All storage tank gauging devices, anti -rotation devices, accesses, seals, hatches, roof drainage systems, support structures, and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened, actuated, or used for necessary and proper activities (e.g. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 48 maintenance). Such opening, actuation, or use shall be limited so as to minimize vapor loss. Detectable vapor loss shall be determined visually, by touch, by presence of odor, or using a portable hydrocarbon analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm. Testing shall be conducted as in Regulation No. 7, Section VIII.C.3. b. Except when otherwise provided by Regulation No. 7, all volatile organic compounds, excluding petroleum liquids, transferred to any tank, container, or vehicle compartment with a capacity exceeding 212 liters (56 gallons), shall be transferred using submerged or bottom filling equipment. For top loading, the fill tube shall reach within six inches of the bottom of the tank compartment. For bottom -fill operations, the inlet shall be flush with the tank bottom. c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably Available Control Technology (RACT) is utilized. d. No owner or operator of a bulk gasoline terminal, bulk gasoline plant, or gasoline dispensing facility as defined in Colorado Regulation No. 7, Section VI, shall permit gasoline to be intentionally spilled, discarded in sewers, stored in open containers, or disposed of in any other manner that would result in evaporation. e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b, above. 30. Wood Stoves and Wood burning Appliances Regulation No. 4, 5 CCR 1001-6 The permittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use of wood stoves and wood burning appliances. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Air Pollution Control Division Colorado Operating Permit Inspection Information OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - REPORTING REQUIREMENTS AND DEFINITIONS C - COMPLIANCE CERTIFICATION REPORT FORMAT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - PERMIT MODIFICATIONS G - EQUIPMENT LIST *DISCLAIMER: None of the information found in these Appendices shall be considered to be State or Federally enforceable, except as otherwise provided in the permit, and is presented to assist the source, permitting authority, inspectors, and citizens. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 50 APPENDIX A Inspection Information Directions to Plant: The plant is located in Northern Colorado near the town of Windsor. From Denver, take I-25 North approximately 60 miles and take the Windsor exit East. Follow Highway 392 through the town of Windsor and turn right on Highway 257. After about 1.5 miles, turn left to access the Health Group facility. Safety Equipment Required: - Eye Protection - Safety Shoes - Conductive Shoes - Hearing Protection Facility Plot Plan: Figure 1 (following page) shows the plot plan as submitted on November 30, 2016. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list, activities may have changed since the last filing. This list is current as of April 2018. Insignificant activities and/or sources of emissions as submitted in the application are as follows: Building C-20 Distribution Center Building C-40, C-41, C-42, C-43, C-46, and C-48 C-41 — Welding Booth C-40 — Quality Control and Process Support Labs C-43 — Chemical Storage Areas C-43 — Dry Chemical Weight Station C-46 — Wet Scrubber C-48 — Cooling Towers East of C-48 Building C-50 C-50 — Quality Lab C-50 — Regeneration of Molecular Sieve Adsorber C-50 — Prepolymer Silos and Conveyance Equipment C-50 — Polymer Silos and Conveyance Equipment Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAM I Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 51 C-50 — PET Reuse Process Building C-15 Color Paper Manufacturing: Slitting, spooling, and packaging of Color Media Testing film for quality Exemption: Regulation 3 Part C, Section II.E.3.i (QA/QC/R&D labs) QA/QC labs located in the following buildings: C-40, C-42, C-43, C-50, C-61, C-70, and the wastewater treatment plant. Exemption: Regulation 3 Part C, Section II.E.3.aaa/ fff (Diesel Fuel/Lubricating Oil Storage Tanks) Location Storage. Capacity (Gallons) Contents C70, UST Day Tank 30,000 No. 2 diesel for back up boiler fuel C20 & C50 Mobile Fuel 200 Diesel Fuel C48, Transformers (2) 1,206 Enviro-Temp FR3 C48, Inside Drum Storage 385 Gear, Lube, Hydraulic, Waste C50, Inside Drum Storage 165 Gear, Lube, Hydraulic, Waste C40's, Inside Drum Storage 275 Gear, Lube, Hydraulic, Waste C15, Inside Drum Storage 55 Gear, Lube, Hydraulic, Waste C20, Inside Drum Storage 370 Gear, Lube, Hydraulic, Waste C43, Slitter 120 Hydraulic, Inside tank C70, Turbine Lube Oil 1,400 Lube Oil, Inside tank C70, Inside Drum Storage 550 Gear, Lube, Hydraulic, Waste C46, Inside Drum Storage 110 Gear, Lube, Hydraulic, Waste C61, Inside Drum Storage 385 Gear, Lube, Hydraulic, Waste Exemption: Regulation 3 Part C, Section II.E.3.eeee (Sulfuric Acid & Caustic Tanks <10,500 Gal) Location Storage Capacity (Gallons) Quantity Contents West of Building C-61 2,050 1 sulfuric acid 10,000 1 sodium hydroxide Exemption: Regulation 3 Part C, Section II.E.3. k (Fuel Burning Equipment < 5 mmbtu/hr) Equipment Rating Quantity Toro Power Shift 824 snow blower 5120 BTU/hr 1 Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: I)RAFt Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 52 Other Insignificant Activities: Exemption: Landscaping/Grounds Keeping Activities Regulation 3 Part C, Section II.E.3.bb/cc/dd/qq HVAC Regulation 3 Part C, Section II.E.3.c Aerosol can usage Regulation 3 Part C, Section II.E.3.0 Non -product adhesive use Regulation 3 Part C, Section II.E.3.y Non -product related caulking operations Regulation 3 Part C, Section II.E.3.aa Smoking Rooms Regulation 3 Part C, Section II.E.3.gg Plastic pipe welding Regulation 3 Part C, Section II.E.3.hh Housekeeping / Janitorial / Office Activities Regulation 3 Part C, Section II.E.3.pp/tt Forklifts Regulation 3 Part C, Section II.E.3.kkk Steam vents Regulation 3 Part C, Section II.E.3.aaaa Natural gas venting during maintenance of boilers Regulation 3 Part C, Section II.E.3.dddd Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 53 ortr HEALTH HEALTH T1 RE;TEa,d: HEALTH :"E''TY Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: TT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 54 APPENDIX B Reporting Requirements and Definitions with codes ver 8/20/14 Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement, representation, or certification in, or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either filed or maintained (whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report #1: Monitoring Deviation Report (due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit, monitoring means any condition determined by observation, by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel analyses, and operational or control device parameter monitoring. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 55 Report #2: Permit Deviation Report (must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from permit requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of such deviations, and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit are required to be summarized or referenced in the annual compliance certification. For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions. Additional discussion on these conditions is provided later in this Appendix. For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern. For example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1, Section IV. In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes of this operating permit are any of the following: (1) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. (only if the emission point is subject to CAM) For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation Report. All deviations shall be reported using the following codes: (3) 1 = Standard: 2 = Process: 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: 8 = CAM: 9 = Other: When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is recordkeeping When the requirement is reporting A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. When the deviation is not covered by any of the above categories Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 56 Report #3: Compliance Certification (annually, as defined in the permit) Submission of compliance certifications with terms and conditions in the permit, including emission limitations, standards, or work practices, is required not less than annually. Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other material information (i.e. information beyond required monitoring that has been specifically assessed in relation to how the information potentially affects compliance status), that information must be identified and addressed in the compliance certification. The compliance certification must include the following: • The identification of each term or condition of the permit that is the basis of the certification; • Whether or not the method(s) used by the owner or operator for determining the compliance status with each permit term and condition during the certification period was the method(s) specified in the permit. Such methods and other means shall include, at a minimum, the methods and means required in the permit. If necessary, the owner or operator also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Federal Clean Air Act, which prohibits knowingly making a false certification or omitting material information; • The status of compliance with the terms and conditions of the permit, and whether compliance was continuous or intermittent. The certification shall identify each deviation and take it into account in the compliance certification. Note that not all deviations are considered violations.1 • Such other facts as the Division may require, consistent with the applicable requirements to which the source is subject, to determine the compliance status of the source. The Certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. (only for emission points subject to CAM) Note the requirement that the certification shall identify each deviation and take it into account in the compliance certification. Previously submitted deviation reports, including the deviation report submitted at the time of the annual certification, may be referenced in the compliance certification. 1 For example, given the various emissions limitations and monitoring requirements to which a source may be subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an exception and/or special circumstances relating to that same event. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 57 Startup, Shutdown, Malfunctions and Emergencies, Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important in both the deviation reports and the annual compliance certifications. Startup, Shutdown, and Malfunctions Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or standards often do not apply unless specifically stated in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and would still be noted in the deviation report. In regard to compliance certifications, the permittee should be confident of the information related to those deviations when making compliance determinations since they are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available Control Technology (BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources. Emergency Provisions Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense against enforcement action if they are properly reported. DEFINITIONS Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily caused by poor maintenance, careless operation, or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions. Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology -based emission limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly de'signed equipment, lack of preventative maintenance, careless or improper operation, or operator error. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 58 APPENDIX B: Monitoring and Permit Deviation Report - Part I Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the. Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety. FACILITY NAME: Carestream Health, Inc. OPERATING PERMIT NO: 06OPWE288 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) AIRS ID Unit Description Deviations noted During Period?' Deviation Code 2 Malfunction/Emergency Condition Reported During Period? YES NO YES NO 001 Sensitizing Complex, Buildings C-40, C-41, C-42, C- 43, C-46 002 Support Manufacturing, Building C-50 003 Five corona treaters used in web coating operations. 005 Coating Assessment Laboratory 004 Boilers Degreasing Units Facility Wide General Conditions Insignificant Activities ' See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information. 2 Use the following entries, as appropriate 1 = Standard: 2 = Process: 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: 8=CAM: 9 = Other: When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is recordkeeping When the requirement is reporting A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. When the deviation is not covered by any of the above categories Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 59 APPENDIX B: Monitoring and Permit Deviation Report - Part II FACILITY NAME: Carestream Health, Inc. OPERATING PERMIT NO: 06OPWE288 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration (start/stop date & time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Malfunctions/Emergencies Reported (if applicable) Deviation Code Division Code QA: SEE EXAMPLE ON THE NEXT PAGE Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 60 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: (For NSPS/MACT) Did the deviation occur during: Emergency Malfunction XX N/A Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control - Unit XXX Operating Permit Condition Number Citation Section II, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Slurry Line Feed Plugged Duration START- 1730 4/10/06 END- 1800 4/10/06 Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Malfunction/Emergencies Reported (if applicable) 5/30/06 to A. Einstein, APCD Deviation Code Division Code QA: Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed. D Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix B Page 61 APPENDIX B: Monitoring and Permit Deviation Report - Part III REPORT CERTIFICATION SOURCE NAME: Carestream Health, Inc. FACILITY IDENTIFICATION NUMBER: 1236350 PERMIT NUMBER: 06OPWE288 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) All information for the Title V Semi -Annual Deviation Reports must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. STATEMENT OF COMPLETENESS I have reviewed the information being submitted in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this submittal are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub -Section 18- 1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of Sub -Section 25-7 122.1, C.R.S. Printed or Typed Name Title Signature of Responsible Official Date Signed Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit. No copies need be sent to the U.S. EPA. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix C Page 62 APPENDIX C Required Format for Annual Compliance Certification Reports Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: Carestream Health, Inc OPERATING PERMIT NO: 06OPWE288 REPORTING PERIOD: I. Facility Status During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/are the method(s) specified in the Permit. With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The method used to determine compliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. AIRS ID Unit Description Deviations Reported 1 Monitoring Method per Permit?2 Was compliance continuous or intermittent?3 Previous Current YES NO Continuous Intermittent 001 Sensitizing Complex, Buildings C-40, C-41, C- 42, C-43, C-46 002 Support Manufacturing, Building C-50 003 Five corona treaters 005 Coating Assessment Laboratory 004 Boilers Degreasing Units Facility Wide General Conditions Insignificant Activities ° Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: b l Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix C Page 63 ' If deviations were noted in a previous deviation report , put an "X" under "previous". If deviations were noted in the current deviation report (i.e. for the last six months of the annual reporting period), put an "X" under "current". Mark both columns if both apply. 2 Note whether the method(s) used to determine the compliance status with each term and condition was the method(s) specified in the permit. If it was not, mark "no" and attach additional information/explanation. 3 Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent Compliance" can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. NOTE: The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not indicate non-compliance, and if 3) the Responsible Official is not aware of any credible evidence that indicates non- compliance, then the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time period. 4 Compliance status for these sources shall be based on a reasonable inquiry using readily available information. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix C Page 64 II. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act) B. If subject: The facility requirements of section 112(r). is is not in compliance with all the 1. A Risk Management Plan will be has been submitted to the appropriate authority and/or the designated central location by the required date. III. Certification All information for the Annual Compliance Certification must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAB" F Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix D Page 62 APPENDIX D Notification Addresses 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B 1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Matt Burgett 2. United States Environmental Protection Agency Compliance Notifications: Office of Enforcement, Compliance and Environmental Justice Mail Code 8ENF-AT U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 502(b)(10) Changes, Off Permit Changes: Office of Partnerships and Regulatory Assistance Mail Code 8P -AR U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 66 APPENDIX E Permit Acronyms Listed Alphabetically: AIRS - Aerometric Information Retrieval System AP -42 - EPA Document Compiling Air Pollutant Emission Factors APEN - Air Pollution Emission Notice (State of Colorado) APCD - Air Pollution Control Division (State of Colorado) ASTM - American Society for Testing and Materials BACT - Best Available Control Technology BTU - British Thermal Unit CAA - Clean Air Act (CAAA = Clean Air Act Amendments) CCR - Colorado Code of Regulations CEM - Continuous Emissions Monitor CF - Cubic Feet (SCF = Standard Cubic Feet) CFR - Code of Federal Regulations CO - Carbon Monoxide COM Continuous Opacity Monitor CRS - Colorado Revised Statute EF - Emission Factor EPA - Environmental Protection Agency FI - Fuel Input Rate in MMBtu/hr FR - Federal Register G - Grams Gal - Gallon GPM - Gallons per Minute HAPs - Hazardous Air Pollutants HP - Horsepower HP -HR - Horsepower Hour (G/HP-HR = Grams per Horsepower Hour) LAER - Lowest Achievable Emission Rate LBS - Pounds M - Thousand MM - Million MMscf - Million Standard Cubic Feet MMscfd Million Standard Cubic Feet per Day N/A or NA - Not Applicable NOx - Nitrogen Oxides NESHAP - National Emission Standards for Hazardous Air Pollutants NSPS - New Source Performance Standards P - Process Weight Rate in Tons/Hr PE - Particulate Emissions Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 67 PM - PMIo - PSD - PIE - RACT - SCC - SCF - SIC - SO2 - TPY - TSP - VOC- Particulate Matter Particulate Matter Under 10 Microns Prevention of Significant Deterioration Potential To Emit Reasonably Available Control Technology Source Classification Code Standard Cubic Feet Standard Industrial Classification Sulfur Dioxide Tons Per Year Total Suspended Particulate Volatile Organic Compounds Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix F Page 68 APPENDIX F Permit Modifications Date Of Revision Section Number, Condition Number Description Of Revision Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix G Page 69 APPENDIX G Equipment List Building Location AIRS ID Description C-40, 41, 42, and 43 (Sensitizing Complex) C-40 001 Coating and Drying Equipment (001 Machine) Sensitizing Complex Process Vessels and Ancillary Equipment C-50 (Innovative Polyester Manufacturing) Polymer Area 002 Railcar Unloading System (HEPA Filter) Polymer Area PET Grinding System Polymer Area Grinding System Dust Collector (DF-50) Polymer Area Powdered Polymer Transfer System (HEPA Filter) Polymer Area Molecular Sieve Adsorbers Extruder Room East/West Extruders C-50 Dornier Heavy Duty Transverse Film Stretching Machine Coating and Exhaust Systems (501 Machine) Chem Weigh Room Dry Chemical Weighing Hood (HEPA Filter) 1PM Complex Process Vessels and Ancillary Equipment IPM Complex Fugitive Emissions C-40 001 Machine 003 Five Corona Treaters (CT1 — CT5) C-70 Boiler House 004 Two Natural Gas and Diesel Fueled Boilers Rated at 206 mmBtu/hr Each C-43 Coating Assessment Laboratory 005 Dixon Coater Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix H Page 70 APPENDIX H Operating and Maintenance Plan OPERATING AND MAINTENANCE PLAN Coating Assessment Laboratory State of Colorado Construction Permit 13WE1T52 Carestrsarn Health, Incorporated 2000 Howard Smith Ave. Wes Windsor, CO 80550 Prepared by. Golder Associates Inc, 2809 East Harmony Road Suite 3U Fort Cans, CO 80528 September 2013 Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix H Page 71 September 2013 Table of Contents 1:D PURPOSE OF THE O&M PLAN._.... 2.0 EMISSION CALCULATIONS AND RECORDi(EEPING... 2.1 Emissions Calculations.. 3.0 PREVENTATIVE MAINTENANCE_... 4.0 MANUFACTURER'S OPERATION RECOMMENDATIONS f Appendices Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Solvent Usage Spreadsheet — Solvent Usage for Month/Year Solvent Usage Spreadsheet — SDS Solvent Service Solvent Usage Spreadsheet - SSM Records Solvent Usage Spreadsheet — Charge Card Records Scale Preventative Maintenance Procedure Dryer Pressure Switch Preventative Maintenance Procedure CAL Operating Procedure 2 .2 S Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: DRAFT TECHNICAL REVIEW DOCUMENT For DRAFT RENEWAL OF OPERATING PERMIT 06OPWE288 Carestream Health, Inc. - Carestream Health Colorado (CHC) Weld County Source ID 123/6350 May 2016 — June 2018 Operating Permit Engineer: Operating Permit Supervisor review: Compliance Monitoring Unit review: I. Purpose: Ramazan Spencer Matt Burgett Paul Carr This document establishes the basis for decisions made regarding the applicable requirements, emission factors, monitoring plan and compliance status of emission units covered by the renewed Operating Permit for the Carestream Health, Inc. Colorado (CHC) facility. The previous Operating Permit for this facility was issued on November 1, 2004, was last revised on May 1, 2007, and expired on November 1, 2009. However, since a timely and complete renewal application was submitted, under Colorado Regulation No. 3, Part C, Section IV.C all of the terms and conditions of the existing permit shall not expire until the renewal operating permit is issued and any previously extended permit shield continues in full force and operation. Subsequent to submittal of the renewal application, the permittee submitted applications on April 24, 2009, requesting that the permit be modified to install spreader bars and concave bars to the Sensitizing coating machine, and an increase of ozone emission limit in anticipation of a new product line; and on May 27, 2009 for an increase in PM and PM10 emission limits due to a calculation error. CHC submitted additional applications on May 11, 2010, June 6, 2014, December 8, 2017, and April 18, 2018. The modification applications submitted in May and June requested to incorporate Construction Permits 10WE1575 and 13WE1752 respectively into the Operating Permit upon renewal. The modification application submitted in December requested a change in emission calculation for particulate matter during unloading of PET pellets. The modification submitted on May 11, 2010 involves an increase in emissions which is over the level of significance; the modification submitted on June 6, 2014 allows the source to trigger NSPS requirements by modifying the CAL without submitting a modification request in the future; the modification submitted on December 8, 2017 modifies emission factors in order to avoid Compliance Assurance Monitoring (CAM); and the modification submitted on April 18, 2018 requests an addition of PET reuse process and two additional changes identified as "Administrative." The modification request did not specify that minor mod procedures were applicable and the changes identified as "Administrative" do not fall under the definition as provided by Regulation No. 3, Part I, Section I.B.1, therefore these modifications must be processed as significant modifications as required by Colorado Regulation No. 3, Part C, Section I.A.7.c. A significant modification is Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 060PWE288 Technical Review Document — Second Renewal processed under the same procedures as a renewal, i.e. it must go through a 30 -day public comment period and EPA 45 -day review period. Therefore, since the renewal application has been submitted, the Division is incorporating the modifications into the renewal. This document is designed for reference during the review of the proposed permit by the EPA, the public, and other interested parties. The conclusions made in this report are based on information provided in the original application submitted on October 29, 2008, comments on the draft permit submitted on April 24, 2018, previous inspection reports and various email correspondence, as well as telephone conversations with the applicant. Please note that copies of the Technical Review Document (TRD) for the original permit and any TRDs associated with subsequent modifications of the original Operating Permit may be found in the Division files as well as on the Division website at www.colorado.gov/cdphe/airTitleV. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this operating permit application have been reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction Permits, and have been found to meet all applicable substantive and procedural requirements. This operating permit incorporates and shall be considered to be a combined construction/operating permit for any such revision, and the permittee shall be allowed to operate under the revised conditions upon issuance of this operating permit without applying for a revision to this permit or for an additional or revised construction permit. II. Source Description CHC is a paper and web manufacturing and coating facility located at 2000 Howard Smith Avenue West, Windsor, CO 80550 in Weld County. The facility is located approximately two miles southeast of Windsor. The campus consists of multiple buildings containing a variety of equipment used in the manufacturing processes. A polyester film support base is produced for X-ray products in Building C50 - Innovative Polyester Manufacturing (IPM). IPM produces a flexible thermoplastic polyester film from polyester pellets. This process involves heating the plastic using heat transfer fluid and friction. The polyester is extruded and allowed to cool and harden. The plastic is then reheated, processed, coated with several sublayers, cooled, and wound into large rolls. C50 also houses mechanical shops that support the process and cleaning services to ensure quality. Medical x-ray film, color photographic paper, and contract manufacturing products are produced in the Sensitizing Complex (Buildings C40, C41, C42, and C43). Light sensitive emulsions consisting of silver halide and other chemicals are applied to a support to produce photographic film and paper. This process involves mixing raw chemicals together into solutions and dispersions. These solutions and dispersions are mixed with gels and coated onto plastic or paper. The coating is dried and rolled onto master rolls. The Sensitizing Complex also houses mechanical shops to support the process, labs to provide quality control and new product testing, and cleaning services to ensure quality. In addition, C43 also houses the Coating Assessment Laboratory (CAL), which provides quality assessments of new coatings and substrate 123/6350 Page 2 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal configurations. Building C46 houses a high efficiency silver recovery operation, which results in a concentrated silver mud recovered from coating formulation waste streams. The mud is shipped offsite for metal recovery. CHC leases space in Building C15, where CHC operates a paper finishing process. This process includes slitting the paper and chopping it into retail dimensions. This paper is packaged and prepared for retail distribution. Building C20 is the warehousing and distribution facility. It also includes a machine shop and forklift shop to support the entire campus. The process includes receiving raw materials and products, onsite storage, and national/international distribution of products. The machine shop produces custom parts and equipment for operations. The forklift shop maintains mobile equipment for the facility. Building C70 houses the main central utilities operations including two boilers, each rated at 206 mmBtu/hour, that supply steam for the site. Natural gas is used as primary fuel and No. 2 fuel oil is used as back up fuel. Utilities support operations occur in Buildings C48, C59, C61, and C63. Utilities include steam production, chilled and cooling water production, compressed air service, industrial wastewater and service water treatment. Buildings C80, C81, and C82 are associated with the onsite industrial wastewater treatment plant. The facility is located in Weld County, near Windsor. This facility is located in an area classified as attainment for all pollutants except ozone. It is classified as non -attainment for the 8 -hr ozone standard and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. Wyoming is an affected state within 50 miles of the plant. The following Federal Class I designated areas are within 100 kilometers of the plant: Rocky Mountain National Park and Rawah National Wilderness Area. This facility is categorized as a Nonattainment New Source Review (NANSR) major stationary source (Potential to Emit (PTE) of NOx > 100 Tons/Year (TPY)). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) for VOC or NOx, or a modification which is major by itself (PTE of > 100 TPY of either VOC or NOx) may result in the application of the NANSR review requirements. Based on the information provided by the applicant, this source is categorized as a minor stationary source for Prevention of Significant Deterioration (PSD) as of the issue date of this permit. Any future modification which is major by itself (PTE of > 250 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. 123/6350 Page 3 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal The boilers are a listed source for PSD purposes and therefore are categorized as a major source for PSD (PTE > 100 TPY). (Colorado Regulation No. 3, Part B, Section IV.D.3). Future modifications related to the boilers resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) or a modification which is major by itself (PTE of > 100 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. The summary of emissions for the renewal permit has been reproduced here. Emissions at the facility are as follows: Sensitizing Complex and Support Manufacturing Pollutant Potential to Emit Actual Emission_ s Source of Data PM 15.0 TPY 4.6 TPY Inspection report submitted on August 17, 2017 PM10 • 15.0 TPY 4.6 TPY Ozone 7.0 TPY 1 TPY APEN (123/6350/003) received on August 12, 2015 VOC 48.3 TPY 13.5 TPY Inspection report submitted on August 17, 2017 Boilers (206 mmBtu/hr each) Pollutant Potential to Emit Actual Emissions Source of Data PM 4.66 TPY 2.0 TPY Inspection report submitted on August 17, 2017 PM1•o 4.62 TPY 2.0 TPY NOx 133.40 TPY 57.8 TPY CO 96.50 TPY 42.0 TPY VOC 3.32 TPY 1.5 TPY Coating Assessment Laboratory (CAL) Pollutant Potential to Emit Actual Emissions Source of Data I VOC 4.8 TPY 0.05 TPY Inspection report submitted on August 17, 2017 HAPs Actual Emissions Source of Data 67561 Methanol 6110 lbs/yr APEN (123/6350/001) received on March 24, 2017, and an APEN (U3/6350/002) received April 30, 2013. 100425 S rene 1259 lbs/yr III. Applicable Requirements Accidental Release Program — 112(r) Section 112(r) of the Clean Air Act mandates a new federal focus on the prevention of chemical accidents. Sources subject to these provisions must develop and implement risk management programs that include hazard assessment, a prevention program, and an emergency response program. They must prepare and implement a Risk Management Plan (RMP) as specified in the Rule. Based on the information provided by the applicant, this facility is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act). Compliance Assurance Monitoring 123/6350 Page 4 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre -control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64 as adopted by reference into Colorado Regulation No. 3, Part C, Section XIV: None. During the renewal process the Division identified Building C-50 Railroad Car PET Pellet Unloading HEPA filter as a control device that could require a CAM plan. Based on compliance records provided by CHC during the 2016 inspection the uncontrolled particulate emissions (PM, PMio) exceeded the major source threshold of 100 tons in 2013 and 2015. The uncontrolled emissions were calculated using the following formula: tons lb lb PM 1 ton PM 1131111° month-- PET month x 0.005 lb PET x 2000 lbs After reviewing the data and calculations CHC submitted a test plan to determine a process specific emission factor. The test plan was reviewed and approved on June 12, 2017. The results of the study indicated that the current assumed emission factor of 0.005 lb PM per lb PET pellets significantly overestimated the actual emission rate. CHC submitted a modification application on December 8, 2017 requesting to change the calculation of the PM emissions. The application included the results of the study and P"I'E calculations. As a result of the modification the PTE of the unloading process falls well below the major source threshold of 100 TPY and therefore is not subject to CAM. For further discussion of the modification reference Section IV. Modifications Requested by the Source of this TRD. Regulation Number 7, Section IX. Surface Coating Operations The source became subject to the regulation since the renewal issuance of the Operating Permit. The source is located in Windsor Colorado, which was designated as attainment for all criteria pollutants when the renewed Operating Permit was issued in 2004. Since then it has been re- classified as non -attainment for the 8 -hr ozone standard and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. As such the source is subject to Regulations No. 7, Section IX. For discussion of specific requirements reference Section V of this TRD. It should be noted that the CAL (AIRS 005) has been granted an exemption from the requirements of Regulation No. 7. In order to maintain exemption status the CAL must not exceed 800 lbs per month of VOC emissions. Additionally, the CAL must be used exclusively for chemical and physical quality analysis in a laboratory setting, and shall not be used to create commercial products for sale. The exemption was approved in writing on March 12, 2013. Regulation Number 7, Section X. Use of Solvents for Degreasing and Cleaning The cold vat degreaser is APEN exempt, however, an emission unit that is subject to specific Regulation No. 7 requirements cannot be considered an insignificant activity. The appropriate applicable requirements are included in the renewal permit; these include transfer and storage of waste/used solvents requirements. 123/6350 Page 5 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal Regulation Number 7, Section XVI. Control of Emissions from Stationary and Portable Engines and Other Combustion Equipment in the 8 -Hour Ozone Control Area Section XVI applies to combustion equipment (specifically, boilers, duct burners, process heaters, stationary turbines, and stationary engines) with uncontrolled actual emissions of NOx greater than five (5) tons per year, and that are located at existing major sources of NOx, as listed in Section XIX.A. CHC is a listed existing major source for NOx in Section XIX.A and according to the most recent inspection report submitted on August 17, 2017 the boilers have exceeded the 5 ton per year threshold of actual NOx emissions. Therefore CHC is subject to the requirements of Section XVI. Applicable requirements consist of annual combustion process adjustments. Regulation Number 7, Section XIX. Control of Emissions from Specific Major Sources of VOC and/or NOx in the 8 -Hour Ozone Control Area Section XIX applies to major sources that emit or have the potential to emit 100 or more tons per year of VOC and/or NOx as of January 1, 2017, and are located in the 8 -hour Ozone Control Area. The sources are specifically listed in Section XIX.A. CHC is listed as a major source of NOx in Section XIX.A and is therefore subject to the requirements of Section XIX. Applicable requirement is to submit a Reasonably Available Control Technology (RACT) analysis for the C-70 Boilers by December 31, 2017. The Division received the RACT analysis from CHC on December 22, 2017; CHC is in compliance with this requirement. Standards of Performance for Metal Coil Surface Coating (40 CFR Part 60 Subpart TT) The metal coil surface coating New Source Performance Standard (NSPS) (40 CFR Part 60 Subpart TT) was published on January 10, 1983, and amended on October 17, 2000. An affected source under NSPS TT is a facility that was constructed after January 5, 1981, and performs surface coating to a continuous metal strip with thickness of 0.15mm (0.006") or more that is packaged in a roll or a coil. The coating operation includes each prime coat operation, each finish coat operation, and each prime and finish coat operation combined when the finish coat is applied wet on wet over the prime coat and both coatings are cured simultaneously. Although CHC has never in the past and is currently not performing metal coil surface coating the CAL does have the capability to perform the process. For operational flexibility of the CAL, CHC requested that metal coil surface coating would be included as an Alternate Operating Scenario. The applicable requirements include a standard for volatile organic compounds (VOCs) which limits VOC concentration to 0.28 kilogram VOC per liter of coating solids applied for each calendar moth. Standards of Performance for Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60 Subpart FFF) The flexible vinyl and urethane coating and printing NSPS (40 CFR Part 60 Subpart FFF) was published on June 29, 1984, and amended on August 17, 1984 and again on October 17, 2000. An affected source under NSPS FFF is a facility constructed after January 18, 1983, and performs surface coating to a supporting web that is more than 50 micrometers (0.002 inches) thick, and that consists of or contains a vinyl or urethane sheet or a vinyl or urethane coated web. Although CHC has never in the past and is currently not surface coating on flexible vinyl or 123/6350 Page 6 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal urethane coating the CAL does have the capability to perform the process. For operational flexibility of the CAL, CHC requested that surface coating of flexible vinyl and urethane would be included as an Alternate Operating Scenario. The applicable requirements include a standard for VOCs which limits VOC weighted average of inks used to less than 1.0 kilogram VOC per kilogram ink solids or a reduction of VOC emissions to atmosphere by 85 percent. As this Alternate Operating Scenario has not occurred yet, the permittee has not indicated which method of compliance would be followed. Standards of Performance for Polymeric Coating of Supporting Substrates Facilities (40 CFR Part 60 Subpart VVV) The polymeric coating of supporting substrates NSPS (40 CFR Part 60 Subpart VVV) was published as final on September 11, 1989. An affected source under NSPS VVV is a facility constructed after April 30, 1987, and applies elastomers, polymers, or prepolymers to a supporting web other than paper, plastic film, metallic foil, or metal coil. The requirements apply to each coating operation and any onsite coating mix preparation equipment used to prepare coatings for the polymeric coating of supporting substrates. Although CHC has never in the past and is currently not applying elastomers, polymers, or prepolymers to a supporting web other than paper, plastic film, metallic foil, or metal coil, the CAL does have the capability to perform the process. For operational flexibility of the CAL, CHC requested applying elastomers, polymers, or prepolymers to a supporting web other than paper, plastic film, metallic foil, or metal coil would be included as an Alternate Operating Scenario. As this facility uses less than 95 Mg of VOC per year the permittee would be required to make semiannual estimates of the projected annual amount of VOC to be used for the manufacture of polymeric coated substrate, as well as maintain records of actual VOC use. No performance testing is required. Hazardous Air Pollutants (HAPs) The facility is a major source of HAPs; therefore, Maximum Achievable Control Technology (MACT) requirements for major sources apply to the equipment at this facility. The potential MACT requirements that may apply to this facility are discussed below. Paper and Other Web Coating (POWC) MACT (40 CFR Part 63 Subpart JJJJ) The provisions of the POWC MACT apply to all web coating lines at a major source for HAP emissions. A web coating line is defined as any number of work stations, of which one or more applies a continuous layer of coating material across the entire width or any portion of the width of a web substrate, and any associated curing/drying equipment between an unwind or feed station and a rewind or cutting station. As discussed in the preamble to the final rule (December 4, 2002 Federal Register, pg 72332, beginning at 1st column, last paragraph), affiliated operations such as mixing or dissolving of coating ingredients prior to application; coating mixing for viscosity adjustment, color tint or additive blending, or pH adjustment; cleaning of coating lines and coating line parts; handling and storage of coatings and solvent; and conveyance and treatment of wastewater are part of the POWC category. However, because EPA was unable to identify emission reductions from these activities they were not included in the affected source and are not subject to the POWC MACT requirements. The applicable requirements from the POWC MACT include an organic HAP (oHAP) emission limit. The MACT provides several compliance options for the HAP emission limitation. The compliance 123/6350 Page 7 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal method chosen by permittee is to limit oHAP emissions level to less than or equal to 4 percent of mass of coating materials applied for each month. To demonstrate compliance with the chosen method the permittee indicated that procedures outlined in 40 CFR 63.3370(c)(3) will be followed. The coating line commenced construction prior to September 13, 2000, and isconsidered an existing affected source. It should be noted that the CAL is not considered an affected source as per §63.3300(g), the CAL falls under the definition of "research or laboratory equipment." Research or laboratory equipment is defined as "any equipment for which the primary purpose is to conduct research and development into new processes and products where such equipment is operated under the close supervision of technically trained personnel and is not engaged in the manufacture of products for commercial sale in commerce except in a de minimis manner." (§63.3310) As such, the CAL is exempt from the requirements of MACT JJJJ. Group IV Polymers and Resins MACT (40 CFR Part 63 Subpart JJJ) The permittee uses PET as a purchased material in the form of polymer powder and pellets. The PET is extruded and is utilized as a substrate for surface coating applications. Permittee does not manufacture a thermoplastic product as defined in §63.1312. Therefore, this facility does not fall under the definition of affected source for 40 CFR Part 63 subpart JJJ. Processes utilized by permittee, such as finishing processes, are specifically listed as excluded from the affected source in 40 CFR Part 63 subpart JJJ and are not subject to the requirements of this subpart. Miscellaneous Organic Chemical Manufacturing (MON) MACT (40 CFR Part 63 Subpart FFFF) As specified in 40 CFR Part 63 Subpart FFFF § 63.2435(c)(3), affiliated operations located at an affected source under 40 CFR Part 63 Subpart JJJJ (POWC MACT) are not subject to the MON MACT requirements. Note that this section states that "[a]ffiliated operations include but are not limited to, mixing or dissolving of coating ingredients; coating mixing for viscosity adjustment, color tint or additive blending, or pH adjustment; cleaning of coating lines and coating line parts; handling and storage of coatings, and solvent; and conveyance and treatment of wastewater." Organic Liquid Distribution (Non -Gasoline) MACT (40 CFR Part 63 Subpart EEEE) The permittee generates ethylene glycol, an oHAP, as a byproduct of the polymer process in Building C-50. After ethylene glycol is generated, it is transferred to a 50 gallon scrubber holding tank containing triethylene glycol with the temperature maintained at approximately 90°F. The spent scrubber solution is then transferred to a 6,000 gallon waste mixed glycol tank that is stored at ambient temperature. Once the waste tank has reached its storage capacity, the contents are then shipped off -site. The waste glycol mixture is approximately 25% ethylene glycol and 75% triethylene glycol. Organic Liquid is defined in §63.2406 as any non -crude oil liquid or liquid mixture that contains 5% by weight or greater of the oHAP listed in Table one of 40 CFR Part 63 Subpart EEEE, and has an annual average true vapor pressure greater than or equal to 0.7 kilopascals. While the waste glycol mixture meets the HAP concentration requirements as ethylene glycol is listed in 123/6350 Page 8 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal Table one of 40 CFR Part 63 Subpart EEEE, the mixtures annual average true vapor pressure is below the 0.7 kilopascals threshold. Therefore CHC is not subject to 40 CFR Part 63 Subpart EEEE. Industrial, Commercial, Institutional Boilers and Process Heaters (40 CFR Part 63 Subpart DDDDD The major source boiler MACT (40 CFR Part 63 Subpart DDDDD) was published as final on November 20, 2015. An affected source under MACT DDDDD is the collection at a major source of all existing industrial, commercial, and institutional boilers and process heaters, as well as each new or reconstructed industrial, commercial, or institutional boiler or process heater. The two existing boilers (commenced construction prior to June 4, 2010) rated at 206 mmBtu/hr each, are subject to the requirements of MACT DDDDD. The boilers are dual fuel fired using natural gas as their primary fuel, and No. 2 oil as back up. Both boilers are equipped with oxygen trim systems which are used to automatically monitor and alter oxygen levels to ensure optimum operation and NOx levels. The boilers fall under "unit designed to burn gas 1 subcategory" and therefore, are required to comply with Work Practice Standards listed in Table 3 to Subpart DDDDD, specifically items 1 and 4. These include five-year tune-ups and a one-time energy assessment. Additionally, in order to qualify as a "unit designed to burn gas 1 subcategory" each boiler shall not exceed 48 hours of No. 2 oil use during any calendar year. During periods of gas curtailment or gas supply interruptions No. 2 oil use is not restricted to or counted against the 48 hour limit. IV. Modifications Requested by the Source The renewal application received on October 29, 2008 requested the following modifications: • Modification of PM emissions calculation for Building C-50 pellet grinders. Current calculation: gr ft3 min hr 1 lbs 1 ton 0.02 ft3 x 1207 minx 60—8760 8760 yr x 7000 gr x 2000 lbs — 0.91tpy h Proposed calculation: lb PM E = P x 2.9x10 -S lb PET extruded) E = PM/PM10 Emissions P = lbs of PET extruded The 2.9X105 emission factor is derived from the maximum designed throughput of the extruder of 71001bs per hour. The emission factor is calculated as follows: 0.91 ton PM x 2000 ton yr — s lb PM lbs hr = 2.9 x 10- lbs PET extruded 7100 hr x 8760 yr 123/6350 Page 9 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal CHC no longer operates the grinders/ extruders on a 24/7 365 basis and the proposed calculation will allow for a more accurate representation of PM/PMio emissions. • Addition of 40 CFR Part 63, Subpart JJJ to the Permit Shield as this facility is not subject to the Subpart. Reference Section III. Applicable Requirements for discussion of this subpart's applicability. • Addition of 40 CFR Part 63, Subpart EEEE to the Permit Shield as this facility is not subject to the Subpart. Reference Section III. Applicable Requirements for discussion of this subpart's applicability. • Addition of 40 CFR Part 63, Subpart FFFF to the Permit Shield as this facility is not subject to the Subpart. Reference Section III. Applicable Requirements for discussion of this subpart's applicability. • Requested language change in Section II - Specific Permit Terms 1.2. The current language states: "In addition, the Building C-50 Rail Car Polymer Unloading, and Dry Chemical Weighing Room HEPA filters shall be replaced at least annually." CHC requests the language to be changed to allow them to not have to replace the HEPA filters on an annual schedule, but prior to start up of operations, if the process has not been used during the previous year. Proposed language is as follows: "In addition, the Building C-50 Railcar Polymer Unloading process, and Dry Chemical Weighing Room HEPA filters shall be replaced at least annually. The HEPA filter associated with the C-50 powder or pellet unloading process shall be replaced at least annually, unless the process is not used during the previous year. In which case, the HEPA filter shall be replaced just prior to startup of any powder or pellet unloading activities." The Division agrees with this rational and does not believe it is necessary to change a filter on an annual schedule if no processing occurred during the previous year. The current language adds financial and labor burden without benefit, and was revised. • In the modification applications submitted on April 24, 2009 and May 27, 2009, the source requested that the permit be revised to install spreader bars and concave bars to the Sensitizing coating machine, an increase of ozone emission limit in anticipation of a new product line, and an increase in PM and PMIo emission limits to due to a calculation error. In the application, the permittee indicated that this modification met the requirements for a minor permit modification and requested that the minor permit modification procedures in Colorado Regulation No. 3, Part C, Section X be used. Colorado Regulation No. 3, Part C, Section X.A identifies those modifications that can be processed under the minor permit modification procedures. Specifically, minor permit modifications "are not otherwise required by the Division to be processed as a significant modification" (Colorado Regulation No. 3, Part C, Section X.A.6). The spreader bars and concave bars will not affect emissions. The increase in Ozone emissions is related to the anticipated increase in use of corona treater units. The new Ozone emission limit will be 7 tons per year. Additionally due to a calculation error the PM and PMIo limits are increased 123/6350 Page 10 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal from 11.8 tons per year to 15 tons per year. Therefore, since the level of significance for Ozone is 40 tons, for PM 25 tons, and for PMio 15 tons, and the increases are all below those thresholds, the Division determines that this modification can be processed as a minor modification. Five Corona Treater (CT) Units. Applicable Requirements — These units already exist at CHC, but have previously been considered insignificant activities due to APEN exempt emissions. CHC would now like to increase the use of these units, which directly emit ozone. Since the permittee has requested that these units be processed as a combined construction/operating permit using the minor modification procedures in Reg 3, Part C, Section X, no construction permit will be issued and all applicable requirements will be incorporated directly into the operating permit with this modification. The applicable requirements for this unit are as follows: • Opacity of emissions shall not exceed 20% (Reg 1, Section II.A.1) Ozone is not a visible pollutant and formal opacity readings are therefore not required. • Use of the CTs shall not exceed 191,780 kW -hr per year. This equates to 7.0 TPY ozone. • Emissions of air pollutants shall not exceed the following limitations (as requested by APEN submitted April 24, 2009): Pollutant I Potential to Emit IOzone 7.0 TPY CHC is a Major Source of HAPs and some MACT standards apply at this facility. However, no specific MACT standard applies to the CT units. Emission Factors — Emissions of ozone are directly emitted during the use of these CT units. CHC submitted an emission factor with the application. Pollutant Emission Factors Emission Factor Source Ozone 0.073 lbs O3/ kW -hr Manufacturer: Pillar Technologies The maximum kW rating of each CT is 7.5 to 10 kW. Monitoring Plan — The emissions from the CT units are directly proportional to the kW -hr operations of the CT units. CHC shall record the kW -hr operations on a monthly basis. This information shall be derived from the process verification boxes that measure both current and voltage. PM/PMio Emissions for Resorcinol consumption. Due to a calculation error CHC requested PM and PM10 limits be increased from 11.8 tons per year to 15 tons per year. The error occurred in 2003. Kodak Colorado Division (KCD), previous 123/6350 Page 11 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal owner of the facility, requested resorcinol emissions in Building C-50 to be accounted for as "PM/PMio Emissions = Amount of Resorcinol consumed". Previously KCD had used a 2% emission factor to calculate the emissions. The emission formula was never updated in the calculations. The error was discovered in April 2009. C-70 Boilers: Two (2) Babcock & Wilcox, Model: FM14-117, Serial Number: NB23915 & NB23916, dual fuel fired (Natural Gas & Diesel), steam boilers rated at 206 mmBtu/hr each. (10WE1575) Applicable Requirements — The modification request received on May 11, 2010 incorporates Construction Permit 10WE1279 into Operating Permit 06OPWE288 as part of the Title V Permit Renewal. The Construction Permit covers the Boiler House (Building. C-70) consisting of two dual fuel fired steam generators, each rated at 206 mmBtu/hour, which provide steam and process heat throughout the facility. Natural gas is used as primary fuel and No. 2 fuel oil is used as back-up fuel. The C-70 Boilers commenced operation in 1971. In 1974 the boilers were covered under Authority to Construct permit C-10, 375. The two boilers were later covered under KCD's Operating Permit 96OPWE128 and Construction Permit 96WE473. In preparation for sale of the two boilers KCD requested that the boilers be split off into a separate Construction Permit, and Construction Permit 10WE1279 was issued to KCD in 2010. As part of a Transfer of Ownership to CHC the Construction Permit was reissued in 2011 as 10WE1575. The C-70 Boilers are a major source for PSD as they are a listed source and have PTE greater than 100 tons of NOx. Applying the "Source Within a Source" method shows that CHC's primary activity fits a non -listed source category and the boilers fit a listed source category; the PTE of the whole facility is below 250 tons per year, but the PTE of the portion of the facility that fits the listed source category is greater than 100 tons per year. Therefore, while the rest of CHC facility is not a major source for PSD the C-70 Boilers are. The appropriate applicable requirements from the modified initial approval construction permit 10WE1575 related to the boilers have been incorporated into the permit as follows: • Opacity of emissions shall not exceed 20%, except under specific conditions, then opacity shall not exceed 30% (Condition 2). • Production limits from both boilers together shall not exceed the following limitations (Condition 3): Fuel Consumption Limits Natural Gas 1203.7 mmscf/yr Fuel Oil 82,500 gal/yr 123/6350 Page 12 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal • Emissions of air pollutants shall not exceed the following limitations (Condition 4): Pollutant Potential to Emit PM 4.66 TPY Mlo 4.62 TPY NOx 133.4 TPY VOC 3.32 TPY CO 96.50 TPY • All emission limits above apply to both boilers together. • Particulate matter emissions from each boiler shall not exceed 0.5(FI)-° 26 lbs/mmBtu, where FI = fuel input in mmBtu/hr (Condition 5 and Reg 1, Section III.A.1.b). • SO2 emission limit in Reg 6, Part B, Section II.D.3.a applies to the boilers. Since these boilers burn both natural gas and fuel oil, the SO2 limit of 1.5 pounds of sulfur dioxide per million BTU of heating input has been included in the Title V permit. (Condition 6 and Reg 1 Section VI.A.3.b.(i)) • APEN reporting (Condition 7): The APEN reporting requirements will not be identified in the permit as a specific condition but are included in Section IV (General Conditions) of the permit, Condition 22.e. 123/6350 Page 13 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal Emission Factors - Approval of emission factors is necessary to monitor compliance with the permit limitations. Fuel Pollutant Emission Factors Emission Factor Source Natural Gas PM 7.6 lbs/mmscf AP -42, Section 1.3, dated 9/98, Tables 1.4-1 uncontrolled boilers > 100 mmBtu/hr, & Stack Testing (4/2005) PM, 0 7.6 lbs/mmscf VOC 5.5 lbs/mmscf NOx 220 lbs/mmscf SOx 0.6 lbs/mmscf CO 160 lbs/mmscf Hexane 1.8 lbs/mmscf Formaldehyde 7.5E-2 llbs/mmscf Fuel Oil PM 2 lbs/1000 gal PMto 1 lbs/1000 gal VOC 0.24 lbs/1000 gal NOx 24 lbs/1000 gal SOx 5.68 lbs/1000 gal CO 5 lbs/1000 gal Formaldehyde 3.3E-2 lbs/1000 gal Note: SOx emissions at the requested fuel consumption limit are below the APEN de minimis level, emission limitations for SOx were not included in the construction permit and will not be included in the Title V renewal permit. HAPs: Emission factor for Hexane and Formaldehyde will not be included as they are not criteria pollutants. Hexane is above reportable levels at the requested fuel consumption limit. Monitoring Plan — The permittee will be required to record fuel consumption and calculate emissions monthly. Monthly fuel consumption and emissions shall be used in twelve month rolling totals to monitor compliance with the annual limitations. In the absence of credible evidence to the contrary, compliance with the particulate matter and opacity standards will be presumed when burning natural gas as fuel. When burning fuel oil opacity shall be monitored by conducting a visible emission observation in accordance with EPA Reference Method 9, once per year, for the 30% opacity requirement during start up. For compliance verification with the 20% opacity requirements opacity shall be monitored by conducting visible emission observations in accordance with EPA Reference Method 9, once per quarter. Additionally, records shall be kept of duration of fuel oil use and reason for use. Emerson & Renwick Ltd. Dixon Division Coating Assessment Laboratory (CAL), Serial No. 31057 Applicable Requirements — The modification request received on June 6, 2014 incorporates Construction Permit 13WE1752 into Operating Permit 06OPWE288 as part of the Title V Permit Renewal. The Construction Permit covers the CAL, which is used to evaluate quality of coatings 123/6350 Page 14 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal and commercial production feasibility. The CAL commenced operation in 2013. An initial approval construction permit (Colorado Construction Permit 13WE1752) was issued on June 26, 2013. The permittee self -certified compliance with Colorado Construction Permit 13WE1752 on March 11, 2014. Final Approval was issued on September 12, 2014. In this issuance the list of specific compounds emitted was updated to include all NCRP emitted above the reportable level of 250 lbs per year. An additional modification was requested by the permittee and issued April 25, 2016. The permit modification clarified Conditions with NSPS regulatory requirements. Original language implied that CAL was utilizing processes and materials that triggered these requirements, and was therefore subject to NSPS TT, FFF, and VVV. The Permit was modified to stipulate that, if in the future the operational conditions were modified such that they triggered these subparts the permittee would not be required to apply for a permit modification or wait for the permit to be reissued. These Conditions were added to the Operating Permit in form of Alternate Operating Scenarios specific to the CAL only. The appropriate applicable requirements from the modified Construction Permit 13WE1752 related to the CAL have been incorporated into the permit as follows: • The permittee shall self -certify within 180 days of triggering additional regulatory requirements associated with NSPS TT, FFF, and/or VVV (Condition 1.a). • A notification shall be submitted no later than 15 days after of operation that would trigger additional regulatory requirements. The notification shall include; reason for submittal, reference to permit, specification of the operational changes, the applicable subpart(s), date subpart(s) became applicable, and applicable requirements (Condition 1.b). • Emissions of air pollutants shall not exceed the following limitations (Condition 2): A cancellation request was submitted on January 31, 2017 for AIRS 006 (fugitive emissions). The fugitive emissions were already accounted for in the mass balance calculations associated with AIRS 005 and therefore AIRS 006 is not included in the Title V Permit. AIRS ID 1 Emission Type Pollutant Potential to Emit (tons/yr) 005 Point VOC 4.8 006 Fugitive 1.2 • Opacity of emissions shall not exceed 20%, except under specific conditions, then opacity shall not exceed 30% (Condition 6). The CAL is not considered to be a source of opacity emissions; therefore, this condition will not be applied to the CAL. • Odor requirements of Regulation No. 2 will not be identified in the permit as a specific condition but are included in Section IV (General Conditions) of the permit, Condition 14 (Condition 7). 123/6350 Page 15 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal • Contingent requirements for metal coil surface coating. If permittee utilizes the CAL to apply surface coating to a continuous metal strip with thickness of 0.15mm (0.006") or more that is packaged in a roll or a coil, NSPS Subpart TT applicability will be triggered. This condition was incorporated into Alternate Operating Scenarios, Section I, Condition 5 of the Operating Permit. Additionally, specific 40 CFR Part 60 Subpart TT requirements were added in Section II, Specific Permit Terms of the Operating Permit (Condition 8). • Contingent requirements for flexible vinyl and urethane coating and printing. If permittee utilizes the CAL to apply surface coating to a supporting web that is more than 50 micrometers (0.002") thick, and that consists of or contains a vinyl or urethane sheet or a vinyl or urethane coated web, NSPS Subpart FFF applicability will be triggered. This condition was incorporated into Alternate Operating Scenarios, Section I, Condition 5 of the Operating Permit. Additionally, specific 40 CFR Part 60 Subpart FFF requirements were added in Section II, Specific Permit Terms of the Operating Permit (Condition 9). • Contingent requirements for polymeric coating. If permittee utilizes the CAL to apply elastomers, polymers, or prepolymers to a supporting web other than paper, plastic film, metallic foil, or metal coil, NSPS Subpart VVV applicability will be triggered. This condition was incorporated into Alternate Operating Scenarios, Section I, Condition 5 of the Operating Permit. Additionally specific 40 CFR Part 60 Subpart VVV requirements were added in Section II, Specific Permit Terms of the Operating Permit (Condition 10). • RACT (Condition 12). This source is located in an ozone non -attainment area and subject to Reasonably Available Control Technology (RACT) requirements of Regulation No. 3, Part B III.D.2.b. No control, due to high cost per ton of pollutant removed, was determined to be RACT for this source. This condition will not be included in the Operating Permit as it has no requirements. • The owner or operator shall comply with the Operating and Maintenance (O&M) Plan, along with a recordkeeping format, that outlines how the applicant will maintain compliance on an ongoing basis with the requirements of this permit. An O&M Plan was submitted on January 15, 2014 to the Division and approved on January 30, 2014. The appropriate requirements from the O&M Plan will be incorporated into the Title V Permit. • APEN reporting (Condition 15): The APEN reporting requirements will not be identified in the Permit as a specific condition but are included in Section IV (General Conditions) of the Permit, Condition 22.e. Emission Factors — Emissions from the CAL are based on material balance, in accordance with the following equation: tons VOC moth = VOC consumption month 123/6350 Page 16 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal The VOC content of the coatings should be based on either the manufacturer's information (i.e. Safety Data Sheets) or EPA Reference Method 24. In cases where discrepancies exist between manufacturer's data and Method 24, Method 24 will govern. Monitoring Plan — The permittee will be required to record the quantities of coatings used. This information will be used to calculate annual VOC emissions. Monthly VOC emissions will be used in twelve month rolling totals to monitor compliance with the annual emission limitations. Compliance with the NSPS limits, when applicable, shall be demonstrated in accordance with the requirements in those particular regulations. PET unloading (AIRS 002) The modification application received on December 8, 2017 requests the modification of the method used to calculate particulate matter emissions generated during PET pellet unloading. Prior to the modification the controlled particulate emissions were calculated using the following formula: tons lb lb PM 1 ton PM/PMlo month= PET month x (1 — 0.9999) x 0.005 lb PET x 2000 lbs CHC requests the formula be changed as follows: tons lb lb PM 1 ton PM/PMlo month= PET month x (1 0.97) x 3.47E- lb PET x 2000 lbs The decrease in control efficiency requested is based on manufacturer specification. The HEPA filters control efficiency is guaranteed at 97% for particulates of 1 micron and 99.5% for particulates of 2 microns. CHC requested the 97% control efficiency for a more conservative estimate. The decrease of the particulate emission factor is requested as a result of a study executed to determine a process -specific emission factor. The test plan was submitted and approved on June 12, 2017. The data gathered during the study is as follows: PET Pellet Bypass Weight Fraction Loading to HEPA Filter Weight of Filter Before & After Unload (kg) PM Captured (kg) PM Emitted (kg) PET Unloaded (kg) Emission Rate (kg/kg) Before After A A/ 0.97 PM Emitted/ PET Unloaded 9.114 9.304 0.190 0.196 172,862 1.133E-06 9.304 9.486 0.182 0.188 158,756 1.182E-06 9.486 9.912 0.426 0.439 338,054 1.299E-06 9.912 10.166 0.254 0.262 504,756 5.188E-07 10.166 10.398 0.232 0.239 427,892 5.590E-07 10.398 10.674 0.276 0.285 434,226 6.553E-07 7.174 9.054 1.880 1.938 670,266 2.892E-06 RER Calculated with 20% safety factor (RER= HER * 1.2) Highest Emission Rate (HER) 2.892E-06 Requested Emission Rate (RER) 3.470E-06 123/6350 Page 17 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal PET Reuse Process, PET Powder Unloading Calculation, & Resorcinol Emission Calculation • CHC is implementing an on -site PET reuse process. Implementation will require installation of additional equipment such as a PET shredder and extruder. The new process will be an insignificant source of VOC and Particulate Matter emissions. P 1E calculations can be found below: Potential to Emit — PET Reuse Process (Shredding & Extrusion) Process Max Design Rate: 500 lb PET/ hr PTE Calculated using the following formula: lb lb hr lb PET 1 ton yr — EF x 8760 x 500 x ton PET yr hr 200O lbs Pollutant Emission Factor (EF) Source II Pounds/Year VOC 2.19E -31b VOC/Ton PET Title V Permit Section II, Condition 1.1.1.2 280 PM/PMIo 8.66E-2 lb PM/Ton PET AP -42 Ch. 4.12 (Retread EF Uncontrolled) 190 • CHC requested a change in calculation methodology for the PET Powder unloading process. The current emission calculation assumes the operation occurs on an 8760 basis and essentially calculates the PTE of the process as actual emissions. CHC requested to change the calculation to reflect actual process usage. Current Emission Calculation: tons gr hr min 1 lb 1 ton PM/PMlo yr = 0.01 dscf x 888 dscfm x 8760 yr x 60 hr x 7000 gr x 2000 lbs Requested Emission Calculation: tons gr hr min 1 lb 1 ton PM/PMlo month — 0.01 dscf x 888 dscfm x Usage month x 60 hr x 7000 gr x 2000 lbs • CHC requested the removal of the emission calculation related to the use of resorcinol. CHC proposed that all PM emissions associated with use of resorcinol are accounted for under the chemical weigh hood emission calculations. In essence that no resorcinol is emitted post material weighing during formulation of the coating. According to the KCD Air Quality Compliance Monitoring Plan, dated May 1999, the drying and heating steps raise the temperature of the support, which increases the volatility of the resorcinol. This causes resorcinol loss to the surroundings. Because of its very low vapor pressure and high melting point, resorcinol tends to precipitate out as exhaust temperatures drop, and is therefore considered a particulate emission rather than VOC. Based on the information provided in the Compliance Monitoring Plan the assertion that all resorcinol related emissions are accounted for in the chemical weigh hood emission calculation is incorrect and therefore the modification request is denied. However, the calculation in the permit has been revised to reflect the correct source of 123/6350 Page 18 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal resorcinol emissions. Drying and heating and subsequent sublimation occurs in the 501 Machine and not in Chemical Making. The source of emissions has been changed from Chemical Making to 501 Machine. The permittee's requested modifications were addressed as follows: Page Following Cover Page • Responsible official and facility contact person information updated. Section I — General Activities and Summary • Facility description updated to reflect current nonattainment status to 8 -Hour Ozone Nonattainment Area and include the Boiler House. • Updated Construction Permit references to reflect the incorporation of Construction Permits 10WE1575 and 13WE1752. • Nonattainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) o NANSR status updated to major. o PSD status of boilers updated to major, while maintaining minor status for the rest of the facility (Source Within a Source). • Summary of Emission Units- Added 5 corona treaters, two boilers rated at 206 mmBtu/hr each, and CAL. • Alternate Operating Scenarios- Updated to reflect the requirements for flexibility of the CAL to be able to analyze various combinations of substrates and coatings. Section II — Specific Permit Terms • Sensitizing Complex and Support Manufacturing o Addition of ozone 7.0 TPY emission limit and throughput limit of 191,780 kW -hr per year related to corona treaters usage. o Increased PM/PM10 emission limits to compensate for calculation error. o Pellet grinders emission calculation modified. o Railroad car PET pellet unloading calculation modified. 123/6350 Page 19 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal o Railroad car PET powder unloading calculation modified. • CAL o Condition 5 was created to incorporate all of the applicable requirements, emission limits, throughput limits, and emission factors from Construction Permit 13WE1752. o Condition 6 outlines NSPS TT requirements if Alternate Operating Scenario of metal coil surface coating is active. o Condition 7 outlines NSPS FFF requirements if Alternate Operating Scenario of flexible vinyl and urethane coating and printing is active. o Condition 8 outlines NSPS VVV requirements if Alternate Operating Scenario of polymeric coating is active. • Two dual -fuel fired (natural gas and diesel) boilers, 206 mmBtu/hr each o Condition 9 was created to incorporate all of the applicable requirements, emission limits, throughput limits, and emission factors from Construction Permit l0WE1575. o Condition 10 added specifying MACT DDDDD requirements. The applicable requirements are described in Section III. Applicable Requirements. Section III — Acid Rain Requirements • No Change Section III/IV — Permit Shield • Modified "40 CFR Parts 9 and 63, as adopted by reference in Colorado Regulation No. 8, Part E" to identify Subpart JJ as the non -applicable Subpart of Part 63. • Added 40 CFR Part 63, Subpart JJJ. • Added 40 CFR Part 63, Subpart EEEE. • Added 40 CFR Part 63, Subpart FFFF. Section IV/V — General Permit Conditions • No Change Appendices 123/6350 Page 20 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal • Appendix A: Added PET reuse process to the list of insignificant activities. V. Other Modifications In addition to the permittee requested modifications, the Division has included changes to make the permit more consistent with recently issued permits, include comments made by EPA on other Operating Permits, as well as correct errors or omissions identified during inspections and/or discrepancies identified during review of this renewal. These changes are as follows: Page Following Cover Page • It should be noted that the monitoring and compliance periods and report and certification due dates are shown as examples. The appropriate monitoring and compliance periods and report and certification due dates will be filled in after permit issuance and will be based on permit issuance date. Note that the permittee may request to keep the same monitoring and compliance periods and report and certification due dates as were provided in the original permit. However, it should be noted that with this option, depending on the permit issuance date, the first monitoring period and compliance period may be short (i.e. less than 6 months and less than 1 year). Section I — General Activities and Summary • Revised the language in Condition 1.4 include current conditions that are state -only enforceable. Section II — Specific Permit Terms • Removed Condition 1.1.3.1. Condition addressed calculation of PM emission associated with dibutyl phthalate (DBP) consumption. CHC has not used DBP since 2003 and has no plans on using the material in the future. All other references to the material have been removed from the Permit as well. • Removed Condition 1.4. Condition stipulated that the permit conditions for the Railroad Car PET Pellet Unloading & three Pellet Grinders shall expire if the owner or operator of the source does not commence and/or finish construction within a timely manner. Construction completed in 2007, Condition is no longer relevant. • MACT JJJJ requirements added in Condition 3. Reference Section III. Applicable Requirements for discussion of requirements. • Added Condition 4. Condition 4 lists applicable requirements from Colorado Regulations° No. 7, Section IX. The source has become subject to the regulation since the initial issuance of the Operating Permit. CHC is located in Windsor, Colorado, which was designated as 123/6350 Page 21 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal attainment for all criteria pollutants when the initial Operating Permit was issued in 2004. Since then it has been re-classified as nonattainment for the 8 -hr ozone standard and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. As such the source is subject to Regulations No. 7, Section IX. The following discussion of the Reg 7, Section IX requirements as they apply to this facility: o Section IX.A.3, Test Methods and Procedures: This section requires the source to use EPA Method 24 and/or manufacturer's formulation data to determine the composition of the coatings used and requires that a performance test be conducted (using EPA Method 25) for sources that use add-on control devices. The source does not use an add-on control device and therefore no performance test is necessary. o Section IX.A.4, Sampling: To determine compliance with applicable surface coating standards, samples shall be taken from the coating as freshly delivered to the reservoir of the coating applicator. o Section IX.A.7, Fugitive Emission Control: Consists of general work practices such as tight -fitting covers for open tanks, covered containers for solvent wiping cloths, and proper disposal of dirty cleanup solvent. o Section IX.A.8, Recordkeeping, Reporting, and Monitoring: The source does not use an add-on control device and is therefore subject to the monitoring and recordkeeping requirements in Section IX.A.8.c. This section directs the source to reference EPA Guidance Document EPA -340/1-88-033, "Recordkeeping Guidance Document for Surface Coating Operations and the Graphic Arts Industry." o Section IX.A.10, Compliance Calculation Procedures: Compliance shall be determined on a daily basis and follow the guidance in "Procedure for Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink, and Other Coatings," EPA -450/3-84/019. o Section IX.I, Paper Coating Operations: CHC operation falls under the definition of "Paper Coating." Specifically "impregnating or applying a uniform layer of `surface coating' to paper." This includes, but is not limited to, photographic paper. The paper coating lines are limited to 2.9 lbs VOC per gallon of coating (minus water and exempt solvents). o Section IX.J, Plastic -Film Coating Operations: 123/6350 Page 22 of 23 Carestream Health, Inc — Carestream Health Colorado Operating Permit No. 06OPWE288 Technical Review Document — Second Renewal CHC operation falls under the definition of "Plastic -Film Coating Operations." Specifically "applying a uniform layer of `surface coating' to a flexible web or sheet of thin plastic substance..." This includes, but is not limited to, photographic film. The Plastic -Film Coating lines are limited to 2.9 lbs VOC per gallon of coating (minus water and exempt solvents). • Added Condition 11. Condition 11 addresses all applicable requirements for the degreasing units. Requirements include limitation of degreasing fluid loss to 20% via evaporation or loss otherwise during transfer. Condition 11 also specifies storage requirements, operational requirements, and requirements for the solvent spray apparatus to reduce splashing and fine atomizing. Degreasing units were removed from the insignificant activates list. Section III — Permit Shield • Updated the Regulation No. 3 citation for the permit shield. • Removed "Colorado Regulation No. 7, except for Sections V, VI.B.1 and VII.C" from the permit shield, as Windsor, Colorado is now designated as nonattainment for the 8 -hr ozone standard and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. The change in attainment status requires the source to comply with Regulation No. 7 requirements. • Removed "General Condition 29.a of this permit" from the Permit Shield, as Windsor, Colorado is now designated as nonattainment for the 8 -hr ozone standard and is part of the 8 - hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. Section IV — General Permit Conditions • Updated the General Permit Conditions to the current version (5/22/2012). Appendices • Updated Appendices B and C (Monitoring and Permit Deviation Reports and Compliance Certification Reports) to the newest versions (2/20/2007). • EPA's mailing address was revised (Appendix D). Removed the Acid Rain addresses in Appendix D, since permittee is not subject to the Acid Rain Program. • Cleared the list of modifications from Appendix F related to the previous issuance. • Attached O&M Plan for the CAL as Appendix H. 123/6350 Page 23 of 23 Sensitizing Complex & Support Manufacturing 15 133.4 96.5 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT RENEWAL SUMMARY PERMIT NUMBER: 06OPWE288 AIRS ID #: 123/6350 DATE: June 12, 2018 APPLICANT: Carestream Health, Inc. — Carestream Health Colorado REVIEW ENGINEER: Ramazan Spencer SOURCE DESCRIPTION Carestream Health, Inc. Colorado (CHC) is a paper and web manufacturing and coating facility located at 2000 Howard Smith Avenue West, Windsor, CO 80550 in Weld County. The campus consists of multiple buildings containing a variety of equipment used in the manufacturing processes. A polyester film support base is produced for X-ray products in Building C-50. Medical x-ray film, color photographic paper, and contract manufacturing products are produced in the Sensitizing Complex (Buildings C-40, C-41, C-42, and C-43). Building C-70 houses the main central utilities operations including two boilers, each rated at 206 mmBtu/hour, that supply steam for the site. This facility is located in an area classified as attainment for all pollutants except ozone. It is classified as nonattainment for the 8 -hr ozone standard and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. There is only one Operating Permit associated with this facility. This source is categorized as a Non -Attainment New Source Review (NANSR) major stationary source and a minor stationary source with respect to Prevention of Significant Deterioration (PSD) requirements. The boilers are a listed source for PSD purposes and therefore are categorized as a major source for PSD purposes. Wyoming is an affected state within 50 miles of the plant. The following Federal Class I designated areas are within 100 kilometers of the plant: Rocky Mountain National Park and Rawah National Wilderness Area. The emission units covered under this permit are not subject to the Accidental Release provisions of section 112(r) of the Federal Clean Air Act. In addition, none of the emission units at this facility are subject to the Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64. FACILITY EMISSION SUMMARY �otent(al ns nd HAPS 15 48.3 7 >10 >25 C-70 Boilers 4.66 4.62 3.32 <10 <25 Coating Assessment Laboratory ;ii3A �'x Total 4.8 <10 <25 19.66 19.62 I 133.4 96.5 56.42 7 I >10 1 >25 EMISSION SOURCES The following discussion identifies the changes that were made in the renewal permit. Sensitizing Complex & Support Manufacturing (AIRS #: 001, 002, 003) — Regulation Number 7, Section IX: Surface Coating Operations applicable requirements added. Paper and Other Web Coating MACT JJJJ applicable requirements added. C-70 Boilers (AIRS #: 004) — MACT DDDDD applicable requirements added. Coating Assessment Laboratory (AIRS #: 005) - NSPS TT, FFF, and VVV applicable requirements added. Degreasing Units — Regulation Number 7, Section X: Use of Solvents for Degreasing and Cleaning applicable requirements added. ALTERNATIVE OPERATING SCENARIOS Added alternative operating scenarios for the Coating Assessment Laboratory. INSIGNIFICANT ACTIVITIES Updated to reflect current operations. PERMIT SHIELD Removed all Permit Shield entries that relied on attainment status of the area. Carstre HEALTH October 28, 2008 Mr. Matt Burgett Operating Permits Unit, Stationary Sources Program CDPH&E Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: Renewal Air Operating Permit (06OPWE288) Dear Mr. Burgett: Enclosed please find our application package for renewal of Operating Permit number 06OPWE228 for Carestream Health Colorado ("CHC"). Except for the proposed modifications identified in the attached "Supporting Documentation", CHC is not requesting any changes to the existing permit. All other terms in our existing permit are incorporated by reference into this application. CHC is aware of the APCD's proposed amendments to Regulation No. 3 and Regulation No. 7. When those amendments are fmalized and adopted, we will supplement this permit renewal application as necessary to address any new applicable requirements, pursuant to the provisions in Regulation No. 3, Part C, sections IV.B.4, III.C.8, and III.C.9. If you have any questions regarding this application, please contact Karen Murphy, Environmental Engineer, at karen.murphy1 @carestreamhealth.com or (970) 686-4032. Sincerely^ c e A5p O4 Michael S. Haas Site Manager, Carestream Health Colorado Division 2000 Howard Smith Ave West Windsor, CO 80550 Enclosed: Forms 2000-100,602, 603, 800 & Attachments cc: Ms. Julie Lewis, Carestream Health Inc. Ms. Karen M. Murphy Carestream HEALTH Carestream Health Colorado (CHC) Application for Renewal of Operating Permit No. 06OPWE288 Supporting Documentation 1. Section I- Compliance Assurance Monitoring (CAM) 5 Change: CHC is exempt from the CAM requirements pursuant to 40 CFR sections 64.2(b)(1)(i)(exemption for emissions subject to National Emission Standards for Hazardous Air Pollutants/Maximum Achievable Control Technology (MACT) standards proposed by the USEPA after Nov. 15, 1990) and (vi) (exemption for emissions subject to a continuous compliance determination methods, as defined in 40 CFR section 64.1). Rationale: As discussed below, CHC is subject to one NESHAP/MACT standard. Emissions limitations associated with such standards are exempt from the CAM requirements pursuant to 40 CFR section 64.2(b)(1)(i). CRC's permit includes emissions limitations for VOCs, PM, and PMIo• However, CHC monitors emissions of those pollutants via continuous compliance determination methods, such as monthly mass balance calculations. Therefore, pursuant to 40 CFR section 64.2(b)(1)(vi), the VOC, PM, and PMI() emissions limitations are also exempt from the CAM requirements. Note also that CHC does not use control devices to capture VOC emissions. 2. Section II- Specific Permit Terms 1.1 Change: Modify PM emissions calculation for building C-50 pellet grinders. Current calculation: Three Pellet Grinders (total): 0.02 gr/cf x 1207 cfm x 60 min/hr x 8760 hr/yr x lb/7000 gr x ton/2000 lb = 0.91 tpy Proposed new calculation: Three Pellet Grinders (total) PM/PMio Emissions/mth = (lbs PET Pellet extruded/mth) x (2.9 * 10 -5 lb PM/lb PET Pellet extruded) Supporting Documentation Permit Renew Application 06OPWE288 October 28, 2008 Page 1 of 6 where: 2.9 * 10"5 is emission factor based on PM emissions of 0.91 tpy for 24/7/365 operation. Rationale: The current calculations account for emissions from pellet grinders based on a 24/7/365 operation. CHC is no longer utilizing the grinders on a 24/7/365 basis, and therefore requests a modification pursuant to which CHC will account for PM emissions based on actual polymer throughput to the extruder. 3. Section II- Specific Permit Terms 3 Change: CHC is required to comply with 40 CFR Part 63, Subpart JJJJ, National Emission Standard for Hazardous Air Pollutants: Paper and Other Web Coating (P&OWC MACT),as adopted by reference in Colorado Regulation No. 8, Part E. Rationale: Building C-40 Coating Machine & Building C-50 501 Machine are both subject to the P&OWC MACT. Since May 1, 2007, CHC has been complying with the P&OWC MACT via the provisions in 40 CFR section 63.3370 (c)(3). CHC requests to continue to demonstrate compliance with emission standards as set forth in subpart 63.3370 (b), (c) or (d). 4. Section III. 1 (Permit Shield Table) Change: Add specific non -applicable requirements to table stating facility is not subject to 40 CFR Part 63, Subpart JJJ, National Emission Standard for Hazardous Air Pollutants: Group IV Polymers and Resins (Group IV Polymers MACT), as adopted by reference in Colorado Regulation No. 8, Part E. Rationale: CHC does not produce in a thermoplastic product process unit any of the products listed in the Group IV Polymers MACT. CHC uses PET as a purchased material in the form of polymer powder and pellets. 5. Section III. 1 (Permit Shield Table) Change: Add specific non -applicable requirements to table stating facility is not subject to 40 CFR Part 63, Subpart EEEE, National Emission Standard for Supporting Documentation Permit Renew Application 06OPWE288 October 28, 2008 Page 2 of 6 Hazardous Air Pollutants: Organic Liquids Distribution (Non -Gasoline) (OLD MACT), as adopted by reference in Colorado Regulation No. 8, Part E. Rationale: CHC has been complying with the OLD MACT since May 1, 2007. However, we have recently reassessed the applicability of thisrequirement to our operations and have concluded that the OLD MACT is not now and never has been applicable because the ethylene glycol generated from CHC's polymer process does not meet the definition of an "organic liquid". Specifically, as set forth below, the annual average true vapor pressure of ethylene glycol is less than 0.1 psia. Background: Ethylene glycol, an oHAP, is a byproduct of the polymer process in building C-50. After ethylene glycol is generated, it is transferred to a 50 gallon scrubber holding tank containing triethylene glycol with the temperature maintained at approximately 90 °F. The spent scrubber solution is then transferred to a 6,000 gallon waste mixed glycol tank that is stored at ambient temperature. Once the waste tank has reached its storage capacity, the contents are then shipped off -site. The waste glycol mixture is approximately 25% ethylene glycol and 75% triethylene glycol. Definitions from the OLD MACT, 40 CFR section 63.2406: Actual annual average temperature, for organic liquids means the temperature determined using the following methods: (2) For ambient temperature storage tanks: (i) Use the annual average of the local (nearest) normal daily mean temperatures reported by the National Climatic Data Center; Organic liquid means: (3) Organic liquids for purposes of this subpart do not include the following liquids: (vi) Any non -crude oil liquid with an annual average true vapor pressure less than 0.7 kilopascals (0.1 psia). Supporting Documentation Permit Renew Application 06OPWE288 October 28, 2008 Page 3 of 6 Discussion: The annual average normal daily mean temperature of Denver is 50 °F (10 °C or 283 K). Using this temperature and the known vapor pressure of ethylene glycol at 20 °C, the vapor pressure of ethylene glycol can be calculated to be 0.0004 psia using the Clausius-Clapeyron equation as demonstrated below. Using the Clausius-Clapeyron equation: In(P2/P1) =-0Hva°/R * (1/T2-1/Ti) Variables Values Units Source AHvap = 65.6 kJ/mol wikipedia R = 8.31x10-3 kJ/mol K --- P2 = calc from eq mm Hg --- P1= 0.06 mm Hg MSDS T2 = x K Temperature of interest Ti = 293 K MSDS Therefore: In(P2/0.06) = -65.6 kJ/8.31x10-3 kJ/mol K *(1/x - 1/293) Pio°c = 0.06 exp (- (65600/8.3145)(1/283 - 1/293)) = 0.023 mm Hg psia Ethylene Glycol @ 10°C 1 atm= 14.696595 psia = 760 mm Hg 1 mmHg = 0.0193367 psia Eq: (0.023 mm Hg) * (14.69595 psia) / 760 mm Hg) = 0.0004 psia Taken a step further, the average normal daily mean temperature would need to be greater than 170 °F (77 °C or 350 K) to reach 0.1 psia as demonstrated in the calculations below. Prrc = 0.06 exp(- (65600/8.3145)*(1/350 - 1/293))= 4.816 mm Hg psia Ethylene Glycol @ 77°C 1 atm= 14.696595 psia = 760 mm Hg 1 mmHg = 0.0193367 psia Eq: (4.816 mm Hg) * (14.69595 psia) / 760 mm Hg) = 0.093 psia Supporting Documentation Permit Renew Application 06OPWE288 October 28, 2008 Page 4 of 6 6. Permit Section III. 1 (Permit Shield Table) Change: Add specific non -applicable requirements to table stating facility is not subject to 40 CFR Part 63, Subpart FFFF, National Emission Standard for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing (MON MACT), as adopted by reference in Colorado Regulation No. 8, Part E. Rationale: CHC is exempt from the MON MACT pursuant to 40 CFR section 63.2435(c)(5): first, NAICS code 325992 generally describes the operations at the CHC facility; second, CHC does not produce or manufacture photographic chemicals, such as fixers or developers. Excerpts from the MON MACT, 40 CFR section 63.2435: (c) The requirements in this subpart do not apply to the operations specified in paragraphs (c)(1) through (7) of this section. (5) Production activities described using the 1997 version of NAICS codes 325131, 325181, 325188 (except the requirements do apply to hydrazine), 325314, 325991 (except the requirements do apply to reformulating plastics resins from recycled plastics products), and 325992 (except the requirements do apply to photographic chemicals). 7. Permit Section III. 1 (Permit Shield Table) Change: Add specific non -applicable requirements to table stating that ozone (O3) emissions generated at the facility from coronal discharge treaters (CDT) are exempt from the Air Pollutant Emission Notice (APEN) Reporting requirements in Colorado Regulation No. 3, Part A Rationale: CHC operates five (5) coronal discharge treaters that only emit O3 while coating color paper. The O3 that is emitted from these units is a very reactive and short-lived molecule. The CDTs vent to the atmosphere via 1 of 2 fans, each with a diameter of one (1) foot and flow temperature of 85 °F. Fan #1 ducts length is 52 feet, and fan # 2 is 41 feet. Based on engineering calculations, CHC believes that from the point of generation at the CDTs to the point of exit to the atmosphere, the O3 reacts and therefore is not released as 03. Note that on September 11, 2008, the Regional Air Quality Council (RAQC) submitted its proposed draft State Implementation Plan (SIP) Supporting Documentation Permit Renew Application 06OPWE288 October 28, 2008 Page 5 of 6 Rule to the Air Quality Control Commission (AQCC) and in this draft specifically identifies the ground -level ozone of concern as that which is "created by complex chemical reactions between nitrogen oxides (NO,) and volatile organic compounds (VOC), and to a lesser extent carbon monoxide (CO), in the presence of sunlight", and not highly reactive and unstable 03 such as the ozone generated by CRC's CDTs. Supporting Documentation Permit Renew Application 06OPWE288 October 28, 2008 Page 6 of 6 ating Permit Application FACILITY IDENTIFICATION irado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-100 Rev 06-95 1. Facility name and Name Carestream Health Inc. mailing address Street or Route 2000 Howard Smith Ave West City, State, Zip Code Windsor, CO 80550 2. Facility location Street Address 2 0 0 0 Howard Smith Ave West (No P.O. Box) City,County, Zip Code Windsor, Weld 80550 3. Parent corporation Name Street or Route City, State, Zip Code Country (if not U.S.) Carestream Health Inc. 150 Verona Street Rochester, NY 14608 4. Responsible Name official Title Telephone Michael S. Haas Site Manager, Carestream Health Inc. (970) 686- 4573 Permit contact person Name Title (If Different than 4) Telephone Karen M. Murphy Environmental Engineer (970) 686-4032 6. Facility SIC code: 3861 7. Facility identification code: CO 1236350 8. Federal Tax 1. D. Number: 20-8190334 9. Primary activity of the operating establishment: Manufacturer of photographic supplies 10. Type of operating permit New Modified x Renewal 11. Is the facility located in a "nonattainment" area: x Yes ' , No If "Yes", check the designated "non -attainment" pollutant(s): ' I Carbon Monoxide x Ozone ! I PM10 •i Other (specify) 12. List all (Federal and State) air pollution permits (including grandfathered units), plan approvals and exemptions issued to this facility. List the number, date and what unit/process is covered by each permit. For a Modified Operating Permit, do not complete this item. 06OPWE288 FACILITY IDENTIFICATION -- Form 2000-100 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Use "NA" where necessary to identify an information request that does not apply. One form should be included with each application. Item 1 Provide full business name and address of corporation, company, association, society, firm, partnership, individual or political subdivision of the state submitting the application. Item 2 Street address where the air pollution sources are or will be located. For remote locations, land plat descriptions (Township, Range, Section, Subsection location) are acceptable. Item 3 If wholly or partly owned by another entity, identify that entity. Item 4 The responsible official is a person legally responsible for the operation of the permitted air pollution sources. For a corporation, this person must be the president, vice-president, secretary or treasurer, or other person with a similar level of responsibility in the company. 'rior to filing the application, if you want the Division to approve your choice of responsible official you may send a letter to the Division escrihing that person's authority in the company and requesting the Division's approval. Item 5 Individual to contact during the permitting process for additional information concerning the air pollution sources. Item 6 The primary Standard Industrial Classification (SIC) code for the facility where the source(s) are located. Item 7 Provide the facility identification (FID) code. The Division has assigned a unique code to your facility. The code begir,- with "CO" (Colorado) and has 7 digits. Item 8 Provide the Facility Federal Tax Number. This is a nine -digit number. Item 9 Provide a short statement about your facility's activities such as "lead -acid battery manufacture" or "sulfite paper mill." Item 10 Indicate the type of permit application being submitted. An applicant may at any time request an operating permit that is otherwise not required. Item 11 Indicate whether the facility is located in a nonattainment areaeven if your facility does not emit the pollutant. Please refer to the instruction booklet and Appendix G of the instruction book. If the area is attainment for all pollutants, enter "Attainment for all Pollutants". Item 12 Identify all facility air pollution permits, plan approvals (fugitive dust), and exemptions issued by U.S. EPA or Colorado APCD that are still in effect. Include grandfathered emission units. Please do not list old permits, exemptions, etc. that have expired or been superseded by more recent approvals. List the permit number, date, and unit or operation covered by the permit. Example: 88DE189 May 15, 1989 Fugitive Dust Sept 1, 1992 Grandfathered Feb 2, 1972 Incinerator Gravel Pit Smith Boiler 2 Operating Permit Application PLANT -WIDE HAZARDOUS AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE Facility name: Carestream Health Inc. 2. Facility identification code: CO 1236350 FORM 2000-602 Rev 06-95 3. Complete the following emissions summary for all hazardous air emissions at this facility. Calculations attached. Attach a copy of all calculations to this form. Attached i ! Pollutant CAS Common or Generic Pollutant Name Actual emissions . Allowable OR Potential to emit Quantity Units Quantity Units HAPs > 25 total or _> 10 any single HAP TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY )TE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 3 r PLANT -WIDE HAZARDOUS AIR POLLUTANTS -- Form 2000-602 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. This is a supplemental form for use only when necessary to provide complete information in the operating permit application. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. Item 1 Provide the name of the facility. Item 2 Provide the facility identification (FID) code. Item 3 Provide an emissions summary for all hazardous air emission sources at this facility: Indicate the hazardous air pollutant's corresponding Chemical Abstract System (CAS) number. If no CAS number has been assigned to a pollutant, write "None". Total the emissions for each hazardous air pollutant listed on each Form 2000-600 completed. This will be the total facility emission of this air pollutant. Use the same units (i.e., pounds per hour, pounds per year, tons per year, etc.) for the hazardous air pollutants as used for the standard in Colorado Regulation No. 8, or section 112 of the 1990 Clean Air Act Amendments (42 U.S.C. 7412). NOTE: A limit on the Criteria Pollutant Volatile Organic Compounds may also be a limit on the Hazardous Air Pollutants. 4 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE PLANT -WIDE CRITERIA AIR POLLUTANTS FORM 2000-603 09-94 1. Facility name: Carestream Health Inc. 2. Facility identification code: CO 1236350 3. Complete the following emissions summary for the listed emissions at this facility. Air pollutant Actual Potential to emit Maximum allowable TPY. TPY TPY Particulates (TSP) ;' N/A N/A PM -10 11 . 8 11 . 8 Nitrogen oxides N/A N/A Volatile organic compounds 4 8. 3 4 8. 3 Carbon monoxide N/A N/A Lead N/A N/A Sulfur dioxide N/A N/A Total reduced sulfur N/A N/A Reduced sulfur compounds N/A N/A Hydrogen sulfide N/A N/A Sulfuric acid mist N/A N/A Fluorides N/A N/A 5 J PLANT -WIDE CRITERIA AIR POLLUTANTS -- Form 2000-603 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permits. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of thi form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. Item 1 Provide the name of the facility. Item 2 Provide the facility identification (FID) code. Item 3 Provide the emission levels in tons per year (TPY). For each pollutant emitted from the facility, sum the annual actual, potential to emit, and the maximum allowable emission rates (tons per year only) reported for all of the facility's emission units. The individual values are on each Form 2000-601 completed for the application. The totals for each pollutant should be reported on Form 2000-603 in tons per year (TPY). ***** Hazardous air pollutant emissions should be reported on Forms 2000-600 and 2000-602. ***** 6 Operating Permit Application Colorado Department of Health Air Pollution Control Division Facility Name: Carestream Health Inc. 1. ADMINISTRATION TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 09-94 Facility Identification Code: CO 1236350 1pplication contains the following forms: x Form 2000-100, Facility Identification Form 2000-101, Facility Plot Plan Forms 2000-102, -102A, and -102B, Source and Site Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler. printing Form 2000-200, Stack Identification Form 2000-300, Boiler or Furnace Operation Form 2000-301, Storage Tanks Form 2000-302, Internal Combustion Engine Form 2000-303, Incineration Form 2000-304, Printing Operations Form 2000-305, Painting and Coating Operations Form 2000-306, Miscellaneous Processes Form 2000-307, Glycol Dehydration Unit III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following forms: Form 2000-400, Miscellaneous Form 2000-401, Condensers Form 2000-402, Adsorbers Form 2000-403, Catalytic or Thermal Oxidation Form 2000-404, Cyclones/Settling Chambers Form 2000-405, Electrostatic Precipitators Form 2000406, Wet Collection Systems Form 2000-407, Baghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the following forms (one for each facility boiler, printing Form 2000-500, Compliance Certification - Monitoring and Renortinr Form 2000-501, Continuous Emission Monitoring Form 2000-502, Periodic Emission Monitoring Using Portable Monitors Form 2000-503, Control System Parameters or Operation Parameters of a Process Form 2000-504, Monitoring Maintenance Procedures Form 2000-505, Stack Testing Form 2000-506, Fuel Sampling and Analysis Form 2000-507, Recordkeeping Form 2000-508, Other Methods 7 V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan Form 2000-600, Emission Unit Hazardous Air Pollutants Form 2000-601, Emission Unit Criteria Air Pollutants x Form 2000-602, Facility Hazardous Air Pollutants x Form 2000-603, Facility Criteria Air Pollutants i ; Form 2000-604, Applicable Requirements and Status of Emission Unit l ' Form 2000-605, Permit Shield Protection Identification Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule I1 Form 2000-607, Plant -Wide Applicable Requirements Cg Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application inquiry, I certify that the statements complete. B. CERTIFICATION OF FACILITY box only) in its entirety and, based on information and belief formed after reasonable and information contained in this application are true, accurate and COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS (check one described in this air pollution permit application is fully in compliance with described in this air pollution permit application is fully in compliance with except for the following emissions unit(s): I certify that the facility all applicable requirements. I certify that the facility all applicable requirements, (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Michael S. Haas Title Site Plant Manager Signature ,, � 2/24.c.O_4_, y Date Signed 10/28/08 8 Operating Permit Application Colorado Department of Health Air Pollution Control Division ity Name: Carestream Health, Inc CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 09-94 Facility Identification Code: CO 1236350 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application reasonable inquiry, I certify accurate and complete. B. CERTIFICATION OF (check one box only) in its entirety and, based on information and belief formed after that the statements and information contained in this application are true, FACILITY COMPLIANCE STATUS FOR STATE -ONLY CONDITIONS facility described in this air pollution permit application is fully in all applicable requirements. facility described in this air pollution permit application is fully in all applicable requirements, except for the following emissions unit(s): -4.I certify that the compliance with I certify that the compliance with (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Michael S. Haas Title Site Plant Manager Signature //,r1 •I ° l,� -G�1� 1� LPL Date Signed 10/28/08 SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 9 MAJOR SOURCE OPERATING PERMIT APPLICATION APPLICATION COMPLETENESS SUMMARY FORM 1. FACILITY NAME: 2. PERMIT: 3. REVIEW ENGINEER: 4. DATE OF APPLICATION: 5. DATE RECEIVED BY APCD COMPLETENESS DETERMINATION I. IDENTIFYING INFORMATION II. EMISSIONS III. APPLICABILITY IV. COMPLIANCE COMPLETE _ INCOMPLETE _ NOT APPLICABLE COMPLETE _ INCOMPLETE _ NOT APPLICABLE COMPLETE _ INCOMPLETE _ NOT APPLICABLE _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE APPLICATION FORM CERTIFIED FOR TRUTH, ACCURACY, AND COMPLETENESS BY: _ OFFICIAL TITLE _ SIGNATURE _ DATE APPLICATION EVALUATION __ COMPLETE (BASIC INFORMATION PRESENT TO BEGIN PROCESSING) INCOMPLETE - RETURN WITH ADDITIONAL INFORMATION BY: COMMENTS REVIEWED BY: DATE 10 MAJOR SOURCE OPERATING PERMIT APPLICATION APPLICATION COMPLETENESS CHECK LIST I. IDENTIFYING INFORMATION COMPLETE INCOMPLETE NOT APPLICABLE r,. FACILITY INFORMATION FACILITY NAME, LOCATION & MAILING ADDRESS PERMIT CONTACT PERSON RESPONSIBLE OFFICIAL PERMIT REQUESTED B. SOURCE DESCRIPTION 1. OPERATIONAL INFORMATION: SIC/SCC CODES LISTING AND DESCRIPTION OF EMISSION SOURCE(S) YES NO YES NO YES NO YES NO YES NO YES NO YES NO 2. IDENTIFICATION AND DESCRIPTION OF ALTERNATIVE OPERATIVE SCENARIOS (IF APPLICABLE) _ YES _ NO _ N/A C. PERMIT SHIELD RECUESTED YES NO II. EMISSIONS COMPLETE INCOMPLETE _ NOT APPLICABLE A. EMISSIONS INFORMATION 1. QUANTIFICATION OF ALL EMISSIONS OF REGULATED AIR POLLUTANTS _ YES _ NO 2. EMISSION SOURCES: IDENTIFICATION AND DESCRIPTION OF ALL EMISSION SOURCES IN SUFFICIENT DETAIL TO _ YES _ NO ESTABLISH THE BASIS FOR FEES AND APPLICABILITY OF REQUIREMENTS. A LIST OF INSIGNIFICANT EMISSIONS UNITS OR ACTIVITIES EXEMPTED _ YES _ NO - N/A BECAUSE OF SIZE OR PRODUCTION RATE. 4. PROCESS INFORMATION TO THE EXTENT IT IS NEEDED TO DETERMINE OR REGULATE EMISSIONS: FUELS RAW MATERIAL(S) / MATERIALS USED PRODUCTION RATES 5. FOR REGULATED AIR POLLUTANTS, LIMITATIONS ON SOURCE OPERATIONS AFFECTING: EMISSIONS ANY WORK PRACTICE STANDARDS 6. OTHER INFORMATION REQUIRED BY ANY APPLICABLE REQUIREMENTS FOR ALL REGULATED AIR POLLUTANTS SUCH AS: FLOW RATES STACK PARAMETERS 7. CALCULATIONS ON WHICH EMISSIONS RELATED INFORMATION ARE BASED _ YES _ NO _ N/A _ YES _ NO _ N/A _ YES _ NO _ N/A YES NO N/A YES NO N/A YES NO N/A YES NO N/A YES NO N/A 11 III. APPLICABILITY _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. CITATION AND DESCRIPTION OF ALL APPLICABLE REQUIREMENTS 2. OTHER SPECIFIC INFORMATION THAT MAY BE NECESSARY TO IMPLEMENT AND ENFORCE OTHER APPLICABLE REQUIREMENTS OR TO DETERMINE THE APPLICABILITY OF REQUIREMENTS YES NO YES NO 3. AN EXPLANATION OF ANY PROPOSED EXEMPTIONS FROM OTHERWISE APPLICABLE REQUIREMENTS _ YES _ NO _ N/A IV. COMPLIANCE COMPLETE _ INCOMPLETE - NOT APPLICABLE A. COMPLIANCE STATUS 1. A DESCRIPTION OF THE COMPLIANCE STATUS OF THE SOURCE WITH RESPECT TO ALL _ YES NO APPLICABLE REQUIREMENTS 2. FOR APPLICABLE REQUIREMENTS WITH WHICH THE SOURCE IS IN COMPLIANCE, A STATEMENT _ YES - NO THAT THE SOURCE WILL CONTINUE TO COMPLY WITH SUCH REQUIREMENTS 3. FOR APPLICABLE REQUIREMENTS THAT WILL BECOME EFFECTIVE DURING THE PERMIT TERM, _ YES - NO _ N/A A STATEMENT THAT THE SOURCE WILL MEET SUCH REQUIREMENTS ON A TIMELY BASIS 4. FOR REQUIREMENTS FOR WHICH THE SOURCE IS NOT IN COMPLIANCE AT THE TIME OF _ YES _ NO _ N/A PERMIT ISSUANCE, A NARRATIVE DESCRIPTION OF HOW THE SOURCE WILL ACHIEVE COMPLIANCE WITH SUCH REQUIREMENTS 5. IDENTIFICATION AND DESCRIPTION OF AIR POLLUTION CONTROL EQUIPMENT AND COMPLIANCE _ YES J NO MONITORING DEVICES OR ACTIVITIES 6. DESCRIPTION OF OR REFERENCE TO ANY APPLICABLE TEST METHOD FOR DETERMINING _ YES _ NO COMPLIANCE WITH EACH APPLICABLE REQUIREMENT B. COMPLIANCE SCHEDULE _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. A SCHEDULE OF COMPLIANCE FOR SOURCES THAT ARE NOT IN COMPLIANCE WITH ALL APPLICABLE REQUIREMENTS AT THE TIME OF PERMIT ISSUES YES NO Nh 2. A SCHEDULE FOR SUBMISSION OF CERTIFIED PROGRESS REPORTS NO LESS FREQUENTLY `YES _ NO _ N/A THAN EVERY SIX MONTHS FOR SOURCES REQUIRED TO HAVE A SCHEDULE OF COMPLIANCE TO REMEDY A VIOLATION C. COMPLIANCE CERTIFICATION _ COMPLETE _ INCOMPLETE ` NOT APPLICABLE 1. CERTIFICATION OF COMPLIANCE WITH ALL APPLICABLE REQUIREMENTS BY _ YES _ NO A RESPONSIBLE OFFICIAL 2. A STATEMENT OF METHODS USED FOR DETERMINING COMPLIANCE, INCLUDING A DESCRIPTION _ YES _ NO OF MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS AND TEST METHODS 3. A SCHEDULE FOR SUBMISSION OF COMPLIANCE CERTIFICATIONS 4. A STATEMENT INDICATING THE SOURCE'S COMPLIANCE STATUS WITH ANY APPLICABLE ENHANCED MONITORING AND COMPLIANCE CERTIFICATION REQUIREMENTS OF THE FEDERAL ACT _ YES NO YES _ NO 12 are strearn J HEALTH Matt Burgett, P.E. Operating Permits Unit, Stationary Sources Program Colorado Department of Public Health & Environment APCD-SS-Bl 4300 Cherry Creek Drive South Denver, CO 80246-1530 Re: Modification to Operating Permit Dear Mr. Burgett: C lid`( 11 x1910 May 6, 2010 Carestream Health Colorado (CHC) would like to request Construction Permit 10WE1279 be incorporated into our Operating Permit 06OPWE288 as part of the Title V Permit Renewal Application submitted October 28, 2008 and amendment submitted May 21, 2009. To enable the incorporation into our Operating Permit, the following forms/documents are included in this package: > 2000-300 > 2000-600 > 2000-601 > 2000-603 > 2000-800 > APEN for boilers > Copy of Construction Permit 10WE1279 If you have any questions regarding these amendments, please contact Karen Murphy, at karen.murphyl@carestreamhealth.com or (970) 304-4619. Sincerely, - -eje)P4-e7-<_ Michael S. Haas Site Manager Carestream Health Colorado Division 2000 Howard Smith Ave West Windsor, CO 80550 cc: Karen M. Murphy COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 10WE1279 DATE ISSUED: APRTT, 15, 2010 ISSUED TO: Kodak Colorado Division THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas & fuel oil fueled boilers supplying steam for manufacturing operations located at 9952 Eastman Park Drive, Windsor, Weld County, Colorade. THE. SPECIFIC EQUIPMENT OR' ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Combustion sources at this facility as detailed below: AIRS PT ID Equipment ID Description 123/0003/050 C-70 Boilers Two (2) Make`_ Babcock & Wilcox, Model: N/A, Serial Number NB23915 & NB23916, Natural gas fueled, steam boilers rated at 206 MMbtu/hour each. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF. THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: Within one hundred and eighty days (180) after commencement of operation; compliance with the conditions contained on this permit shall be demonstrated to the Division, tt is the permittee's responsibility to self certify compliance with the conditions. Failure to demonstrate compliance within 180 days, may result in revocation of the permit. *(Information on how to certify compliance was mailed.with•the permit) The permit number (for example, "APCD Permit No. 10WE1279") shall be marked on the subject equipment for ease of identification. (Reference.. Regulation No: 3, Part B, Section III.E.) (State only enforceable) Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment -visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Opacity shall be measured by EPA Method 9. (Reference: Regulation No. 1, Section ILA_1. &.4. '12310003!050 • Kodak Colorado Division Permit No. 10WE1279 initial Approval Page 2 Colorado Department of Public Health and Environment Air Pollution Control Division 4_ This source shall be limited to a maximum raw material process rate or fuel use rate as listed below`and all other activities, operational rates and numbers of equipment as stated in the application. Monthly records of the actual consumption rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, Section II:A:4.) Consumption of natural gas fuel shall not exceed 1,203.7 MMscf per year. Consumption of fuel oil shall not exceed 82,500 gallons per year. Compliance with the yearly consumption limits shall be determined on a rolling twelve (12) month total_ 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary. analysis): Compliance with the annual limits shall be determined on a roiling (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly emissions and keep a compliance record on site for Division review_ (Reference. Regulation No. 3, Part B, Section 11A.4) Particulate Matter. PM10 (Particulate Matter<10 gm): Nitrogen Oxides: Volatile Organic Compounds: Carbon Monoxide: 4.66 tons per year. 4.62 tons per year_ 133.40 tons per year. 3.32 tons per year. 96.50 tons per year. No owner or operator shall cause or permit to be emitted into the atmosphere from any fuel - burning equipment, particulate matter in the flue gases which exceeds the following (Reference: Regulation No. 1, ;III.A.1.b): -0.26 PE=0.5(FI)' there: PE = Particulate Emission in Pounds per million BTU heat input. Fl = Fuel -Input .in Million BTU per hour. Existing oil -fired sources of sulfur dioxide shall not emit sulfur dioxide in excess of the following process -specific limitations. (Heat input rates shall be the manufacturers guaranteed maximum :..heat input rates) (Reference: Regulation No, 1, VI A.3.b_(i)): 1,5 pounds of sulfur dioxide per million BTU of heating input. 8. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, Section 11.O.) Annually whenever a significant increase in"emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five 123/0003/050 ver. 2 . • Kodak Colorado Division Permit No_. 10WE1279 Initial Approval Page 3 Colorado Department of Public Health and Environment Air Pollution Control Division tons per year or more, above the level reported on the last APEN submitted; or For VOC and nitrogen oxide sources in an ozone non -attainment area emitting less than 100 tons of VOC or nitrogen oxide per year, a change in actual emissions of one ton per year or more or five percent, whichever is greater, above the level reported on the last APEN submitted; or • For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or . Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or No later than 30 days before the existing APEN expires. Matthew S. Burgett, P.E. Permit Review Engineer Permit History: R K Hancdck Ill, RE_ Construction Permits Unit Leader Date Action Description This issuance IA Initial Approval 10WE1279 issued to Kodak Colorado Division.' 06/04/2004 IA Boilers covered under Kodak Colorado Division's Initial Approval construction permit 96WE473. 09/01/1999 OP . Boilers covered under Kodak Colorado Division's Operating Permit 96OPWE128. 03/2711987 FA Boilers covered under Kodak Colorado Division's emission permit '10WE375. 03/06/1974 Authority to Construct Boilers covered under Authority to Construct permit C-10, 375. ' ' Kodak Colorado Division Permit No. 10WE1279 initial Approval Page 4 Notes to Permit Holder: Colorado Department of Public Health and Environment Air Pollution Control Division 1) The'production or raw material processing limits and emission limits contained in this permit are based on the production/processing rates requested in the permit application. These limits may be -revised upon request of the permittee providing there is no exceedence.of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (ADEN) and application form must be submitted with a request for a permit revision. 2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1, of the Common Provisions Regulation. See: http:/lwww. cdphe,state.co. uslregulationstairregs/100102agcccommonprovisionsreg. pdf 3) This source is subject to the provisions of Regulation No. 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The application for the Operating Permit is due within one year of permit issuance. 4} The emission levels contained in this permit are based on the following emission factors from AP- 42 1,4 (7/98), Stack Testing (4/2005), and AP -42 1.3 (9/98): Natural Gas: Particulate Matter: PMIto (particles less than 10 microns): Volatile Organic Compounds: Nitrogen Oxides: Sulfur Oxides: Carbon Monoxide: Formaldehyde: Hexane:' Fuel Oil`: Particulate Matter. PM10 (particles less than 10 microns): Volatile Organic Compounds: Nitrogen Oxides: Sulfur Oxides: Carbon Monoxide: Formaldehyde: 5) This source is classified as a: 7.6 pounds per mmscf 7,6 pounds per mmscf 5.5 pounds per mmscf .220 pounds per mmscf 0.6 pounds per mmscf 160 pounds per mmscf 7.5e-2 pounds per mmscf 1"_8 pounds per mmscf 2 pounds per 1 000 gal 1 pounds per 1000 gal 0.2 pounds per 1000 gal 24 pounds per 1000 gal, 5.68 pounds per 1000 gal 5 pounds per 1000 gal 3.30e-2 pounds per 1000 gal Major Stationary Source New Source Review applicability MajorStationary Source for Prevention of Significant Deterioration (PSD) applicability Major Source for Title V.operating permit applicability Major Facility Kodak Colorado Division Permit No_ 10WE1279 Initial Approval Page 5 Colorado Department of Public Health and Environment Air Pollution Control Division :. GENERAL TERMS AND CONDITIONS: (IMPORTANT€ READ ITEMS 5,6,7 AND 8) This permit is issued: in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon conduct of. the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the applicant or applicant's 'agents. It is valid Only for the equipment and operations or activity specifically identified on the permit. 2. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions ofSection 25-7 114.5(7)(a), C.R.S. 3. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of, a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab'irrtfo: This permit may be revoked at any time prior to final approval by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit.. If the Division denies a permit, conditions imposed upon a permit are contested by the applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. This permit and any required attachments must be retained and made available for inspection upon request at the location set forth herein. With respect to a portable source that is moved to a new location, a copy of the Relocation Notice (required by law to be submitted to the APCD whenever a portable source is :relocated) should be attached to this permit. The'permit may be reissued to a new owner by the APCD as • provided in AQCC Regulation No. 3, Part. B, Section 11B. upon a request for transfer of ownership and the 1.submittal of a revised APEN and the required fee_ Issuance (initial approval),of an emission permit does not provide "final" authority for• this activity or operation of this source, final approval ofthe'permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C,R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final approval cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the, permit. If the APCD so determines, it will provide written documentation of such final approval, which does constitute "final" authority to operate. Compliance with the permit conditions must be demonstrated within 180 days after commencement of operation. THIS' PERMIT AUTOMATICALLY EXPIRES IF you (1) do not commence construction Of operation within 18 months after either the date of issuance of this permit or the date on which such construction or activity was scheduled to commence as set forth_in the permit, whichever is later; (2) discontinue construction for a period of 1a months Or more; or (3) do not complete construction within e reasonable time of the estimated completion date_ • Extensions o€ the expiration date may be granted by the APCD upon a showing of good cause by the perrnittee prior to the expiration date: YOU -MUST notify the APCD no later than thirty days after commencement of the permitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to do.so is a violation of AQCC Regulation No. 3, Part B, Section lll.G.1., and can result in the revocation of the permit. You must demonstrate compliance with the permit conditions within 180 days after 'commencement of operation as stated in condition 5. Section 25-7-1'14.7(2)(x), C.R.S.. requires that all sources'required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner; must notify the Division in writing requesting a cancellation of the permit. ,,Uponnotifiration, annual fee billing will terminate Violation of the'terms of a perrnitor of the-provisians of the Colorado Air Pollution Prevention and control Act or the regulations of the AQCC may result in administrative; civil or criminalenforcement actions under Section's 2527415 (enforcement)., 121.(injunctions); -172 (civil penal₹ies), -122.'1 (criminal penalties), C.R.S.' AIR POLLUTANT EMISSION NOTICE (APEN) ._Application for Construction Permit — General Permit Number: 0 6OPWE2 8 8 [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 12:77 1 V P Facility Equipment ID: C-70 Boilers (#7 1 & 72) [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 01— Administrative Information Company Name: Carestream Health, INC. Source Name: C-70 Boilers Source Location: 2 0 0 0 Howard Smith Ave West Portable Source Home Base: Windsor, CO 80550 1,O NAICS, or SIC Code: 3861 County: Elevation: • Weld Mailing Address: 2000 Howard Smith Ave West ZIP Code: 80550 Person To Contact: Windsor, CO Karen Murphy E-mail Address: karen.murphylacarestreamhealth.com Section 03 — General Information For existing sources, operation began on: Normal Hours of Source Operation: General description of equipment and purpose: Phone Number: Feet (970)304-4619 Fax Number: (970) 392-3434 2 4 hours/day Section 02 — Requested Action (check applicable request boxes) Request for NEW permit or newly reported emission source Request PORTABLE source permit ❑ Request MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change permit limit O Change company name • Transfer of ownership ❑ Request to limit HAPs with a Federally enforceable limit on PTE O Request APEN update only (check the box below that applies) ❑ Revision to actual calendar year emissions for emission inventory Update 5 -Year APEN term without change to permit limits or previously reported emissions 0 Additional Info. & Notes: ❑ Other 1?( -61/ v a. L ��s�� J to e X231 W °3 I boo Ale2,11 Transfer of Ownership May 1 ,2010 For new or reconstructed sources, the projected startup date is: 7 days/week 52 weeks/year Will this equipment be operated in any NAAQS nonattainment area? (httn://www.cdplie.state.co.us/ap/attainmaintain.html) ® Yes ❑ No ❑ Section 04 — Processine/Manufacturint=- Equipment Information & Material Use Description of equipment': Manufacturer: Model No.: Serial No.: Don't know Description Actual Level (For Data Year) Annual Requested Permitted Level'. _ (Specify Units) Design Process Rate (Specify Units/Hour) Raw Materials: Finished Products: Other Process: 'If additional space is required, please attach a separate list of equipment, materials and throughputs. 'Requested values will become permit limitations. Requested level should consider process growth over the next five years. J 44.1),;;;4 410 (PCL FORM APCD-200 Page 1 of 2 Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for $152.90 to: Colorado Department of Public It AliE APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 JUN 1 4 2010 For guidance on how to complete this APEN form: ® Air Pollution Control Division: i p j � 180 SPo Small Business Assistance Prog am (SBAP): (303) 692-3148 or (303) 692-3175 APEN forms: http://www.cdphe.state.co.us/an/downloadforms.html Application status: http://www.cdphe.state.co.us/anississucpt.html ❑ Check box to request copy of draft permit prior to issuance. ❑ Check box to request copy of draft permit prior to public notice. 123-6350-004—APEN-2010-05-11-01 Z AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Permit Number: 0 6OPWE2 8 8 Emission Source AIRS ID: Section 05 — Emission Release Information (Attach a separate sheet with relevant information in the event of multiple releases; provide datum & either Lat/Long or UTM) Operator Stack ID No. Base Elevation (feet) Discharge Height Above Ground Level (Feet) Temp, ('F) Flow Rate (ACFM) Velocity (ft/sec) Moisture (%) Horizontal Datum (NAD27, NAD83, WGS84) UTM Zone (12 or 13) UTM Easting or Longitude (meters or degrees) UTM Northing or Latitude ree (meters or degrees) Method of Collection for Location Data (e.g. ma GPS, GoogleEarth) p' g ) 4,800 200 [ -104.867108 40.453550 GoogleEarth Direction of outlet (check one): IJ Vertical ❑ Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): ® Circular: Inner Diameter (inches) = 132 Section 06 — Combustion Equipment & Fuel Consumption Information Company equipment Identification No.: 71 & 72 Boilers Manufacturer: O Horizontal El Down ❑ Other: Length (inches) = Babcock & Wilcox Model: ❑ Other (Describe): Width (inches) = Serial No.: NB23915 3 915 & NB23916 3 916 Fuel Type Design Input Rate (10 Btu/hr) Actual Level (For Data Year) Annual Requested Permitted Level2 (Specify Units) Fuel Heating Value (Indicate:, Btu/lb, Btu/gal, Btu/SCF) Percent by Weight Seasonal Fuel Use (% of Annual Use) Sulfur] Ash = Dec -Feb Mar -May Jun -Aug Sep -Nov Natural Gas 206 2009 1203.7 MMscf/yr 1050 Btu/scf 28 25 25 22 'Requested values will become permit limitations. Requested level should consider process growth over the next five years. Section 07 — Emissions Inventory Information & Emission Control Information Attach any emission calculations and emission factor documentation to this APEN form. ❑ Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput above (e.g. 2007): Pollutant Control Device Description Overall Collection Eticiency Control Efficiency E u ( /o Reduction) Emission Factor Actual Calendar ar Year ; a Emissions • Requested Permitted Emissions a Estimation Method or. Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled (Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) TSP 7.6 lbs/MMscf 4.66 AP -42 PMio 7.6 lbs/MMscf 4.62 AP -42 PM25 SOx NOx 220 lbs/MMscf 133.40 2005 Stack Test VOC '5.5 lbs/MMscf 3.32 AP -42 CO 160 lbs/MMscf 96.50 2005 Stack Test Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Annual emission fees will be based on actual emissions reported here. If left blank, annual emission fees will be based on requested emissions If Requested Permitted Emissions is left blank, the APCD will calculate emissions based on the information supplied in sections 03 - 07. * Represents Natural Gas Emission Factors ** Include Natural Gas & #2 Fuel emissions Section 08 —Applicant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. CaYestream Health Colorado Signature of Person Legally Authorized to Supply Data] % C< Date Michael S. Haas Name of Legally Authorized Person (Please print) Title Site Manager Page ? rf 2 Form APCD-200 - General APEN - Ver 9-10-2008.doc )perating Permit Application BOILER OR FURNACE OPERATION Colorado Department of Public Health and Environment Air Pollution Control Division SPE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Carestream Health Colorado FORM 2000-300 09-94 2. Facility identification code: CO 1236350 3. Stack identification code: 4. Unit code: #71 & #72 5. Unit description: Two (2) Babcock & Wilcox natural gas fueled, steam boilers rated at 206 mmBTU/hour each. 6. Seasonal Fuel Usage(%) Dec -Feb: 28 Mar -May: 25 Jun -Aug: 25 Sep -Nov: 22 7. Normal Operation Hours/Day: 24 of Unit Days/Week: 7 Hours/Year: 365 8. Space Heat(%) 9. Indicate the boiler/furnace control technology status. ® Uncontrolled ❑ Controlled If the boiler/furnace is controlled, enter the control device number(s) from the appropriate forms: 2000-400 2000-401 2000-402 2000-403 2000-404 2000-405 2000-406 2000-407 10. Furnace type: N/A 11. Max continuous rating(mmBTU/hr): 206 each unit 12. Manufacturer: Babcock & Wilcox 13. Model & Serial #: Serial #NB23915 & NB23916 14. Date first placed in service: 00/00/1973 Date of last modification: 00 15. Fuels and firing conditions: Primary fuel Backup fuel #1 Backup fuel #2 Fuel name Natural Gas #2 Fuel Higher heating value (with units) 10 5 0 BTU/scf 13 7 , 0 0 0 BTU/gal Maximum sulfur content (Wt.%) 0 . 04 Maximum ash content (Wt.%) Eke6St Combustion Air OR;°%%O2 (Circle c} oice = ;> > ; ."rteti '* Moisture content (as fired) (°�O : r i ;ta N ' -r �s"rry.; ,u. �^ �' ttx a _ fib , Maximum hourly fuel usage (units/hr.) Actual annual fuel usage for l9 ***** For this emissions unit, identify the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. ***** * * * Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. 1 BOILER OR FURNACE OPERATION -- Form 2000-300 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. This is a supplemental form for use only when necessary to provide comple`" information in the operating permit application. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. Complete one form for each boiler or furnace with regulated emissions. Item 1 , Provide the name of the facility. Item 2 Provide the facility identification (FID) code. Item 3 Provide the identification code for the stack exhausting this boiler or furnace. Use the same code used on form 2000-200. Item 4 Assign an identification code to this boiler or furnace (e.g., B021). Item 5 Provide a brief description of this unit. Identify any special features designed to provide reduced emissions (e.g. low NOX burners, steam injection, etc.) Use Form 2000-700 as needed for additional information. Item 6 Report the seasonal fuel usage by quarter. Total usage must equal 100 %. Item 7 Report the normal operating hours for the boiler or furnace, NOT for the general plant. Item 8 The space heating is the percent of the annual fuel use by this combustion unit attributed to space heating needs. Item 9 If this boiler or furnace is controlled, assign a control device code (e.g., C30) to the air pollution control device associated with it. Use this code on the appropriate form(s) 2000-400 through -407. Enter the code after the form number here also. Item 10 State the type of furnace in terms of the firing configuration (e.g., cyclone, spreader stoker, fluidized bed, etc.). Item 11 The maximum continuous rating of the furnace refers to the furnace's ability to sustain a maximum heat input for three hours. Provide the rating (in million BTU per hour). Item 12 Provide the boiler or furnace manufacturer. If it is unknown, write "unknown". Item 13 Provide the boiler or furnace model number and serial number. If it is unknown, write "unknown". Item 14 Record the date the unit was first placed in service and the date of the last modification of the emissions unit that might have affected the air pollutant emissions. Provide the month and day if possible. Write in "00" if unknown (e.g., 00/00/56). Item 15 Complete the table for all fuels presently used with this boiler or furnace, plus all fuels desired for use in alternative operating scenarios that don't require physical changes to the boiler to accommodate the fuels. In other words, identify those fuels presently fired in the boiler (primary and backup fuels) as well as fuels of future interest that could be burned without modifying the boiler. If a facility presently operates a gas -only boiler and wants the capability to burn heavy oil in the future, the facility will need to obtain a construction permit to make the modification because a physical change to the boiler - adding a fuel oil burner - would be required to accommodate the heavy oil. Please attach Form 2000-700 if needed to explain alternative scenarios for the unit. The maximum sulfur and ash percentage is referring to the maximum of the normal range for the fuel supply being used. Note: For "excess combustion air", provide the percent oxygen (O2) in the flue gas, if known, typically observed during the firing of each fuel listed in the table. If flue gas O2 is not known, provide the furnace excess air as the percent above stoichiometric (i.e., 20 percent excess air is equivalent to 120 percent theoretical air, where "theoretical air" means the amount of combustion air exactly sufficient to completely combust the fuel in perfect (i.e., theoretical) combustion conditions. For natural gas combustion, 5 - 10 percent excess air is typical, and for stoker coal combustion, 30 - 50 percent excess air is a typical range. Circle which value is being reported. 2 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment \ir Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 09-94 1. Facility name: Carestream Health Colorado 2. Facility identification code: CO 1236350 3. Stack identification code: 4. Unit identification code: #71 & #72 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached ❑ Air pollutant Actual,. Potential to emit Maximum allowable Quantity. U . ;` TPY. °= U TPY Particulates (TSP) PM -10 N/A TPY 4.66 N/A TPY 4.62 Nitrogen oxides N/A TPY 133.40 Volatile organic compounds N/A TPY 3.32 Carbon monoxide N/A TPY 96.50 Lead N/A TPY N/A Sulfur dioxide N/A TPY 0.60 ital reduced sulfur N/A TPY N/A Reduced sulfur compounds N/A TPY N/A Hydrogen sulfide N/A TPY N/A Sulfuric Acid Mist N/A TPY N/A Fluorides N/A TPY N/A TPY TPY TPY TPY Units (U) should be entered as follows: 1 = lb/hr 2 = Ib/mmBTU 3 = grains/dscf 4 = lb/ gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 3 = other (specify) 9 = other (specify) 10 = other (specify) 3 EMISSION UNIT CRITERIA AIR POLLUTANTS -- Form 2000-601 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permits. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. Item 1 Provide the name of the facility. Item 2 Provide the facility identification (FID) code. Item 3 Provide the identification code of the stack that exhausts this equipment. Use the same code used on form 2000-200. Item 4 Provide the identification code from the appropriate form(s) 2000-300, -301, -302, -303, -304, -305, -306, or -307 completed for the emissions unit that will have its emissions summarized on this form. Item 5 Provide the emission levels for each listed pollutant emitted from this source. The emissions should be presented using the same units as the applicable limits shown on Form 2000-604 and in tons per year (TPY). The list of footnotes found in the lower left corner of this form allows the applicant to specify the units of each reported emission level. To specify the appropriate units, write the appropriate footnote number in the columns headed by the letter "U". For example: to indicate an emission rate of 3.2 lbs SO2/MMBTU, write Sulfur dioxide 3.2 2 on the line for sulfur dioxide (SO2). Potential to emit should represent emissions at full production capacity of the source after reduction by any air pollution control equipment. This is normally 24 hours/day for 365 days/year (i.e., 8760 hours/year), although physical or operational limitations that are in a construction permit issued by the Division, or in the applicable emission control regulation, are considered in determining the potential to emit. Please see the instruction manual for the precise definition of "potential to emit." You may want to use emission factors to determine these emissions. Maximum allowable emissions should represent the greatest amount of emissions allowed under any permit or applicable standards, taking into consideration the equipment limitations, such as line speed, and pollution control efficiencies of the equipment. In cases where the emission unit has a construction permit, the maximum allowable emissions are equal to the potential to emit. Please remember to: Report hazardous air pollutants on Forms 2000-600 and 2000-602. State the reference(s) for the calculations. Emission factors may be compiled in published documents, such as EPA's AP -42, or may be based on stack test results. A separate page of numbered references is appropriate and may be attached to form 2000-601. Form 2000-700 may be used for this purpose. 4 Operating Permit Application Colorado Department of Public Health and Environment air Pollution Control Division jEE INSTRUCTIONS ON REVERSE SIDE PLANT -WIDE CRITERIA AIR POLLUTANTS FORM 2000-603 09-94 1. Facility name: Carestream Health 2. Facility identification Colorado code: CO 1236350 3. Complete the following emissions summary for the listed emissions at this facility. Air pollutant Actual Potential to emit Maximum allowable TPY TPY TPY Particulates (TSP) n/a 19.66 PM -10 n/a 19.62 Nitrogen oxides n/a 133.40 Volatile organic compounds n/a 51.62 Carbon monoxide n/a 96.50 Lead n/a n/a Sulfur dioxide n/a 0.60 Total reduced sulfur n/a n/a Reduced sulfur compounds n/a n/a Hydrogen sulfide n/a n/a Sulfuric acid mist , n/a n/a Fluorides n/a n/a 5 PLANT -WIDE CRITERIA AIR POLLUTANTS -- Form 2000-603 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permits. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. Item 1 Provide the name of the facility. Item 2 Provide the facility identification (FID) code. Item 3 Provide the emission levels in tons per year (TPY). For each pollutant emitted from the facility, sum the annual actual, potential to emit, and the maximum allowable emission rates (tons per year only) reported for all of the facility's emission units. The individual values are on each Form 2000-601 completed for the application. The totals for each pollutant should be reported on Form 2000-603 in tons per year (TPY). ***** Hazardous air pollutant emissions should be reported on Forms 2000-600 and 2000-602. ***** 6 Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 Colorado Department of Health Air Pollution Control Division Facility Name: Carestream Health Colorado Facility Identification Code:CO 1236350 ADMINISTRATION 09-94 This application contains the following forms: O Form 2000-100, Facility Identification O Form 2000-101, Facility Plot Plan O Forms 2000-102, -102A, and -102B, Source and Site Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler, printing 0 Form 2000-200, Stack Identification @ Form 2000-300, Boiler or Fumace Operation 1 0 Form 2000-301, Storage Tanks ❑ Form 2000-302, Internal Combustion Engine ❑ Form 2000-303, Incineration 0 Form 2000-304, Printing Operations 0 Form 2000-305, Painting and Coating Operations • Form 2000-306, Miscellaneous Processes ❑ Form 2000-307, Glycol Dehydration Unit III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following forms: 0 Form 2000-400, Miscellaneous ❑ Form 2000-401, Condensers ❑ Form 2000-402, Adsorbers 0 Form 2000-403, Catalytic or Thermal Oxidation 0 Form 2000-404, Cyclones/Settling Chambers ❑ Form 2000-405, Electrostatic Precipitators ❑ Form 2000-406, Wet Collection Systems ❑ Form 2000-407, Baghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION Total Number of This Form - This application contains the following forms (one for each facility boiler, printing operation, 0 Form 2000-500, Compliance Certification - Monitoring and Reporting ❑ Form 2000-501, Continuous Emission Monitoring ❑ Form 2000-502, Periodic Emission Monitoring Using Portable Monitors ❑ Form 2000-503, Control System Parameters or Operation Parameters of a Process ❑ Form 2000-504, Monitoring Maintenance Procedures ❑ Form 2000-505, Stack Testing -. ❑ Form 2000-506, Fuel Sampling and Analysis - ❑ Form 2000-507, Recordkeeping 0 Form 2000-508, Other Methods 7 V: EMISSION SUMMARY AND COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan ❑ Form 2000-600, Emission Unit Hazardous Air Pollutants • Form 2000-601, Emission Unit Criteria Air Pollutants 1 ❑ Form 2000-602, Facility Hazardous Air Pollutants • Form 2000-603, Facility Criteria Air Pollutants 1 ❑ Form 2000-604, Applicable Requirements and Status of Emission Unit ❑ Form 2000-605, Permit Shield Protection Identification ❑ Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule ❑ Form 2000-607, Plant -Wide Applicable Requirements ❑ Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule "VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief the statements and information contained in this application are true, accurate and B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE formed after reasonable inquiry, I certify that complete. CONDITIONS (check one box only) is fully in compliance with all applicable is fully in compliance with all applicable any false material statement, representation, misdemeanor and may be punished in /1 I certify that the facility described in this air pollution permit application requirements. ❑ I certify that the facility described in this air pollution permit application requirements, except for the following emissions unit(s): (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes or certification in, or omits material information from this application is guilty of a accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Michael S. Haas Title Site Manager, Carestream Health Colorado Signature W Date Signed Si‘//0 Operating Permit Application Colorado Department of Health -ollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 09-94 Facility Name: Facility Identification Code: CO VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief the statements and information contained in this application are true, accurate and B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY O I certify that the facility described in this air pollution permit application requirements. ❑ I certify that the facility described in this air pollution permit application requirements, except for the following emissions unit(s): formed after reasonable inquiry, I certify that complete. CONDITIONS (check one box only) is fully in compliance with all applicable is fully in compliance with all applicable any false material statement, representation, ...,;_ misdemeanor and may be punished in (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes certification in, or omits material information from this application is guilty of a accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B I 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 9 MAJOR SOURCE OPERATING PERMIT APPLICATION APPLICATION COMPLETENESS SUMMARY FORM 1. FACILITY NAME: 3. REVIEW ENGINEER: 4. DATE OF APPLICATION: I. IDENTIFYING INFORMATION II. EMISSIONS III. APPLICABILITY IV: COMPLIANCE 2. PERMIT: 5. DATE RECEIVED BY APCD COMPLETENESS DETERMINATION COMPLETE _ INCOMPLETE COMPLETE _ INCOMPLETE _ COMPLETE INCOMPLETE NOT APPLICABLE NOT APPLICABLE NOT APPLICABLE COMPLETE _ INCOMPLETE _ NOT APPLICABLE APPLICATION FORM CERTIFIED FOR TRUTH, ACCURACY, AND COMPLETENESS BY: _ OFFICIAL TITLE _ SIGNATURE _ DATE APPLICATION EVALUATION COMPLETE (BASIC INFORMATION PRESENT TO BEGIN PROCESSING) _ INCOMPLETE - RETURN WITH ADDITIONAL INFORMATION BY: COMMENTS REVIEWED BY: DATE 10 MAJOR SOURCE OPERATING PERMIT APPLICATION APPLICATION COMPLETENESS CHECK LIST DENTIFYING INFORMATION A. FACILITY INFORMATION FACILITY NAME, LOCATION & MAILING ADDRESS PERMIT CONTACT PERSON RESPONSIBLE OFFICIAL COMPLETE _ INCOMPLETE _ NOT APPLICABLE PERMIT REQUESTED B. SOURCE DESCRIPTION 1. OPERATIONAL INFORMATION: SIC/SCC CODES LISTING AND DESCRIPTION OF EMISSION SOURCE(S) YES NO YES NO YES NO YES NO YES _ NO _ YES _ NO _ YES _ NO 2. IDENTIFICATION AND DESCRIPTION OF ALTERNATIVE OPERATIVE SCENARIOS (IF APPLICABLE) _ YES _ NO _ N/A C. PERMIT SHIELD REQUESTED II. EMISSIONS A. EMISSIONS INFORMATION COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. QUANTIFICATION OF ALL EMISSIONS OF REGULATED AIR POLLUTANTS 2. EMISSION SOURCES: IDENTIFICATION AND DESCRIPTION OF ALL EMISSION SOURCES IN SUFFICIENT DETAIL TO ESTABLISH THE BASIS FOR FEES AND APPLICABILITY OF REQUIREMENTS. A LIST OF INSIGNIFICANT EMISSIONS UNITS OR ACTIVITIES EXEMPTED BECAUSE OF SIZE OR PRODUCTION RATE. YES NO _ YES _ NO YES _ NO YES _ NO _ N/A 4. PROCESS INFORMATION TO THE EXTENT IT IS NEEDED TO DETERMINE OR REGULATE EMISSIONS: FUELS 'RAW MATERIAL(S) / MATERIALS USED PRODUCTION RATES 5. FOR REGULATED AIR POLLUTANTS, LIMITATIONS ON SOURCE OPERATIONS AFFECTING: EMISSIONS ANY WORK PRACTICE STANDARDS 6. OTHER INFORMATION REQUIRED BY ANY APPLICABLE REQUIREMENTS FOR ALL REGULATED AIR POLLUTANTS SUCH AS: FLOW RATES STACK PARAMETERS 7. CALCULATIONS ON WHICH EMISSIONS RELATED INFORMATION ARE BASED _ YES _ NO _ N/A _ YES _ NO _ N/A YES _ NO _ N/A YES NO N/A YES NO N/A YES NO N/A YES NO N/A YES NO N/A 11 III. APPLICABILITY _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. CITATION AND DESCRIPTION OF ALL APPLICABLE REQUIREMENTS _ YES _ NO 2. OTHER SPECIFIC INFORMATION THAT MAY BE NECESSARY TO IMPLEMENT AND ENFORCE OTHER _ YES _ NO APPLICABLE REQUIREMENTS OR TO DETERMINE THE APPLICABILITY OF REQUIREMENTS 3. AN EXPLANATION OF ANY PROPOSED EXEMPTIONS FROM OTHERWISE APPLICABLE REQUIREMENTS _ YES _ NO _ N/A IV. COMPLIANCE _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE A. COMPLIANCE STATUS 1. A DESCRIPTION OF THE COMPLIANCE STATUS OF THE SOURCE WITH RESPECT TO ALL _ YES _ NO APPLICABLE REQUIREMENTS 2. FOR APPLICABLE REQUIREMENTS WITH WHICH THE SOURCE IS IN COMPLIANCE, A STATEMENT _ YES _ NO THAT THE SOURCE WILL CONTINUE TO COMPLY WITH SUCH REQUIREMENTS 3. FOR APPLICABLE REQUIREMENTS THAT WILL BECOME EFFECTIVE DURING THE PERMIT TERM, _ YES _ NO _ N/A A STATEMENT THAT THE SOURCE WILL MEET SUCH REQUIREMENTS ON A TIMELY BASIS 4. FOR REQUIREMENTS FOR WHICH THE SOURCE IS NOT IN COMPLIANCE AT THE TIME OF _ YES _ NO _ N/A PERMIT ISSUANCE, A NARRATIVE DESCRIPTION OF HOW THE SOURCE WILL ACHIEVE COMPLIANCE WITH SUCH REQUIREMENTS 5. IDENTIFICATION AND DESCRIPTION OF AIR POLLUTION CONTROL EQUIPMENT AND COMPLIANCE YES _ NO MONITORING DEVICES OR ACTIVITIES 6. DESCRIPTION OF OR REFERENCE TO ANY APPLICABLE TEST METHOD FOR DETERMINING _ YES _ NO COMPLIANCE WITH EACH APPLICABLE REQUIREMENT B. COMPLIANCE SCHEDULE COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. A SCHEDULE OF COMPLIANCE FOR SOURCES THAT ARE NOT IN COMPLIANCE WITH ALL APPLICABLE REQUIREMENTS AT THE TIME OF PERMIT ISSUES _ YES NO N/A 2. A SCHEDULE FOR SUBMISSION OF CERTIFIED PROGRESS REPORTS NO LESS FREQUENTLY . _ YES _ NO _ N/A THAN EVERY SIX MONTHS FOR SOURCES REQUIRED TO HAVE A SCHEDULE OF COMPLIANCE TO REMEDY A VIOLATION C. COMPLIANCE CERTIFICATION _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. CERTIFICATION OF COMPLIANCE WITH ALL APPLICABLE REQUIREMENTS BY _ YES _ NO A RESPONSIBLE OFFICIAL 2. A STATEMENT OF METHODS USED FOR DETERMINING COMPLIANCE, INCLUDING A DESCRIPTION _ YES _ NO OF MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS AND TEST METHODS 3. A SCHEDULE FOR SUBMISSION OF COMPLIANCE CERTIFICATIONS _ YES NO 4. A STATEMENT INDICATING THE SOURCE'S COMPLIANCE STATUS WITH ANY APPLICABLE ENHANCED MONITORING AND COMPLIANCE CERTIFICATION REQUIREMENTS OF THE FEDERAL ACT YES NO 12 arestream HEALTH ftZ April 20, 2009 Matt Burgett, P.E. Operating Permits Unit, Stationary Sources Program Colorado Department of Public Health & Environment, Air Pollution Control Division APCD-SS-Bl 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: Minor Permit Modification Request for Carestream Health, Inc. - Permit #060PWE288 Dear Mr. Burgett: Carestream Health Colorado (CHC) is pursing installing spreader bars and concave bars to the Sensitizing coating machine throughout the drying alley. The purpose of this modification is to allow the manufacturing of a new product line that contains no reportable pollutants under the Clean Air Act. The purpose of these bars is to allow the web to flow through the drying alley in a fashion that will allow CHC to produce a new product. The installation of these bars will not impact the coating of our typical products, nor our current permitted emissions. Therefore, this modification will not increase our current permitted VOC or PM emissions. However, this new product CHC is anticipating coating, will require the use of our corona treaters (CTs), and could potentially increase our ozone emissions. Therefore, we have enclosed a revised Air Pollution Emission Notice (APEN) for the O3 emissions and are requesting 7 tpy to be added to our permit as a maximum annual emission. In addition, Appendix G will require updating for the permitted CTs. No change is necessary for the spreader or concave bars as the dryers are already documented in the equipment list. Appendix A will need to be updated by removing the "C40-Corornal Discharge Treatment" from the insignificant activity list. The following equation is being proposed to account for the CT ozone emissions: Corona Treaters: O3 Emissions = 0.073 lb O3 /kW -hr * (CT1 kW -hr + CT2 kW -hr+ CT3 kW -hr + CT4 kW -hr + CT5 kW -hr) Since this new product contains no hazardous air pollutants (HAPs), there will be no changes in our current Maximum Achievable Control Technology (MACTs) standards nor will we be subject to any additional MACT's. We have also reviewed the New Source Performance Standards (NSPS) and none apply to this source. Please find enclosed the following completed forms and requested Operating Permit Updates: Form APCD-200 Non -Criteria Reportable APEN Addendum Form 2000-306 Form 2000-601 Form 2000-800 CT Process Diagram Operating Permit (Specific Sections with Changes Only): Section I- Specific Permit Terms 1.Facility Wide Limit (table) 1.1 Emission calculations Appendix A - Inspection Information: List of Insignificant Activities Appendix G - Equipment List Should you have any comments or questions, please contact me at 970-304-4619 or Karen.murphy 1 @carestreamhealth.com. Thank you for your consideration. Sincerely K • en M. Murphy Environmental Engineer 2000 Howard Smith Ave West C-42 Windsor, CO 80550 karen. murphy 1 @carestreamhealth.com Enclosures Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division ;EE INSTRUCTIONS ON REVERSE SIDE MISCELLANEOUS PROCESSES FORM 2000-306 Rev 06-95 1. Facility name: Carestream Health Colorado 2. Facility identification code: CO 1236350 3. Stack identification code: N/A 4. Process (Unit) code: CTs 1-5 5. Unit description: Corona Treaters (CTs) 6. Indicate the control technology status. ® Uncontrolled ❑ Controlled If the process is controlled, eater the control device code(s) from the appropriate form(s): 2000-400 2040-401 2000-402 2000-403 2000-404 2000-405 2000-406 2000-407 ,7. annual process ratea, for 8. Date first placed in service: 00 Date of last modification: 00 9. Normal operating schedule: Varies depending on type of product coating. _ hrs./day days/wk. _ hours/yr. I 10. Describe this process (please attach a flow diagram of the process). CTs are used during Attached? ❑ web coating operations. Attached is the CT Process Diagram. 11. List the types and amounts of raw materials used in this process: N/A Material Storage/material handling process 1.ctual=usage - i Units Maximum usage Units Clean-up solvents ;r. Other (specify) �t 12. List the types and amounts of finished products: N/A Material Storage/material handling process Actual amount ror duced uc� d h�� Vents � , . Maximum Units amount produced o-h';�Yt-',.: 13. Process fuel usage: N/A Type of fuel Maximum heat input to process million BTU/hr. Actualusage _ Vic' Units `ri E r , Maximum usage Units } 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc.: N/A * * * * * For this emissions unit, identify the method(s) of compliance demonstration by completing Form 2000-500, * * * * * DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. * * * * * Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. * * * * * MISCELLANEOUS PROCESSES -- Form 2000-306 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. This is a supplemental form for use only when necessary to provide complete information in the operating permit application. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. Complete one form for each regulated miscellaneous process. Item 1 Provide the name of the facility. Item 2 Provide the facility identification (FED) code. Item 3 Provide the identification code for the stack exhausting this process. Use the same code used on form 2000-200. Item 4 Assign an identification code to this process (e.g., P021). Use this code on other forms related to this operation. Item 5 Provide a brief description of this unit. List the manufacturer and model number. Item 6 If this process is controlled, assign a control device code (e.g., C30) to the air pollution control device associated with it. Use this code on the appropriate form(s) 2000-400 through -407. Enter the code after the form number here also. Item 7 Enter the year for which the actual process rates are given in the following. Item 8 Record the date the emission unit was first placed in service and the date of the last modification that may have affected the air pollutant emissions. Provide the month and day if possible. Write in "00" if unknown (e.g., 00/00/56). Item 9 Provide the normal operating schedule. Item 10 Briefly describe the process, including types of operations involved, end product of the process and use of the product. Attach a flow diagram of the process, identifying major pieces of equipment; pickup points for dusts, fumes and vapors; control and collection devices; exhaust stack and vents; where raw materials enter the process; and where finished products exit. Indicate if the process is batch or continuous. Use form 2000-700 for additional information, and mark the box "attached." Item 11 List all of the materials put into the process and the actual and maximum amounts used (in pounds per hour or tons per hour). This is the process weight rate. List any solvents, additives, cleaners, etc. (in gallons per hour or per year) used with this process. If the process produces more than one product, include a list of the raw materials used to produce each product. Describe any storage and materials handling processes. If the process has no "raw materials" per se, write "NA" in each field across the first line of item 11. Item 12 List the types of finished products and the average and maximum amounts produced. Describe any storage and material handling processes. If the process has no "finished products" per se, write "NA" in each field across the first line of item 13. Item 13 List all of the fuels the process uses or is capable of using. Provide the average and maximum amount of fuel used per hour of operation of the process. Provide the maximum heat input capacity for the fuel burner for the process. Provide an analysis of the fuel used, including at a minimum heat content, sulfur content and density. Coal, residual (#5 and #6) oils, sludge, waste oils, refuse derived fuels, etc., will require the submittal of an analysis of hazardous contaminants. Please attach these analyses to this form. If the process uses no process fuels, write "none" under "type of fuel" and "NA" in the remaining fields of the first line of item 12. Item 14 Briefly describe the fugitive sources. Include size of storage piles, material stored, length of roads, and any control measures used. Attach detailed information as appropriate. If you've used this form to describe a source of fugitive emissions, write "see shave." Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-601 09-94 Facility name: Carestream Health Colorado 2. Facility identification code: CO 1236350 3. Stack identification code: N/A 4. Unit identification code: N/A 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached D Air pollutant Actua ; .. Potential to emit Maximum allowable Quanti `. U TY U TPY Particulates (TSP) TPY PM -10 qs }wE fi= K . TPY Nitrogen oxides � � �. . i TPY Volatile organic: compounds E TPY Carbon monoxide - TPY Lead TPY Sulfur dioxide TPY Total reduced sulfurr�Ih£ TPY )duced sulfur compounds TPY Hydrogen sulfide ` `. TPY Sulfuric Acid Mist ra`: TPY Fluorides TPY Ozone y� m��f 7 TPY } TPY TPY TPY Units (U) should be entered as follows: 1 = lb/hr 2 = lb/mmBTU 3 = grains/dscf 4 = lb/ gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 = other (specify) 9 = other (specify) 10 = other (specify) EMISSION UNIT CRITERIA AIR POLLUTANTS -- Form 2000-601 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS 3 NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permits. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. Item 1 Provide the name of the facility. Item 2 Provide the facility identification (FID) code. Item 3 Provide the identification code of the stack that exhausts this equipment. Use the same code used on form 2000-200. Item 4 Provide the identification code from the appropriate form(s) 2000-300, -301, -302, -303, -304, -305, -306, or -307 completed for the emissions unit that will have its emissions summarized on this form. Item 5 Provide the emission levels for each listed pollutant emitted from this source. The emissions should be presented using the same units as the applicable limits shown on Form 2000-604 and in tons per year (TPY). The list of footnotes found in the lower left corner of this form allows the applicant to specify the units of each reported emission level. To specify the appropriate units, write the appropriate footnote number in the columns headed by the letter "U". For example: to indicate an emission rate of 3.2 lbs SO2/MMBTU, write Sulfur dioxide 3.2 2 on the line for sulfur dioxide (SO2). Potential to emit should represent emissions at full production capacity of the source after reduction by any air pollution control equipment. This is normally 24 hours/day for 365 days/year (i.e., 8760 hours/year), although physical or operational limitations that are in a construction permit issued by the Division, or in the applicable emission control regulation, are considered in determining the potential to emit. Please see the instruction manual for the precise definition of "potential to emit." You may want to use emission factors to determine these emissions. Maximum allowable emissions should represent the greatest amount of emissions allowed under any permit or applicable standards, taking into consideration the equipment limitations, such as line speed, and pollution control efficiencies of the equipment. In cases where the emission unit has a construction permit, the maximum allowable emissions are equal to the potential to emit. Please remember to: Report hazardous air pollutants on Forms 2000-600 and 2000-602. State the reference(s) for the calculations. Emission factors may be compiled in published documents, such as EPA's AP -42, or may be based on stack test results. A separate page of numbered references is appropriate and may be attached to form 2000-601. Form 2000-700 may be used for this purpose. 4 Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 Colorado Department of Health Air Pollution Control Division Facility Name: Carestream Health Colorado Facility Identification Code:CO 1236350 ADMINISTRATION 09-94 This application contains the following forms: ❑ Form 2000-100, Facility Identification ❑ Form 2000-101, Facility Plot Plan ❑ Forms 2000-102, -102A, and -102B, Source and Site Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler, printing 0 Form 2000-200, Stack Identification ❑ Form 2000-300, Boiler or Fumace Operation 0 Form 2000-301, Storage Tanks ❑ Form 2000-302, Internal Combustion Engine 0 Form 2000-303, Incineration ❑ Form 2000-304, Printing Operations ❑ Form 2000-305, Painting and Coating Operations Form 2000-306, Miscellaneous Processes 1 0 Form 2000-307, Glycol Dehydration Unit III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following forms: 0 Form 2000-400, Miscellaneous ❑ Form 2000-401, Condensers ❑ Form 2000-402, Adsorbers ❑ Form 2000-403, Catalytic or Thermal Oxidation ❑ Form 2000-404, Cyclones/Settling Chambers ❑ Form 2000-405, Electrostatic Precipitators ❑ Form 2000-406, Wet Collection Systems ❑ Form 2000-407, Baghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the following forms (one for each facility boiler, printing operation, ❑ Form 2000-500, Compliance Certification - Monitoring and Reporting ❑ Form 2000-501, Continuous Emission Monitoring ❑ Form 2000-502, Periodic Emission Monitoring Using Portable Monitors ❑ Form 2000-503, Control System Parameters or Operation Parameters of a Process 0 Form 2000-504, Monitoring Maintenance Procedures ❑ Form 2000-505, Stack Testing ❑ Form 2000-506, Fuel Sampling and Analysis 0 Form 2000-507, Recordkeeping 0 Form 2000-508, Other Methods 5 V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan ❑ Form 2000-600, Emission Unit Hazardous Air Pollutants Form 2000-601, Emission Unit Criteria Air Pollutants 1 e ❑ Form 2000-602, Facility Hazardous Air Pollutants ❑ Form 2000-603, Facility Criteria Air Pollutants ❑ Form 2000-604, Applicable Requirements and Status of Emission Unit ❑ Form 2000-605, Permit Shield Protection Identification ❑ Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule ❑ Form 2000-607, Plant -Wide Applicable Requirements ❑ Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief the statements and information contained in this application are true, accurate and B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE formed after reasonable inquiry, I certify that complete. CONDITIONS (check one box only) is fully in compliance with all applicable is fully in compliance with all applicable any false material statement, representation, misdemeanor and may be punished in /1 I certify that the facility described in this air pollution permit application requirements. ❑ I certify that the facility described in this air pollution permit application requirements, except for the following emissions unit(s): (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes or certification in, or omits material information from this application is guilty of a accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Michael Haas Title Site Manager, Carestream Health Colorado Signature � Date Signed 9/z a/2OO9 6 Operating Permit Application Colorado Department of Health ollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 09-94 Facility Name: Facility Identification Code: CO VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief the statements and information contained in this application are true, accurate and B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY 0 I certify that the facility described in this air pollution permit application requirements. ❑ I certify that the facility described in this air pollution permit application requirements, except for the following emissions unit(s): formed after reasonable inquiry, I certify that complete. CONDITIONS (check one box only) is fully in compliance with all applicable is fully in compliance with all applicable any false material statement, representation, misdemeanor and may be punished in (list all non -complying units) -"ARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes certification in, or omits material information from this application is guilty of a accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-S S -B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 7 MAJOR SOURCE OPERATING PERMIT APPLICATION APPLICATION COMPLETENESS SUMMARY FORM 1. FACILITY NAME: 3. REVIEW ENGINEER: 4. DATE OF APPLICATION: I. IDENTIFYING INFORMATION II. EMISSIONS III. APPLICABILITY IV. COMPLIANCE 2. PERMIT: 5. DATE RECEIVED BY APCD COMPLETENESS DETERMINATION COMPLETE _ INCOMPLETE _ COMPLETE _ INCOMPLETE _ COMPLETE _ INCOMPLETE COMPLETE _ INCOMPLETE _ APPLICATION FORM CERTIFIED FOR TRUTH, ACCURACY, AND COMPLETENESS BY: OFFICIAL TITLE _ SIGNATURE _ DATE APPLICATION EVALUATION COMPLETE (BASIC INFORMATION PRESENT TO BEGIN PROCESSING) INCOMPLETE - RETURN WITH ADDITIONAL INFORMATION BY: COMMENTS REVIEWED BY: DATE NOT APPLICABLE NOT APPLICABLE NOT APPLICABLE NOT APPLICABLE 8 MAJOR SOURCE OPERATING PERMIT APPLICATION APPLICATION COMPLETENESS CHECK LIST IDENTIFYING INFORMATION A. FACILITY INFORMATION FACILITY NAME, LOCATION & MAILING ADDRESS PERMIT CONTACT PERSON RESPONSIBLE OFFICIAL PERMIT REQUESTED B. SOURCE DESCRIPTION 1. OPERATIONAL INFORMATION: _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE SIC/SCC CODES LISTING AND DESCRIPTION OF EMISSION SOURCE(S) _ YES NO YES NO YES NO YES NO YES NO YES NO YES NO 2. IDENTIFICATION AND DESCRIPTION OF ALTERNATIVE OPERATIVE SCENARIOS (IF APPLICABLE) _ YES _ NO _ N/A C. PERMIT SHIELD REQUESTED _ YES _ NO II. EMISSIONS A. EMISSIONS INFORMATION _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. QUANTIFICATION OF ALL EMISSIONS OF REGULATED AIR POLLUTANTS '. EMISSION SOURCES: IDENTIFICATION AND DESCRIPTION OF ALL EMISSION SOURCES IN SUFFICIENT DETAIL TO ESTABLISH THE BASIS FOR FEES AND APPLICABILITY OF REQUIREMENTS. A LIST OF INSIGNIFICANT EMISSIONS UNITS OR ACTIVITIES EXEMPTED BECAUSE OF SIZE OR PRODUCTION RATE. 4. PROCESS INFORMATION TO THE EXTENT IT IS NEEDED TO DETERMINE OR REGULATE EMISSIONS: FUELS RAW MATERIAL(S) / MATERIALS USED PRODUCTION RATES 5. FOR REGULATED AIR POLLUTANTS, LIMITATIONS ON SOURCE OPERATIONS AFFECTING: EMISSIONS ANY WORK PRACTICE STANDARDS 6. OTHER INFORMATION REQUIRED BY ANY APPLICABLE REQUIREMENTS FOR ALL REGULATED AIR POLLUTANTS SUCH AS: FLOW RATES STACK PARAMETERS 7. CALCULATIONS ON WHICH EMISSIONS RELATED INFORMATION ARE BASED YES NO YES NO YES NO N/A YES _ NO _ N/A _ YES _ NO _ N/A YES _ NO _ N/A YES NO N/A YES NO N/A YES NO N/A YES NO N/A _ YES NO N/A 9 III. APPLICABILITY _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. CITATION AND DESCRIPTION OF ALL APPLICABLE REQUIREMENTS _ YES _ NO 2. OTHER SPECIFIC INFORMATION THAT MAY BE NECESSARY TO IMPLEMENT AND ENFORCE OTHER _ YES _ NO APPLICABLE REQUIREMENTS OR TO DETERMINE THE APPLICABILITY OF REQUIREMENTS 3. AN EXPLANATION OF ANY PROPOSED EXEMPTIONS FROM OTHERWISE APPLICABLE REQUIREMENTS _ YES _ NO _ N/A IV. COMPLIANCE COMPLETE INCOMPLETE _ NOT APPLICABLE A. COMPLIANCE STATUS 1. A DESCRIPTION OF THE COMPLIANCE STATUS OF THE SOURCE WITH RESPECT TO ALL _ YES _ NO APPLICABLE REQUIREMENTS 2. FOR APPLICABLE REQUIREMENTS WITH WHICH THE SOURCE IS IN COMPLIANCE, A STATEMENT _ YES _ NO THAT THE SOURCE WILL CONTINUE TO COMPLY WITH SUCH REQUIREMENTS 3. FOR APPLICABLE REQUIREMENTS THAT WILL BECOME EFFECTIVE DURING THE PERMIT TERM, _ YES _ NO _ N/A A STATEMENT THAT THE SOURCE WILL MEET SUCH REQUIREMENTS ON A TIMELY BASIS 4. FOR REQUIREMENTS FOR WHICH THE SOURCE IS NOT IN COMPLIANCE AT THE TIME OF _ YES _ NO _ N/A PERMIT ISSUANCE, A NARRATIVE DESCRIPTION OF HOW THE SOURCE WILL ACHIEVE COMPLIANCE WITH SUCH REQUIREMENTS 5. IDENTIFICATION AND DESCRIPTION OF AIR POLLUTION CONTROL EQUIPMENT AND COMPLIANCE _ YES _ NO MONITORING DEVICES OR ACTIVITIES 6. DESCRIPTION OF OR REFERENCE TO ANY APPLICABLE TEST METHOD FOR DETERMINING _ YES _ NO • COMPLIANCE WITH EACH APPLICABLE REQUIREMENT B. COMPLIANCE SCHEDULE _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. A SCHEDULE OF COMPLIANCE FOR SOURCES THAT ARE NOT IN COMPLIANCE WITH ALL _ YES _ NO _ N/A APPLICABLE REQUIREMENTS AT THE TIME OF PERMIT ISSUES 2. A SCHEDULE FOR SUBMISSION OF CERTIFIED PROGRESS REPORTS NO LESS FREQUENTLY _ YES _ NO _ N/A THAN EVERY SIX MONTHS FOR SOURCES REQUIRED TO HAVE A SCHEDULE OF COMPLIANCE TO REMEDY A VIOLATION C. COMPLIANCE CERTIFICATION _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. CERTIFICATION OF COMPLIANCE WITH ALL APPLICABLE REQUIREMENTS BY _ YES _ NO A RESPONSIBLE OFFICIAL 2. A STATEMENT OF METHODS USED FOR DETERMINING COMPLIANCE, INCLUDING A DESCRIPTION _ YES _ NO OF MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS AND TEST METHODS 3. A SCHEDULE FOR SUBMISSION OF COMPLIANCE CERTIFICATIONS 4. A STATEMENT INDICATING THE SOURCE'S COMPLIANCE STATUS WITH ANY APPLICABLE _ YES _ NO ENHANCED MONITORING AND COMPLIANCE CERTIFICATION REQUIREMENTS OF THE FEDERAL ACT YES NO 10 kir Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 5 Building C-50: Mass balance shall be used to estimate emissions using the following equation: VOC emissions = VOC consumption For thermal degradation byproducts in extruded material: VOC emissions = 64 (lbs VOC/Million lbs extruded) x Extruder Throughput (Millions lbs/month) For pre -polymer byproducts removed by molecular sieve regenerations: VOC emissions = 3.5 (lbs VOC/Regeneration) x Regenerations/month O3 Emissions: Building C-40: Corona Discharge Treaters: O3 Emissions = 0.073 lb O3 /kW -hr * (CT1 kW -hr + CT2 kW -hr + CT3 kW -hr + CT4 kW -hr + CT5 kW -hr) PM/PM10 Emissions: Building C-40, C-41, C-42, C-43, & C-46: For dibutyl phthalate: PM/PM10 Emissions = 1% weight of consumption Building C-50: Railroad Car PET Powder Unloading: PM/PM10 Emissions = 0.01 gr/dscf x 888 dscfm x 8760 hr/yr x 60 min/hr x lb/7000 gr x ton/2000 lb Railroad Car PET Pellet Unloading: PM/PM10 Emissions = PET pellet throughput lb/yr x (1- 0.9999) x 0.005 x ton/2000 lb Three Pellet Grinders (total): 0.02 grief x 1207 cfm x 60 min/hr x 8760 hr/yr x lb/7000 gr x ton/2000 lb Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: November 1, 2004 Last Revised: May 1, 2007 Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 1 APPENDIX A - Inspection Information Directions to Plant: The plant is located in Northern Colorado near the town of Windsor. From Denver, take I-25 North approximately 60 miles and take the Windsor exit East. Follow Highway 392 through the town of Windsor and turn right on Highway 257. After about 1.5 miles, turn left to access the Health Group facility. Safety Equipment Required: - Eye Protection - Safety Shoes - Conductive Shoes - Hearing Protection Facility Plot Plan: Figure 1 (following page) shows the plot plan as submitted on June 16, 1998 with the source's revised Title V Operating Permit Application. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list, activities may have changed since the last filing. Insignificant activities and/or sources of emissions as submitted in the application are as follows: Building C-20 Distribution Center Building C-40, C-41, C-42, C-43, and C-46 C-41-8 - Welding Booth C 10 Coronal Discharge Treatment C -40s — Quality Control and Process Support Labs C-43 — Chemical Storage Areas C-43 — Dry Chemical Weight Station C-46 — Wet Scrubber Building C-50 C-50-73 - Quality Lab C-50 - Regeneration of Molecular Sieve Adsorber C50-51, 50-52, 50-53: Prepolymer Silos Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: November 1, 2004 Last Revised: May 1, 2007 Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix G Page 1 Appendix G Equipment List BUILDING LOCATION AIRS IDENTIFIER EQUIPMENT NUMBER DESCRIPTION C-40, 41, 42, and 43 Melting Rm 152 C40-2 Melting Kettles Coating Machine 153 C40-3 through 10 Dryers Pre -Coat Rm Corona Treaters 5 units Hardener Rm C40-11 Process Vessels Melting Rm C40-12 Melting Vessels 150 C40 Fugitive Emissions SMU C041 SMU (Solution Making Unit) Dye Rms 200 C41-1 Chemical Making Kettles Dye Rms 200 C41-2 Chemical Making Kettles, Filters Dye Rms 201 C41-3 Chemical Making Kettles Misc Gel Rm 202 C41-4 Chemical Making Kettles, Filters Dispersion Rm 204 C41-6 Process Vessel Dispersion Rm 204 C41-7 Process Vessel Emulsion Rms C42-EF426 Chemical and Emulsion Preparation Shop C-50 U -Coat Making Rm 401 C50-11 Doctoring Room Chem Weigh Rm C50-13 Dry Chemical Wei • fling Hood 501 Machine Molecular Sieve Adsorbers 501 Machine Extruder & Clean Scrap Recycle 501 Machine C50-14 No. 1 & 2 Air Sections 501 Machine 402 C50-16 Drafter Heat Section Exhaust 501 Machine C50-17 Drafter Cool Section Exhaust 501 Machine 403 C50-18 Tenter Heat Section Exhaust 501 Machine 404 C50 -21/21A No. 5 Air Section 501 Machine 405 C50-22 No. 6 Air Section 501 Machine 406 C50 -25A 5x and 6x Coating Section 501 Machine C50 -27A No. 8 Air Section C-50 Polymer Area C50-51 Railroad Car PET Powder Unloading F -50 -SS Railroad Car PET Pellet Unloading DF-50 Three Pellet Grinders with associated cyclones and dust collector 407 C50-72 X -Hopper Cleaning Room Jperating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: November 1, 2004 Last Revised: May 1, 2007 Air Pollution Control Division Colorado Operating Permit Permit # 06OPWE288 Carestream Health, Inc. Page 4 SECTION I - Specific Permit Terms 1. Facility Wide Limit See Equipment List, Appendix G Parameter Permit Condition Number Limitation Compliance Emission Factor Monitoring Method Interval VOC 1.1 48.3Tons/Yr See Condition 1.1 Recordkeeping Calculation Monthly O3 1.1 7.0 Tons/Yr PM 1.1 11.8 Tons/Yr PKo 1.1 11.8 Tons/Yr Opacity 1.2 Not to exceed 20%, except as provided for below Nature of the Processes Annually Certain Operating Conditions - Not to exceed 30%, for a period or periods aggregating more than six (6) minutes in any 60 consecutive minutes Consumption 1.3 See Condition 1.3 Recordkeeping Monthly 1.1 Facility -wide emissions shall not exceed the rates listed in the above table (Construction Permit 96WE473). Compliance with annual limits shall be determined on a rolling twelve month total. By the 45th day after the close of each month a new twelve month total shall be calculated using the previous twelve months' data. The permit holder shall calculate monthly emissions using the procedures described below and keep a compliance record on site for Division review. VOC Emissions: Building C-40, C-41, C-42, C-43, & C-46: Except for the separately listed chemicals, mass balance shall be used to estimate emissions using the following equation: VOC emissions = VOC consumption. Note: Dibutyl Phthalate is not emitted as a VOC. Operating Permit Number: 06OPWE288 First Issued: September 1, 1999 Renewed: November 1, 2004 Last Revised: May 1, 2007 (5/18/2009) MATT S Burgett - Re: CT questions Page 1 From: To: Date: Subject: Attachments: KAREN MURPHY<karen.murphy1@carestreamhealth.com> "MATT S Burgett" <msburget@smtpgate.dphe.state.co.us> 5/18/2009 3:50 PM Re: CT questions pic05907.jpg Hi Matt, answers are in bold below. Please let me know if you need further clarification. thanks! Karen M. Murphy, CHMM Environmental Engineer Environmental, Health & Safety karen.murphy1@carestreamhealth.com P 970.304.4619 F 970.392.3434 Carestream Health, Inc. 2000 Howard Smith Ave West C-42 Windsor, CO 80550 (Embedded image moved to file: pic05907.jpg) "MATT S Burgett" <msburget@smtpgat e.dphe.state.co.0 To s> <karen.murphy1@carestreamhealth.com 05/18/2009 03:13 cc PM Subject CT questions Karen, I have a few questions regarding the corona treaters. 1. Are there any stacks associated with the CTs? Exhaust fan #1 and #2 (as shown on process diagram in application) exhaust out of building C40 roof. 2. Where does the emission factor (0.073 lb O3/kW-hr) come from? Pillar Technologies (the manufacturer). 3. What is the maximum kW rating on the CT units? CT 3,4,5 are 10 kW CT 1 is 7.5 and CT 2 10 kw. We can only operate 4 units at any one time. The kW shown on the diagram are the most usable power after efficiency loss. We measure actual power (5/18/2009) MATT S Burgett - Re: CT questions Page 2 being used by PV (process verification) boxes that measure both current and voltage. Matt Burgett, P.E. Permit Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division 303-692-3183 (phone) 303-782-0278 (fax) F(3/13/2009) MATT S Burgett - Re: CHC's air permit - modification question Page 1 From: MATT S Burgett To: MURPHY, KAREN CC: Pusey, David A Date: 3/13/2009 3:45 PM Subject: Re: CHC's air permit - modification question Karen, I talked with Roland about the ozone emissions. You should submit an APEN for the CDTs with an application for a minor mod to your Title V permit. See Reg. 3, Part C, Section X for the minor mod application requirements. Also, RACT does not apply to these units. The Reg. 3 RACT requirement does not mention ozone, and Reg. 7 RACT only applies to VOC. I don't think RACT would be triggered with the sensitizing mod either since it will not result in an emissions increase. Contact me with any questions on what you need to submit for the minor mod. Matt Burgett, P.E. Permit Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division 303-692-3183 (phone) 303-782-0278 (fax) >>> KAREN MURPHY <karen.murphyl@carestreamhealth.com> 3/12/2009 8:57 AM >>> Matt, Dave and I will call you tomorrow at 1:30 pm your office. Greatly appreciated! Karen M. Murphy, CHMM Environmental Engineer Environmental, Health & Safety karen.murphy1@carestreamhealth.com P 970.304.4619 F 970.392.3434 Carestream Health, Inc. 2000 Howard Smith Ave West C-42 Windsor, CO 80550 (Embedded image moved to file: pic20242.jpg) "MATT S Burgett" <msburget@smtpgat e.dphe.state.co.0 To s> "KAREN MURPHY" <karen.murphv1@carestreamhealth.com 03/12/2009 08:51 > AM cc "David A Pusey" (3/13/2009) MATT S Burgett - Re: CHC's air permit - modification question Page 2 <david.pusey@carestreamhealth.com> Subject Re: CHC's air permit - modification question Karen, I will be free on Friday to discuss this. Late morning (10:00) or the afternoon (1:00 - 4:00) would be best for me. Matt Burgett, P.E. Permit Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division 303-692-3183 (phone) 303-782-0278 (fax) >>> KAREN MURPHY <karen.murphy1@carestreamhealth.com> 3/11/2009 1:17 PM >>> Hi Matt, if you have time today (or later this week) could we give you a call to briefly discuss a project CHC is considering on the Sensitizing machine? Summary: We are considering physically modifying our Sensitizing machine to allow us to coat a new product. This modification would cost around $300 k, and would only be for the capability of coating a new product. The modification would have no impact on our current products that contain regulated pollutants, meaning we could not run our current products any faster or emit more pollutants than we currently are allowed under our air permit. This new product does not contain CM regulated pollutants. However, we would be using the CDTs that generate the very reactive and unstable ozone. We have asked for the CDTs to be added to our permit shield (as part of our renewal process) because we feel this is not what is being regulated by the APCD, but rather VOCs and NOxs that form the much more stable and harmful ozone. So we would like to discuss with you if we need to submit a minor modification or major modification to the State, an information letter or if we do not need to make any notifications under our air permit (3/13/2009) MATT S Burgett Re: CHC's air permit - modification question requirements. If you can review this with me via phone, could you let me know when it would be convenient for you? thank you, Karen M. Murphy, CHMM Environmental Engineer Environmental, Health & Safety karen.murphvl@carestreamhealth.com P 970.304.4619 F 970.392.3434 Carestream Health, Inc. 2000 Howard Smith Ave West C-42 Windsor, CO 80550 (Embedded image moved to file: pic17731.jpg) AIR POLLUTANT EMISSION NOTICE (APEN) \hpplication for Construction Permit — General Permit Number: 06OPWE288 [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 123 / 6350 - / Facility Equipment ID: S040 Section 01 — Administrative Information Company Name: Carestream Health Inc. [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] is 6711 Source Name: Corona Treaters Source Location: Sensitizing Complex Portable Source Home Base: Mailing Address: 2000 Howard Smith Ave West C42 Windsor, CO Person To Contact: Karen M Murphy E-mail Address: karen.murphyl@carestreamhealth.co m Section 03 — General Information For existing sources, operation began on: Normal Hours of Source Operation: General description of equipment and purpose: NAICS, or SIC Code: 3861 County: Weld Elevation: 4,797 Feet ZIP Code: 80550 Phone Number: 970.304.4619 Fax Number: 970.392.3434 00 / 00 / hours/day days/week Section 02 — Requested Action (check applicable request boxes) 11 Request for NEW permit or newly reported emission source Request PORTABLE source permit Request MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment O Change company name ❑ Change permit limit O Transfer of ownership ® Other ❑ Request to limit HAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) O Revision to actual calendar year emissions for emission inventory ❑ Update 5 -Year APEN term without change to permit limits or previously reported emissions S CAN N Additional Info. & Notes: MAY 14 Z00l For new or reconstructed sources, the projected startup date is: weeks/year Corona treaters are used to improve the wettability and adhesion characteristics of plastic substrates prior to coating with an aqueous solution. Will this equipment be operated in any NAAQS nonattainment area? (http://www.cdphe.state.co.us/ap/attainmaintain.html) Section 04 — Processing/Manufacturing Equipment Information & Material Use Description of equipment': Corona Treaters Manufacturer: Pillar Technologies ® Yes Model No.: CTl: AB4515-1; CT2: AB1413-3; CT3,4,5: P6100 Seri al No.: No Don't know CT1: 32261MS; CT2: 2624EQ; CT3: 46670-3; CT4: 46670-1; CT5: 46670-2 Description Actual Level (For Data Year) Annual Requested Permitted Level2 (Specify Units) Design Process Rate (Specify Units/Hour) Raw Materials: Finished Products: `' ii Z l SIN Process: Corona Treaters 2.5 tpy fOther 7.0 tpy F{oe;. Colorado Department of Public Health arid Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for $152.90 to: Colorado Department of Public Health & Environment APCD-SS-Bl 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SBAP): (303) 692-3148 or (303) 692-3175 APEN forms: http://www.cdphe.state.co.us/ap/downloadforms.html Application status: http://www.cdphe.state.co.us/ap/ss/sspcpt.html Page 1 of 3 123-6350-003-APEN-2009-04-24-01 Z AIR POLLUTANT EMISSION NOTICE (A' ) & Application for Construction Permit — General `If additio,.. _ space is required, please attach a separate list of equipment, materials and throughputs. 'Requested values will become permit limitations. Requested level should consider process growth over the next five years. FORM APCD-J nj it Number: 06OPWE288 ❑ Check box to request copy of draft permit prior to issuance. ❑ Check box to request copy of draft permit prior to public notice. Emission Source AIRS ID: 123 / 6350 / Section 05 — Emission Release Information (Attach a separate sheet with relevant information in the event of multiple releases; provide datum & either Lat/Long or UTM) Operator Stack ID No. Base Elevation (feet) Discharge Height Above Ground Level (Feet) Temp. CF) Flow Rate (ACFM) Velocity (ft/sec) (%) Horizontal Datum (NAD27, NAD83, WGS84) UTM Zone (12 or 13) UTM Easting or Moisture Method of Collection for Location Longitude (meters or degrees) UTM Northing or Latitude (meters or degrees) Data (e.g. map, GPS, GoogleEarth) Direction of outlet (check one): ❑ Vertical O Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): 0 Circular: Inner Diameter.(inches) = Section 06 — Combustion Equipment & Fuel Consumption Information Company equipment Identification No.: Manufacturer: ❑ Horizontal 0 Down 0 Other: Length (inches) = Model: ❑ Other (Describe): Width (inches) _ Serial No.: Fuel Type Design Input Rate (106 Btu/hr) Actual Level (For Data Year) Annual Requested Permitted Level2 (Specify Units) Fuel Heating Value (Indicate: Btu/lb, Btu/gal, Btu/SCF) Percent by Weight Seasonal Fuel Use (% of Annual Use) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov ' J,.x: I 441242 ir. 'Requested values will become permit limitations. Requested level should consider process growth over the next five years. Section 07 — Emissions Inventory Information & Emission Control Information Attach any emission calculations and emission factor documentation to this APEN form. Data year for actual calendar yr. emissions below & throughput above (e.g. 2007): ❑ Emission Factor Documentation attached Pollutant Control Device Description Overall Collection Efficiency Control Efficiency ° (% Reduction) Emission Factor Actual Calendar Year Emissions Requested Permitted Emissions Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled (Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) TSP PM10 PM2.5 SOx NOx VOC CO Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. 3 Annual emission fees will be based on actual emissions reported here. If left blank, annual emission fees will be based on requested emissions. 4If Requested Permitted Emissions is left blank, the APCD will calculate emissions based on the information supplied in sections 03 - 07. Section 08 —Applicant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Page 2 of 3 FormAPCD-200-GeneralAPEN-Ver.9-10-2008.doe AIR POLLUTANT EMISSION NOTICE (APEN) pplication for Construction Permit — General 9/2Z/2009 Signature of Person Legally Authorized to Supply Data Date Michael Haas Carestream Hearn Colorado, Site Manager Name of Legally Authorized Person (Please print) Title Page 3 of 3 FonnAPCD-200-GeneralAPEN-Ver.9-10-2008.doc )N -CRITERIA REPORTABLE AIR POLL 'ANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: 06OPWE288 Company Name: Plant Location: Person to Contact: Karen M. Murphy E-mail Address: Carestream Health Colorado 2000 Howard Smith Ave West Karen.murphy1(cr�carestreamhealth.com AIRS ID Number: 123/6350 f bc3 County: Weld Phone Number: 970.304.4619 Zip Code: 80550 Fax Number: 970.392.3434 Chemical Abstract Service (CAS) Number Chemical Name Reporting BIN Control Equipment / Reduction %) Emission Factor (Include Units) Emission Factor Source Uncontrolled Actual Emissions (lbs/year) Controlled Actual Emissions (lbs/year) 10028-15-6 Ozone N/A- CP Reporting here as advised by APCD None -- 14,000 Reporting Scenario (1, 2 or 3): N/A Calendar Year for which Actual Data Applies: 2008 Signature of Person Legally Authorized to Supply Data Michael Haas Name of Person Legally Authorized to Supply Data (Please print) 9/22/zoo? Date Carestream Health Colorado, Site Manager Title of Person Legally Authorized to Supply Data Form Revision Date: December 4, 2006 GUIDANCE FOR NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM Non -Criteria Reportable Air Pollutant Emission Notice Addendum: This form should be completed to report emissions of Hazardous Air Pollutants (HAP) and other non -criteria reportable pollutants listed in Regulation 3, Part A, Appendix B. Permit Number: For New Permit Applications leave this blank. For modifications to existing permits, please list the permit number previously issued by the APCD. AIRS ID Number: For New Permit Applications leave this blank. For modifications to existing permits, please list the emissions point AIRS ID number previously issued by the APCD. Chemical Abstract Service (CAS) Number and Chemical Name: Please list the CAS number and common chemical name for each non -criteria reportable air pollutant that is emitted from this emission point. A list of CAS numbers and common chemical names may be found in Regulation 3, Appendix B. Reporting BIN: Please list the reporting BIN for each non -criteria reportable pollutant reported. The reporting BIN may be determined by reviewing Regulation 3, Appendix B. Reporting Scenario: The reporting scenario is established by evaluating the release point of the emission unit and the proximity of the property boundary closest to the release point according to the definitions and scenarios described below. Further details on how to determine the appropriate reporting scenario are contained in Regulation 3, Appendix A. The Division will assume scenario "1" if this information is left blank. Otherwise, an operator may choose scenario "1" by default or evaluate the reporting scenario based on the following definitions: Release Point: the lowest height above ground level from which the pollutants are emitted to the atmosphere. Property Boundary: the distance from the base of the release point to the nearest property boundary. Point: an individual emission point or a group of individual emission points reported on one Air Pollutant Emission Notice as provided for in Part A, section II.B.4. Scenario 1: Release point less than 10 meters (- 33 feet) or property boundary less than 100 meters (- 328 feet); Scenario 2: Release point equal to or greater than 10 meters (- 33 feet), but less than 50 meters (- 164 feet), or property boundary equal to or greater than 100 meters (- 328 feet), but less than 500 meters (- 1,640 feet); or Scenario 3: Release point equal to or greater than 50 meters (- 164 feet), or property boundary equal to or greater than 500 meters (— 1,640 feet). Control Equipment / Reduction (%): Please list the type of control equipment used (i.e. SCR, NSCR, Flare, Thermal Oxidizer, etc.) and report the minimum percent reduction achieved by the control equipment. Emission Factor: Please list the emission factor used to calculate the emission rates listed in the actual emission columns. Fill this information out if the applicant has calculated emissions in lieu of having the Air Pollution Control Division (APCD) calculate the emissions for the company. Emission Factor Source: Example emission factor sources include: AP -42, GRI HAP Calc., EPA TANKS, GRI GLY Calc., Manufacturer's Emission Factor, and Mass Balance. Uncontrolled Actual Emissions: Enter the actual uncontrolled data year (projected first year emissions for new sources) emissions (lbs/year) from the reported emission point excluding any emission reduction achieved by control equipment. Controlled Actual Emissions: Enter the actual controlled data year (projected first year emissions for new sources) emissions (lbs/year) from the reported emission point including the emission reduction listed in the "Control Equipment Reduction (%)" column. Enter "N/A" if the emissions are uncontrolled. SUBMITTAL OF THIS ADDENDUM MUST BE ACCOMPANIED BY AN AIR POLLUTANT EMISSION NOTICE (APEN) Copies of this form may be obtained on the Internet at the following URL: http://www.cdphe.state.co.us/ap/downloadforms.html Form Revision Date: December 4, 2006 R5118/2009) MATT S Burgett - pic04796.jpg Page 1 CHC C40 CDT Exhaust Flow 6 -May -08 Duct Diameter - Feet Duct Cross Sectional Area - Sq Ft Duct Length to Fan - Feet Measured Flow Rate - FPM Measured FlowTe mp - Deg F Flow Corrected to Standard Conditions - FPM Calculated Standard CFM CDT Fan 1 1.00 0.79 52.00 2200.00 85.00 2420.00 1900.66 CDT Fan 1.00 0.79 41.00 280 0.00 8 8.00 308 0.00 241 9.03 ROOF 3" FIB' 2rd FIaor Ousgoing Web P ? atc'tff HotiltitArege 11r' "16c1r' Valid CT Crrnbnainnx.• CT1,2,3,4 CT1,2,3,5 CT2.3A.5 Cl (*roue' damper on unused rCTs Mnxlmum Total UsuaWs CT Pa+.ver = 30KW 1-40414000 Proem 9!u y HKW Cfl tioviougo Pone' .`4trc v Exhaust Fan #1 CT1,4,5 OFf 12) Cincinari Fan 4ladal PB-18WA 25HP. 363ORPM Cr4 Exhaust. Fan 002 CT2.3 CT3 OT1,2 Pillar Terctnc[oglea P100 Gonna Treaters 013.4,5 Filter Tachnokbgle& P5O00 Corona Oles:barge Treaters High ll 26 -MAR -20419 (5/19/2009) MATT S Burgett - Minor Modification complete Page 1 From: To: CC: Date: Subject: Attachments: MATT S Burgett MURPHY, KAREN Reinhardt, Christopher 5/19/2009 9:21 AM Minor Modification complete 06we288 2009 Minor Mod TRD1.docx; minor mod complete not issuing.pdf; 06we2 88 2009 Minor Modl.docx Karen, Please find attached the Minor Modification draft permit, technical review document and completeness letter for the Minor Modification application submitted by Carestream Health on April 24, 2009. You will need to comply with this draft permit until your permit is reissued. Contact me with any questions. Matt Burgett, P.E. Permit Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division 303-692-3183 (phone) 303-782-0278 (fax) STATE OF COLORADO Bill Ritter, Jr., Governor James B. Martin, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 TDD Line (303) 691-7700 Located in Glendale, Colorado http://www.cdphe.state.co.us May 19, 2009 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Ms. Karen M Murphy Environmental Engineer Carestream Health, Inc. 2000 Howard Smith Ave West C-42 Windsor, CO 80550 Colorado Department of Public Health and Environment SUBMITTED ELECTRONICALLY VIA EMAIL RE: Complete Application for Minor Modification to Operating Permit 06OPWE288 Dear Ms. Murphy: The Division received your request for a minor modification to the Operating Permit along with the proposed additional draft permit conditions on April 24, 2009. The Division agrees that the modifications requested can be processed as a minor modification. The Division considers your application for a minor modification to the Operating Permit to be complete as of April 24, 2009. As specified in Colorado Regulation 3, Part C, Section X.I, "a source shall be allowed to make the changes proposed in its application for a minor permit modification immediately after it files such [complete] application." Please be aware that if you choose to make the changes proposed in your minor permit application before the Division issues the revised permit that Colorado Regulation 3, Part C, Section X.I requires that: "...the source must comply with both the applicable requirements governing the change and the proposed permit terms and conditions. During this time the source does not need to comply with existing permit terms and conditions it seeks to modify, but if the source fails to comply with its proposed permit terms and conditions during this period, the existing permit terms and conditions it seeks to modify shall be fully enforceable by the Division." This minor modification application will allow Carestream Health, Inc. to install spreader bars and concave bars to the Sensitizing coating machine throughout the drying alley, and operate the Corona Treaters (CTs) up to 191,780 kW -hr per year. As we have discussed, the Division is not planning on issuing this minor modification permit, but will roll these changes into the renewal permit (renewal application submitted October 29, 2008). If you have any further questions please contact me at (303) 692-3183. Sincerely, Matthew S. Burgett, P.E. Permit Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division Cc: Christopher Reinhardt, APCD (5/19/2009) MATT S Burgett - Carestream Minor Modification Page 1 From: To: Date: Subject: Attachments: MATT S Burgett law.donald@epa.gov 5/19/2009 9:24 AM Carestream Minor Modification minor mod EPA notice.docx DJ, Please find attached a notification letter regarding a Minor Modification application for Carestream Health, Inc. Contact me with any questions. Matt Burgett, P.E. Permit Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division 303-692-3183 (phone) 303-782-0278 (fax) STATE OF COLORADO Bill Ritter, Jr., Governor James B. Martin, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 TDD Line (303) 691-7700 Located in Glendale, Colorado http://www.cdphe.state.co.us May 19, 2009 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Mr. DJ Law Office of Partnerships and Regulatory Assistance Air and Radiation Programs, 8P -AR U.S. EPA, REGION VIII 1595 Wynkoop Street Denver, Colorado 80202-1129 Dear Mr. Law: Colorado Department of Public Health and Environment [Sent electronically via email] The Division received a complete application for a minor modification to the Operating Permit for the following Colorado facility: Applicant/Facility Name: Carestream Health, Inc. AIRS ID#: 1236350 Permit No: 06OPWE288 Facility Address: 2000 Howard Smith Ave West Facility City, State ZIP: Windsor, CO 80550 The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. As required by Colorado Regulation No. 3, Part C, Section X.F, the Division is notifying you that a complete application for a minor permit modification has been submitted. The application was deemed to be complete on April 24, 2009. The Division is not planning on issuing this minor modification permit, but will include these minor modification changes in the renewal permit (renewal application has been submitted on October 29, 2008). Please do not hesitate to contact me if you have any questions at (303) 692-3183. Sincerely, Matthew S. Burgett, P.E. Review Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division STATE OF COLORADO Bill Ritter, Jr., Governor James B. Martin, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 TDD Line (303) 691-7700 Located in Glendale, Colorado http://www.cdphe.state.co.us May 19, 2009 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Mr. David A. Finley Administrator, Air Quality Division Wyoming DEQ Air Quality Division 122 W 25th Street Cheyenne, WY 82002 REF: Carestream Health, Inc. (1236350) SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Mr. Finley: Colorado Department of Public Health and Environment The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the Operating Permit (06OPWE288) issued for Carestream Health, Inc.. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located at 2000 Howard Smith Ave West, Windsor, CO in Weld County. Since this facility is located within 50 miles of the Wyoming border, your organization represents an affected state. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on April 24, 2009. - If you have any questions or require any additional information, please contact Matthew S. Burgett at (303) 692 - 3183. Sincerely, ames A. King, Manager Operating Permit Unit Stationary Sources Program Air Pollution Control Division HEALTH May 21, 2009 Matt Burgett, P.E. Operating Permits Unit, Stationary Sources Program Colorado Department of Public Health & Environment, Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: Minor Permit Modification Request for Carestream Health, Inc. - Permit #06OPWE288 Dear Mr. Burgett: Carestream Health Colorado (CHC) is requesting a minor modification for an increase in facility wide PM/PMio emission limit from 11.8 tpy to 15.0 tpy. This request is being made to address a recently discovered calculation error in our 12 -month rolling total (MRT) spreadsheet. There have been no process changes at CHC that cause a need to increase our PM/PMio emissions. On May 1, 2007 Carestream Health Inc., acquired Eastman Kodak's Health Group. As part of the sale, the Kodak Colorado Division (KCD) split its air permit number 96OPWE128, including its facility wide limits, and shared its 12 MRT spreadsheet with CHC. KCD used its 12 MRT spreadsheet to allocate 11.8 tpy PM/PMio emissions to CHC and 12.5 tpy to the remaining KCD operations. Unfortunately, KCD's 12 MRT spreadsheet contained a calculation error, which resulted in a lower apportionment in PM/PMio emissions to CHC than should have been given. This problem dates back to 2003, when, in a permit renewal application, KCD requested resorcinol emissions in building C-50 to be accounted for as "PM/PMio Emissions = Amount of Resorcinol consumed" and it became effective November 1, 2004. KCD had been using a 2% emission factor for resorcinol. KCD apparently forgot to revise the 12 MRT to reflect the newly permitted "100% emissions" requirement. This error was carried over to CHC in the 12 MRT spreadsheet we inherited from KCD, and was not discovered until last month. Had this error been detected prior to the split, the PM/PMio limit in CRC's permit would have been approximately 14 tpy. Additionally, this oversight caused an APEN reporting error when KCD transferred ownership of the existing APEN for Building C-50 to CHC. The actual emissions submitted were 2 tpy PM/PMio, when in fact it should have been submitted for 6 tpy. The attached revised APEN corrects for this deficiency. A copy of this revised APEN is being submitted to the APEN group, along with the back fees. This emission increase request will not impact any current Maximum Achievable Control Technology (MACTs) standards that we are subject to, nor will we be subject to any additional MACT's. We have also reviewed the New Source Performance Standards (NSPS) and none apply to this source. Please find enclosed the following completed forms and requested Operating Permit Update: Form APCD-200 Form 2000-601 Form 2000-603 Form 2000-800 Operating Permit (Specific Sections with Changes Only): Section II- Specific Permit Terms 1. Facility Wide Limit (table) Should you have any comments or questions, please contact me at 970-304-4619 or Karen.murphyl@carestreamhealth.com. Thank you for your consideration. GuA`" / Karen M. Murphy Environmental Engineer 2000 Howard Smith Ave West C-42 Windsor, CO 80550 karen. murphylcarestreamhealth.com@ Enclosures Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS Colorado Department of Public Health and Environment 4ir Pollution Control Division ' LEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-601 09-94 1. Facility name: Carestream Health Colorado 2. Facility identification code: CO 1236350 3. Stack identification code: N/A 4. Unit identification code: N/A 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached ❑ Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY U TPY Particulates (TSP) PM -10 N/A TPY N/A N/A TPY 15.0 Nitrogen oxides N/A TPY N/A Volatile organic compounds N/A TPY N/A Carbon monoxide N/A TPY N/A Lead . N/A TPY N/A Sulfur dioxide N/A TPY N/A tal reduced sulfur N/A TPY N/A Reduced sulfur compounds N/A TPY N/A Hydrogen sulfide N/A TPY N/A Sulfuric Acid Mist N/A TPY N/A Fluorides N/A TPY N/A TPY TPY TPY TPY Units (U) should be entered as follows: 1 = lb/hr 2 = lb/mmBTU 3 = grains/dscf 4 = lb/ gallon 5 = ppmdv 6 = gram/HP-hour 7 = Ib/mmscf 1= other (specify) = other (specify) 10 = other (specify) EMISSION UNIT CRITERIA AIR POLLUTANTS -- Form 2000-601 1 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permits. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. Item 1 Provide the name of the facility. Item 2 Provide the facility identification (FID) code. Item 3 Provide the identification code of the stack that exhausts this equipment. Use the same code used on form 2000-200. Item 4 Provide the identification code from the appropriate form(s) 2000-300, -301, -302, -303, -304, -305, -306, or -307 completed for the emissions unit that will have its emissions summarized on this form. Item 5 Provide the emission levels for each listed pollutant emitted from this source. The emissions should be presented using the same units as the applicable limits shown on Form 2000-604 and in tons per year (TPY). The list of footnotes found in the lower left corner of this form allows the applicant to specify the units of each reported emission level. To specify the appropriate units, write the appropriate footnote number in the columns headed by the letter "U". For example: to indicate an emission rate of 3.2 lbs SO2/MMBTU, write Sulfur dioxide 3.2 2 on the line for sulfur dioxide (SO2). Potential to emit should represent emissions at full production capacity of the source after reduction by any air pollution control equipment. This is normally 24 hours/day for 365 days/year (i.e., 8760 hours/year), although physical or operational limitations that are in a construction permit issued by the Division, or in the applicable emission control regulation, are considered in determining the potential to emit. Please see the instruction manual for the precise definition of "potential to emit." You may want to use emission factors to determine these emissions. Maximum allowable emissions should represent the greatest amount of emissions allowed under any permit or applicable standards, taking into consideration the equipment limitations, such as line speed, and pollution control efficiencies of the equipment. In cases where the emission unit has a construction permit, the maximum allowable emissions are equal to the potential to emit. Please remember to: Report hazardous air pollutants on Forms 2000-600 and 2000-602. State the reference(s) for the calculations. Emission factors may be compiled in published documents, such as EPA's AP -42, or may be based on stack test results. A separate page of numbered references is appropriate and may be attached to form 2000-601. Form 2000-700 may be used for this purpose. 2 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE PLANT -WIDE CRITERIA AIR POLLUTANTS FORM 2000-603 09-94 1. Facility name: Carestream Health 2. Facility identification Colorado code: CO 1236350 3. Complete the following emissions summary for the listed emissions at this facility. Air pollutant Actual Potential to emit Maximum allowable TPY TPY TPY Particulates (TSP) n/a n/a PM -10 n/a 15.0 Nitrogen oxides n/a n/a Volatile organic compounds n/a n/a Carbon monoxide n/a n/a Lead n/a n/a Sulfur dioxide n/a n/a Total reduced sulfur n / a n / a Reduced sulfur compounds n / a n / a Hydrogen sulfide n / a n / a Sulfuric acid mist n / a n / a Fluorides n / a n / a 3 PLANT -WIDE CRITERIA AIR POLLUTANTS — Form 2000-603 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permits. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. Item 1 Provide the name of the facility. Item 2 Provide the facility identification (FID) code. Item 3 Provide the emission levels in tons per year (TPY). For each pollutant emitted from the facility, sum the annual actual, potential to emit, and the maximum allowable emission rates (tons per year only) reported for all of the facility's emission units. The individual values are on each Form 2000-601 completed for the application. The totals for each pollutant should be reported on Form 2000-603 in tons per year (TPY). * * * * * Hazardous air pollutant emissions should be reported on Forms 2000-600 and 2000-602. * * * * * 4 Operating Permit Application Colorado Department of Health Air Pollution Control Division Facility Name: Carestream Health Colorado ADMINISTRATION TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 09-94 Facility Identification Code:CO 1236350 •1 his application contains the following forms: ❑ Form 2000-100, Facility Identification ❑ Form 2000-101, Facility Plot Plan ❑ Forms 2000-102, -102A, and -102B, Source and Site Descriptions H. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler, printing ❑ Form 2000-200, Stack Identification ❑ Form 2000-300, Boiler or Furnace Operation o Form 2000-301, Storage Tanks o Form 2000-302, Internal Combustion Engine ❑ Form 2000-303, Incineration o Form 2000-304, Printing Operations ❑ Form 2000-305, Painting and Coating Operations ■ Form 2000-306, Miscellaneous Processes o Form 2000-307, Glycol Dehydration Unit III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following forms: 0 Form 2000-400, Miscellaneous o Form 2000-401, Condensers o Form 2000-402, Adsorbers o Form 2000-403, Catalytic or Thermal Oxidation o Form 2000-404, Cyclones/Settling Chambers ❑ Form 2000-405, Electrostatic Precipitators o Form 2000-406, Wet Collection Systems o Form 2000-407, Baghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the following forms (one for each facility boiler, printing operation, D Form 2000-500, Compliance Certification - Monitoring and Reporting ❑ Form 2000-501, Continuous Emission Monitoring o Form 2000-502, Periodic Emission Monitoring Using Portable Monitors ❑ Form 2000-503, Control System Parameters or Operation Parameters of a Process ❑ Form 2000-504, Monitoring Maintenance Procedures o Form 2000-505, Stack Testing o Form 2000-506, Fuel Sampling and Analysis o Form 2000-507, Recordkeeping o Form 2000-508, Other Methods 5 V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan 0 Form 2000-600, Emission Unit Hazardous Air Pollutants ►� Form 2000-601, Emission Unit Criteria Air Pollutants 1 0 Form 2000-602, Facility Hazardous Air Pollutants ►I Form 2000-603, Facility Criteria Air Pollutants 1 0 Form 2000-604, Applicable Requirements and Status of Emission Unit 0 Form 2000-605, Permit Shield Protection Identification ❑ Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule 0 Form 2000-607, Plant -Wide Applicable Requirements 0 Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. B. STATEMENT I have the CERTIFICATION 111 ❑ OF COMPLETENESS reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify that statements and information contained in this application are true, accurate and complete. OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS (check one box only) I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements, except for the following emissions unit(s): (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Michael Haas Title Site Manager, Carestream Health Colorado Signature 946-r---49091,--61-- Date Signed s lZZ la 7 6 Operating Permit Application CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 Colorado Department of Health A Pollution Control Division I —ility Name: Facility Identification Code: CO 09-94 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief the statements and information contained in this application are true, accurate and B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY ❑ I certify that the facility described in this air pollution permit application requirements. ❑ I certify that the facility described in this air pollution permit application requirements, except for the following emissions unit(s): formed after reasonable inquiry, I certify that complete. CONDITIONS (check one box only) is fully in compliance with all applicable is fully in compliance with all applicable any false material statement, representation, misdemeanor and may be punished in (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes certification in, or omits material information from this application is guilty of a accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 7 MAJOR SOURCE OPERATING PERMIT APPLICATION APPLICATION COMPLETENESS SUMMARY FORM 1. FACILITY NAME: 3. REVIEW ENGINEER: 4. DATE OF APPLICATION: I. IDENTIFYING INFORMATION II. EMISSIONS III. APPLICABILITY IV. COMPLIANCE 2. PERMIT: 5. DATE RECEIVED BY APCD COMPLETENESS DETERMINATION COMPLETE _ INCOMPLETE COMPLETE _ INCOMPLETE COMPLETE INCOMPLETE NOT APPLICABLE NOT APPLICABLE NOT APPLICABLE COMPLETE _ INCOMPLETE _ NOT APPLICABLE APPLICATION FORM CERTIFIED FOR TRUTH, ACCURACY, AND COMPLETENESS BY: _ OFFICIAL TITLE _ SIGNATURE _ DATE APPLICATION EVALUATION _ COMPLETE (BASIC INFORMATION PRESENT TO BEGIN PROCESSING) _ INCOMPLETE - RETURN WITH ADDITIONAL INFORMATION BY: COMMENTS REVIEWED BY: DATE 8 MAJOR SOURCE OPERATING PERMIT APPLICATION APPLICATION COMPLETENESS CHECK LIST DENTIFYING INFORMATION A. FACILITY INFORMATION FACILITY NAME, LOCATION & MAILING ADDRESS PERMIT CONTACT PERSON RESPONSIBLE OFFICIAL COMPLETE _ INCOMPLETE _ NOT APPLICABLE PERMIT REQUESTED B. SOURCE DESCRIPTION 1. OPERATIONAL INFORMATION: SIC/SCC CODES LISTING AND DESCRIPTION OF EMISSION SOURCE(S) YES NO YES NO YES NO YES NO YES NO YES NO YES NO 2. IDENTIFICATION AND DESCRIPTION OF ALTERNATIVE OPERATIVE SCENARIOS (IF APPLICABLE) _ YES _ NO _ N/A C. PERMIT SHIELD REQUESTED II. EMISSIONS A. EMISSIONS INFORMATION _ YES NO COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. QUANTIFICATION OF ALL EMISSIONS OF REGULATED AIR POLLUTANTS 2. EMISSION SOURCES: IDENTIFICATION AND DESCRIPTION OF ALL EMISSION SOURCES IN SUFFICIENT DETAIL TO ESTABLISH THE BASIS FOR FEES AND APPLICABILITY OF REQUIREMENTS. A LIST OF INSIGNIFICANT EMISSIONS UNITS OR ACTIVITIES EXEMPTED BECAUSE OF SIZE OR PRODUCTION RATE. YES _ NO YES _ NO _ YES _ NO _ N/A 4. PROCESS INFORMATION TO THE EXTENT IT IS NEEDED TO DETERMINE OR REGULATE EMISSIONS: FUELS RAW MATERIAL(S) / MATERIALS USED PRODUCTION RATES 5. FOR REGULATED AIR POLLUTANTS, LIMITATIONS ON SOURCE OPERATIONS AFFECTING: EMISSIONS ANY WORK PRACTICE STANDARDS 6. OTHER INFORMATION REQUIRED BY ANY APPLICABLE REQUIREMENTS FOR ALL REGULATED AIR POLLUTANTS SUCH AS: FLOW RATES STACK PARAMETERS 7. CALCULATIONS ON WHICH EMISSIONS RELATED INFORMATION ARE BASED _ YES _ NO _ N/A _ YES _ NO _ N/A _ YES _ NO _ N/A YES NO N/A YES NO N/A YES NO N/A YES NO N/A YES NO N/A 9 III. APPLICABILITY _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. CITATION AND DESCRIPTION OF ALL APPLICABLE REQUIREMENTS _ YES _ NO 2. OTHER SPECIFIC INFORMATION THAT MAY BE NECESSARY TO IMPLEMENT AND ENFORCE OTHER _ YES _ NO APPLICABLE REQUIREMENTS OR TO DETERMINE THE APPLICABILITY OF REQUIREMENTS 3. AN EXPLANATION OF ANY PROPOSED EXEMPTIONS FROM OTHERWISE APPLICABLE REQUIREMENTS _ YES _ NO _ N/A IV. COMPLIANCE _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE A. COMPLIANCE STATUS 1. A DESCRIPTION OF THE COMPLIANCE STATUS OF THE SOURCE WITH RESPECT TO ALL _ YES _ NO APPLICABLE REQUIREMENTS 2. FOR APPLICABLE REQUIREMENTS WITH WHICH THE SOURCE IS IN COMPLIANCE, A STATEMENT _ YES _ NO THAT THE SOURCE WILL CONTINUE TO COMPLY WITH SUCH REQUIREMENTS 3. FOR APPLICABLE REQUIREMENTS THAT WILL BECOME EFFECTIVE DURING THE PERMIT TERM, _ YES _ NO _ N/A A STATEMENT THAT THE SOURCE WILL MEET SUCH REQUIREMENTS ON A TIMELY B,QNSIS 4. FOR REQUIREMENTS FOR WHICH THE SOURCE IS NOT IN COMPLIANCE AT THE TIME OF _ YES _ NO _ N/A PERMIT ISSUANCE, A NARRATIVE DESCRIPTION OF HOW THE SOURCE WILL ACHIEVE COMPLIANCE WITH SUCH REQUIREMENTS 5. IDENTIFICATION AND DESCRIPTION OF AIR POLLUTION CONTROL EQUIPMENT AND COMPLIANCE _ YES _ NO MONITORING DEVICES OR ACTIVITIES 6. DESCRIPTION OF OR REFERENCE TO ANY APPLICABLE TEST METHOD FOR DETERMINING _ YES _ NO COMPLIANCE WITH EACH APPLICABLE REQUIREMENT B. COMPLIANCE SCHEDULE COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. A SCHEDULE OF COMPLIANCE FOR SOURCES THAT ARE NOT IN COMPLIANCE WITH ALL APPLICABLE REQUIREMENTS AT THE TIME OF PERMIT ISSUES YES NO N/A 2. A SCHEDULE FOR SUBMISSION OF CERTIFIED PROGRESS REPORTS NO LESS FREQUENTLY _YES _ NO _ N/A THAN EVERY SIX MONTHS FOR SOURCES REQUIRED TO HAVE A SCHEDULE OF COMPLIANCE TO REMEDY A VIOLATION C. COMPLIANCE CERTIFICATION COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. CERTIFICATION OF COMPLIANCE WITH ALL APPLICABLE REQUIREMENTS BY _ YES _ NO A RESPONSIBLE OFFICIAL 2. A STATEMENT OF METHODS USED FOR DETERMINING COMPLIANCE, INCLUDING A DESCRIPTION _ YES _ NO OF MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS AND TEST METHODS 3. A SCHEDULE FOR SUBMISSION OF COMPLIANCE CERTIFICATIONS _ YES _ NO 4. A STATEMENT INDICATING THE SOURCE'S COMPLIANCE STATUS WITH ANY APPLICABLE _ YES _ NO ENHANCED MONITORING AND COMPLIANCE CERTIFICATION REQUIREMENTS OF THE FEDERAL ACT 10 SECTION II- Specific Permit Terms 1. Facility Wide Limit See Equipment List, Appendix G Parameter Permit Condition Number Limitation Compliance Emission Factor Monitoring Method Interval VOC 1.1 48.3Tons/Yr See Condition 1.1 Recordkeeping Calculation Monthly PM 1.1 15.0 Tons/Yr PMI0 1.1 15.0 Tons/Yr Opacity 1.2 Not to exceed 20%, except as provided for below Consumption 1.3 Certain Operating Conditions - Not to exceed 30%, for a period or periods aggregating more than six (6) minutes in any 60 consecutive minutes Nature of the Processes Annually See Condition 1.3 Recordkeeping Monthly restrea HEALTH May 21, 2009 Mr. Matt Burgett Operating Permits Unit, Stationary Sources Program CDPH&E Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: Amendment to Renewal Air Operating Permit Application (06OPWE288) Dear Mr. Burgett: Carestream Health Colorado (CHC) respectfully requests to make the following modifications to our permit renewal application submitted to you on October 28, 2008 for renewal of our Operating Permit 06OPWE228: 1) Section II- Specific Permit Terms 1.2 Change: Revision of the following requirement: Replace current language "In addition, the building C-50 Rail Car Polymer Unloading, Pellet Unloading, and Dry chemical Weighing Room HEPA filters shall be replaced at least annually." with "In addition, the building C-50 Rail Car Polymer Unloading, and Dry chemical Wei. hing Room HEPA filters shall be replaced at least annually. The HEPA filter associated with the C-50 pellet unloading shall be replaced at least annually, unless the process is not used during the previous year. In which case, the HEPA filter shall then be replaced just prior to startup of any pellet unloading activities." Rationale: CHC has ceased use of the pellet grinders since August 2007, but wishes to leave on the permit as an option for future use if necessary. However, under the current permit, the filter would need to be replaced annually even if not being used for pellet grinding operations for the previous year. This requires unnecessary work hours of the maintenance personnel as well as financial burden to replace. If you have any questions regarding these amendments, please contact Karen Murphy, Environmental Engineer, at karen.murphv1 @carestreamhealth.com or (970) 304-4619. Sincerely, Michael S. Haas Site Manager, Carestream Health Colorado Division 2000 Howard Smith Ave West Windsor, CO 80550 cc: Ms. Karen M. Murphy Permit Number: 06OPWE288 AIR POLLUTANT EMISSION NOTICE (APEN) pplication for Construction Permit — General Emission Source AIRS ID: 123 / 6350 / (001, [Leave blank unless APCD has already assigned a permit # & AIRS ID] Facility Equipment ID: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 01— Administrative Information Company Name: Carestream Health Inc. Source Name: Source Location: Building C50, Support Manufacturing Portable Source Home Base: .? tI CS eN NAICS, or 3861 SIC Code: County: Weld Elevation: 4,797 Feet Mailing Address: 2000 Howard Smith Ave West C42 ZIP Code: 80550 Windsor, CO Person To Contact: Karen M Murphy Phone Number: 970.304.4619 E-mail Address: karen.murphyl@carestreamhealth.co m Section 03 — General Information For existing sources, operation began on: Normal Hours of Source Operation: General description of equipment and purpose: Fax Number: 970.392.3434 Section 02 — Requested Action (check applicable request b Request for NEW permit or newly reported emission sou Request PORTABLE source permit Request MODIFICATION to existing permit (check each tin g bel ', *Xi.•es) ❑ Change fuel or equipment ❑ Change company nam ® Change permit limit ❑ Transfer of ownership ❑ Other ❑ Request to limit HAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) ❑ Revision to actual calendar year emissions for emission inventory ❑ Update 5 -Year APEN term without change to permit limits or previbu ly reported emissions ty Additional Info. & Notes: This APEN provides aggregated emissions for Building C50, Support Manufacturing. For new or reconstructed sources, the projected startup date is: hours/day days/week weeks/year Will this equipment be operated in any NAAQS nonattainment area? ® Yes O No O (http://www.cdphe.state.co.us/ap/attainmaintain.html) Section 04 — Processing/Manufacturing Equipment Information & Material Use Description of equipment: Manufacturer: Model No.: Seri al No.: Don't know Description Raw Materials: Actual Level (For Data Year) Annual Requested Permitted Level2 (Specify Units) Design Process Rate (Specify Units/Hour) Finished Products: Other Process: I lIf additional space is required, please attach a separate list of equipment, materials and throughputs. Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check f Colorado Department of Public Hea APCD-SS-B1 4300 Cherry Creek Drive South JUN 1 Denver, CO 80246-1530 .1 2009 For guidance on how to complete t 's Air Pollution Control Division: L' (303 Small Business Assistance Program (SBAP): (303) 692-3148 or (303) 692-3175 APEN forms: http://www.cdphe.state.co.us/ap/downloadforms.html Application status: htio://Nmw.cdphe.state.co.us/ap/ss/ssocpt.html O Check box to request copy of draft permit prior to issuance. Page 1 of 3 123-6350-002-APEN-2009-05-27-01 Z FORM " -"(7,D-200 AIR POLLUTANT EMISSION NOTICE (AP: & Application for Construction Permit — General 'Requested values will become permit limitations. Requested level should consider process growth over the next five years. Permit Number: 06OPWE288 ❑ Check box to request copy of draft permit prior to public notice. Emission Source AIRS ID: 123 / 6350 / Section 0 Emission Release Information (Attach a separate sheet with relevant information in the event of multiple releases; provide datum & either Lat/Long or UTM) r Operator P ID o.. evation ,(feet) Discharge AboGround Height Level (Feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Moisture i (/o) Horizontal oAI)27 NAD83 WGS84) (12 orM ( 13) Easting or Lo or a degrees) ers met Northor orud e a es ( ) dlod of Collection for Location Data (e.g. map, GPS, GoogleEarth) Direction of outlet (check one): 0 Vertical ❑ Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): ❑ Circular: Inner Diameter (inches) = Section 06 — Combustion Equipment & Fuel Consumption Information Company equipment Identification No.: Manufacturer: ❑ Horizontal 0 Down 0 Other: Length (inches) _ Model: ❑ Other (Describe): Width (inches) = Serial No.: Fuel Type Design Input Rate (106 Btu/hr) Actual Level (For Data Year) Annual Requested Permitted Levee (Specify Units) Fuel Heating Value (Indicate: Btu/lb, Btu/gal, Btu/SCF) Percent by Weight Seasonal Fuel Use (% of Annual Use) Sulfur Ash Dec -Feb I Mar -May Jun -Aug I Sep -Nov 'Requested values will become permit limitations. Requested level should consider process growth over the next five years. Section 07 — Emissions Inventory Information & Emission Control Information Attach any emission calculations and emission factor documentation to this APEN form. ❑ Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput above (e.g. 2007): Pollutant Control Device Description Overall Collection Efficiency Control Efficiency o (% Reduction) Emission Factor Actual Calendar Year Emissions 3 Requested Permitted Emissions4 Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled, (Tons/Year) = Controlled , (Tons/Year) Uncontrolled. (Tons/Year) Controlled (Tons/Year) TSP PM10 5.51 6.0 PM2 5 SOx NOx VOC CO Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. 2008 'Annual emission fees will be based on actual emissions reported here. If left blank, annual emission fees will be based on requested emissions. 4If Requested Permitted Emissions is left blank, the APCD will calculate emissions based on the information supplied in sections 03 - 07. Section 08 —Applicant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. FormAPCD-200-GeneralAPEN-Ver.9-10-2008.doc Page 2 of 3 AIR POLLUTANT EMISSION NOTICE (APEN) 8 )plication for Construction Permit — General Signature of Person Legally Authorized to Supply Data Date Michael Haas Name of Legally Authorized Person (Please print) Carestream Heal...2olorado, Site Manager Title Page 3 of 3 FormAPCD-200-GeneralAPEN-Ver.9-10-2008.doc STATE OF COLORADO Bill Ritter, Jr., Governor James B. Martin, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 TDD Line (303) 691-7700 Located in Glendale, Colorado http://www.cdphe.state.co.us August 5, 2009 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Ms. Karen M Murphy Environmental Engineer Carestream Health, Inc. 2000 Howard Smith Ave West C-42 Windsor, CO 80550 Colorado Department of Public Health and Environment SUBMITTED ELECTRONICALLY VIA EMAIL RE: Complete Application for Minor Modification to Operating Permit 06OPWE288 Dear Ms. Murphy: The Division received your request for a minor modification to the Operating Permit along with the proposed additional draft permit conditions on May 27, 2009. The Division agrees that the modifications requested can be processed as a minor modification. The Division considers your application for a minor modification to the Operating Permit to be complete as of May 27, 2009. As specified in Colorado Regulation 3, Part C, Section X.I, "a source shall be allowed to make the changes proposed in its application for a minor permit modification immediately after it files such [complete] application." Please be aware that if you choose to make the changes proposed in your minor permit application before the Division issues the revised permit that Colorado Regulation 3, Part C, Section X.I requires that: "...the source must comply with both the applicable requirements governing the change and the proposed permit terms and conditions. During this time the source does not need to comply with existing permit terms and conditions it seeks to modify, but if the source fails to comply with its proposed permit terms and conditions during this period, the existing permit terms and conditions it seeks to modify shall be fully enforceable by the Division." This minor modification application will allow Carestream Health, Inc. to emit up to 15.0 tons per year of both PM and PM10. The Division is not planning on issuing this minor modification permit, but will roll these changes into the renewal permit (renewal application submitted October 29, 2008). If you have any further questions please contact me at (303) 692-3183. Sincerely, Matthew S. Burgett, P.E. Permit Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division STATE OF COLORADO Bill Ritter, Jr., Governor James B. Martin, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 TDD Line (303) 691-7700 Located in Glendale, Colorado http://www.cdphe.state,co.us August 5, 2009 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Mr. DJ Law Office of Partnerships and Regulatory Assistance Air and Radiation Programs, 8P -AR U.S. EPA, REGION VIII 1595 Wynkoop Street Denver, Colorado 80202-1129 Dear Mr. Law: Colorado Department of Public Health and Environment [Sent electronically via email] The Division received a complete application for a minor modification to the Operating Permit for the following Colorado facility: Applicant/Facility Name: AIRS ID#: Permit No: Facility Address: Facility City, State ZIP: Carestream Health, Inc. 1236350 06OPWE288 2000 Howard Smith Ave West Windsor, CO 80550 The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. As required by Colorado Regulation No. 3, Part C, Section X.F, the Division is notifying you that a complete application for a minor permit modification has been submitted. The application was deemed to be complete on May 27, 2009. The Division is not planning on issuing this minor modification permit, but will include these minor modification changes in the renewal permit (renewal application has been submitted on October 29, 2008). Please do not hesitate to contact me if you have any questions at (303) 692-3183. Sincerely, Matthew S. Burgett, P.E. Review Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division Carestream JUN -62014 June 3rd, 2014 Jayson Ellis Permit Engineer Air Pollution Control Division Colorado Department of Public Health and Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Re: Construction Permit Incorporation Request for Carestream Health, Inc. - Permit #06OPWE288 Dear Mr. Ellis: Carestream Health Colorado (CHC) has submitted and been approved for the Construction permit 13WE1752. This construction permit is for the Coating Assesment Laboratory (CAL). The CAL is part of the ongoing operations at CHC. Carestream is. requesting that the division incorporate this into the existing operating permit for the site (06OWE228) as a part of the permit renewal. Attached is a copy of the approved construction permit. Additionally the site manager has signed below to approve this request. Should you have any comments or questions, please contact me at 970-304-4619 or Keith.Runyon@carestream.com. Thank you for your consideration. Sincerely, wit 1,41- Keith Runyon Environmental Engin 7r (Facility Contact) 2000 Howard Smith Ave West C-42 Windsor, CO 80550 keith.runyon@carestream.com Enclosures Construction Permit 13WE1 752 C// Christopher Schmachtenberger Site Manager (Responsible Official) 2000 Howard Smith Ave West C-42 Windsor, CO 80550 c.schmachtenberger@carestream.com STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 13WE1752 DATE ISSUED: June 26, 2013 INITIAL APPROVAL ISSUED TO: Carestream Health, Incorporated THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Photographic film, paper, plate and chemical manufacturing facility, located at 2000 Howard Smith Avenue West, Windsor in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description NA 005 One (1) Coating assessment laboratory, model: N/A, SN: N/A and the associated volatile materials usage. 006 Fugitive equipment leaks THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL APPROVAL 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of the permitted operation or activity In submittinct a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation, compliance with the conditions contained on this permit shall be demonstrated to the Division. It is the permittee's responsibility to self certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit or enforcement action by the Division. Information on how to certify compliance was mailed with the permit or can be obtained from the Division. (Reference: Regulation No. 3, Part B, II.G.2) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) AIRS ID: 123/6350/005 & 006 Page 1 of 8 Carestream Health, Incorporated Permit No. 13WE1752 INITIAL APPROVAL Colorado Department of Public Health and Environment Air Pollution Control Division 4. Within one hundred and eighty days (180) after commencement of operation, the operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E. 5. Within one hundred and eighty days (180) after commencement of operation, the permit number or AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation No. 3, Part B, III.E.) (State only enforceable) 6. The manufacturer, model number and serial number of the subject equipment shall be provided to the Division within one hundred and eighty days (180) after commencement of operation. (Reference: Regulation No. 3, Part B, III.E.) EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated using the emission factors* included in the Notes to Permit Holder section of this permit). Annual records of the actual emission rates shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Emissions Per Averaging. Year (Rolling 12 Moth Total) (ton peryear) TSP PM�o PM2.5 SO2 NO), VOC CO Pb Emission Type NA 005 4.8 Point 006 1.2 0 Fugitive 8. The above emission rate is based on consumption rates, and on all other activities, operational rates and numbers of equipment as stated in the application. Annual records of the actual consumption rates shall be maintained by the applicant and made available to the Division for inspection upon request: (Reference: Regulation No. 3, Part B, III.E.) 9. Compliance with the annual emission limits listed above shall be demonstrated by adequate recordkeeping. The permit holder shall keep a compliance record on site for Division review. See Attachment A for an example of recordkeeping format. (Reference: Regulation 3, Part B.III.E) 10. See "Notes to Permit Holder #4" for information on emission methods used to calculate limits. PROCESS LIMITATIONS AND RECORDS 11. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Annual records of the actual process rate shall be maintained by the applicant and made available to the Division for inspection upon request (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit N/A 005 Volatile materials usage Shall be limited VOC limits above 006 Equipment component fitting counts AIRS ID: 123/6350/005 & 006 Page 2 of 8 Carestream Health, Incorporated Permit No. 13WE1752 INITIAL APPROVAL Colorado Department of Public Health and Environment Air Pollution Control Division Note * Emissions of organic material released during clean-up operations, disposal, and other fugitive emissions shall be included when determining total emissions, unless the source owner or operator documents that the VOC's are collected and disposed of in a manner that prevents evaporation to the atmosphere. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Opacity shall be determined using EPA Method 9. (Reference: Regulation No. 1, Section II.A.1. & 4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. This source is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart TT, Standards of Performance for Metal Coil Surface Coating, 40 C.F.R. Part 60 (July 1, 1998), and as amended on October 17, 2000 (65 FR 61744), including, but not limited to, the following: (i) § 60.462 Standards for volatile organic compounds. (a) On and after the date on which § 60.8 requires a performance test to be completed, each owner or operator subject to this subpart shall not cause to be discharged into the atmosphere more than: (1) 0.28 kilogram VOC per liter (kg VOC/l) of coating solids applied for each calendar month for each affected facility that does not use an emission control device(s); or (2) 0.14 kg VOC/I of coating solids applied for each calendar month for each affected facility that continuously uses an emission control device(s) operated at the most recently demonstrated overall efficiency; or 10 percent of the VOC's applied for each calendar month (90 percent emission reduction) for each affected facility that continuously uses an emission control device(s) operated at the most recently demonstrated overall efficiency; or (4) A value between 0.14 (or a 90 -percent emission reduction) and 0.28 kg VOC/I of coating solids applied for each calendar month for each affected facility that intermittently uses an emission control device operated at the most recently demonstrated overall efficiency. (3) 15. This source is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart W, Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry, 40 C.F.R. Part 60 (July 1, 1998), and as amended on October 17, 2000 (65 FR 61744), and as amended on December 14, 2000 (65 FR 87268), including, but not limited to, the following: (i) § 60.482-1 Standards: General. (a) Each owner or operator subject to the provisions of this subpart shall demonstrate compliance with the requirements of §§ 60.482-1 through 60.482-10 or § 60.480(e) for all equipment within 180 days of initial startup. (b) Compliance with §§ 60.482-1 to 60.482-10 will be determined by review of records and reports, review of performance test results, and inspection using the methods and procedures specified in § 60.485. 16. This source is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart FFF, Standards of Performance for Flexible Vinyl and Urethane Coating and Printing, 40 C.F.R. Part 60 (July 1, 1998), and as amended on October 17, 2000 (65 FR 61744), including, but not limited to, the following: (i) § 60.582 Standard for volatile organic compounds. AIRS ID: 123/6350/005 & 006 Page 3 of 8 Carestream Health, Incorporated Permit No. 13WE1752 INITIAL APPROVAL Colorado Department of Public Health and Environment Air Pollution Control Division (a) On and after the date on which the performance test required by § 60.8 has been completed, each owner or operator subject to this subpart shall either: (1) Use inks with a weighted average VOC content less than 1.0 kilogram VOC per kilogram ink solids at each affected facility, or (2) Reduce VOC emissions to the atmosphere by 85 percent from each affected facility. 17. In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply. a. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation No. 6, Part A. General Provisions from 40 CFR 60.11 b. No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§ 60.12) c. Written notification of construction and initial startup dates shall be submitted to the Division as required under § 60.7. d. Records of startups, shutdowns, and malfunctions shall be maintained, as required under § 60.7. 18. This source is located in an ozone non -attainment or attainment -maintenance area and subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.b. No control due to high cost per ton of pollutant removed was determined to be RACT for this source. OPERATING & MAINTENANCE REQUIREMENTS 19. The owner or operator shall develop an operating and maintenance (O&M) plan, along with a recordkeeping format, that outlines how the applicant will maintain compliance on an ongoing basis with the requirements of this permit. Compliance with the O&M plan shall commence at startup. Within one hundred and eighty days (180) after commencement of operation, the owner or operator shall submit the O&M plan to the Division. Failure to submit an acceptable operating and maintenance plan could result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.E.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 20. The owner or operator of this source shall conduct an initial performance test as required under § 60.8(a) and thereafter a performance test for each calendar month for each affected facility according to the procedures in this section. Periodic Testing Requirements 21. Periodic testing is met by compliance with the requirement of condition no. 17 above. AIRS ID: 123/6350/005 & 006 Page 4 of 8 Carestream Health, Incorporated Permit No. 13WE1752 INITIAL APPROVAL Colorado Department of Public Health and Environment Air Pollution Control Division ADDITIONAL REQUIREMENTS 22. The permit number shall be marked on the subject equipment for ease of identification. (Reference: Regulation No. 3, Part B, III.E.) (State only enforceable) 23. A Revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Reg. 3, Part A,II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five tons per year or more, above the level reported on the last APEN submitted; or For VOC sources in the Denver Metro ozone attainment -maintenance area emitting less than 100 tons of VOC per year, a change in actual emissions of one ton per year or more or five percent, whichever is greater, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 24. This source is subject to the provisions of Regulation No. 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of the issuance of this permit. GENERAL TERMS AND CONDITIONS: 25. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the Division as provided in Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 26. If this permit specifically states that final approval has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final approval of the permit must be secured from the Division in writing in accordance with the provisions of 25- 7-114.5(12)(a) C.R.S. and Regulation No. 3, Part B, Section III.G. Final approval cannot be granted until the operation or activity commences and has been verified by the Division as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final approval. Details for obtaining final approval to operate are located in the Requirements to Self -Certify for Final Approval section of this permit. 27. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with AIRS ID: 123/6350/005 & 006 Page 5 of 8 Carestream Health, Incorporated Permit No. 13WE1752 INITIAL APPROVAL Colorado Department of Public Health and Environment Air Pollution Control Division representations made by the applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 28. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the Division to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 29. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Division on grounds set forth in the Colorado Air Pollution Prevention and Control Act and regulations of the AQCC including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 30. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 31. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: • Sunday A. Fadeyi, P. E. Permit Engineer Permit History: By: R K Hancock III, P.E. Construction Permits Unit Supervisor Issuance Date Description Initial Approval This issuance Issued to Carestream Health, Incorporated Notes to Permit Holder: 1) The production or raw material processing limits and emission limits contained in this permit are based on the production/processing rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedence of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be submitted with a request for a permit revision. 2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as AIRS ID: 123/6350/005 & 006 Page 6 of 8 I Carestream Health, Incorporated Permit No. 13WE1752 INITIAL APPROVAL Colorado Department of Public Health and Environment Air Pollution Control Division soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.cdphe.state.co.us/regulations/airregs/5CCR1001-2.pdf. 3) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations AIRS Point Pollutant CAS BIN Controlled Emission Rate (lb/yr 005 & 006 Dimethylformamide 68-12-2 A 533 Methyl Isobutyl Ketone 108-10-1 B 533 Methanol 67-56-1 C 3,198 Toluene 108-88-3 C 3,198 4) The emission levels contained in this permit are based on the folbwing controlled emission factors: Point 005 & 006 - Volatile Materials Usage: VOC/HAP Emissions: Mass balance assuming that the entire solvent contents in the products are emitted. VOCemissions = (ProdUCtconsumption)`(VOC%), TSP/PM10/PM2.5 emissions = (Product consumption)•(Particulate%)•(1-TE)*(1-CE), Where: Productconsumption = Beginning Inventory + New Purchases — End Inventory VOC%/ HAP% is in weight percent (i.e. VOC/HAP's weight percent in the product), Particulate% is in weight percent (i.e. particulate's weight percent in the product) TE = Transfer Efficiency in weight percent CE = Control efficiency if weight fraction If volatile materials consumption is in tons, then emissions are in tons per year. If volatile materials consumption is in Ibs, then emissions are in lbs per year. 5) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 6) This facility is classified as follows: Applicable Requirement Status Operating Permit Minor at a major Title V facility, VOC NANSR/PSD Minor at a major Title V facility, VOC 7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: httg://ecfr.ggoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart TT, FFF and VVV NSPS Part 60, Appendixes Appendix A — Appendix I AIRS ID: 123/6350/005 & 006 Page 7 of 8 PUBLIC COPY Carestream 2000 Howard Smith Avenue West Windsor, CO 80550 970.304.4600 December 1, 2017 Mr. Ramazan Spencer Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: Carestream Health, Inc. Title V Operating Permit Application for Modification — PET Pellet Unloading HEPA Filter Operating Permit No. 060PWE288 Dear Mr. Spencer, Carestream Health, Inc. (CHC) is pleased to submit to the Colorado Department of Public Health and Environment Air Pollution Control Division (Division) the attached Title V Operating Permit application for modification (Attachment A) and APEN (Attachment B). Per your direction, the application includes Forms 2000-100, 2000-601, 2000-603, and 2000-800. The application for modification is being submitted for the "Railroad Car PET Pelet Unloading" HEPA filter located in the Polymer Yard of Building C-50, and identified in Appendix G of Operating Permit No. 06OPWE288 (Permit) as F -50 -SS. In April 2017, during the Division's review of CHC's Title V renewal application, a question was raised whether the HEPA filter controlling 1Iie "Railroad Car PET Pellet Unloading" process is subject to compliance assurance monitoring (CAM). Further questions were raised regarding the facility -wide PM/PM10 emission limit (15 tons per year [tpy]) and whether the current equation for calculating emissions of PM/FM10 included in Permit Condition 1.1 for the "Railroad Car PET Pellet Unloading" HEPA filter was truly representative of the process. The equation is as follows: Railroad Car PET Pellet Unloading: PM/PM10 Emissions = (PET pellet throughput Ib/yr) (1 — 0.9999) (0.005) (ton/2,000 lb) Where: "0.9999" represents the removal efficiency of the filter element "0.005" represents the weight fraction of the incoming PET stream that is bypassing the cyclone separator, i.e., the Bypass Weight Fraction (BWF) Mr. Matthew Burgett of the Division wrote a technical review document in 2007 providing the background on the basis for the equation: PUBLIC COPY December 1, 2017 Mr. Ramazan Spencer CDPHE Page 2 Emission Factors — Railroad car pellet unloading: The PET pellets are unloaded from the rail cars via air conveyance. The pellets are conveyed to a storage silo. The conveyance system consists of a cyclone separator, dust collector and HEPA filter. The Division considers the cyclone separator and dust collector to be integral process equipment since the main purpose is to collect the PET material, not to control emissions. Collected material is recycled back into the process. This equipment meets the requirements of PS Memo 96-4. The cyclone and dust collector can be considered when determining uncontrolled emissions. The following equation can be used to estimate emissions and is based on 0.5% of the pellet throughput being emitted as PM & PM1o: PM & PM10 = PET pellet throughput lb/yr x (1-0.9999) x 0.005 x ton/2000 lb CHC firmly believed the assumption in the Permit that 0.5% (0.005 wt. fraction) of the PET pellet throughput is being emitted as PM/PM10 was inaccurate and/or not representative of the process. At the direction of the Division via email dated June 12, 2017, CHC prepared a test plan/protocol for review and approval to conduct testing to establish a more accurate and representative BWF and to demonstrate that plant -wide PM/PM10 emission limits have not been exceeded nor is the HEPA filter subject to CAM requirements. In addition, the control efficiency of 99.99% was also incorrect; the HEPA filter vendor guarantees are 97% for 1 micron and 99.5% for 2 microns. The Division agreed that a conservative HEPA filter control efficiency of 97% would be used in the equation instead of 99.99% for future compliance demonstrations. The Test Plan is provided as Attachment C. Table 1 provides the test results. Results of the sampling were consistent and as expected in that the BWF decreased as the filter element became dirtier. The most conservative results were obtained with a brand new, clean filter element. The results indicate that the current assumed BWF of 0.005 is grossly over -estimated. Thus, CHC is requesting that the current equation as listed in Permit Condition 1.1 for the "Railroad Car PET Pellet Unloading" HEPA filter be corrected as follows: PM/PM10 Emissions = (PET pellet throughput Ib/yr) (1 — 0.97) (3.470&06) (ton/2,000 lb) Where: "0.97" represents the removal efficiency of the filter element "3.47e-°6" represents the BWF It should be noted that the proposed BWF of 3.47e06 is based on the BWF obtained with the brand new, clean filter element with a safety factor of 20% added for conservatism: (2.892e 06) (1.20) = 3.470e °6 PUBLIC COPY • The HEPA filter housing contains 2 filter elements. A certified scale will be used to weigh the filters, and both filters will be weighed simultaneously. • CHC typically offloads 2 railcars of PET pellets sequentially prior to completing offloading activities, however, this is not always the case. If/When CHC offloads more than one railcar before re - weighing the filter elements then the total weight of the PET pellets offloaded will be used to calculate the bypass rate for that particular trial run. • Particulates are not deposited on the filter elements when offloading activities are not in process, and therefore, the weight of the HEPA filter elements is assumed to be constant between offloading activities. Thus, the AFTER weight obtained after offloading the first set of railcars is assumed to be equivalent to the BEFORE weight for the next set of railcars. • According to the manufacturer, the removal efficiency of the filter element is 97% on 1 micron and 99.5% on 2 microns. Due to lack of definitive information on the particle size of the emitted particulates, and in order to be conservative, the removal efficiency is assumed to be 97%. Procedure 1. Remove the filter elements from the housing. Tare the certified scale. Weigh both filter elements. Record the weight in grams. This is the BEFORE weight. Re -install the filter elements. 2. Unload the PET pellets from a railcar and record the weight of the PET pellets as provided on the Bill of Lading. If more than one railcar is offloaded, then record the total weight of PET pellets. 3. Remove the filter elements from the housing. Tare the certified scale. Weigh both filter elements. Record the weight in grams. This is the AFTER weight. Re -install the filter elements. 4. Calculate the bypass rate: [AFTER] (g) — [BEFORE] (g) ( 1 (kg) / 1 l Weight of PET Pellets (kg) x 1000 (g) x \0.97/ = Bypass Rate Where 0.97 is the filter efficiency. 5. Calculate the emission rate: Efficiency of Filter Element Bypass Rate x ( 100 ) = Emission Rate 6. Repeat steps 1— 5 a minimum of three times. 7. Calculate the average Bypass Rate and average Emission Rate. Page 2 of 2 PUBLIC COPY 2000 Howard Smith Avenue West Windsor, CO 80550 970.304.4600 Proposed Test Plan Determination of PET Pellet HEPA Filter Emission Rate Carestream Health, Inc. (CHC) believes the PET pellet HEPA filter bypass rate in the facility Title V air permit (permit number 06OPWE288) is inaccurate and is proposing the following methodology to calculate an actual bypass rate and emission rate. Introduction The emissions calculation for PET pellet unloading in the Title V permit is: Railroad Car PET Pellet Unloading: PM/PM10 Emissions = PET pellet throughput lb/yr x (1- 0.9999) x 0.005 x ton/2000 lb Where "0.9999" represents the removal efficiency of the filter element, and "0.005" represents that portion of the incoming stream, i.e., 0.5%, that is assumed to bypass the cyclone separator (CS -30B). This is discussed in a technical review document written by Mr. Burgett in 2007: Emission Factors — Railroad car pellet unloading: The PET pellets are unloaded from the rail cars via air conveyance. The pellets are conveyed to a storage silo. The conveyance system consists of a cyclone separator, dust collector and HEPA filter. The Division considers the cyclone separator and dust collector to be integral process equipment since the main purpose is to collect the PET material, not to control emissions. Collected material is recycled back into the process. This equipment meets the requirements of PS Memo 96-4. The cyclone and dust collector can be considered when determining uncontrolled emissions. The following equation can be used to estimate emissions and is based on 0.5% of the pellet throughput being emitted as PM & PM1o: PM & PM -to = PET pellet throughput lb/yr x (1-0.9999) x 0.005 x ton/2000 lb CHC believes the bypass rate is inaccurate as discussed in emailed correspondence from Laura Jackson of CHC to Ramazan Spencer at CDPHE on June 9, 2017. In order to determine a source -specific emissions rate, CHC proposes that the filter elements be weighed before and after transferring a railcar(s) of PET pellets according to the following methodology and in light of the following assumptions: Assumptions • CHC receives PET pellets via railcar. CHC does not have an onsite rail scale, and therefore the weight of the PET pellets provided by the vendor is assumed to be accurate. Page 1 of 2 PUBLIC COPY December 1, 2017 Mr. Ramazan Spencer CDPHE Page 4 These potential -to -emit emission rates clearly demonstrate that the facility -wide PM/PMio emission limit (15 tons per year [tpy]) has not been exceeded nor is the source subject to CAM requirements. In addition to the complete permit application package, APEN fees in the amount of $152.90 for one (1) APEN have been paid and a copy of the receipt is attached. Please note, CHC received assistance from the Small Business Assistance Unit in completing the APEN. Should you have any questions regarding this submittal, please contact Laura Jackson at laura.pales@carestream.com or via phone at 970.304.4768. Thank you for your assistance throughout the course of this project. Sincerely, Christopher Schmachtenberger Colorado Site Manager Attachments: As stated cc: Jamie Christopher, SLR Michael Boyer December 1, 2017 Mr. Ramazan Spencer CDPHE Page 3 Table 1 PET Pellet Unloading Activities Development of PET Pellet Bypass Weight Fraction Loading to HEPA Filter Date Weight of Filter Elements [BEFORE] Weight of Filter Elements [AFTER] PET Captured by Filter ([AFTER] - [BEFORE]) Number of Railcars Offoaded Total Weight of PET Pellets Offloaded Bypass Wt. Fraction DI 06/14/17 9.114 kg 9.304 kg 0.190 kg 2 172,862 kg 1.133E-06 06/19/17 9.304 kg 9.486 kg 0.182 kg 2 158,756 kg 1.182E-06 06/30/17 9.486 kg 9.912 kg 0.426 kg 4 338,054 kg 1.299E-06 07/05/17 9.912 kg 10.166 kg 0.254 kg 6 504,756 kg 5.188E-07 07/18/17 10.166 kg 10.398 kg 0.2s2 Kg 5 427,892 kg 5.590E-07 07/26/17 10.398 kg 10.674 kg 0.276 kg 5 434,226 kg 6.553E-07 Average 8.912E-07 Maximum Rate 1.299E-06 Test completed with new filter 10/28/17 I 7.174 kg I 9.054 kg I 1.880 kg I 6 I 670,266 kg I 2.892E-06 Requested Bypass Wt. Fraction (2) 3.470E-06 Ill Assumes a filter efficiency of 97%. x(2) Based on Bypass Wt. Fraction from new filter data plus a 20% safetyfactor. Results of the sampling were consistent and expected (i.e., Bypass Wt. Fraction decreased as the filter became dirtier). Most conservative Bypass Wt. Fraction is therefore based on new filter data plus 20% safety factor: (2.892e-06) (1.20) =3.470e°6. AdO3 011Stld PUBLIC COPY Carestrecim Attachment A - Operating Permit Application Forms FORM 2000-100 Facility Identification FORM 2000-601 Emission Unit Criteria Air Pollutants FORM 2000-603 Plant -Wide Criteria Air Pollutants FORM 2000-800 Tabulation of Permit Application Forms & Signature of Responsible Official PUBLIC COPY 1 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division FACILITY IDENTIFICATION SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-100 Rev 06-95 1. Facility name and Name mailing address Street or Route City, State, Zip Code Carestream Health, Inc. 2000 Howard Smith Avenue West Windsor, Colorado 80550 2. Facility location Street Address (No P.O. Box) City,County, Zip Code 2000 Howard Smith Avenue West Windsor, Colorado 80550 3. Parent corporation Name 4. Responsible Street or Route City, State, Zip Code Country (if not U.S.) Carestream Health, Inc. 150 Verona St. Rochester, NY 14608 Name official Title Telephone 5. Permit contact person Name Title (If Different than 4) Telephone 6. Facility SIC code: Christopher L. Schmachtenberger Colorado Site Manager 970-304-4712 Laura Jackson Pales Environmental Engineer 970-304-4768 3861 8. Federal Tax I. D. Number: 7. Facility identification code: CO 1236350_ 9. Primary activity of the operating establishment: Manufacturer of photographic supplies 10. Type of operating permit New Modified X Renewal 11. Is the facility located in a "nonattainment" area: Yes X No If "Yes", check the designated "non -attainment" pollutant(s): Carbon Monoxide Ozone X PM10 Other (specify) 12. List all (Federal and State) air pollution permits (including grandfathered units), plan approvals and exemptions issued to this facility. List the number, date and what unit/process is covered by each permit. For a Modified Operating Permit, do not complete this item. Not applicable - this is an application for Modified Operating Permit. PUBLIC COPY Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-601 09-94 1. Facility name: Carestream Health, Inc. 2. Facility identification code: CO 123635.0 3. Stack identification code: PET HEPA Filter 4. Unit identification code: F -50 -SS 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U^ TPY. U TPY Particulates (TSP) 0.0037 TPY 0.0037 PM -10 0.0037 TPY 0.0037 Nitrogen oxides TPY Volatile organic compounds TPY Carbon monoxide TPY Lead TPY Sulfur dioxide TPY Total reduced sulfur TPY Reduced sulfur compounds Hydrogen sulfide TPY TPY Sulfuric Acid Mist TPY Fluorides TPY TPY TPY TPY TPY Units (U) should be entered as follows: 1 = lb/hr 2 = lb/mmBTU 3 = grains/dscf 4 = lb/ gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 = other (specify) 9 = other (specify) 10 = other (specify) 74 PUBLIC COPY EMISSION UNIT CRITERIA AIR POLLUTANTS -- Form 2000-601 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permits. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. Item 1 Provide the name of the facility. Item 2 Provide the facility identification (FID) code. Item 3 Provide the identification code of the stack that exhausts this equipment. Use the same code used on form 2000-200. Item 4 Provide the identification code from the appropriate form(s) 2000-300, -301, -302, -303, -304, -305, -306, or -307 completed for the emissions unit that will have its emissions summarized on this form. Item 5 Provide the emission levels for each listed pollutant emitted from this source. The emissions should be presented using the same units as the applicable limits shown on Form 2000-604 and in Inns per year (TPY). The list of footnotes found in the lower left corner of this form allows the applicant to specify the units of each reported emission level. To specify the appropriate units, write the appropriate footnote number in the columns headed by the letter "U". For example: to indicate an emission rate of 3.2 lbs SO2/MMBTU, write on the line for sulfur dioxide (S02). Sulfur dioxide 3.2 2 Potential to emit should represent emissions at full production capacity of the source after reduction by any air pollution control equipment. This is normally 24 hours/day for 365 days/year (i.e., 8760 hours/year), although physical or operational limitations that are in a construction permit issued by the Division, or in the applicable emission control regulation, are considered in determining the potential to emit. Please see the instruction manual for the precise definition of "potential to emit" You may want to use emission factors to determine these emissions. Maximum allowable emissions should represent the greatest amount of emissions allowed under any permit or applicable standards, taking into consideration the equipment limitations, such as line speed, and pollution control efficiencies of the equipment. In cases where the emission unit has a construction permit, the maximum allowable emissions are equal to the potential to emit. Please remember to: Report hazardous air pollutants on Forms 2000-600 and 2000-602. State the reference(s) for the calculations. Emission factors may be compiled in published documents, such as EPA's AP - 42, or may be based on stack test results. A separate page of numbered references is appropriate and may be attached to form 2000-601. Form 2000-700 may be used for this purpose. 75 PUBLIC COPY Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE PLANT -WIDE CRITERIA AIR POLLUTANTS FORM 2000-603 09-94 1. Facility name: Carestream Health, Inc. 2. Facility identification code: CO 123535a. 3. Complete the following emissions summary fpr the listed emissions at this facility. Air pollutant Actual Potential to emit Maximum allowable TI'Y TPY TPY Particulates (TSP) 15.0 15.0 PM -10 15.0 15.0 Nitrogen oxides Volatile organic compounds 48.3 48.3 Carbon monoxide Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric acid mist Fluorides 78 PUBLIC COPY PLANT -WIDE CRITERIA AIR POLLUTANTS -- Form 2000-603 AIR POLLUTION CONTROL, OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permits. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area Item 1 Provide the name of the facility. Item 2 Provide the facility identification (FID) code. Item 3 Provide the emission levels in tons per year (TPY). For each pollutant emitted from the facility, sum the annual actual, potential to emit, and the maximum allowable emission rates (tons per year only) reported for all of the facility's emission units. The individual values are on each Form 2000-601 completed for the application. The totals for each pollutant should be reported on Form 2000-603 in tons per year (TPY). ***** Hazardous air pollutant emissions should be reported on Forms 2000-600 and 2000-602. ***** 79 Operating Permit Application Colorado Department of Health Air Pollution Control Division Facility Name: Carestream Health, Inc. I. ADMINISTRATION TABULATION OF PERMIT APPLICATION FORMS Facility Identification Code: CO 1236350 09-94 PUBLIC COPY FORM 2000-800 This application contains the following forms: 2000-100, 2000-601, 2000-603, 2000-800 Form 2000-100, Facility Identification X Form 2000-101, Facility Plot Plan N/A Forms 2000-102, -102A, and -102B, Source and Site Descriptions N/A II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler, printing operation, etc.): Form 2000-200, Stack Identification 0 Form 2000-300, Boiler or Furnace Operation 0 Form 2000-301, Storage Tanks 0 Form 2000-302, Internal Combustion Engine 0 Form 2000-303, Incineration 0 Form 2000-304, Printing Operations 0 Form 2000-305, Painting and Coating Operations 0 Form 2000-306, Miscellaneous Processes 0 Form 2000-307, Glycol Dehydration Unit 0 III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following forms: Form 2000-400, Miscellaneous 0 Form 2000-401, Condensers 0 Form 2000-402, Adsorbers 0 Form 2000-403, Catalytic or Thermal Oxidation 0 Form 2000-404, Cyclones/Settling Chambers 0 Form 2000-405, Electrostatic Precipitators 0 Form 2000-406, Wet Collection Systems 0 Form 2000-407, Baghouses/Fabric Filters 0 IV. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the following forms (one for each facility boiler, printing operation, etc.): Form 2000-500, Compliance Certification - Monitoring and Reporting 0 Form 2000-501, Continuous Emission Monitoring 0 Form 2000-502, Periodic Emission Monitoring Using Portable Monitors 0 Form 2000-503, Control System Parameters or Operation Parameters of a Process 0 Form 2000-504, Monitoring Maintenance Procedures 0 Form 2000-505, Stack Testing 0 Form 2000-506, Fuel Sampling and Analysis 0 Form 2000-507, Recordkeeping 0 Form 2000-508, Other Methods 0 92 PUBLIC COPY Operating Permit Application Colorado Department of Health Air Pollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 09-94 Facility Name: Carestream Health, Inc. Facility Identification Code: CO 1236350 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY CONDITIONS I certify that the facility described in this air pollution permit application is fully I certify that the facility described in this air pollution permit application is fully for the following emissions unit(s): after reasonable inquiry, I certify that the statements (check one box only) in compliance with all applicable requirements. in compliance with all applicable requirements, except material statement, representation, or certification be punished in accordance with the provisions of § 25- (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false in, or omits material information from this application is guilty of a misdemeanor and may 7 122.1, C.R.S. Printed or Typed Name Christopher L. Schmachtenberger Title Colorado Site Manager Signature Date Signe ,- s Z(::// SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 94 PUBLIC COPY V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan Form 2000-600, Emission Unit Hazardous Air Pollutants Form 2000-601, Emission Unit Criteria Air Pollutants 1 Form 2000-602, Facility Hazardous Air Pollutants 0 Form 2000-603, Facility Criteria Air Pollutants 1 Form 2000-604, Applicable Requirements and Stairs of Emission Unit 0 Form 2000-605, Permit Shield Protection Identification 0 Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule 0 Form 2000-607, Plant -Wide Applicable Requirements 0 Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule 0 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS I certify that the facility described in this air pollution permit application is fully I certify that the facility described in this air pollution permit application is fully for the following emissions unit(s): after reasonable inquiry, I certify that the statements (check one box only) in compliance with all applicable requirements. in compliance with all applicable requirements, except material statement, representation, or certification be punished in accordance with the provisions of § 25- (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false in, or omits material information from this application is guilty of a misdemeanor and may 7122.1, C.R.S. Printed or Typed Name Christopher L. Schmachtenberger Title Colorado Site Manager Signature Date Signed A2//' //,7 Cam✓` 93 PUBLIC COPY Carestream Attachment B - Air Pollution Emission Notice (APEN) APCD Form 200 General APEN APEN Filing Fee Receipt PUBLIC COPY Carestream Attachment C Test Plan - Determination of PET Pellet HEPA Filter Emission Rate PUBLIC COP General APEN - Form APCD-200 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. There may be a more specific APEN for your source (e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 06OPWE288 002 AIRS ID Number: 123 /6350 /N/A [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Site Name: Site Location: Mailing Address: (Include Zip Code) Carestream Health, Inc. Carestream Health Colorado 2000 Howard Smith Ave West Windsor, CO 80550 2000 Howard Smith Ave West Windsor, CO 80550 Portable Source N/A Home Base: Site Location Weld County: NAICS or SIC Code: 325992 Permit Contact: Laura Jackson Phone Number: 970.304.4768 E Mail Address2: laura.pales@carestream.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 37 2329 06OPWE288 PUBLIC COPY 123 6350 N/A Section 2- Requested Action ❑ NEW permit OR newly -reported emission source (check one below) O STATIONARY source ❑ PORTABLE source -OR - ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name O Add point to existing permit O Change permit limit ❑ Transfer of ownership;❑ Other (describe below) OR- ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: Revise the PM/PM10 emissions calculation for railroad car PET pellet unloading activities included in Section I - Condition 1.1 of Colorado Operating Permit # 06OPWE288. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: The PET pellet unloading HEPA filter is located on the inlet to CR-50 and removes particulates from the discharge air stream during PET conveyance. Manufacturer: Universal Model No.: ILVF-10 Company equipment Identification No. (optional): For existing sources, operation began on: N/A Serial No.: N/A 2007 For new or reconstructed sources, the projected start-up date is: NJA E Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Seasonal use percentage: Dec -Feb: Mar -May: Jun -Aug: Sep -Nov: 060PWE288 PUBLIC COPY 123 6350 N/A Section 4 - Processing/Manufacturing Information Et Material Use 0 Check box if this information is not applicable to source or process From what year is the actual annual amount? Material _ _ Consumption: Finished Product(s): Design Process Rate (Specify Units) Actual Annual Amount (Specify Units) Requested Annual Permit Limit4 (Specify Units)` 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) • Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. ).T A "k 4 �� _ 4 Operator Sta D o. 44A141. K �ptschargeHeight �, =.y ove Groulrrd Level eel r �- 3� k (�k�w y � a' S,Tt5 . zT Temp _��fAC _. f� ryysl 1' Flow Rafe ) ,-. rix e h 1Ce oc t r sec Indicate the direction of the stack outlet: (check one) ❑ Upward O Horizontal El Downward O Other (describe): Indicate the stack opening and size: (check one) O Circular Interior stack diameter (inches): O Upward with obstructing raincap ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): O Other (describe): 06OPWE288 PUBLIC COPY 123 6350 N/A Section 6 - Combustion Equipment >* Fuel Consumption Information 0 Check box if this information is not applicable to the source (e.g. there is no fuel -burning equipment associated with this emission source) Design Input Rate (MMBTU/hr) Actual Annual Fuel Use (Specify Units) Requested Annual Permit Limit4 (Specify Units) From what year is the actual annual fuel use data? Indicate the type of fuel used5: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) ❑ Field Natural Gas Heating value: BTU/SCF ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑ Coal Heating value: BTU/lb Ash Content: Sulfur Content: ❑ Other (describe): Heating value (give units): a Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description - Overall Collection Efficiency ` Overall Control Efficiency (% reduction in emissions) TSP (PM) HEPA Filter 97% PM,0 HEPA Filter 97% PM2.5 SOX NO), CO VOC Other: ;0 ,L• 06OPWE288 PUBLIC COPY 123 6350 N/A Section 7 (continued) From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these em Pollutant Uncontrolled Emission Factor (Specify Units) Emission Factor Source (� etc_Mfg. 4ctual Annual Ertlissions �, nested' ' ` o : uaC P mit aft s Uncontrolled ons/year) C(Tons/yeard)6 Uncontrolled (Tons/year (Tons/year) Controlled (Tons/year) TSP (PM) 3.47E-06 lb/lb Test Data N/A N/A PM10 3.47E-06 lb/lb Test Data N/A N/A PM25 SOx NOx CO VOC Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP- hazardous air pollutant) emissions equal to or greater than 250 lbs/year? O Yes E No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: CAS Nurnberg Chemical Name Overall Control Efficiency Uncontrolled Emission Factor (specify units) Emission Factor Source (AP -42, Mfg. etc) Uncontrolled Actual. Emissions (lbs/year) Controlled - Actual ,` Emissions6 (lbs/year) 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 06OPWE288 PUBLIC COPY 123 6350 N/A Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. December 1, 2017 Signature of Legally Author ed Person (not a vendor or consultant) Date Christopher Schmachtenberger Colorado Site Manager Name (print) Title Check the appropriate box to request a copy of the: ❑r Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Carestream 2000 Howard Smith Avenue West Windsor, CO 80550 970.304.4600 April 12, 2018 Mr. Ramazan Spencer Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: Carestream Health, Inc. Title V Operating Permit Application for Modification Operating Permit No. 06OPWE288 Dear Mr. Spencer: Carestream Health Inc., Colorado site (CHC) is pleased to submit to the Colorado Department of Public Health and Environment Air Pollution Control Division (Division) the attached Title V Operating Permit application for modification (Attachment A) and APEN (Attachment B). Per your direction the application includes Forms 2000-100, 2000-601, 2000-603, and 2000-800. The application for modification is being submitted for the "PET Reuse Project". In addition, CHC is requesting two administrative amendments be made to the current Operating Permit No. 06OPWE288 (Permit). PET REUSE PROJECT The purpose of the polyethylene terephthalate (PET) Reuse Project is to convert uncoated waste PET material, currently sold to outside recycling companies, into reusable PET pellets to be used in the C-50 PET extrusion process. CHC produces varying amounts of scrap with every roll of web produced. This PET scrap is a result of various manufacturing process including, but not limited to: • Trimming the wide roll edges to remove the crimped edge caused by tentor clips, • Trimming web to customer-speciic widths, • Leaving a small amount of web on the core to facilitate splicing, etc. The proposed process is depicted in Figure 1. The operation will take in PET scrap in various forms (i.e., extruded purgings, rolls, sheets, etc.) which will be shredded into pieces within a fully enclosed compartment, melted, vacuum degassed, filtered for impurities, and then extruded into long PET strands. The PET strands will then be cooled in a water bath and pelletized (cut into pellet form, also under water), dewatered, and dispensed into storage containers. The containers will be transferred to an on -site storage location, and the pellets will be reused in the main extrusion process as needed by product type. Particulate emissions generated during the scrap PET reuse process are removed via an existing cyclone separator ("Scrap Re -Use Cyclone"). In January 2012, CHC submitted an off -permit modification for the "Scrap Re -Use Cyclone" to allow for an additional source of manufacturing scrap to be processed simultaneously with the existing flow of recovered PET through the cyclone. Historically this cyclone has been considered an insignificant source. CHC believes that this modification does not change its standing as an insignificant source. April 12, 2018 Mr. Ramazan Spencer Colorado Department of Public Health and Environment Page 2 In December 2011, at the request of the Division, CHC conducted emissions measurements on the cyclone to determine the potential maximum emissions for the cyclone. Emissions at maximum capacity and flow rate were determined to be 0.0246 pounds PM10 per hour (lb/hr). For conservatism, to account for the additional source of PET scrap, CHC has applied a safety factor of 50% to this value and the resulting emissions level is as follows: (0.0246 lb PM10 / hr) * (1.5) = 0.0446 lb PM10 / hr; or (0.0446 lb PN/110 / hr) * (8,760 hr / yr) * (ton / 2,000 lb) = 0.20 tons PM10 / yr CHC has conservatively assumed the "Scrap Re -Use Cyclone" control efficiency to be 80%, which would mean the estimated uncontrolled PM10 emissions are approximately 1.0 tpy, which is less than the 2 tpy APEN reporting threshold. However, for conservatism we have provided an APEN for this source in Appendix B. Volatile organic compounds (VOCs) will also be emitted during the PET reuse extrusion process identified in Figure 1. The VOC emissions will be calculated according to the permitted "thermal degradation by-products in extruded material" emission calculation included in the Operating Permit: VOC emissions = 64 (lbs VOC/Million lbs extruded) x Extruder Throughput (Million lbs/month) Based on a maximum operating capacity of 500 pounds of scrap per hour, the annual uncontrolled VOC emissions generated by the PET Reuse Project are: lbs VOC 500 mmlbs hr lbs 64 x 8760 yr = 280 y mmlbs x 10E6 hr r This is less than the 1 tpy APEN reporting threshold. ADMINISTRATIVE AMENDMENT REQUEST #1 CHC has not consumed PET in powder form in several years, however CHC would like to retain the option of using powder in the future. The current emission factor affiliated with the consumption of PET powder assumes a consumption rate of 8760 hrs per year. CHC would like to revise the calculation to include actual hours of operation in lieu of 8760 hrs per year. CHC requests that the equation for calculating emissions of PM/PM10 as contained in Permit Condition 1.2 for particulate emissions generated in Building C-50: Railroad Car PET Powder Unloading: PM/PM10 Emissions = 0.01 gr/dscf x 888 dscfm x 8760 hr/yr x 60 min/hr x lb/7000 gr x ton/2000 lb Be modified as follows: Railroad Car PET Powder Unloading: PM/PM10 Emissions = 0.01 gr/dscf x 888 dscfm x X hr/yr x 60 min/hr x lb/7000 gr x ton/2000 lb where "X" equals the actual hours of operation. April 12, 2018 Mr. Ramazan Spencer Colorado Department of Public Health and Environment Page 3 ADMINISTRATIVE AMENDMENT REQUEST #2 CHC requests that the following equation for calculating emissions of PM/PM10 as contained in Permit Condition 1.2 for particulate emissions generated in Building C-50 be removed from the Operating Permit: Chemical Making: PM/PM10 Emissions = Amount of Resorcinol consumed. Resorcinol is a powder. This equation indicates that 100 percent (%) of the powder consumed is emitted as particulate matter to the atmosphere. This is an inaccurate assumption and is not correct. Resorcinol is a key ingredient that remains in the web product. There are two ways in which particulate matter is created due to processing of resorcinol: • Emissions generated during dispensing of the powdered resorcinol in the chemical making process, and • Emissions generated during processing of resorcinol -containing scrap PET web. Fugitive emissions created during chemical weighing activities are already included in the "Chem Weighing Hood" calculation listed in the permit: Chemical Weighing Hood: PM/RM10 Emissions = 0.04 gr/dscf x 8500 dscfm x 365 hr/yr x 60 min/hr x lb/7000 gr x ton/2000 lb In addition, particulate emissions generated as a result of processing scrap web material that contains resorcinol are accounted for under the PET Reuse Project discussed above. As such, please remove the Chemical Making equation from the permit as emissions generated from processing resorcinol are accounted for in other emission calculations. In addition to the complete permit application package, APEN fees in the amount of $152.90 for one (1) APEN will be paid online with a credit card. We trust the attached permit application package will meet your expectations. Please contact Laura Jackson at (970) 304-4768 or via email at laura.pales@carestream.com if you have any questions or need additional information. Sincerely, Christophe Site Manager Attachments: As stated erger cc: Jamie Christopher, SLR Figure 1. PET Reuse Process Particulates to Scrap Re -use Cyclone ".11 DIED III(Illll, IX! Pa! IIIHI Ik ROII n ph I(HI II (I! h pill Illtl I R ;r1 filr {IIII!III Rol irtfee. Vacuum Extraction Screen Changer Pelii Co14ecticn Atmosphere via Extruder Room Exhaust System Dewatering Attachment A - Operating Permit Application Forms FORM 2000-100 Facility Identification FORM 2000-601 Emission Unit Criteria Air Pollutants FORM 2000-603 Plant -Wide Criteria Air Pollutants FORM 2000-800 Tabulation of Permit Application Forms & Signature of Responsible Official Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division 1. Facility name and mailing address 2. Facility location (No P.O. Box) FACILITY IDENTIFICATION SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-100 Rev 06-95 Name Street or Route City, State, Zip Code Carestream Health, Inc. 2000 Howard Smith Avenue West Windsor, Colorado 80550 3. Parent corporation 4. Responsible Street Address City,County, Zip Code 2000 Howard Smith Avenue West Windsor, Colorado 80550 Name Street or Route City, State, Zip Code Country (if not U.S.) Carestream Health, Inc. 150 Verona St. Rochester, NY 14608 Name official Title Telephone 5. Permit contact person Name Title (If Different than 4) Telephone 6. Facility SIC code: Christopher L. Schmachtenberger Colorado Site Manager 970-304-4712 Laura Jackson Pales Environmental Engineer 970-304-4768 3861 8. Federal Tax I. D. Number: 7. Facility identification code: CO.1236.350 9. Primary activity of the operating establishment Manufacturer of photographic supplies 10. Type of operating permit New Modified X Renewal 11. Is the facility located in a "nonattainment" area: Yes X No If "Yes", check the designated "non -attainment" pollutant(s): Carbon Monoxide Ozone X PM l0 Other (specify) 12. List all (Federal and State) air pollution permits (including grandfathered units), plan approvals and exemptions issued to this facility. List the number, date and what unit/process is covered by each permit. For a Modified Operating Permit, do not complete this item. Not applicable - this is an application for Modified Operating Permit. Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-601 09-94 1. Facility name: Carestream Health, Inc. 2. Facility identification code: CO 1g635.0 3. Stack identification code: Scrap Re -Use Cyclone 4. Unit identification code: 5. Complete the following emissions summary for the following pollutants. Attach ell calculations and emission factor references. Attached Air pollutant Actual F ' y Potential to emit Maximum allowable Quantity U TPY U TPY Particulates (TSP) PM -10 0.20 TPY 0.20 0.20 TPY 0.20 Nitrogen oxides TPY Volatile organic compounds TPY Carbon monoxide TPY Lead TPY Sulfur dioxide TPY Total reduced sulfur TPY Reduced sulfur compounds TPY Hydrogen sulfide TPY Sulfuric Acid Mist TPY Fluorides TPY TPY TPY TPY TPY Units (U) should be entered as follows: 1 = Ib/hr 2 = Ib/mmBTU 3 = grains/dscf 4 = lb/ gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 = other (specify) 9 = other (specify) 10 = other (specify) 74 EMISSION UNIT CRITERIA AIR POLLUTANTS -- Form 2000-601 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permits. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. Item 1 Provide the name of the facility. Item 2 Provide the facility identification (FID) code. Item 3 Provide the identification code of the stack that exhausts this equipment. Use the same code used on form 2000-200. Item 4 Provide the identification code from the appropriate form(s) 2000-300, -301, -302, -303, -304, -305, -306, or -307 completed for the emissions unit that will have its emissions summarized on this form. Item 5 Provide the emission levels for each listed pollutant emitted from this source. The emissions should be presented using the same units as the applicable limits shown on Form 2000-604 and in tons per year (TPY). The list of footnotes found in the lower left corner of this form allows the applicant to specify the units of each reported emission level. To specify the appropriate units, write the appropriate footnote number in the columns headed by the letter "U". For example: to indicate an emission rate of 3.2 lbs SO2/MNIBTU, write Sulfur dioxide 3.2 2 on the line for sulfur dioxide (SO2). Potential to emit should represent emissions at full production capacity of the source after reduction by any air pollution control equipment. This is normally 24 hours/day for 365 days/year (i.e., 8760 hours/year), although physical or operational limitations that are in a construction permit issued by the Division, or in the applicable emission control regulation, are considered in determining the potential to emit. Please see the instruction manual for the precise definition of "potential to emit" You may want to use emission factors to determine these emissions. Maximum allowable emissions should represent the greatest amount of emissions allowed under any permit or applicable standards, taking into consideration the equipment limitations, such as line speed, and pollution control efficiencies of the equipment. In cases where the emission unit has a construction permit, the maximum allowable emissions are equal to the potential to emit. Please remember to: Report hazardous air pollutants on Forms 2000-600 and 2000-602. State the reference(s) for the calculations. Emission factors may be compiled in published documents, such as EPA's AP - 42, or may be based on stack test results. A separate page of numbered references is appropriate and may be attached to form 2000-601. Form 2000-700 may be used for this purpose. 75 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE PLANT -WIDE CRITERIA AIR POLLUTANTS FORM 2000-603 09-94 1. Facility name: Carestream Health, Inc. 2. Facility identification code: CO 1 2.363.5Q 3. Complete the following emissions summary fDr the listed emissions at this facility. Air pollutant Actual Potential to emit Maximum allowable ITY TPY TPY Particulates (TSP) 15.0 15.0 PM -10 15.0 15.0 Nitrogen oxides Volatile organic compounds 48.3 48.3 Carbon monoxide Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric acid mist Fluorides 78 PLANT -WIDE CRITERIA AIR POLLUTANTS -- Form 2000-603 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INS1RUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permits. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optimal. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. Item 1 Provide the name of the facility. Item 2 Provide the facility identification (FID) code. Item 3 Provide the emission levels in tons per year (TPY). For each pollutant emitted from the facility, sum the annual actual, potential to emit, and the maximum allowable emission rates (tons per year only) reported for all of the facility's emission units. The individual values are on each Form 2000-601 completed for the application. The totals for each pollutant should be reported on Form 2000-603 in tons per year (TPY). ***** Hazardous air pollutant emissions should be reported on Forms 2000-600 and 2000-602. ***** 79 Operating Permit Application Colorado Department of Health Air Pollution Control Division Facility Name: Carestream Health, Inc. I. ADMINISTRATION TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 09-94 Facility Identification Code: CO 1236350 This application contains the following forms: 2000-100, 2000-601, 2000-603, 2000-800 Form 2000-100, Facility Identification X Form 2000-101, Facility Plot Plan N/A Forms 2000-102, -102A, and -102B, Source and Site Descriptions N/A II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler, printing operation, etc.): Form 2000-200, Stack Identification 0 Form 2000-300, Boiler or Furnace Operation 0 Form 2000-301, Storage Tanks 0 Form 2000-302, Internal Combustion Engine 0 Form 2000-303, Incineration 0 Form 2000-304, Printing Operations 0 Form 2000-305, Painting and Coating Operations 0 Form 2000-306, Miscellaneous Processes 0 Form 2000-307, Glycol Dehydration Unit 0 III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following forms: Form 2000-400, Miscellaneous 0 Form 2000-401, Condensers 0 Form 2000-402, Adsorbers 0 Form 2000-403, Catalytic or Thermal Oxidation 0 Form 2000-404, Cyclones/Settling Chambers 0 Form 2000-405, Electrostatic Precipitators 0 Form 2000-406, Wet Collection Systems 0 Form 2000-407, Baghouses/Fabric Filters 0 IV. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the following forms (one for each facility boiler, printing operation, etc.): Form 2000-500, Compliance Certification - Monitoring and Reporting 0 Form 2000-501, Continuous Emission Monitoring 0 Form 2000-502, Periodic Emission Monitoring Using Portable Monitors 0 Form 2000-503, Control System Parameters or Operation Parameters of a Process 0 Form 2000-504, Monitoring Maintenance Procedures 0 Form 2000-505, Stack Testing 0 Form 2000-506, Fuel Sampling and Analysis 0 Form 2000-507, Recordkeeping 0 Form 2000-508, Other Methods 0 92 V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan Form 2000-600, Emission Unit Hazardous Air Pollutants o Form 2000-601, Emission Unit Criteria Air Pollutants 1 Form 2000-602, Facility Hazardous Air Pollutants 0 Form 2000-603, Facility Criteria Air Pollutants 1 Form 2000-604, Applicable Requirements and Status of Emission Unit 0 Form 2000-605, Permit Shield Protection Identification 0 Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule 0 Form 2000-607, Plant -Wide Applicable Requirements 0 Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule 0 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS I certify that the facility described in this air pollution permit application is fully I certify that the facility described in this air pollution permit application is fully for the following emissions unit(s): after reasonable inquiry, I certify that the statements (check one box only) in compliance with all applicable requirements. in compliance with all applicable requirements, except material statement, representation, or certification be punished in accordance with the provisions of § 25- (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false in, or omits material information from this application is guilty of a misdemeanor and may 7 122.1, C.R.S. Printed or Typed Name Christopher L. Schmachtenberger Title Colorado Site Manager Signature � Date Signed April 12, 2018 � 93 Operating Permit Application Colorado Department of Health Air Pollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 09-94 Facility Name: Carestream Health, Inc. Facility Identification Code: CO 1236350 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY CONDITIONS I certify that the facility described in this air pollution permit application is fully I certify that the facility described in this air pollution permit application is fully for the following emissions unit(s): after reasonable inquiry, I certify that the statements (check one box only) in compliance with all applicable requirements. in compliance with all applicable requirements, except material statement, representation, or certification be punished in accordance with the provisions of § 25- (list all noncomplying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false in, or omits material information from this application is guilty of a misdemeanor and may 7122.1, C.R.S. Printed or Typed Name Christopher L. Schmachtenberger Title Colorado Site Manager Signature Date Signed April 12, 2018 47/7 SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 94 Attachment B - Air Pollution Emission Notice (APEN) APCD Form 200 General APEN General APEN - Form APCD-200 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. There may be a more specific APEN for your source (e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 06OPWE288 AIRS ID Number: 123 /6350 / N/A [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Site Name: Site Location: Mailing Address: Carestream Health, Inc. Carestream Health Colorado 2000 Howard Smith Ave West Windsor, CO 80550 (Include Zip code) 2000 Howard Smith Ave West Windsor, CO 80550 Portable Source N/A Home Base: Site Location Weld County: NAICS or SIC Code: 325992 Permit Contact: Laura Jackson Phone Number: 970.304.4768 E -Mail Address2: Iaura.pales@carestream.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processinginvoices will be issued by APCD via e-mail to the address provided. Form APCD-200 - General APEN - Revision 1/2017 3782,66 COLORADO 1 I WperenmtNpultle Nu1Nb Gtviran.n.M Permit Number: 06OPWE288 AIRS ID Number: 123 / 6350 /N/A [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ❑ NEW permit OR newly -reported emission source (check one below) ❑ STATIONARY source ❑ PORTABLE source -OR - MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership; r❑ Other (describe below) -OR- ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: Revise the PM/PM10 emissions calculation for the Scrap Re -Use Cyclone. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: The Scrap Re -Use Cyclone is used to control PET material that is recovered from the Support Manufacturing (C-50) process. Manufacturer: Model No.: Serial No.: Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Seasonaruse` percentage: Dec -Feb: 25 24 hours/day 7 days/week 52 weeks/year Mar -May: 25 Jun -Aug: 25 Sep -Nov: 25 Form APCD-200 - General APEN - Revision 1/2017 2 AV COLOR ADO ubm 0,101030c Permit Number: 06OPWE288 AIRS ID Number: 123 /6350/ N/A [Leave blank unless APCD has already assigned a permit # and MRS ID] Section 4 - Processing/Manufacturing Information £t Material Use ❑✓ Check box if this information is not applicable to source or process From what year is the actual annual amount? Material Consumption: Finished Product(s). Design Process ,.Rate (Specify Units) Actual Annual Amount (Specify Units) Requested Annual Permit Lirnit4- (Specify Units) 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. -.,:. Operator tacfc ID No a �d_a,2 � � . •_ Discharge Height Abo a Ground Level y � {Feet .. ,�., _..,3 .--.._ emp •� �~ _ � r_ Rates T r eici tie 120 F 3281 acfm Indicate the direction of the stack outlet: (check one) 0 Upward O Horizontal O Downward ❑ Other (describe): O Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): 12 inches ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): O Other (describe): Form APCD-200 - General APEN - Revision 1/2017 3I AY COLORADO H Ilepartrnent. mt.n PWIN 6 CmImrwmf Permit Number: 06OPWE288 AIRS ID Number: 123 /6350/ N/A [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Combustion Equipment Et Fuel Consumption Information D Check box if this information is not applicable to the source (e.g. there is no fuel -burning equipment associated with this emission source) Design Input Rate (MMBTU/hr) "- Actual Annual Fuel Use (Specify Units) Requested Annual Permit Limit4 (Specify Units) From what year is the actual annual fuel use data? Indicate the type of fuel useds: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) ❑ Field Natural Gas Heating value: BTU/SCF ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑ Coat Heating value: BTU/lb Ash Content: Sulfur Content: ❑ Other (describe): Heating value (give units): a Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Section 7 Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? D Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Collection Efficiency ` Overall Control Efficiency (% reduction in emissions) TSP (PM) PM10 Cyclone — 80% PM2.s sox NO„ CO VOC Other: Form APCD-200 - General APEN - Revision 1/2017 41 AV COLORADO Department of P, 4dc Permit Number: 06OPWE288 AIRS ID Number: 123 /6350 / N/A [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. April 12, 2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Christopher Schmachtenberger Colorado Site Manager Name (print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-200 - General APEN - Revision 1/2017 6 I �® COLORADO M.,I.h b 1m..erun.n Permit Number: 06OPWE288 AIRS ID Number: 123 /6350 / N/A [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 (continued) From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions. Pollutant Uncontrolled Emission Factor(SpecifyUnits),, Emission Factor Source (--A!:-4e 2tc')fg~ Actual Annual Emissions que edAnnual rm : Emission imtt(s) � it .--g34 _ , _ �, r Uncontrolled C(Ton ear) ye ) Uncontrolled (Tons/year) __' CTons/ eontrollara ( y TSP (PM) PM10 0.0446 lb/hr test data w/safety factor 1.0 0.2 0.2 PM2.s SOX NOX CO VOC Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP- hazardous air pollutant) emissions equal to or greater than 250 lbs/year? O Yes 2 No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: CAS Number' Overall Control Efficiency Uncontrolled Emission Factor (specify units) Emission Factor Source (AP -42, Mfg. etc) Uncontrolled Actual Emissions (lbs/year) Controlled Actual r. Emissions6 Os/year) 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-200 - General APEN - Revision 1/2017 COLORADO 5 1 _ gum., 20O0 Howard Smith Avenue West Windsor, CO 80550 970.304.4600 CERTIFIED MAIL 7009 0080 0001 4859 2005 Electronic mail: ramazan.spencer@state.co.us April 12, 2018 Mr. Ramazan Spencer Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: Carestream Health, Inc. Comments on Draft Title V Operating Permit Operating Permit No. 06OPWE288 Dear Mr. Spencer: Carestream Health Inc., Colorado site (CHC) has completed its review of the draft Title V Operating Permit (Permit). For your convenience, redlined electronic copies of the Permit and Technical Review Document are being emailed to the address listed above. Enclosed with this document is an Application for Modification in support of requested modifications to the Permit. In addition to minor grammatical errors identified in the electronic version, the following Permit changes are requested: Page 2 Change: Update facility contact person. Change: Update reporting compliance period to January 1— December 31. Section 4.1 Change: Add PET Reuse Process and associated cyclone to AIRS ID 002. Explanation: Refer to attached Application for Modification. Change: Remove "C -70A" and "C -70B" and replace with "C-70". (There are multiple locations in the Permit where this needs to be updated.) Explanation: The facility does not use "A" and "B" designations. April 12, 2018 Mr. Ramazan Spencer Colorado Department of Public Health and Environment Page 2 Section II, Condition 1.1.3.2 Change: Revise calculation for PET powder unloading. Explanation: Refer to Administrative Amendment Request #1 in enclosed Application for Modification Change: Delete Chemical Making calculation. Explanation: Refer to Administrative Amendment Request #2 in enclosed Application for Modification Change: Add calculation for Scrap Re -Use Cyclone. Explanation: Refer to enclosed Application for Modification. Section II, Condition 2 Change: Remove compliance options that are not applicable to the site. (Please review redlined version to ensure correct changes have been proposed.) Explanation: The CAL does not have control equipment. Inclusion of non -applicable compliance options is confusing and misleading. Section III, Condition 1 Change: Remove "P040" as an Emission Unit (EU) and replace with "C-40". Explanation: EU P040 is a historical unit. The current Permit references "C-40". Appendix A, Facility Plot Plan Change: Update the date of receipt for plot plan. Explanation: CHC emailed a copy of an updated facility plan for use in the permit. List of Insignificant Activities Change: Update list of insignificant activities. Explanation: CHC has updated the list. April 12, 2018 Mr. Ramazan Spencer Colorado Department of Public Health and Environment Page 3 Change: Add "and Conveyance Equipment" to C-50 prepolymer and polymer silos. Explanation: There are many cyclones used in the process for conveyance and these cyclones are considered to be integral process equipment meeting the requirement of PS Memo 96-4 (per Mr. Burgett, CDPHE in 2007). Exemption Table for Sulfuric Acid and Caustic Tanks Change: Correct storage capacity for sulfuric acid tank. Explanation: Permit had incorrect capacity. Appendix G Change: Update equipment list to include PET Reuse Process extruder and scrap re -use cyclone. Explanation: Refer to enclosed Application for Modification. Please contact Laura Jackson at (970) 304-4768 or via email at laura.pales@carestream.com ifyou have any questions or need additional information. Sincerely, Christopher Schmachtenberger Site Manager Encl. cc: Jamie Christopher —SLR 6/12/2018 State.co.us Executive Branch Mail - Draft Comments STATE OF COLO RADO Spencer - CDPHE, Ramazan <ramazan.spencer@state.co.us> Draft Comments 1 message Spencer - CDPHE, Ramazan <ramazan.spencer@state.co.us> Mon, Apr 30, 2018 at 9:49 AM To: Laura Pales <laura.pales@carestream.com> Hi Laura, Below you will find the Divisions responses to comments made by CHC. Comment: We specifically requested confidentiality for this submittal due to inclusion of raw material throughput. Can we discuss the results without including this table? Response: Every item identified as confidential (redacted) on the documents marked as Public Copy was omitted from the TRD and Permit. The information included in the TRD was not redacted and therefore not requested to be confidential. That information is also considered emission data and can not be confidential. Emission data is defined as "information necessary to determine the identity, amount, frequency, concentration, or other characteristics (to the extent related to air quality) of any emission which has been, or will be, emitted by the source (or of any pollutant resulting from any emission by the source), or any combination thereof." Comment: "Sources may request a revision ... for longer times for compliance determination." Can we request a longer time, and if so, what is the procedure to do so? We would like to request that compliance be demonstrated monthly as this is consistent with the rest of our compliance requirements. Response: A request to modify the SIP can be made. Questions regarding the process and documentation requirements should be addressed to Dena Wojtach. (dena.wojtach@state.co.us / (303) 692-3147). Please keep in mind that this is a very lengthy process which takes a minimum of 3 years during which CHC would still need comply with the current Reg 7 requirements. Best Regards, Raz Spencer Title V Permit Engineer Operating Permits Unit Stationary Sources Program COLORADO Air Pollution Control Division Department of Public Health Er Environment P 303.692.3201 4300 Cherry Creek Drive South, Denver, CO 80246-1530 ramazan.spencer@state.co.us I www.colorado.gov/cdphe/apcd https://mail.google.com/mail/u/0/?ui=2&ik=42a273c46b&jsver—k8XTJOJ1kuE.en.&cbl=gmail fe_180606.07_p4&view=pt&q=laura.pales%40carestream.com&qs=ti 6/12/2018 State.co.us Executive Branch Mail - Resorcinol STATE O F COLORADO Spencer - CDPHE, Ramazan <ramazan.spencer@state.co.us> Resorcinol 2 messages Laura Pales <laura.pales@carestream.com> To: "Spencer - CDPHE, Ramazan" <ramazan.spencer@state.co.us> Wed, May 30, 2018 at 10:43 AM Hi Raz, I have had many internal discussions and have dug through old Kodak documents in search of information on resorcinol. There is conflicting belief amongst the tenured engineers - some believe all of the resorcinol sublimes in the heating/stretching processes, i.e., the Drafter and Tenter sections of the 501 Machine (the web making machine), and others do not. Those that believe it sublimes also believe that it condenses in sections of the machine and ductwork and is never emitted to atmosphere as resorcinol condenses at a high temperature and would readily condense after the heating and stretching processes. In addition, we do roof inspections as part of our stormwater compliance program and have never observed white flakes on the roof. However, for the sake of moving forward with the Permit, let's please assume that all of the resorcinol is emitted and keep the existing calculation of: PM/PM10 Emissions = Amount of Resorcinol Consumed The Permit indicates that these emissions are generated in the Chemical Making area, which is not accurate if we assume the emissions are generated in the 501 Machine. I suggest that we delete "Chemical Making:" and replace it with "501 Machine:". Thus 501 Machine: PM/PM10 Emissions = Amount of Resorcinol Consumed This would include all emissions generated from resorcinol and would still result in double -counting of resorcinol -related emissions generated in the Chemical Weighing Hood but I don't know how to quantify the quantity being double counted. Please let me know if you agree. Also, we will not be submitting the minor mod for the new process until later in June or early July. We are still finalizing the formulation and new equipment list. Laura Jackson Pales I Environmental Engineer QUALITY-EHS OPERATIONS CHC laura.pales@carestream.com Office: 970-304-4768 I Mobile: 970-689-4397 ww careStream.cam Carestream Hea€th, Inc. I US Follow us on Twitter Facebook YovTube EverythingRAD Spencer - CDPHE, Ramazan <ramazan.spencer@state.co.us> Thu, May 31, 2018 at 4:25 PM To: Laura Pales <laura.pales@carestream.com> Hi Laura, This approach is acceptable. Emission source renamed to "501 Machine." Please provide PTE calculations for VOC (0.0527 lb CHCI3/Mgal Recirc Flow) and PM emissions (AP 42 CH 13.4) for the cooling towers to show that they are an insignificant activity. Attached you will find Division responses to the remaining comments made by CHC that were not previously addressed. Please provide PTE calculations and feedback if any by end of business June 7, 2018. Best Regards, https://mail.google.com/mail/u/0/?ui=2&ik=42a273c46b&jsver-k8XTJOJ1 kuE.en.&cbl=gmail_fe_180606.07_p4&view=pt&q=laura.pales%40carestream.com&qs=t 6/12/2018 State.co.us Executive Branch Mail - Re: Title V - Resorcinol STATE OF COLORADO Spencer - CDPHE, Ramazan <ramazan.spencer@state.co.us> Re: Title V - Resorcinol Laura Pales <laura.pales@carestream.com> To: "Spencer - CDPHE, Ramazan" <ramazan.spencer@state.co.us> Tue, Apr 24, 2018 at 7:58 AM Hi Raz, I reviewed the Kodak document. If Kodak assumed a conservative loss of less than 2% then why did the permit include an equation that indicated a 100% loss, i.e.: al 1 .aIL : P t . toEntssir;ps = Amount of Resurclnol consumed, Was this an equation error in the Permit and should the calculation have included a multiplier of 0,02? If you are in agreement then I'm fine with that assumption. Would I need to submit a revised letter requesting that the Permit be modified to account for 2% loss? Laura Jackson Pales I Environmental Engineer QUALITY-EHS OPERATIONS CHC laura.oa€es/carestrea m.com Office: 970-304-4768 I Mobile: 970-689-4397 www.carestream.com Carestream Health, Inc. I US Follow us on Twitter Facebook YouTube EverythingRAD From: "Spencer - CDPHE, Ramazan" <ramazan.spencer@state.co.us> To: Laura Pales <€aura.pales@carestream.com> Date: 04/23/2018 11:17 AM Subject: Title V Good morning Laura, I have just received the Mod request along with comments on the draft Permit. Have not seen anything hit my email for the electronic drafts comments/edits. When should I be expecting those? In regards to the Resorcinol mod I have attached an exchange between Kodak and CDPHE from 98. On the bottom of page 3 Mr. Bill F. Burke addresses the emissions. Based on this letter I do not believe that chemical weighing hood emission calculation sufficiently addresses the emissions caused by consumption and use of Resorcinol. Let me know if you have any questions I will be available to discuss this further this afternoon. Best Regards, Raz Spencer Title V Permit Engineer Operating Permits Unit Stationary Sources Program https://mail.google.cam/mail/u/0/?ui=2&ik=42a273c46b&jsvekBXTJOJIkuE.en.&cbl=gma€I_fe_180606.07_p4&view=pt&msg=162f7fb153e22dcd&q=laura.pales5 6/12/2018 State.co.us Executive Branch Mail - Re: Permit Update - PET Reuse Cyclone STATE OF COLORADO Spencer - CDPHE, Ramazan <ramazan.spencer@state.co.us> Re: Permit Update - PET Reuse Cyclone 4 messages Laura Pales <laura.pales@carestream.com> To: "Spencer - CDPHE, Ramazan" <ramazan.spencer@state.co.us> Tue, May 8, 2018 at 11:17 AM Hi Raz, I'm going to address each of your questions in separate emails to help me stay organized. Regarding the cyclone, I have not been able to find a D50 value. The unit was installed pre-Carestream and I can't find any specifications. I haven't been able to find any throughput data generated during stack testing either. However, we aren't necessarily comparing apples to apples. In its current configuration, the cyclone is truly used for conveyance of flaked material and the cyclone meets the requirements of PS Memo 96-4 as integral process equipment. Its purpose is to convey material, not to control emissions. In the new scrap reuse process, the cyclone will be used strictly as a means of dust collection for fugitives. Material conveyance in the new scrap reuse process occurs via "teeth" that mechanically rotate and pull the material into the base of the equipment while simultaneously shredding the material as it enters the extruder. Particulate emissions will be generated during this shredding process, however, the shredding occurs in an enclosure and air flow is in the direction of the extruder, i.e., INTO the equipment, and not out a vent stack. I've attached a copy of the equipment installation manual. The hood is shown on page 14. You can see how the feeder chute attaches to the enclosure on page 25. The entire unit is depicted on the first page of the manual. The sheet material is fed into the chute. The roller bar with "teeth" is located in the yellow compartment under the hood. The roller bar teeth grab the sheet material and physically create enough force to pull the sheet into the chute and through the hood. Shredding occurs in the base of the yellow compartment which direct feeds the shredded material into the extruder to the right. The emissions generated from this process are going to be minimal. Our intent was to proactively install a vent line from the hood to the existing reuse cyclone feed line to capture any fugitive emissions generated by the new process. The overall particulate loading on the cyclone is going to substantially decrease as we divert scrap from the current flaking/conveying process to the new extruding process. We decided to submit an APEN and permit the cyclone as we were being ultra conservative. I had looked for throughput data prior to preparing the APEN and when we couldn't find any, we applied a 50% safety factor and also assumed a relatively low efficiency of 80%. We then DOUBLED the calculated emissions for additional conservatism. At this point, I'm not sure how to proceed. Does this additional information suffice to permit the unit? Laura Jackson Pales I Environmental Engineer QUALITY -EFTS OPERATIONS CHC laura.oa lesvca restream.com Office: 970-304-4768 I Mobile: 970-689-4397 www.carestream.con Carestream Health, Inc. I US 6/12/2018 State.co.us Executive Branch Mail - Re: Permit Update - PET Reuse Cyclone Follow us on Twitter Facebook YouTube EverythingRAD From: "Spencer - CDPHE, Ramazan" <ramazan.spencer@state.co.us> To: Laura Pales <laura.pales@carestream.com> Date: 05/08/2018 08:47 AM Subject: Permit Update Good morning Laura, I just wanted to give you a status update and collect the outstanding information requests into a single email. I have finished editing/responding to all the comments in the draft Permit & TRD that do not involve Resorcinol or the scrap reuse process as I still need additional information to finalize those items. • Resorcinol: Could you provide a more detailed explanation for the calculation of the Resorcinol in Coated Web (does the bill of materials have a tolerance? if so which value was used? Does the bill of materials reflect the exact value that was called for during formulation of the coating?) ? Maybe an example of a specific product? Also what is the function of Resorcinol in the coating? Is there QA conformity testing verifying what ever specific function the Resorcinol serves? • PET Reuse Cyclone: Cyclone Cut Size (D50) value? Process throughput during stack test? New Stuff • PM Emission Limit: Should the emissions calcs/contribution to the PM limit related to DBP use be completely removed? Since emissions from the scrubber are no longer in the permit CHC would have to submit a mod request to add those back in. • New Coating Formulation: What is the time frame on the modification request submission? Thanks Laura! Raz Spencer Title V Permit Engineer Operating Permits Unit Stationary Sources Program P 303.692.3201 4300 Cherry Creek Drive South, Denver, CO 80246-1530 ramazan.spencer@state.co.us I www.colorado.gov/cdphe/aped PRE _S -GRAN V_AG_15.7.2_en.pdf 1653K Laura Pales <laura.pales@carestream.com> To: "Spencer - CDPHE, Ramazan" <ramazan.spencer@state.co.us> Wed, May 9, 2018 at 11:14 AM Hi Raz, 6/12/2018 State.co.us Executive Branch Mail - Re: Permit Update - PET Reuse Cyclone I talked to our engineering department this morning and it would be very easy to install a small, dedicated dust collector on the system in lieu of venting it to the scrap raise cyclone. That would be much easier for us and it would make the permitting process cut and dry. I do believe, however, that the unit is going to be insignificant and not require permitting. We conducted actual testing on our material in Austria and the test unit was not equipped with any type of dust collection system at all. We have actual photos from the test run. If you would like to see the equipment and the photos, then I can set up an online meeting and I share my screen. Laura Jackson Pales I Environmental Engineer. QUALITY-EHS OPERATIONS CHC laura.paley@carestream.com Office: 970-304-4768 I Mobile: 970-6894397 www.carestream.com Carestream Health, Inc. I US Follow us on Twitter Facebook YouTube EverythingRAD From: Laura Pales/19017921/USC/CSH To: "Spencer - CDPHE, Ramazan" <ramazan.spencer@state.co.us> Date: 05/08/2018 11:17 AM Subject: Re: Permit Update - PET Reuse Cyclone Hi Raz, I'm going to address each of your questions in separate emails to help me stay organized. Regarding the cyclone, I have not been able to find a D50 value. The unit was installed pre-Carestream and I can't find any specifications. I haven't been able to find any throughput data generated during stack testing either. However, we aren't necessarily comparing apples to apples. In its current configuration, the cyclone is truly used for conveyance of flaked material and the cyclone meets the requirements of PS Memo 96-4 as integral process equipment. Its purpose is to convey material, not to control emissions. In the new scrap reuse process, the cyclone wil be used strictly as a means of dust collection for fugitives. Material conveyance in the new scrap reuse process occurs via "teeth" that mechanically rotate and pull the material into the base of the equipment while simultaneously shredding the material as it enters the extruder. Particulate emissions will be generated during this shredding process, however, the shredding occurs in an enclosure and air flow is in the direction of the extruder, i.e., INTO the equipment, and not out a vent stack. I've attached a copy of the equipment installation manual. [attachment "PRE_S-GRAN_V_AG_15.7.2_en_pdf" deleted by Laura Pales/19017921/USC/CSH] [Quoted text hidden] Spencer - CDPHE, Ramazan <ramazan.spencer@state.co.us> Wed, May 9, 2018 at 1:24 PM To: Laura Pales <Iaura.pales@carestream.com> Laura, I think it would be easiest to treat this as an insignificant activity than trying to justify some sort of emission factors based ona stack test with no process information what so ever. I used emission factors from shredding tires which is as close the process as I could find in AP -42 and uncontrolled PTE @ 500 lbs/hr came out below reporting threshold (Ch 4.12 - Uncontrolled EF=4.33E-5Ib/lb processed). We have used this emission factor for tire shredding in multiple Construction Permits. So just waiting on the Resorocinol info and I'm all set. 6/12/2018 Best Regards, [Quoted text hidden] [Quoted text hidden] State.co.us Executive Branch Mail - Re: Permit Update - PET Reuse Cyclone COLORADO Air Pollution Control Division Department of Public Health Er Environment P 303.692.3201 4300 Cherry Creek Drive South, Denver, CO 80246-1530 ramazan.spencer@state.co.us I www.colorado.gov/cdphe/apcd Laura Pales <laura.pales@carestream.com> Wed, May 9, 2018 at 2:44 PM To: "Spencer - CDPHE, Ramazan" <ramazan.spencer@state.co.us> Thank you, that works really well. I will send Resorcinol in a confidential email. Laura Jackson Pales I Environmental Engineer QUALITY -ENS OPERATIONS CHC laura.oales@carestream.com Office: 970-304-4768 I Mobile: 970-689-4397 wvw.carestream.com Carestream Health, Inc. I US Follow us on T=> tier Facebook YouTube EverythingRAD From: "Spencer - CDPHE, Ramazan" <ramazan.spencer@state.co.us> To: Laura Pales <laura.pales@carestream.com> Date: 05/09/2018 01:24 PM [Quoted text hidden] Hello