HomeMy WebLinkAbout20173891.tiffCOLORADO
Department of Public
Health Fs Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
November 14, 2017
Dear Sir or Madam:
RECEIVED
NOV 162017
WELD COUNTY
COMMISSIONERS
On November 16, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for
Kodak Alaris, Inc. - Kodak Alaris. 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., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor
PCB i G ��a. V i eu�
I 119O / I 7
Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
PLC(VIM / TP), Ht.C3'T),
PWLER/CH/5e(1/C1C)
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Air Pollution Control Division
Notice Of A Proposed Renewal Title V Operating Permit
Warranting Public Comment
Website Title: Kodak Alaris, Inc. - Kodak Alaris - Weld County
Notice Period Begins: November 16, 2017
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: Kodak Alaris, Inc.
9952 Eastman Park Drive
Windsor, CO 80551-1590
Facility: Kodak Alaris
9952 Eastman Park Drive
Windsor, CO 80551-1590
Kodak Alaris, Inc. has applied to renew the Operating Permit for the Kodak Alaris in Weld County, CO.
Facility manufactures and applies coatings to a plastic film. This modification will reduce the operating limit
of the two 157 mmbtu/hr boilers. This modification will result in a decrease in VOC of 5 tons, a decrease in
NOx of 178.11 tons, a decrease in CO of 182.87 tons, and a decrease in PM/PM10 of 12.3 tons. A copy of the
application, including supplemental information, the Division's analysis, and a draft of the Renewal
Operating Permit 96OPWE128 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.
Colorado Department
of Public Health
and Environment
OPERATING PERMIT
Kodak Alaris Inc
Kodak Alaris Colorado
First Issued: September 1, 1999
Renewed: DRAFT
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME:
FACILITY ID:
RENEWED:
EXPIRATION DATE:
MODIFICATIONS:
Kodak Alaris
Colorado
123/0003
DRAFT
DRAFT
See Appendix F of Permit
OPERATING PERMIT NUMBER
96OPWE128
Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et
sec . and applicable rules and regulations.
ISSUED TO:
Kodak Alaris, Inc.
9952 Eastman Park Drive
Windsor, CO 80551-1590
PLANT SITE LOCATION:
Kodak Alaris Colorado
9952 Eastman Park Drive
Windsor, CO 80551-1590
Weld County
INFORMATION RELIED UPON
Operating Permit Renewal Application Received:
And Additional Information Received:
Nature of Business:
Primary SIC:
November 3, 2008
March 5, 2008, March 26, 2010, March 7, 2016,
July 1, 2016, June 6, 2017
Manufacturer of photographic material and supplies.
3861
RESPONSIBLE OFFICIAL
Name: Stephen Kozak
Title: Site Manager
Phone: (970) 686-4015
FACILITY CONTACT PERSON
Name: Keli Shaipee
Title: HSE Coordinator
Phone: (970) 686-4348
SUBMITTAL DEADLINES —
First Semi -Annual Monitoring Period:
Subsequent Semi -Annual Monitoring Periods:
Semi -Annual Monitoring Reports:
First Annual Compliance Period:
Subsequent Annual Compliance Pen
Annual Compliance Certification:
Note that the Semi -Annual Monitoring Reports and Annual Compliance report 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.
October 1,2010 —December 31, 2010
January 1— June 30, July 1— December 3841
Due February 1 2011 B�August 1, 2011 subsequent years
October 1,2010 —December 31 2010
January 1 -- December 3
Due February 1, 2011 &'subsequent years
TABLE OF CONTENTS:
SECTION I - General Activities and Summary 1
1. Permitted Activities 1
2. Alternative Operating Scenarios 2
3. Non -Attainment New Source Review (NANSR) and Prevention of Significant Deterioration
(PSD) 2
4. Accidental Release Prevention Program (112(r)) 2
5. Compliance Assurance Monitoring (CAM) 2
6. Summary of Emission Units 3
SECTION II - Specific Permit Terms 4
1. S029 - Chemical Manufacturing Building C-29 (AIRS # 100) 4
2. S29B-Chem Mix and Thermal Media Manufacturing, Building C -29B, #291 Coating
Machine, RTO1 (AIRS # 107) S29C- Thermal Media Manufacturing, Building C -29C, #292
Coating Machine, RTO2 (AIRS # 108) 31
3. S030 Two Natural Gas Fired Boilers (157 mmbtu/hr each, AIRS # 051). 42
4. E01, E02 Two Cummins Emergency Fire Pump Engines (HP 240 each) 47
5. Degreasing Unit: Building C-29 53
SECTION III - Permit Shield 55
1. Specific Non -Applicable Requirements 55
2. General Conditions 56
3. Stream -lined Conditions 56
SECTION IV - General Permit Conditions (ver 5/22/2012) 57
1. Administrative Changes 57
2. Certification Requirements 57
3. Common Provisions 58
4. Compliance Requirements 62
5. Emergency Provisions 63
6. Emission Controls for Asbestos 64
7. Emissions Trading, Marketable Permits, Economic Incentives 64
8. Fee Payment 64
9. Fugitive Particulate Emissions 64
10. Inspection and Entry 65
11. Minor Permit Modifications 65
12. New Source Review 65
13. No Property Rights Conveyed 65
14. Odor 65
15. Off -Permit Changes to the Source 66
16. Opacity 66
17. Open Burning 66
18. Ozone Depleting Compounds 66
19. Permit Expiration and Renewal 66
20. Portable Sources 67
21. Prompt Deviation Reporting 67
22. Record Keeping and Reporting Requirements ' 68
23. Reopenings for Cause 69
24. Section 502(b)(10) Changes 69
TABLE OF CONTENTS:
25. Severability Clause 69
26. Significant Permit Modifications 70
27. Special Provisions Concerning the Acid Rain Program 70
28. Transfer or Assignment of Ownership 70
29. Volatile Organic Compounds 70
30. Wood Stoves and Wood burning Appliances 71
APPENDIX A - Inspection Information 73
1. Directions to Plant: 73
1. Safety Equipment Required: 73
2. Facility Plot Plan: 73
3. List of Insignificant Activities. 74
APPENDIX B 76
Reporting Requirements and Definitions 76
Monitoring and Permit Deviation Report - Part I 80
Monitoring and Permit Deviation Report - Part II 81
Monitoring and Permit Deviation Report - Part III 83
APPENDIX C 84
Required Format for Annual Compliance Certification Reports 84
APPENDIX D 86
Notification Addresses 86
APPENDIX E 87
Permit Acronyms 87
APPENDIX F 89
Permit Modifications 89
APPENDIX G 90
Equipment. List 90
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 1
1. Permitted Activities
1.1
SECTION I - General Activities and Summary
This facility consists of several buildings containing a variety of equipment used to manufacture
photographic supplies. Building C-29 contains a small chemical manufacturing reactor room for
producing various aqueous polymers. In Buildings C -29B and C -29C, the company produces thermal
media which customers use in color printers to transfer color and clear laminate onto paper or other
surfaces. Dry dye powder is weighed and dissolved in solvents. The coating solutions are piped to a
coating machine where they are applied to plastic substrate material. Two natural gas -fired boilers
(Building C-30), each rated at 157 MMBtu/hour, are used as back-up steam sources only, as process
steam is purchased from and provided by an external source.
The facility is located in Weld County, near Windsor, an attainment area for all pollutants. The facility is
located in the 8 -Hour 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.
1.3 The 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 all 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 (except as noted in Section II) from the following
construction permits: 96WE473 & 10WE1280.
1.4 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 - Conditions 3.g (last
paragraph), 14, & 18 (as noted).
1.5 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.
Either electronic or hard copy records are acceptable.
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 2
2. Alternative Operating Scenarios
2.1 The permittee shall be allowed to make the following changes to its method of operation without
applying for a revision of this permit.
2.1.1 None.
3. Non -Attainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD)
3.1 This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC or NOx ≥
100 Tons/Year). 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
(i.e. a Potential to Emit of > 100 TPY of either VOC or NOx) may result in the application of the
NANSR review requirements.
3.2 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 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.
3.3 There are no other Operating Permits associated with this facility for purposes of determining
applicability of Prevention of Significant Deterioration regulations.
4. Accidental Release Prevention Program (112(r))
4.1 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).
5. Compliance Assurance Monitoring (CAM)
5.1 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 in Colorado Regulation No. 3, Part C,
Section XIV:
None. (MACT standards and sources with continuous monitoring devices are not subject to
CAM requirements.)
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 3
6. Summary of Emission Units
6.1 The emissions units regulated by this permit are the following:
I AIRS
Identifier
Facility
Identifier
Description
Pollution
Control Device
Construction
Permit
100
S029
Chemical Manufacturing, Building C-29
96WE473
107
S29B
Thermal Media Manufacturing, Building C -29B
Thermal
Oxidizer
#291 Coating Line
108
S29C
Thermal Media Manufacturing, Building C -29C
Thermal
Oxidizer
#292 Coating Line
051
S030
*Two (2) Babcock & Wilcox Boilers, Fuel: Natural Gas, SN:
NB23487 & NB23488, rated at 157 mmbtu/hour each, limited use
only
,
10WE1280
E01, E02
Two Cummins Emergency Fire Pump Engines, Fuel: Diesel,
� 3
Model #: 6CTA8.3-F2, SN: 46031463 & 45545437, HP: 240 (site),
270 (max)
E03
C-29 Degreasing Unit
�' g
*Sources listed in bold face are sources with specific emission limits that are not included in the facility wide emission limit
and are listed separately in this Operating Permit.
6.2 Equipment Replacement
6.2.1 This permit covers only the specific existing equipment listed in Appendix G of this permit.
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 4
SECTION II - Specific Permit Terms
1. S029 - Chemical Manufacturing Building C-29 (AIRS # 100)
Parameter
Condition
Number
Limitation
Monitoring
Method
Interval
Facility Wide VOC
1.1
169.7 tons/year
Recordkeeping
Calculation
Monthly
MACT Subpart FFFF
1.2
See Condition 1.2
Note: See Equipment List, Appendix G.
1.1
Facility -wide emissions of VOC shall not exceed the limitations stated in the table above (96WE473 as
modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C,
Section I.A.7 and Part C, Section III.B.7). The source shall record total chemical product batches on a
monthly basis. The number of batches and the quantity of VOC, to be determined by method described
in 40 CFR Part 63 Subpart FFFF Paragraph 63.2460(b), that volatizes in each batch shall be used to
calculate emissions following a mass balance calculation. VOC emissions shall be summed to
determine monthly emissions. VOC monthly emissions from this emission unit shall be summed with
the VOC monthly emissions from other emission units and a twelve month rolling total of facility wide
VOC emissions will be maintained to verify compliance with the annual emission limitations. Each
month, a new twelve month total of facility -wide VOC emissions shall be calculated using the previous
twelve months data. Records of the calculations and compliance determinations shall be maintained and
made available for Division review upon request.
For the Cyclohexanone, emissions from each batch of Cyclohexanone shall be calculated using the
following equation:
VOC Emitted lbs = Cyclehexanone Initial Batch Weight(lbs) — Cyclehexanone Spent Batch Weight(lbs) x 0.99
The source shall maintain a record of each Cyclohexanone batch used and its initial and final weight.
1.2 This source is subject to the National Emissions Standards for Hazardous Air Pollutants requirements of
Regulation No. 8, Part E, Subpart FFFF (40 CFR Part 63, Subpart FFFF), for Miscellaneous Organic
Chemical Manufacturing, including, but not limited to, the following:
[The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart
FFFF published in the Federal Register on 12/22/2008. 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 FFFF.]
1.2.1 The miscellaneous organic chemical manufacturing affected source is the facilitywide collection
of MCPU and heat exchange systems, wastewater, and waste management units'that are
associated with manufacturing materials described in §63.2435(b)(1). (63.2440(b))
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 5
1.2.2 An existing source must comply with the requirements for existing sources in Subpart FFFF no
later than May 10, 2008. (63.2445(b))
1.2.3 You must meet the notification requirements in §63.2515 according to the dates specified in that
section and in subpart A of this part 63. Some of the notifications must be submitted before you
are required to comply with the emission limits, operating limits, and work practice standards in
Subpart FFFF. (63.2445(c))
1.2.4 If you have a Group 2 emission point that becomes a Group 1 emission point after the
compliance date for your affected source, you must comply with the Group 1 requirements
beginning on the date the switch occurs. An initial compliance demonstration as specified in
Subpart FFFF must be conducted within 150 days after the switch occurs. (63.2445(d))
1.2.5 If, after the compliance date for your affected source, hydrogen halide and halogen HAP
emissions from, process vents in a process increase to more than 1,000 lb/yr, or HAP metals
emissions from a process at a new affected source increase to more than 150 lb/yr, you must
comply with the applicable emission limits specified in Table 3 to Subpart FFFF and the
associated compliance requirements beginning on the date the emissions exceed the applicable
threshold. An initial compliance demonstration as specified in Subpart FFFF must be conducted
within 150 days after the switch occurs. (63.2445(e))
1.2.6 When §§63.2455 through 63.2490 reference other subparts in this part 63 that use the term
"periodic report," it means "compliance report" for the purposes of Subpart FFFF. The
compliance report must include the information specified in §63.2520(e), as well as the
information specified in referenced subparts. (63.2444(m)(1))
1.2.7 When there are conflicts between Subpart FFFF and referenced subparts for the due dates of
reports required by Subpart FFFF, reports must be submitted according to the due dates
presented in Subpart FFFF. (63.2444(m)(2))
1.2.8 Opening a safety device, as defined in §63.2550, is allowed at any time conditions require it to
avoid unsafe conditions. (63.2444(p))
1.2.9 For the purposes of determining Group status for continuous process vents, batch process vents,
and storage tanks in §§63.2455, 63.2460, and 63.2470, hydrazine is to be considered an organic
HAP. (63.2444(s))
1.2.10 For batch process vents you must meet each emission limit in Table 2 to Subpart FFFF that
applies to you, and you must meet each applicable requirement specified in paragraphs (b) and
(c) of §63.2460. (63.2460(a))
Note: Table 2 to Subpart FFFF of Part 63 does not contain any emission limits for Group 2
batch process vents.
1.2.11 Group status. If a process has batch process vents, as defined in §63.2550, you must determine
the group status of the batch process vents by determining and summing the uncontrolled organic
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 6
HAP emissions from each of the batch process vents within the process using the procedures
specified in §63.1257(d)(2)(i) and (ii), except as specified in paragraphs (b)(1) through (7) of
§63.2460. (63.2460(b))
Note: Source indicated in the Semi Annual MONMACT Report received on March 2, 2015
group status of the batch process vents to be Group 2.
Equipment Leaks
1.2.12 For equipment leaks you must meet each requirement in table 6 to Subpart FFFF that applies to
your equipment leaks, except as specified in paragraphs (b) through (d) of §63.2480.(63.2480(a))
1.2.13 Equipment that is in organic HAP service: (Item 1, Table 6 to Subpart FFFF of Part 63)
1.2.13.1 Comply with the requirements of subpart UU of this part 63 and the requirements
referenced therein, except as specified in §63.2480(b) and (d); or
1.2.13.2 Comply with the requirements of subpart H of this part 63 and the requirements
referenced therein, except as specified in §63.2480(b) and (d); or
1.2.13.3 Comply with the requirements of 40 CFR part 65, subpart F and the requirements
referenced therein, except as specified in §63.2480(c) and (d).
1.2.14 The source must indicate one of the three compliance 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 compliance options, The
Division must be notified in the semi-annual reports specified in Condition 1.2.52.2. The
permittee has previously indicated that they would comply with the requirements in Condition
1.2.13.1.
[The requirements of Conditions 1.2.15 through 1.2.31 reflect the current rule language as of the
revisions to 40 CFR Part 63 Subpart UU published in the Federal Register on 07/12/2002. 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 UU. It should be noted that
the language has been modified as required by 40 CFR Part 63 Subpart FFFF and described in
Conditions 1.2.6 and 1.2.7]
1.2.15 The owner or operator of a regulated source subject to Subpart UU shall monitor regulated
equipment as specified in paragraph (a)(1) of 63.1023for instrument monitoring and paragraph
(a)(2) of §63.1023 for sensory monitoring. (63.1023(a))
1.2.15.1 Instrument monitoring for leaks. (63.1023(a)(1))
a. Valves in gas and vapor service and in light liquid service shall be monitored
pursuant to §63.1025(b). (63.1023(a)(1)(i))
b. Pumps in light liquid service shall be monitored pursuant to §63.1026(b).
(63.1023(a)(1)(ii))
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAT I
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 7
c. Connectors in gas and vapor service and in light liquid service shall be monitored
pursuant to §63.1027(b). (63.1023(a)(1)(iii))
d. Agitators in gas and vapor service and in light liquid service shall be monitored
pursuant to §63.1028(c). (63.1023(a)(1)(iv))
e. Pressure relief devices in gas and vapor service shall be monitored pursuant to
§63.1030(c). (63.1023(a)(1)(v))
1.2.15.2 Sensory monitoring for leaks. (63.1023(a)(2))
a. Pumps in light liquid service shall be observed pursuant to §§63.1026(b)(4) and
(e)(1)(v). (63.1023(a)(2)(i))
b. Agitators in gas and vapor service and in light liquid service shall be observed
pursuant to §63.1028(c)(3) or (e)(1)(iv). (63.1023(a)(2)(iii))
1.2.16 Instrument monitoring, as required under Subpart W, shall comply with the requirements
specified in paragraphs (b)(1) through (b)(6) of §63.1023. (63.1023(b))
1.2.16.1 Monitoring shall comply with Method 21 of 40 CFR part 60, appendix A, except as
otherwise provided in §63.1023. (63.1023(b)(1))
1.2.16.2 Detection instrument performance criteria. (63.1023(b)(2))
a. Except as provided for in paragraph (b)(2)(ii) of §63.1023, the detection
instrument shall meet the performance criteria of Method 21 of 40 CFR part 60,
appendix A, except the instrument response factor criteria in section 3.1.2,
paragraph (a) of Method 21 shall be for the representative composition of the
process fluid not each individual VOC in the stream. For process streams that
contain nitrogen, air, water or other inerts that are not HAP or VOC, the
representative stream response factor shall be determined on an inert -free basis.
The response factor may be determined at any concentration for which monitoring
for leaks will be conducted. (63.1023(b)(2)(i))
b. If there is no instrument commercially available that will meet the performance
criteria specified in paragraph (b)(2)(i) of §63.1023, the instrument readings may
be adjusted by multiplying by the representative response factor of the process
fluid, calculated on an inert -free basis as described in paragraph (b)(2)(i) of
§63.1023. (63.1023(b)(2)(ii))
1.2.16.3 The detection instrument shall be calibrated before use on each day of its use by the
procedures specified in Method 21 of 40 CFR part 60, appendix A. (63.1023(b)(3))
1.2.16.4 Calibration gases shall be zero air (less than 10 parts per million of hydrocarbon in
air); and the gases specified in paragraph (b)(4)(i) of §63.1023 except as provided in
paragraph (b)(4)(ii) of §63.1023. (63.1023(b)(4))
a. Mixtures of methane in air at a concentration no more than 2,000 parts per million
greater than the leak definition concentration of the equipment monitored. If the
monitoring instrument's design allows for multiple calibration scales, then the
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 8
lower scale shall be calibrated with a calibration gas that is no higher than 2,000
parts per million above the concentration specified as a leak, and the highest scale
shall be calibrated with a calibration gas that is approximately equal to 10,000
parts per million. If only one scale on an instrument will be used during
monitoring, the owner or operator need not calibrate the scales that will not be
used during that day's monitoring. (63.1023(b)(4)(i))
b. A calibration gas other than methane in air may be used if the instrument does not
respond to methane or if the instrument does not meet the performance criteria
specified in paragraph (b)(2)(i) of §63.1023. In such cases, the calibration gas
may be a mixture of one or more of the compounds to be measured in air.
(63.1023(b)(4)(ii))
1.2.16.5 Monitoring shall be performed when the equipment is in regulated material service or
is in use with any other detectable material. (63.1023(b)(5))
1.2.16.6 Monitoring data obtained prior to the regulated source becoming subject to the
referencing subpart that do not meet the criteria specified in paragraphs (b)(1) through
(b)(5) of §63.1023 may still be used to qualify initially for less frequent monitoring
under the provisions in §63.1025(a)(2), (b)(3) or (b)(4) for valves or §63.1027(b)(3)
for connectors provided the departures from the criteria or from the specified
monitoring frequency of §63.1025(b)(3) or (b)(4) or §63.1027(b)(3) are minor and do
not significantly affect the quality of the data. Examples of minor departures are
monitoring at a slightly different frequency (such as every 6 weeks instead of monthly
or quarterly), following the performance criteria of section 3.1.2, paragraph (a) of
Method 21 of appendix A of 40 CFR part 60 instead of paragraph (b)(2) of §63.1023,
or monitoring using a different leak definition if the data would indicate the presence
or absence of a leak at the concentration specified in Subpart UU. Failure to use a
calibrated instrument is not considered a minor departure. (63.1023(b)(6))
1.2.17 The owner or operator may elect to adjust or not to adjust the instrument readings for
background. If an owner or operator elects not to adjust instrument readings for background, the
owner or operator shall monitor the equipment according to the procedures specified in
paragraphs (b)(1) through (b)(5) of §63.1023. In such cases, all instrument readings shall be
compared directly to the applicable leak definition for the monitored equipment to determine
whether there is a leak or to determine compliance with §63.1030(b) (pressure relief devices) or
§63.1031(f) (alternative compressor standard). If an owner or operator elects to adjust instrument
readings for background, the owner or operator shall monitor the equipment according to the
procedures specified in paragraphs (c)(1) through (c)(4) of §63.1023. (63.1023(c))
1.2.17.1 The background level shall be determined, using the procedures in Method 21 of 40
CFR part 60, appendix A. (63.1023(c)(2))
1.2.17.2 The instrument probe shall be traversed around all potential leak interfaces as close to
the interface as possible as described in Method 21 of 40 CFR part 60, appendix A.
(63.1023(c)(3))
1.2.17.3 The arithmetic difference between the maximum concentration indicated by the
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 9
instrument and the background level shall be compared to the applicable leak
definition for the monitored equipment to determine whether there is a leak or to
determine compliance with §63.1030(b) (pressure relief devices) or §63.1031(f)
(alternative compressor standard). (63.1023(c)(4))
1.2.18 Leaking equipment identification and records.
1.2.18.1 When each leak is detected pursuant to the monitoring specified in paragraph (a) of
§63.1023, a weatherproof and readily visible identification, shall be attached to the
leaking equipment. (63.1023(e)(1))
1.2.18.2 When each leak is detected, the information specified in §63.1024(f) shall be recorded
and kept pursuant to the referencing subpart, except for the information for connectors
complying with the 8 year monitoring period allowed under §63.1027(b)(3)(iii) shall
be kept 5 years beyond the date of its last use. (63.1023(e)(2))
1.2.19 The owner or operator shall repair each leak detected as soon as practical, but not later than 15
calendar days after it is detected, except as provided in paragraphs (d) and (e) of §63.1024. A
first attempt at repair as defined in Subpart UU shall be made no later than 5 calendar days after
the leak is detected. First attempt at repair for pumps includes, but is not limited to, tightening
the packing gland nuts and/or ensuring that the seal flush is operating at design pressure and
temperature. First attempt at repair for valves includes, but is not limited to, tightening the
bonnet bolts, and/or replacing the bonnet bolts, and/or tightening the packing gland nuts, and/or
injecting lubricant into the lubricated packing. (63.1024(a))
1.2.20 Leak identification removal. (63.1024(c))
1.2.20.1 Valves and connectors in gas/vapor and light liquid service. The leak identification on
a valve in gas/vapor or light liquid service may be removed after it has been monitored
as specified in §63.1025(d)(2), and no leak has been detected during that monitoring.
The leak identification on a connector in gas/vapor or light liquid service may be
removed after it has been monitored as specified in §63.1027(b)(3)(iv) and no leak has
been detected during that monitoring. (63.1024(c)(1))
1.2.20.2 The identification that has been placed, pursuant to §63.1023(e)(1), on equipment
determined to have a leak, except for a valve or for a connector in gas/vapor or light
liquid service that is subject to the provisions of §63.1027(b)(3)(iv), may be removed
after it is repaired. (63.1024(c)(2))
1.2.21 Delay of repair is allowed for any of the conditions specified in paragraphs (d)(1) through (d)(5)
of §63.1024. The owner or operator shall maintain a record of the facts that explain any delay of
repairs and, where appropriate, why the repair was technically infeasible without a process unit
shutdown. (63.1024(d))
1.2.21.1 Delay of repair of equipment for which leaks have been detected is allowed if repair
within 15 days after a leak is detected is technically infeasible without a process unit
or affected facility shutdown. Repair of this equipment shall occur as soon as practical,
but no later than the end of the next process unit or affected facility shutdown, except
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 10
as provided in paragraph (d)(5) of §63.1024. (63.1024(d)(1))
1.2.21.2 Delay of repair of equipment for which leaks have been detected is allowed for
equipment that is isolated from the process and that does not remain in regulated
material service. (63.1024(d)(2))
1.2.21.3 Delay of repair for valves, connectors, and agitators is also allowed if the provisions of
paragraphs (d)(3)(i) and (d)(3)(ii) of §63.1024 are met. (63.1024(d)(3))
a. The owner or operator determines that emissions of purged material resulting
from immediate repair would be greater than the fugitive emissions likely to result
from delay of repair, and (63.1024(d)(3)(i))
b. When repair procedures are effected, the purged material is collected and
destroyed, collected and routed to a fuel gas system or process, or recovered in a
control device complying with either §63.1034 or §63.1021(b) of this part.
(63.1024(d)(3)(ii))
1.2.21.4 Delay of repair for pumps is also allowed if the provisions of paragraphs (d)(4)(i) and
(d)(4)(ii) of §63.1024 are met. (63.1024(d)(4))
a. Repair requires replacing the existing seal design with a new system that the
owner or operator has determined under the provisions of §63.1035(d) will
provide better performance or one of the specifications of paragraphs (d)(4)(i)(A)
through (d)(4)(i)(C) of §63.1024 are met. (63.1024(d)(4)(i))
(i) A dual mechanical seal system that meets the requirements of §63.1026(e)(1)
will be installed; (63.1024(d)(4)(i)(A))
(ii) A pump that meets the requirements of §63.1026(e)(2) will be installed; or
(63.1024(d)(4)(i)(B))
(iii) A system that routes emissions to a process or a fuel gas system or a closed
vent system and control device that meets the requirements of §63.1026(e)(3)
will be installed; (63.1024(d)(4)(i)(C))
b. Repair is completed as soon as practical, but not later than 6 months after the leak
was detected. (63.1024(d)(4)(ii))
1.2.21.5 Delay of repair beyond a process unit or affected facility shutdown will be allowed for
a valve if valve assembly replacement is necessary during the process unit or affected
facility shutdown, and valve assembly supplies have been depleted, and valve
assembly supplies had been sufficiently stocked before the supplies were depleted.
Delay of repair beyond the second process unit or affected facility shutdown will not
be allowed unless the third process unit or affected facility shutdown occurs sooner
than 6 months after the first process unit or affected facility shutdown. (63.1024(d)(5))
1.2.22 Any connector that is designated, as described in §63.1022(d), as an unsafe -to -repair connector is
exempt from the requirements of §63.1027(d), and paragraph (a) of §63.1024. (63.1024(e))
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 11
1.2.23 For each leak detected, the information specified in paragraphs (f)(1) through (f)(5) of §63.1024
shall be recorded and maintained pursuant to the referencing subpart. (63.1024(f))
1.2.23.1 The date of first attempt to repair the leak. (63.1024(f)(1))
1.2.23.2 The date of successful repair of the leak. (63.1024(f)(2))
1.2.23.3 Maximum instrument reading measured by Method 21 of 40 CFR part 60, appendix A
at the time the leak is successfully repaired or determined to be nonrepairable.
(63.1024(f)(3))
1.2.23.4 "Repair delayed" and the reason for the delay if a leak is not repaired within 15
calendar days after discovery of the leak as specified in paragraphs (f)(4)(i) and
(f)(4)(ii) of §63.1024. (63.1024(f)(4))
a. The owner or operator may develop a written procedure that identifies the
conditions that justify a delay of repair. The written procedures may be included
as part of the startup, shutdown, and malfunction plan, as required by the
referencing subpart for the source, or may be part of a separate document that is
maintained at the plant site. In such cases, reasons for delay of repair may be
documented by citing the relevant sections of the written procedure.
(63.1024(f)(4)(i))
b. If delay of repair was caused by depletion of stocked parts, there must be
documentation that the spare parts were sufficiently stocked on -site before
depletion and the reason for depletion. (63.1024(f)(4)(ii))
1.2.23.5 Dates of process unit or affected facility shutdowns that occur while the equipment is
unrepaired. (63.1024(f)(5))
1.2.24 Valves in gas and vapor service and in light liquid service standards. (63.1025)
1.2.24.1. Unless otherwise specified in §63.1021(b) or paragraph (e) of §63.1025, or the
referencing subpart, the owner or operator shall monitor all valves at the intervals
specified in paragraphs (b)(3) and/or (b)(4) of §63.1025 and shall comply with all
other provisions of §63.1025. (63.1025(b))
a. The valves shall be monitored to detect leaks by the method specified in
§63.1023(b) and, as applicable, §63.1023(c). (63.1025(b)(1))
b. The instrument reading that defines a leak is 500 parts per million or greater.
(63.1025(b)(2))
c. The owner or operator shall monitor valves for leaks at the intervals specified in
paragraphs (b)(3)(i) through (b)(3)(v) of §63.1025 and shall keep the record
specified in paragraph (b)(3)(vi) of §63.1025. (63.1025(b)(3))
(i) If at least the greater of 2 valves or 2 percent of the valves in a process unit
leak, as calculated according to paragraph (c) of §63.1025, the owner or
operator shall monitor each valve once per month. (63.1025(b)(3)(i))
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 12
(ii) At process units with less than the greater of 2 leaking valves or 2 percent
leaking valves, the owner or operator shall monitor each valve once each
quarter, except as provided in paragraphs (b)(3)(iii) through (b)(3)(v) of
§63.1025. Monitoring data generated before the regulated source became
subject to the referencing subpart and meeting the criteria of either
§63.1023(b)(1) through (b)(5), or §63.1023(b)(6), may be used to qualify
initially for less frequent monitoring under paragraphs (b)(3)(iii) through
(b)(3)(v) of §63.1025. (63.1025(b)(3)(ii))
(iii) At process units with less than 1 percent leaking valves, the owner or
operator may elect to monitor each valve once every two quarters
(63.1025(b)(3)(iii))
(iv) At process units with less than 0.5 percent leaking valves, the owner or
operator may elect to monitor each valve once every four quarters.
(63.1025(b)(3)(iv))
(v) At process units with less than 0.25 percent leaking valves, the owner or
operator may elect to monitor each valve once every 2 years.
(63.1025(b)(3)(v))
(vi) The owner or operator shall keep a record of the monitoring schedule for
each process unit. (63.1025(b)(3)(vi))
d. For a process unit or a group of process units to which Subpart UU applies, an
owner or operator may choose to subdivide the valves in the applicable process
unit or group of process units and apply the provisions of paragraph (b)(3)
§63.1025 to each subgroup. If the owner or operator elects to subdivide the valves
in the applicable process unit or group of process units, then the provisions of
paragraphs (b)(4)(i) through (b)(4)(viii) of §63.1025. (63.1025(b)(4))
1.2.24.2 Percent leaking valves calculation. (63.1025(c))
a. The owner or operator shall decide no later than the compliance date of this part
or upon revision of an operating permit whether to calculate percent leaking
valves on a process unit or group of process units basis. Once the owner or
operator has decided, all subsequent percentage calculations shall be made on the
same basis and this shall be the basis used for comparison with the subgrouping
criteria specified in paragraph (b)(4)(i) of §63.1025. (63.1025(c)(1)(i))
b. The percent leaking valves for each monitoring period for each process unit or
valve subgroup, as provided in paragraph (b)(4) of §63.1025, shall be calculated
using the following equation: (63.1025(c)(1)(ii))
%Vi,=(w..)x100
%VL = Percent leaking valves.
Vi = Number of valves found leaking, excluding nonrepairable valves, as provided in
paragraph (c)(3) of §63.1025, and including those valves found leaking pursuant to
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
paragraphs (d) (2) (iii) (A) and (d) (2) (iii) (B)of §63.1025.
VT = The sum of the total number of valves monitored.
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 13
c. When determining monitoring frequency for each process unit or valve subgroup
subject to monthly, quarterly, or semiannual monitoring frequencies, the percent
leaking valves shall be the arithmetic average of the percent leaking valves from
the last two monitoring periods. When determining monitoring frequency for each
process unit or valve subgroup subject to annual or biennial (once every 2 years)
monitoring frequencies, the percent leaking valves shall be the arithmetic average
of the percent leaking valves from the last three monitoring periods.
(63.1025(c)(2))
d. Nonrepairable valves. (63.1025(c)(3))
(i)
Nonrepairable valves shall be included in the calculation of percent leaking
valves the first time the valve is identified as leaking and nonrepairable and
as required to comply with paragraph (c)(3)(ii) of §63.1025. Otherwise, a
number of nonrepairable valves (identified and included in the percent
leaking valves calculation in a previous period) up to a maximum of 1
percent of the total number of valves in regulated material service at a
process unit or affected facility may be excluded from calculation of percent
leaking valves for subsequent monitoring periods. (63.1025(c)(3)(i))
(ii) If the number of nonrepairable valves exceeds 1 percent of the total number
of valves in regulated material service at a process unit or affected facility,
the number of nonrepairable valves exceeding 1 percent of the total number
of valves in regulated material service shall be included in the calculation of
percent leaking valves. (63.1025(c)(3)(ii))
1.2.24.3 Leak repair. (63.1025(d))
a. If a leak is determined pursuant to paragraph (b), (e)(1), or (e)(2) of §63.1025,
then the leak shall be repaired using the procedures in §63.1024, as applicable.
(63.1025(d)(1))
b. After a leak has been repaired, the valve shall be monitored at least once within
the first 3 months after its repair. The monitoring required by this paragraph is in
addition to the monitoring required to satisfy the defmition of repaired and first
attempt at repair. (63.1025(d)(2))
(i) The monitoring shall be conducted as specified in §63.1023(b) and (c) of
§63.1025, as appropriate, to determine whether the valve has resumed
leaking. (63.1025(d)(2)(i))
(ii) Periodic monitoring required by paragraph (b) of §63.1025 may be used to
satisfy the requirements of this paragraph, if the timing of the monitoring
period coincides with the time specified in this paragraph. Alternatively,
other monitoring may be performed to satisfy the requirements of this
paragraph, regardless of whether the timing of the monitoring period for
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 14
periodic monitoring coincides with the time specified in this paragraph.
(63.1025(d)(2)(ii))
(iii) If a leak is detected by monitoring that is conducted pursuant to paragraph
(d)(2) of §63.1025, the owner or operator shall follow the provisions of
paragraphs (d)(2)(iii)(A) and (d)(2)(iii)(B) of §63.1025, to determine whether
that valve must be counted as a leaking valve for purposes of paragraph
(c)(1)(ii) of §63.1025. (63.1025(d)(2)(iii))
(A) If the owner or operator elected to use periodic monitoring required by
paragraph (b) of §63.1025to satisfy the requirements of paragraph (d)(2)
of §63.1025, then the valve shall be counted as a leaking valve.
(63.1025(d)(2)(iii)(A))
(B) If the owner or operator elected to use other monitoring, prior to the
periodic monitoring required by paragraph (b) of §63.1025, to satisfy the
requirements of paragraph (d)(2) of §63.1025, then the valve shall be
counted as a leaking valve unless it is repaired and shown by periodic
monitoring not to be leaking. (63.1025(d)(2)(iii)(B))
1.2.24.4 Any valve that is designated, as described in §63.1022(c)(1), as an unsafe -to -monitor
valve is exempt from the requirements of paragraphs (b) and (d)(2) of §63.1025 and
the owner or operator shall monitor the valve according to the written plan specified in
§63.1022(c)(4). (63.1025(e)(1))
1.2.24.5 Any valve that is designated, as described in §63.1022(c)(2), as a difficult -to -monitor
valve is exempt from the requirements of paragraph (b) of §63.1025 and the owner or
operator shall monitor the valve according to the written plan specified in
§63.1022(c)(4). (63.1025(e)(2))
1.2.24.6 Any equipment located at a plant site with fewer than 250 valves in regulated material
service is exempt from the requirements for monthly monitoring specified in
paragraph (b)(3)(i) of §63.1025. Instead, the owner or operator shall monitor each
valve in regulated material service for leaks once each quarter, as provided in
paragraphs (e)(1) and (e)(2) of §63.1025. (63.1025(e)(3))
1.2.25 Pumps in light liquid service standards. (63.1026)
1.2.25.1 Unless otherwise specified in §63.1021(b), §63.1036, §63.1037, or paragraph (e) of
§63.1026, the owner or operator shall monitor each pump to detect leaks and shall
comply with all other provisions of §63.1026. (63.1026(b))
a. The pumps shall be monitored monthly to detect leaks by the method specified in
§63.1023(b) and, as applicable, §63.1023(c). (63.1026(b)(1))
b. The instrument reading that defines a leak is specified in paragraphs (b)(2)(i)
through (b)(2)(iii) of §63.1026. (63.1026(b)(2))
(i) 5,000 parts per million or greater for pumps handling polymerizing
monomers; (63.1026(b)(2)(i))
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 15
(ii) 2,000 parts per million or greater for pumps in food/medical service; and
(63.1026(b)(2)(ii))
(iii) 1,000 parts per million or greater for all other pumps. (63.1026(b)(2)(iii))
c. For pumps to which a 1,000 parts per million leak definition applies, repair is not
required unless an instrument reading of 2,000 parts per million or greater is
detected. (63.1026(b)(3))
d. Each pump shall be checked by visual inspection each calendar week for
indications of liquids dripping from the pump seal. The owner or operator shall
document that the inspection was conducted and the date of the inspection. If
there are indications of liquids dripping from the pump seal at the time of the
weekly inspection, the owner or operator shall follow the procedure specified in
either paragraph (b)(4)(i) or (b)(4)(ii) of §63.1026. (63.1026(b)(4))
(i)
The owner or operator shall monitor the pump as specified in §63.1023(b)
and, as applicable, §63.1023(c). If the instrument reading indicates a leak as
specified in paragraph (b)(2) of §63.1026, a leak is detected and it shall be
repaired using the procedures in §63.1024, except as specified in paragraph
(b)(3) of §63.1026; or (63.1026(b)(4)(i))
(ii) The owner or operator shall eliminate the visual indications of liquids
dripping. (63.1026(b)(4)(ii))
1.2.25.2 Percent leaking pumps calculation. (63.1026(c))
a. The owner or operator shall decide no later than the compliance date of this part
or upon revision of an operating permit whether to calculate percent leaking
pumps on a process unit basis or group of process units basis. Once the owner or
operator has decided, all subsequent percentage calculations shall be made on the
same basis. (63.1026(c)(1))
b. If, when calculated on a 6 -month rolling average, at least the greater of either 10
percent of the pumps in a process unit or three pumps in a process unit leak, the
owner or operator shall implement a quality improvement program for pumps that
complies with the requirements of §63.1035. (63.1026(c)(2))
c. The number of pumps at a process unit or affected facility shall be the sum of all
the pumps in regulated material service, except that pumps found leaking in a
continuous process unit or affected facility within 1 month after start-up of the
pump shall not count in the percent leaking pumps calculation for that one
monitoring period only. (63.1026(c)(3))
d. Percent leaking pumps shall be determined by the following equation:
(63.1026(c)(4))
%PL=(PT—PS)x100
%PL = Percent leaking pumps.
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 16
PL = Number of pumps found leaking as determined through monthly monitoring as
required in paragraph (b) (1) of §63.1026. Do not include results from inspection of unsafe -
to -monitor pumps pursuant to paragraph (e)(6) of §63.1026.
Ps = Number of pumps leaking within 1 month of start-up during the current monitoring
period.
PT = Total pumps in regulated material service, including those meeting the criteria in
paragraphs (e)(1), (e)(2), (e)(3), and (e)(6) of §63.1026.
1.2.25.3 If a leak is detected pursuant to paragraph (b) of §63.1026, then the leak shall be
repaired using the procedures in §63.1024, as applicable, unless otherwise specified in
paragraph (b)(5) of §63.1026 for leaks identified by visual indications of liquids
dripping. (63.1026(d))
1.2.25.4 Each pump equipped with a dual mechanical seal system that includes a barrier fluid
system is exempt from the requirements of paragraph (b) of §63.1026, provided the
requirements specified in paragraphs (e)(1)(i) through (e)(1)(viii) of §63.1026 are met.
(63.1026(e)(1))
a. The owner or operator determines, based on design considerations and operating
experience, criteria applicable to the presence and frequency of drips and to the
sensor that indicates failure of the seal system, the barrier fluid system, or both.
The owner or operator shall keep records at the plant of the design criteria and an
explanation of the design criteria; and any changes to these criteria and the
reasons for the changes. This record must be available for review by an inspector.
(63.1026(e)(1)(i))
b. Each dual mechanical seal system shall meet the requirements specified in
paragraph (e)(1)(ii)(A), (e)(1)(ii)(B), or (e)(1)(ii)(C) of §63.1026.
(63.1026(e)(1)(ii))
(i) Each dual mechanical seal system is operated with the barrier fluid at a
pressure that is at all times (except periods of startup, shutdown, or
malfunction) greater than the pump stuffing box pressure; or
(63.1026(e)(1)(ii)(A))
(ii) Equipped with a barrier fluid degassing reservoir that is routed to a process or
fuel gas system or connected by a closed -vent system to a control device that
complies with the requirements of either §63.1034 or §63.1021(b) of this
part; or (63.1026(e)(1)(ii)(B))
(iii) Equipped with a closed -loop system that purges the barrier fluid into a
process stream. (63.1026(e)(1)(ii)(C))
c. The barrier fluid is not in light liquid service. (63.1026(e)(1)(iii))
d. Each barrier fluid system is equipped with a sensor that will detect failure of the
seal system, the barrier fluid system, or both. (63.1026(e)(1)(iv))
e. Each pump is checked by visual inspection each calendar week for indications of
liquids dripping from the pump seal. The owner or operator shall document that
the inspection was conducted and the date of the inspection. If there are
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 17
indications of liquids dripping from the pump seal at the time of the weekly
inspection, the owner or operator shall follow the procedure specified in
paragraphs (e)(1)(v)(A) or (e)(1)(v)(B) of §63.1026 prior to the next required
inspection. (63.1026(e)(1)(v))
(i) The owner or operator shall monitor the pump as specified in §63.1023(b)
and, as applicable, §63.1023 (c), to determine if there is a leak of regulated
material in the barrier fluid. If an instrument reading of 1,000 parts per
million or greater is measured, a leak is detected and it shall be repaired using
the procedures in §63.1024; or (63.1026(e)(1)(v)(A))
(ii) The owner or operator shall eliminate the visual indications of liquids
dripping. (63.1026(e)(1)(v)(B))
f. If indications of liquids dripping from the pump seal exceed the criteria
established in paragraph (e)(1)(i) of §63.1026, or if based on the criteria
established in paragraph (e)(1)(i) of §63.1026 the sensor indicates failure of the
seal system, the barrier fluid system, or both, a leak is detected.
(63.1026(e)(1)(vi))
Each sensor as described in paragraph (e)(1)(iv) of §63.1026 is observed daily or
is equipped with an alarm unless the pump is located within the boundary of an
unmanned plant site. (63.1026(e)(1)(vii))
h. When a leak is detected pursuant to paragraph (e)(1)(vi) of §63.1026, it shall be
repaired as specified in §63.1024. (63.1026(e)(1)(viii))
1.2.25.5 Any pump that is designed with no externally actuated shaft penetrating the pump
housing is exempt from the requirements of paragraph (b) of §63.1026.
(63.1026(e)(2))
1.2.25.6 Any pump that is routed to a process or fuel gas system or equipped with a closed vent
system capable of capturing and transporting leakage from the pump to a control
device meeting the requirements of §63.1034 of this part or §63.1021(b) is exempt
from the requirements of paragraph (b) of §63.1026. (63.1026(e)(3))
1.2.25.7 Any pump that is located within the boundary of an unmanned plant site is exempt
from the weekly visual inspection requirement of paragraphs (b)(4) and (e)(1)(v) of
§63.1026, and the daily requirements of paragraph (e)(1)(vii) of §63.1026, provided
that each pump is visually inspected as often as practical and at least monthly.
(63.1026(e)(4))
1.2.25.8 If more than 90 percent of the pumps at a process unit or affected facility meet the
criteria in either paragraph (e)(1) or (e)(2) of §63.1026, the process unit or affected
facility is exempt from the percent leaking calculation in paragraph (c) of §63.1026.
(63.1026(e)(5))
1.2.25.9 Any pump that is designated, as described in §63.1022(c)(1), as an unsafe -to -monitor
pump is exempt from the requirements of paragraph (b) of §63.1026, the monitoring
and inspection requirements of paragraphs (e)(1)(v) through (viii) of §63.1026, and the
g.
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 18
owner or operator shall monitor and inspect the pump according to the written plan
specified in §63.1022(c)(4). (63.1026(e)(6))
1.2.26 Connectors in gas and vapor service and in light liquid service standards. (63.1027)
1.2.26.1 Except as allowed in §63.1021(b), §63.1036, §63.1037, or as specified in paragraph
(e) of §63.1027, the owner or operator shall monitor all connectors in gas and vapor
and light liquid service as specified in paragraphs (a) and (b)(3) of §63.1027.
(63.1027(b))
a. The connectors shall be monitored to detect leaks by the method specified in
§63.1023(b) and, as applicable, §63.1023(c). (63.1027(b)(1))
b If an instrument reading greater than or equal to 500 parts per million is
measured, a leak is detected. (63.1027(b)(2))
c. The owner or operator shall perform monitoring, subsequent to the initial
monitoring required in paragraph (a) of §63.1027, as specified in paragraphs
(b)(3)(i) through (b)(3)(iii) of §63.1027, and shall comply with the requirements
of paragraphs (b)(3)(iv) and (b)(3)(v) of §63.1027. The required period in which
monitoring must be conducted shall be determined from paragraphs (b)(3)(i)
through (b)(3)(iii) of §63.1027 using the monitoring results from the preceding
monitoring period. The percent leaking connectors shall be calculated as specified
in paragraph (c) of §63.1027. (63.1027(b)(3))
(i) If the percent leaking connectors in the process unit was greater than or equal
to 0.5 percent, then monitor within 12 months (1 year). (63.1027(b)(3)(i))
(ii) If the percent leaking connectors in the process unit was greater than or equal
to 0.25 percent but less than 0.5 percent, then monitor within 4 years. An
owner or operator may comply with the requirements of this paragraph by
monitoring at least 40 percent of the connectors within 2 years of the start of
the monitoring period, provided all connectors have been monitored by the
end of the 4 year monitoring period. (63.1027(b)(3)(ii))
(iii) If the percent leaking connectors in the process unit was less than 0.25
percent, then monitor as provided in paragraph (b)(3)(iii)(A) of §63.1027 and
either paragraph (b)(3)(iii)(B) or (b)(3)(iii)(C) of §63.1027, as appropriate.
(63.1027(b)(3)(iii))
(A) An owner or operator shall monitor at least 50 percent of the connectors
within 4 years of the start of the monitoring period.
(63.1027(b)(3)(iii)(A))
(B) If the percent leaking connectors calculated from the monitoring results
in paragraph (b)(3)(iii)(A) of §63.1027 is greater than or equal to 0.35
percent of the monitored connectors, the owner or operator shall monitor
as soon as practical, but within the next 6 months, all connectors that
have not yet been monitored during the monitoring period. At the
conclusion of monitoring, a new monitoring period shall be started
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 19
pursuant to paragraph (b)(3) of §63.1027, based on the percent leaking
connectors of the total monitored connectors. (63.1027(b)(3)(iii)(B))
(C) If the percent leaking connectors calculated from the monitoring results
in paragraph (b)(3)(iii)(A) of §63.1027 is less than 0.35 percent of the
monitored connectors, the owner or operator shall monitor all connectors
that have not yet been monitored within 8 years of the start of the
monitoring period. (63.1027(b)(3)(iii)(C))
(iv) If, during the monitoring conducted pursuant to paragraph (b)(3)(i) through
(b)(3)(iii) of §63.1027, a connector is found to be leaking, it shall be re -
monitored once within 90 days after repair to confirm that it is not leaking.
(63.1027(b)(3)(iv))
(v) The owner or operator shall keep a record of the start date and end date of
each monitoring period under §63.1027 for each process unit.
(63.1027(b)(3)(v))
1.2.26.2 For use in determining the monitoring frequency, as specified in paragraphs (a) and
(b)(3) of §63.1027, the percent leaking connectors as used in paragraphs (a) and (b)(3)
of §63.1027 shall be calculated by using the following equation: (63.1027(c))
%CL=(CL
C)x 100
%CL = Percent leaking connectors as determined through periodic monitoring required in
paragraphs (a) and (b)(3)(i) through (b)(3)(iii) of §63.1027.
CL = Number of connectors measured at 500 parts per million or greater, by the method
specified in §63.1023(b).
Cr = Total number of monitored connectors in the process unit or affected facility.
1.2.26.3 If a leak is detected pursuant to paragraphs (a) and (b) of §63.1027, then the leak shall
be repaired using the procedures in §63.1024, as applicable. (63.1027(d))
1.2.26.4 Any connector that is designated, as described in §63.1022(c)(1), as an unsafe -to -
monitor connector is exempt from the requirements of paragraphs (a) and (b) of
§63.1027 and the owner or operator shall monitor according to the written plan
specified in §63.1022(c)(4). (63.1027(e)(1))
1.2.26.5 Inaccessible, ceramic, or ceramic -lined connectors. (63.1027(e)(2))
a. Any connector that is inaccessible or that is ceramic or ceramic -lined (e.g.,
porcelain, glass, or glass -lined), is exempt from the monitoring requirements of
paragraphs (a) and (b) of §63.1027, from the leak repair requirements of
paragraph (d) of §63.1027, and from the recordkeeping and reporting
requirements of §§63.1038 and 63.1039. An inaccessible connector is one that
meets any of the provisions specified in paragraphs (e)(2)(i)(A) through
(e)(2)(i)(F) of §63.1027, as applicable. (63.1027(e)(2)(i))
b. If any inaccessible, ceramic or ceramic -lined connector is observed by visual,
audible, olfactory, or other means to be leaking, the visual, audible, olfactory, or
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
f
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 20
other indications of a leak to the atmosphere shall be eliminated as soon as
practical. (63.1027(e)(2)(ii))
1.2.27 Agitators in gas and vapor service and in light liquid service standards. (63.1028)
1.2.27.1 Each agitator seal shall be monitored monthly to detect leaks by the methods specified
in §63.1023(b) and, as applicable, §63.1023(c), except as provided in §63.1021(b),
§63.1036, §63.1037, or paragraph (e) of §63.1028. (63.1028(c)(1))
1.2.27.2 If an instrument reading equivalent of 10,000 parts per million or greater is measured,
a leak is detected. (63.1028(c)(2))
1.2.27.3 Each agitator seal shall be checked by visual inspection each calendar week for
indications of liquids dripping from the agitator seal. The owner or operator shall
document that the inspection was conducted and the date of the inspection.
(63.1028(c)(3)(i))
1.2.27.4 If there are indications of liquids dripping from the agitator seal, the owner or operator
shall follow the procedures specified in paragraphs (c)(3)(ii)(A) or (c)(3)(ii)(B) of
§63.1028 prior to the next required inspection. (63.1028(c)(3)(ii))
a. The owner or operator shall monitor the agitator seal as specified in §63.1023(b)
and, as applicable, §63.1023(c), to determine if there is a leak of regulated
material. If an instrument reading of 10,000 parts per million or greater is
measured, a leak is detected, and it shall be repaired according to paragraph (d) of
§63.1028; or (63.1028(c)(3)(ii)(A))
b. The owner or operator shall eliminate the indications of liquids dripping from the
agitator seal. (63.1028(c)(3)(ii)(B))
1.2.27.5 If a leak is detected, then the leak shall be repaired using the procedures in §63.1024.
(63.1028(d))
1.2.27.6 Each agitator equipped with a dual mechanical seal system that includes a barrier fluid
system is exempt from the requirements of paragraph (c) of §63.1028, provided the
requirements specified in paragraphs (e)(1)(i) through (e)(1)(vi) of §63.1028 are met.
(63.1028(e)(1))
1.2.27.7 Any agitator that is designed with no externally actuated shaft penetrating the agitator
housing is exempt from paragraph (c) of §63.1028. (63.1028(e)(2))
1.2.27.8 Any agitator that is located within the boundary of an unmanned plant site is exempt
from the weekly visual inspection requirement of paragraphs (c)(3) and (e)(1)(iv) of
§63.1028, and the daily requirements of paragraph (e)(1)(v) of §63.1028, provided that
each agitator is visually inspected as often as practical and at least monthly.
(63.1028(e)(4))
1.2.27.9 Any agitator seal that is designated, as described in §63.1022(c)(2), as a difficult -to -
monitor agitator seal is exempt from the requirements of paragraph (c) of §63.1028
and the owner or operator shall monitor the agitator seal according to the written plan
specified in §63.1022(c)(4). (63.1028(e)(5))
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 21
1.2.27.10 Any agitator seal that is obstructed by equipment or piping that prevents access to the
agitator by a monitor probe is exempt from the monitoring requirements of paragraph
(c) of §63.1028. (63.1028(e)(6))
1.2.27.11 Any agitator seal that is designated, as described in §63.1022(c)(1), as an unsafe -to -
monitor agitator seal is exempt from the requirements of paragraph (c) of §63.1028
and the owner or operator of the agitator seal monitors the agitator seal according to
the written plan specified in §63.1022(c)(4). (63.1028(e)(7))
1.2.28 Pressure relief devices in gas and vapor service standards. (63.1030)
1.2.28.1 Except during pressure releases as provided for in paragraph (c) of §63.1030, or as
otherwise specified in §§63.1036, 63.1037, or paragraphs (d) and (e) of §63.1030,
each pressure relief device in gas and vapor service shall be operated with an
instrument reading of less than 500 parts per million as measured by the method
specified in §63.1023(b) and, as applicable, §63.1023(c). (63.1030(b))
1.2.28.2 After each pressure release, the pressure relief device shall be returned to a condition
indicated by an instrument reading of less than 500 parts per million, as soon as
practical, but no later than 5 calendar days after each pressure release, except as
provided in §63.1024(d). (63.1030(c)(1))
1.2.28.3 The pressure relief device shall be monitored no later than five calendar days after the
pressure to confirm the condition indicated by an instrument reading of less than 500
parts per million above background, as measured by the method specified in
§63.1023(b) and, as applicable, §63.1023(c). (63.1030(c)(2))
1.2.28.4 The owner or operator shall record the dates and results of the monitoring required by
paragraph (c)(2) of §63.1030 following a pressure release including the background
level measured and the maximum instrument reading measured during the monitoring.
(63.1030(c)(3))
1.2.28.5 Any pressure relief device that is equipped with a rupture disk upstream of the
pressure relief device is exempt from the requirements of paragraphs (b) and (c) of
§63.1030 provided the owner or operator installs a replacement rupture disk upstream
of the pressure relief device as soon as practical after each pressure release but no later
than 5 calendar days after each pressure release, except as provided in §63.1024(d).
(63.1030(e))
1.2.29 Quality improvement program for pumps.(63.1035) If, on a 6 -month rolling average, at least the
greater of either 10 percent of the pumps in a process unit or affected facility (or plant site) or
three pumps in a process unit or affected facility (or plant site) leak, the owner or operator shall
comply with the requirements specified below: (63.1035(a))
1.2.29.1 The owner or operator shall comply with the requirements of §63.1035 until the
number of leaking pumps is less than the greater of either 10 percent of the pumps or
three pumps, calculated as a 6 -month rolling average, in the process unit or affected
facility (or plant site). Once the performance level is achieved, the owner or operator
shall comply with the requirements in §63.1026. (63.1035(b))
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 22
1.2.29.2 If, in a subsequent monitoring period, the process unit or affected facility (or plant
site) has greater than either 10 percent of the pumps leaking or three pumps leaking
(calculated as a 6 -month rolling average), the owner or operator shall resume the
quality improvement program starting at performance trials. (63.1035(c))
1.2.29.3 The quality improvement program shall meet the requirements specified in paragraphs
(d)(1) through (d)(7) of §63.1035. (63.1035(d))
1.2.29.4 In addition to the records required by paragraph (d)(2) of §63.1035, the owner or
operator shall maintain records for the period of the quality improvement program for
the process unit or affected facility as specified in paragraphs (e)(1) through (e)(6) of
§63.1035. (63.1035(e))
1.2.30 The permittee shall retain records as specified in §§ 63.1038(a), (b), and (c).
1.2.31 The owner or operator shall report the information specified in paragraphs (b)(1) through (b)(8)
of §63.1039, as applicable, in the Periodic Report specified in the referencing subpart.
(63.1039(b))
1.2.31.1 For the equipment specified in paragraphs (b)(1)(i) through (b)(1)(v) of §63.1039,
report in a summary format by equipment type, the number of components for which
leaks were detected and for valves, pumps and connectors show the percent leakers,
and the total number of components monitored. Also include the number of leaking
components that were not repaired as required by §63.1024, and for valves and
connectors, identify the number of components that are determined by §63.1025(c)(3)
to be nonrepairable. (63.1039(b)(1))
a. Valves in gas and vapor service and in light liquid service pursuant to
§63.1025(b) and (c). (63.1039(b)(1)(i))
b. Pumps in light liquid service pursuant to §63.1026(b) and (c). (63.1039(b)(1)(ii))
c. Connectors in gas and vapor service and in light liquid service pursuant to
§63.1027(b) and (c). (63.1039(bX1)(iii))
d. Agitators in gas and vapor service and in light liquid service pursuant to
§63.1028(c). (63.1039(b)(1)(iv))
e. Compressors pursuant to §63.1031(d). (63.1039(b)(1)(v))
1.2.31.2 Where any delay of repair is utilized pursuant to §63.1024(d), report that delay of
repair has occurred and report the number of instances of delay of repair.
(63.1039(b)(2))
1.2.31.3 If applicable, report the valve subgrouping information specified in
§63.1025(b)(4)(iv). (63.1039(b)(3))
1.2.31.4 For pressure relief devices in gas and vapor service pursuant to §63.1030(b) and for
compressors pursuant to §63.1031(1) that are to be operated at a leak detection
instrument reading of less than 500 parts per million, report the results of all
monitoring to show compliance conducted within the semiannual reporting period.
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 23
(63.1039(b)(4))
1.2.31.5 Report, if applicable, the initiation of a monthly monitoring program for valves
pursuant to §63.1025(b)(3)(i). (63.1039(b)(5))
1.2.31.6 Report, if applicable, the initiation of a quality improvement program for pumps
pursuant to §63.1035. (63.1039(b)(6))
1.2.31.7 Where the alternative means of emissions limitation for batch processes is utilized,
report the information listed in §63.1036(f). (63.1039(b)(7))
1.2.31.8 Report the information listed in paragraph (a) of §63.1039 for the Initial Compliance
Status Report for process units or affected facilities with later compliance dates.
Report any revisions to items reported in an earlier Initial Compliance Status Report if
the method of compliance has changed since the last report. (63.1039(b)(8))
1.2.32 If you comply with subpart UU of this part 63, you may elect to comply with the provisions in
paragraphs (b)(1) through (5) of §63.2480 as an alternative to the referenced provisions in
subpart H or subpart UU of this part. (63.2480(b))
1.2.32.1. For an existing source, you are not required to develop an initial list of identification
numbers for connectors as would otherwise be required under §63.1022(b)(1).
(63.2480(b)(3))
1.2.32.2 For connectors in gas/vapor and light liquid service at an existing source, you may
elect to comply with the requirements in §63.1029 for connectors in heavy liquid
service, including all associated recordkeeping and reporting requirements, rather than
the requirements of §63.1027. (63.2480(b)(4))
a. For pumps in light liquid service in an MCPU that has no continuous process
vents and is part of an existing source, you may elect to consider the leak
definition that defines a leak to be 10,000 parts per million (ppm) or greater as an
alternative to the values specified in §63.1026(b)(2)(i) through (iii).
(63.2480(b)(5))
1.2.32.3 The provisions of §63.2480 do not apply to bench -scale processes, regardless of
whether the processes are located at the same plant site as a process subject to the
provisions of Subpart FFFF. (63.2480(d))
Wastewater Streams
1.2.33 For wastewater streams you must meet each requirement in Table 7 of Subpart FFFF of Part 63
that applies to your wastewater streams and liquid streams in open systems within an MCPU,
except as specified in paragraphs (b) through (o) of §63.2485. (63.2485(a))
1.2.33.1 For each process wastewater stream you must comply with the requirements in
§§63.132 through 63.148 and the requirements referenced therein, except as specified
in §63.2485. (Item 1, Table 7 to Subpart FFFF of Part 63)
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 24
[The requirements of Conditions 1.2.34 through 1.2.38 reflect the current rule language as of the
revisions to 40 CFR Part 63 Subpart G published in the Federal Register on 02/27/2014. 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 G. It should be noted that the
language has been modified as required by 40 CFR Part 63 Subpart FFFF and described in Conditions
1.2.6, 1.2.7, 1.2.39, and 1.2.40]
1.2.34 This paragraph specifies the requirements applicable to process wastewater streams located at
existing sources. The owner or operator shall comply with the requirements in paragraphs (a)(1)
and (a)(2) of §63.132, no later than the applicable dates specified in Condition 1.2.2. (63.132(a))
1.2.34.1 Determine whether each wastewater stream requires control for Table 8 and Table 9 of
Subpart FFFF of Part 63 compounds by complying with the requirements in either
paragraph (a)(1)(i) or (a)(1)(ii) of §63.132, and comply with the requirements in
paragraph (a)(1)(iii) of §63.132. (63.132(a)(1))
a. Comply with paragraph (c) of §63.132, determining whether the wastewater
stream is Group 1 or Group 2 for Table 8 and Table 9 of Subpart FFFF of Part 63
compounds; (63.132(a)(1)(i))
b. Comply with paragraph (e) of §63.132, designating the wastewater stream as a
Group 1 wastewater stream. (63.132(a)(ii))
c. Comply with paragraph (f) of §63.132. (63.132(a)(iii))
1.2.34.2 For wastewater streams that are Group 2 for Table 8 and Table 9 of Subpart FFFF of
Part 63 compounds, comply with the applicable recordkeeping and reporting
requirements specified in §§63.146(b)(1) and 63.147(b)(8). (63.132(a)(3))
1.2.35 A process wastewater stream is Group 1 for compounds in Table 8 and Table 9 of Subpart FFFF
of Part 63 if any of the conditions specified in paragraphs (c) (1) through (3) of §63.2485 are
met. (63.2485(c))
1.2.35.1 The total annual average concentration of compounds in Table 8 to Subpart FFFF is
greater than or equal to 10,000 ppmw at any flowrate, and the total annual load of
compounds in Table 8 to Subpart FFFF is greater than or equal to 200 lb/yr.
(63.2485(c)(1))
1.2.35.2 The total annual average concentration of compounds in Table 8 to Subpart FFFF is
greater than or equal to 1,000 ppmw, and the annual average flowrate is greater than or
equal to 1 1/min. (63.2485(c)(2))
1.2.35.3 The combined total annual average concentration of compounds in Tables 8 and 9 to
Subpart FFFF is greater than or equal to 30,000 ppmw, and the combined total annual
load of compounds in Tables 8 and 9 to Subpart FFFF is greater than or equal to 1 tpy.
(63.2485(c)(3))
1.2.35.4 A wastewater stream is a Group 2 wastewater stream for Table 8 and Table 9 of
Subpart FFFF of Part 63 compounds if it is not a Group 1 wastewater stream for Table
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 25
8 and Table 9 of Subpart FFFF of Part 63 compounds by the criteria in paragraph (c)
of §63.2485. (63.132(c)(2))
1.2.35.5 The owner or operator of a Group 2 wastewater shall re -determine group status for
each Group 2 stream, as necessary, to determine whether the stream is Group 1 or
Group 2 whenever process changes are made that could reasonably be expected to
change the stream to a Group 1 stream. Examples of process changes include, but are
not limited to, changes in production capacity, production rate, feedstock type, or
whenever there is a replacement, removal, or addition of recovery or control
equipment. For purposes of this paragraph (c)(3), process changes do not include:
Process upsets; unintentional, temporary process changes; and changes that are within
the range on which the original determination was based. (63.132(c)(3))
Note: Source has determined the wastewater stream to be Group 2.
1.2.36 Owners or operators of sources subject to Subpart G shall not discard liquid or solid organic
materials with a concentration of greater than 10,000 parts per million of Table 8 and Table 9 of
Subpart FFFF of Part 63 compounds (as determined by analysis of the stream composition,
engineering calculations, or process knowledge, according to the provisions of §63.144(b)) from
a chemical manufacturing process unit to water or wastewater, unless the receiving stream is
managed and treated as a Group 1 wastewater stream. This prohibition does not apply to
materials from the activities listed in paragraphs (f)(1) through (f)(4) of §63.132. (63.132(f))
1.2.36.1 Equipment leaks; (63.132(O(1))
1.2.36.2 Activities included in maintenance or startup/shutdown/malfunction plans;
(63.132(O(2))
1.2.36.3 Spills; or (63.132(O(3))
1.2.36.4 Samples of a size not greater than reasonably necessary for the method of analysis that
is used. (63.132(O(4))
1.2.37 For Group 2 wastewater streams, the owner or operator shall include the information specified in
paragraphs (b)(1)(i) through (iv) of §63.146 in the Notification of Compliance Status Report.
This information may be submitted in any form. Table 15 of Subpart G of Part 63 is an example.
(63.146(b)(1))
1.2.37.1 Process unit identification and description of the process unit. (63.146(b)(1)(i))
1.2.37.2 Stream identification code. (63.146(b)(1)(ii))
1.2.37.3 For existing sources, concentration of Table 8 and Table 9 of Subpart FFFF of Part 63
compound(s) in parts per million, by weight. Include documentation of the
methodology used to determine concentration. (63.146(b)(1)(iii)) •
1.2.37.4 Flow rate in liter per minute. (63.146(b)(1)(iv))
1.2.38 For Group 2 wastewater streams, the owner or operator shall keep in a readily accessible location
the records specified in paragraphs (b)(8)(i) through (iv) of §63.147. (63.147(b)(8))
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 26
1.2.38.1 Process unit identification and description of the process unit. (63.147(b)(8)(i))
1.2.38.2 Stream identification code. (63.147(b)(8)(ii))
1.2.38.3 For existing sources, concentration of Table 8 and Table 9 of Subpart FFFF of Part 63
compound(s) in parts per million, by weight. Include documentation of the
methodology used to determine concentration. (63.147(b)(8)(iii))
1.2.38.4 Flow rate in liter per minute. (63.147(b)(8)(iv))
1.2.39 Where §63.105 and §§63.132 through 63.148 refer to compounds in Table 9 of subpart G of Part
63, the compounds in Tables 8 and 9 of Subpart FFFF of Part 63 apply for the purposes of
Subpart FFFF. (63.2485(b))
1.2.40 Section 63.132(c)(1) (i) and (ii) do not apply. For the purposes of Subpart FFFF, a process
wastewater stream is Group 1 for compounds in Tables 8 and 9 to Subpart FFFF if any of the
conditions specified in paragraphs (c) (1) through (3) of §63.2485 are met. (63.2485(c))
Heat Exchange System
1.2.41 For heat exchange systems you must comply with each requirement in Table 10 of Subpart FFFF
of Part 63 that applies to your heat exchange systems, except as specified in paragraphs (b) and
(c) of §63.2490. (63.2490(a))
1.2.41.1 For each heat exchange system, as defined in §63.101, you must Comply with the
requirements of §63.104 and the requirements referenced therein, except as specified
in §63.2490. (Item 1, Table 10 to Subpart FFFF of Part 63)
[The requirements of Conditions 1.2.42 through 1.2.47 reflect the current rule language as of the
revisions to 40 CFR Part 63 Subpart F published in the Federal Register on 12/21/2006. 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 F. It should be noted that the
language has been modified as required by 40 CFR Part 63 Subpart FFFF and described in Conditions
1.2.6, 1.2.7, 1.2.48, and 1.2.49]
1.2.42 Owners and operators of sources subject to Subpart F shall monitor each heat exchange system
used to cool process equipment in an MCPU meeting the conditions of §63.2435, according to
the provisions in either paragraph (c) of §63.104. Whenever a leak is detected, the owner or
operator shall comply with the requirements in paragraph (d) of §63.104. (63.104(a))
1.2.43 The owner or operator who elects to comply with the requirement of paragraph (a) of §63.104 by
monitoring using a surrogate indicator of heat exchange system leaks shall comply with the
requirements specified in paragraphs (c)(1) through (c)(3) of §63.104. Surrogate indicators that
could be used to develop an acceptable monitoring program are ion specific electrode
monitoring, pH, conductivity or other representative indicators. (63.104(c))
1.2.43.1 The owner or operator shall prepare and implement a monitoring plan that documents
the procedures that will be used to detect leaks of process fluids into cooling water.
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 27
The plan shall require monitoring of one or more surrogate indicators or monitoring of
one or more process parameters or other conditions that indicate a leak. Monitoring
that is already being conducted for other purposes may be used to satisfy the
requirements of §63.104. The plan shall include the information specified in
paragraphs (c)(1)(i) and (c)(1)(ii) of §63.104. (63.104(c)(1))
a. A description of the parameter or condition to be monitored and an explanation of
how the selected parameter or condition will reliably indicate the presence of a
leak. (63.104(c)(1)(i))
b. The parameter level(s) or conditions(s) that shall constitute a leak. This shall be
documented by data or calculations showing that the selected levels or conditions
will reliably identify leaks. The monitoring must be sufficiently sensitive to
determine the range of parameter levels or conditions when the system is not
leaking. When the selected parameter level or condition is outside that range, a
leak is indicated. (63.104(c)(1)(ii))
c. The monitoring frequency which shall be no less frequent than monthly for the
first 6 months and quarterly thereafter to detect leaks. (63.104(c)(1)(iii))
d. The records that will be maintained to document compliance with the
requirements of §63.104. (63.104(c)(1)(iv))
1.2.43.2 If a substantial leak is identified by methods other than those described in the
monitoring plan and the method(s) specified in the plan could not detect the leak, the
owner or operator shall revise the plan and document the basis for the changes. The
owner or operator shall complete the revisions to the plan no later than 180 days after
discovery of the leak. (63.104(c)(2))
1.2.43.3 The owner or operator shall maintain, at all times, the monitoring plan that is currently
in use. The current plan shall be maintained on -site, or shall be accessible from a
central location by computer or other means that provides access within 2 hours after a
request. If the monitoring plan is superseded, the owner or operator shall retain the
most recent superseded plan at least until 5 years from the date of its creation. The
superseded plan shall be retained on -site (or accessible from a central location by
computer or other means that provides access within two hours after a request) for at
least 6 months after its creation. (63.104(c)(3))
1.2.44 If a leak is detected according to the criteria of paragraph (b) or (c) of §63.104, the owner or
operator shall comply with the requirements in paragraphs (d)(1) and (d)(2) of §63.104, except as
provided in paragraph (e) of §63.104. (63.104(d))
1.2.44.1 The leak shall be repaired as soon as practical but not later than 45 calendar days after
the owner or operator receives results of monitoring tests indicating a leak. The leak
shall be repaired unless the owner or operator demonstrates that the results are due to a
condition other than a leak. (63.104(d)(1))
1.2.44.2 Once the leak has been repaired, the owner or operator shall confirm that the heat
exchange system has been repaired within 7 calendar days of the repair or startup,
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 28
whichever is later. (63.104(d)(2))
1.2.45 Delay of repair of heat exchange systems for which leaks have been detected is allowed if the
equipment is isolated from the process. Delay of repair is also allowed if repair is technically
infeasible without a shutdown and any one of the conditions in paragraph (e)(1) or (e)(2) of
§63.104 is met. All time periods in paragraphs (e)(1) and (e)(2) of §63.104 shall be determined
from the date when the owner or operator determines that delay of repair is necessary.
(63.104(e))
1.2.45.1 If a shutdown is expected within the next 2 months, a special shutdown before that
planned shutdown is not required. (63.104(e)(1))
1.2.45.2 If a shutdown is not expected within the next 2 months, the owner or operator may
delay repair as provided in paragraph (e)(2)(i) or (e)(2)(ii) of §63.104. Documentation
of a decision to delay repair shall state the reasons repair was delayed and shall specify
a schedule for completing the repair as soon as practical. (63.104(e)(2))
a. If a shutdown for repair would cause greater emissions than the potential
emissions from delaying repair, the owner or operator may delay repair until the
next shutdown of the process equipment associated with the leaking heat
exchanger. The owner or operator shall document the basis for the determination
that a shutdown for repair would cause greater emissions than the emissions likely
to result from delaying repair as specified in paragraphs (e)(2)(i)(A) and
(e)(2)(i)(B) of §63.104. (63.104(e)(2)(i))
(i)
The owner or operator shall calculate the potential emissions from the leaking
heat exchanger by multiplying the concentration of total hazardous air
pollutants listed in Table 4 of Subpart F of Part 63 in the cooling water from
the leaking heat exchanger by the flowrate of the cooling water from the
leaking heat exchanger by the expected duration of the delay. The owner or
operator may calculate potential emissions using total organic carbon
concentration instead of total hazardous air pollutants listed in Table 4 of
Subpart F of Part 63. (63.104(e)(2)(i)(A))
(ii) The owner or operator shall determine emissions from purging and
depressurizing the equipment that will result from the unscheduled shutdown
for the repair. (63.104(e)(2)(i)(B))
b. If repair is delayed for reasons other than those specified in paragraph (e)(2)(i) of
§63.104, the owner or operator may delay repair up to a maximum of 120
calendar days. The owner shall demonstrate that the necessary parts or personnel
were not available. (63.104(e)(2)(ii))
1.2.46 The owner or operator shall retain the records identified in paragraphs (f)(1)(i) through (f)(1)(iv)
of §63.104 as specified in §63.103(c)(1). (63.104(O(1))
1.2.46.1 Monitoring data required by §63.104 indicating a leak and the date when the leak was
detected, and if demonstrated not to be a leak, the basis for that determination;
(63.104(f)(1)(i))
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 29
1.2.46.2 Records of any leaks detected by procedures subject to paragraph (c)(2) of §63.104
and the date the leak was discovered; (63.104(f)(1)(ii))
1.2.46.3 The dates of efforts to repair leaks; and (63.104(f)(1)(iii))
1.2.46.4 The method or procedure used to confirm repair of a leak and the date repair was
confirmed. (63.104(f)(1)(iv))
1.2.47 If an owner or operator invokes the delay of repair provisions for a heat exchange system, the
following information shall be submitted in the next semi-annual periodic report required by
§63.152(c) of subpart G of this part. If the leak remains unrepaired, the information shall also be
submitted in each subsequent periodic report, until repair of the leak is reported. (63.104(O(2))
1.2.47.1 The owner or operator shall report the presence of the leak and the date that the leak
was detected. (63.104(O(2)(i))
1.2.47.2 The owner or operator shall report whether or not the leak has been repaired.
(63.104(O(2)(ii))
1.2.47.3 The owner or operator shall report the reason(s) for delay of repair. If delay of repair is
invoked due to the reasons described in paragraph (e)(2) of §63.104, documentation of
emissions estimates must also be submitted. (63.104(O(2)(iii))
1.2.47.4 If the leak remains unrepaired, the owner or operator shall report the expected date of
repair. (63.104(O(2)(iv))
1.2.47.5 If the leak is repaired, the owner or operator shall report the date the leak was
successfully repaired. (63.104(O(2)(v))
1.2.48 The phrase "a chemical manufacturing process unit meeting the conditions of §63.100 (b)(1)
through (b)(3) of this section" in §63.104(a) means "an MCPU meeting the conditions of
§63.2435" for the purposes of Subpart FFFF. (63.2490(b))
1.2.49 The reference to §63.100(c) in §63.104(a) does not apply for the purposes of Subpart FFFF.
(63.2490(c))
1.2.50 You must submit all of the notifications in §§63.6(h)(4) and (5), 63.7(b) and (c), 63.8(e), (O(4)
and (6), and 63.9(b) through (h) that apply to you by the dates specified. (63.2515(a))
1.2.51 As specified in §63.9(b)(2), if you startup your affected source before November 10, 2003, you
must submit an initial notification not later than 120 calendar days after November 10, 2003.
(63.2515(b))
Note: Initial notification received on March 9, 2004.
1.2.52 You must submit each report in Table 11 of Subpart FFFF of Part 63 that applies to you.
(63.2550(a))
1.2.52.1 You must submit a notification of compliance status report that shall contain the
information specified in §63.2520(d). You must submit the report no later than 150
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 30
days after the compliance date specified in §63.2445. (Item 2, Table 11 to Subpart
FFFF of Part 63)
1.2.52.2 You must submit compliance report containing the information specified in
§63.2520(e). You must submit the report semiannually according to the requirements
in 63.2520(b). (Item 3, Table 11 to Subpart FFFF of Part 63)
1.2.53 The permittee shall retain records as specified in §§ 63.2525(a), (b), (e), and (f).
1.2.54 Table 12 of Subpart FFFF of Part 63 shows which parts of the General Provisions in §§63.1
through 63.15 apply.
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 31
2. S29B-Chem Mix and Thermal Media Manufacturing, Building C -29B, #291 Coating Machine,
RTO1 (MRS # 107)
S29C- Thermal Media Manufacturing, Building C -29C, #292 Coating Machine, RTO2 (AIRS #
108)
Parameter
Condition
Number
Limitation
Compliance
Emission
Factor
Monitoring
Method
Interval
#291 Coating Machine
/ RTO1 VOC
2.1
*77.59 tons/year
5.5 lbs/mmscf
Recordkeeping
Calculation
Monthly
Facility Wide VOC
2.2
169.7 tons/year
5.5 lbs/mmscf
Recordkeeping
Calculation
Monthly
NOx
7.15 tons/year
100 lbs/mmscf
CO
6.01 tons/year
84 lbs/mmscf
RTO Combined Fuel
Use
2.3
Natural Gas: 143 mmscf/year
Fuel Meter
Monthly
MACT Subpart KK
2.4
No more than 5% of organic
HAP applied for each month
(95% reduction) OR No more
than 4% of the mass of the
coating materials applied each
month OR No more than 20% of
the mass of solids applied each
month
Operating
Parameter
Monitoring
Continuous
RTO Combustion
Chamber Temperature
2.5.1
RTO1 1387° F
Temperature
Monitor
Continuous
RTO2 1578° F
Capture Efficiency
u
100%
2.5.2
RTO1- Fan Operation Status:
"On"
Fan Operation
Monitors
RTO2- #291 Coating Machine
coating room to ambient
differential pressure:
< -0.007" WC
Continuous
Enclosure
Differential
Pressure
Monitors
Colorado Regulation
No. 7, Section IX
2.6
VOC Emissions Shall Not
Exceed 4.8 lbs per Gallon of
Solids
; � "
Recordkeeping
and Calculation
Daily
See Condition
2.6.1
*Note: Emissions limitations accounted for in the Facility Wide limit.
2.1 Emissions of Volatile Organic Compounds (VOC) from Building C -29B #291 Coating Machine and
RTO1 shall not exceed the limitations state in Table 2 (96WE473 as modified under the provisions of
Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section.
III.B.7). Monthly emissions shall be calculated as described below and used in a twelve month rolling
total to monitor compliance with the annual emission limit. Each month, a new twelve month total shall
be calculated using the previous twelve month's total.
#291 Coating Machine (reference Condition 2.5 for RTO control efficiency):
tons lbs 1 ton
VOC month= Coating Solvents Used month x (1 — RT01 Control Efficiency) x 2000 lbs
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 32
RTO1 Emissions:
tons lbs VOC mmscf 1 ton
VOC month = 5.5 mmscf x Natural Gas Consumed Month x 2000 lbs
2.2 Facility wide emissions of Volatile Organic Compounds (VOC), and emission of Nitrogen Oxides
(NOx), and Carbon Monoxide (CO) from both RTOs together shall not exceed the limitations stated in
Table 2 (96WE473 as modified under the provisions of Section I, Condition 1.3 and Colorado
Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7). Monthly emissions of each
pollutant shall be calculated as described below and used in a twelve month rolling total to monitor
compliance with the annual emission limit. Each month, a new twelve month total shall be calculated
using the previous twelve month's total.
Chem Mix:
VOC = Total Vented Volume x Solvent Vapor Density
#291 Coating Machine (reference Condition 2.5 for RTO control efficiency):
tons lbs 1 ton
VOC = Coating Solvents Used x (1 — RT01 Control Efficiency) x
month month 2000 lbs
#292 Coating Machine (reference Condition 2.5 for RTO control efficiency):
tons _ lbs 1 ton
VOC month = Coating Solvents Used month x (1 — RT02 Control Efficiency) x 2000 lbs
RT0 Emissions:
tons lbs NOX mmscf 1 ton
VOC month = 5.5 mmscf x Natural Gas Consumed Month x 20001'bs
tons lbs NOX mmscf 1 ton
CO month = 84 mmscf x Natural Gas Consumed Month x 2000 lbs
tons lbs NOX mmscf 1 ton
NOX month 100 mmscf x Natural Gas Consumed Month x 2000 lbs
2.3 Natural gas consumption for both RTO's together shall not exceed the limitations listed in Table 2
(96WE473 as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3,
Part C, Section I.A.7 and Part C, Section III.B.7). Natural gas consumed by the RTO's shall be recorded
monthly. Monthly quantities of natural gas consumed shall be used in a twelve month rolling total to
monitor compliance with the annual limitations. Each month a new twelve month rolling total shall be
calculated using the previous twelve months data.
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 33
2.4 This source is subject to the National Emissions Standards for Hazardous Air Pollutants requirements of
Regulation No. 8, Part E, Subpart KK (40 CFR Part 63, Subpart KK), for the Printing and Publishing
Industry, including, but not limited to, the following:
[The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart
KK published in the Federal Register on 4/21/2011. 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 KK.]
2.4.1 Each owner or operator of any product and packaging rotogravure or wide -web flexographic
printing affected source that is subject to the requirements of Subpart KK shall comply with
these requirements on and after the compliance dates as specified in §63.826 of Subpart KK.
(63.825(a))
Note: Compliance date for #291 Coating Machine and RTO1 is May 30, 1999 as it is an existing
affected source. Compliance date for #292 Coating Machine and RTO2 is April 22, 2005, which
is the start-up date.
2.4.2 Each product and packaging rotogravure or wide -web flexographic printing affected source shall
limit organic HAP emissions to no more than 5 percent of the organic HAP applied for the
month; or to no more than 4 percent of the mass of inks, coatings, varnishes, adhesives, primers,
solvents, reducers, thinners, and other materials applied for the month; or to no more than 20
percent of the mass of solids applied for the month; or to a calculated equivalent allowable mass
based on the organic HAP and solids contents of the inks, coatings, varnishes, adhesives,
primers, solvents, reducers, thinners, and other materials applied for the month. The owner or
operator of each product and packaging rotogravure or wide -web flexographic printing affected
source shall demonstrate compliance with this standard by following one of the procedures in
paragraphs (b)(1) through (b)(10) of §63.825: (63.825(b))
2.4.3 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 2.4.13.5. The permittee has previously indicated that
they would limit organic HAP emissions to no more than 5 percent of the organic HAP applied
for the month.
2.4.3.1 Operate a capture system and control device and demonstrate an overall organic HAP
control efficiency of at least 95 percent for each month. If the affected source operates
more than one capture system or more than one control device, and has only always
controlled work stations, then the owner or operator shall demonstrate compliance in
accordance with the provisions of either paragraph (1) or (h) of §63.825. If the affected
source operates one or more never -controlled work stations or one or more
intermittently -controllable work stations, then the owner or operator shall demonstrate
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution. Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 34
compliance in accordance with the provisions of paragraph (f) of §63.825. Otherwise,
the owner or operator shall demonstrate compliance in accordance with the procedure
in paragraph (c) of §63.825 when emissions from the affected source are controlled by
a solvent recovery device or the procedure in paragraph (d) of §63.825 when
emissions are controlled by an oxidizer. (63.825(b)(7))
2.4.4 If the affected source operates more than one capture system or more than one control device,
and has no never -controlled work stations and no intermittently -controllable work stations, then
the affected source is in compliance with the 95 percent overall organic HAP control efficiency
requirement for the month if for each press or group of presses controlled by a common control
device: (63.825(h))
2.4.4.1 The overall organic HAP control efficiency as determined by paragraphs (d)(1)(i)-(iii)
and (d)(1)(x) of §63.825 for each press or group of presses served by that control
device and a common capture system is equal to or greater than 95 percent, the
oxidizer is operated such that the average operating parameter value is greater than the
operating parameter value established in accordance with §63.828(a)(4) for each three
hour period, and the average capture system operating parameter value for each
capture system serving that control device is greater than or less than (as appropriate)
the operating parameter value established for that capture system in accordance with
§63.828(a)(5) for each three hour period. (63.825(h)(3))
2.4.4.2 Demonstrate initial compliance through performance tests of capture efficiency and
control device efficiency and continuing compliance through continuous monitoring of
capture system and control device operating parameters following the procedures in
paragraph (d)(1)(i) through (d)(1)(xi) of §63.825: (63.825(d)(1))
a. Determine the oxidizer destruction efficiency (E) using the procedure in
§63.827(d). (63.825(d)(1)(i))
b. Determine the capture system capture efficiency (F) in accordance with
§63.827(e) -(f). (63.825(d)(1)(ii))
c. Calculate the overall organic HAP control efficiency, (R), achieved using
Equation 13. (63.825(d)(1)(iii))
d. Install, calibrate, operate and maintain the instrumentation necessary to measure
continuously the site -specific operating parameters established in accordance with
§63.828(a)(4)-(5) whenever a product and packaging rotogravure or wide -web
flexographic press is operating. (63.825(d)(1)(x))
e. The affected source is in compliance, if the oxidizer is operated such that the
average operating parameter value is greater than the operating parameter value
established in accordance with §63.828(a)(4) for each three-hour period, and the
capture system operating parameter is operated at an average value greater than or
less than (as appropriate) the operating parameter value established in accordance
with §63.828(a)(5) for each three hour period, and (63.825(d)(1)(xi))
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 35
(i) The overall organic HAP control efficiency, R, is 95 percent or greater,
(63.825(d)(1)(xi)(A))
2.4.5 The compliance date for an owner or operator of an existing affected source subject to the
provisions of Subpart KK is May 30, 1999. (63.826(a))
2.4.6 The compliance date for an owner or operator of a new affected source subject to the provisions
of Subpart KK is immediately upon start-up of the affected source, or May 30, 1996, whichever
is later. (63.826(b))
2.4.7 Performance tests shall be conducted under such conditions as the Administrator specifies to the
owner or operator based on representative performance of the affected source for the period
being tested. Upon request, the owner or operator shall make available to the Administrator such
records as may be necessary to determine the conditions of performance tests. (63.827)
2.4.7.1 A performance test of a control device to determine destruction efficiency for the
purpose of meeting the requirements of §63.825 shall be conducted by the owner or
operator in accordance with §63.827(d)(i) through (ix). (63.827(d))
2.4.7.2 A performance test to determine the capture efficiency of each capture system venting
organic emissions to a control device for the purpose of meeting the requirements of
§63.825(d)(1) shall be conducted by the owner or operator in accordance with the
following: (63.827(e))
a. You may assume your capture efficiency equals 100 percent if your capture
system is a permanent total enclosure (PTE). You must confirm that your capture
system is a PTE by demonstrating that it meets the requirements of section 6 of
Method 204 of 40 CFR part 51, appendix M, and that all exhaust gases from the
enclosure are delivered to a control device. (63.827(e)(1))
Note: Capture systems for Coating Lines #291 and #292 have been determined to
meet the requirements for a total enclosure.
2.4.8 Following the date on which the initial performance test of a control device is completed, to
demonstrate continuing compliance with the standard, the owner or operator shall monitor and
inspect each control device required to comply with §63.825 to ensure proper operation and
maintenance by implementing the applicable requirements in paragraph (a)(1) through (a)(5) of
§63.828. (63.828(a))
2.4.8.1 All temperature monitoring equipment shall be installed, calibrated, maintained, and
operated according to manufacturers specifications. The calibration of the chart
recorder, data logger, or temperature indicator shall be verified every three months; or
the chart recorder, data logger, or temperature indicator shall be replaced. The
replacement shall be done either if the owner or operator chooses not to perform the
calibration, or if the equipment cannot be calibrated properly. (63.828(a)(2)(ii))
2.4.8.2 For an oxidizer other than a catalytic oxidizer, install, calibrate, operate, and maintain
a temperature monitoring device equipped with a continuous recorder. The device
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 36
shall have an accuracy of ±1 percent of the temperature being monitored in °C or ±1
°C, whichever is greater. The thermocouple or temperature sensor shall be installed in
the combustion chamber at a location in the combustion zone. (63.828(a)(4)(i))
2.4.8.3 An owner or operator complying with the requirements of §§63.824-63.825 through
the use of a control device and demonstrating continuous compliance by monitoring
an operating parameter to ensure that the capture efficiency measured during the initial
compliance test is maintained, shall: (63.828(a)(5))
a. Submit to the Administrator with the compliance status report required by
§63.9(h) of the General Provisions, a plan that: (63.828(a)(5)(i))
(i) Identifies the operating parameter to be monitored to ensure that the capture
efficiency measured during the initial compliance test is maintained,
(63.828(a)(5)(i)(A))
(ii) Discusses why this parameter is appropriate for demonstrating ongoing
compliance, and (63.828(a)(5)(i)(B))
(iii) Identifies the specific monitoring procedures; (63.828(a)(5)(i)(C))
(iv) Set the operating parameter value, or range of values, that demonstrate
compliance with §63.825, and (63.828(a)(5)(i)(C))
(v) Conduct monitoring in accordance with the plan submitted to the
Administrator unless comments received from the Administrator require an
alternate monitoring scheme. (63.828(a)(5)(i)(D))
Note: #291 Coating Machine and RTO1: The Regenerative Thermal Oxidizer fan
operational status (on) is the parameter identified to be monitored to ensure
capture efficiency is maintained. Combustion chamber temperature (greater than
1,387 °F for each three hour period as established in performance test conducted
on January 30, 2008) is the operating parameter chosen to demonstrate
compliance with §63.825.
#292 Coating Machine and RTO2: The coating room to ambient differential
pressure (less than -0.007 "of water column) is the parameter identified to be
monitored to ensure capture efficiency is maintained. Combustion chamber
temperature (greater than 1,578 °F for each three hour period as established in
performance test conducted on September 28, 2005) is the operating parameter
chosen to demonstrate compliance with §63.825.
2.4.9 Any excursion from the required operating parameters which are monitored in accordance with
paragraphs (a)(4) and (a)(5) of §63.828, unless otherwise excused, shall be considered a violation
of the emission standard. (63.828(b))
2.4.10 Each owner or operator of an affected source subject to Subpart KK shall maintain the records
specified in paragraphs (b)(1) through (b)(3) of §63.829 on a monthly basis in accordance with
the requirements of §63.10(b)(1) of this part: (63.829(b))
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 37
2.4.10.1 Records specified in §63.10(b)(2) of this part, of all measurements needed to
demonstrate compliance with this standard, such as continuous emission monitor data,
control device and capture system operating parameter data, material usage, HAP
usage, volatile matter usage, and solids usage that support data that the source is
required to report. (63.829(b)(1))
2.4.10.2 Records specified in §63.10(b)(3) of this part for each applicability determination
performed by the owner or operator in accordance with the requirements of §63.820(a)
of Subpart KK, and (63.829(b)(2))
2.4.10.3 Records specified in §63.10(c) of this part for each continuous monitoring system
operated by the owner or operator in accordance with the requirements of §63.828(a)
of Subpart KK. (63.829(b)(3))
2.4.11 Each owner or operator of an affected source subject to Subpart KK shall maintain records of the
occurrence and duration of each malfunction of operation (i.e., process equipment), air pollution
control equipment, or monitoring equipment. (63.829(g))
2.4.12 Each owner or operator of an affected source subject to Subpart KK shall maintain records of
actions taken during periods of malfunction to minimize emissions in accordance with
§63.823(b), including corrective actions to restore malfunctioning process and air pollution
control and monitoring equipment to its normal or usual manner of operation. (63.829(h))
2.4.13 Each owner or operator of an affected source subject to Subpart KK shall submit the reports
specified in paragraphs (b)(1) through (b)(6) of §63.830 to the Administrator: (63.830(b))
2.4.13.1 An initial notification required in §63.9(b). (63.830(b)(1))
a. Initial notifications for existing sources shall be submitted no later than one year
before the compliance date specified in §63.826(a). (63.830(b)(1)(i))
b. Initial notifications for new and reconstructed sources shall be submitted as
required by §63.9(b). (63.830(b)(1)(ii))
c. For the purpose of Subpart KK, a Title V or part 70 permit application may be
used in lieu of the initial notification required under §63.9(b), provided the same
information is contained in the permit application as required by §63.9(b), and the
State to which the permit application has been submitted has an approved
operating permit program under part 70 of this chapter and has received
delegation of authority from the EPA. (63.830(b)(1)(iii))
2.4.13.2 A Notification of Performance Tests specified in §§63.7 and 63.9(e) of this part. This
notification, and the site -specific test plan required under §63.7(c)(2) shall identify the
operating parameter to be monitored to ensure that the capture efficiency measured
during the performance test is maintained. The operating parameter identified in the
site -specific test plan shall be considered to be approved unless explicitly disapproved,
or unless comments received from the Administrator require monitoring of an
alternate parameter. (63.830(b)(2))
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 38
2.4.13.3 A Notification of Compliance Status specified in §63.9(h) of this part. (63.830(b)(3))
2.4.13.4 Performance test reports specified in §63.10(d)(2) of this part. (63.830(b)(4))
2.4.13.5 A summary report specified in §63.10(e)(3) of this part shall be submitted on a semi-
annual basis (i.e., once every 6 -month period). These summary reports are required
even if the affected source does not have any control devices or does not take the
performance of any control devices into account in demonstrating compliance with the
emission limitations in §63.825. In addition to a report of operating parameter
exceedances as required by §63.10(e)(3)(i), the summary report shall include, as
applicable: (63.830(b)(6))
a. Exceedances of the standards in §63.825. (63.830(b)(6)(i))
b. Exceedances of the criterion of §63.821(a)(2)(ii)(A). (63.830(b)(6)(iv))
c. The number, duration, and a brief description for each type of malfunction which
occurred during the reporting period and which caused or may have caused any
applicable emission limitation to be exceeded. The report must also include a
description of actions taken by an owner or operator during a malfunction of an
affected source to minimize emissions in accordance with §63.823(b), including
actions taken to correct a malfunction. (63.830(b)(6)(v))
2.4.14 As of January 1, 2012, and within 60 days after the date of completing each performance test, as
defined in §63.2 and as required in Subpart KK, you must submit performance test data, except
opacity data, electronically to EPA's Central Data Exchange by using the ERT
(see https://www3.epa.gov/ttn/chief/ert/index.html) or other compatible electronic spreadsheet.
Only data collected using test methods compatible with ERT are subject to this requirement to be
submitted electronically into EPA's WebFIRE database. (63.830(c)(1))
2.4.15 All reports required by Subpart KIK not subject to the requirements in paragraph (c)(1) of
§63.830 must be sent to the Administrator at the appropriate address listed in §63.13. If
acceptable to both the Administrator and the owner or operator of a source, these reports may be
submitted on electronic media. The Administrator retains the right to require submittal of reports
subject to paragraph (c)(1) of §63.830 in paper format. (63.830(c)(2))
2.4.16 Table 1 to subpart KK provides cross references to the 40 CFR Part 63, subpart A, general
provisions, indicating the applicability of the general provisions requirements to subpart KK.
(63.823(a))
2.4.17 Each owner or operator of an affected source subject to subpart KK must at all times operate and
maintain that affected source, 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, which
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.
(63.823(b))
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 39
2.5 The Permittee may use control efficiency higher than 95% for estimating HAP and VOC emissions for
compliance, APEN, and fee purposes, provided that:
2.5.1 The three hour average combustion temperature of the RTO shall be maintained above the
combustion chamber temperature set point established during the most recently approved
performance test. The combustion chamber temperature shall be reestablished each time a
Division approved performance test is conducted. The combustion temperature of the RTO shall
be continuously monitored. If on a rolling 115 minute average the combustion chamber
temperature falls below the set point the coating machine shall immediately shutdown. An event
log shall be maintained to document any such occurrence. The log will be made available for the
Division review upon request.
Note: The most recent performance test conducted on RTO1 occurred on January 30, 2008
identified an RTO combustion chamber temperature set point of 1,387 °F and determined a
destruction efficiency of 98.8%. The most recent performance test conducted on RTO2 occurred
on September 28, 2005 identified an RTO combustion chamber set point of 1,578 °F and
determined a destruction efficiency of 98.9%.
Each time a new operating temperature is established from the Division approved performance
test, a written notice shall be submitted to the Air Pollution Control Division contact in Appendix
D to notify the Division of the change in operating temperature. A copy of the most recently
approved performance test shall remain onsite and made available for Division review upon
request.
2.5.2 The three hour average capture efficiency shall be maintained at 100%. Capture efficiency shall
be considered at 100% when the following conditions are met:
2.5.2.1 ROT1 capture efficiency of 100% is met while the main fan of RTO1 is on. The fan
shall be interlocked to the coating operation such that if the fan is not on, coating
cannot take place. An event log shall be maintained to document any occurrence of
fan shut down and operational status of #291 Coating Line during the shutdown
period. The log will be made available for the Division review upon request.
2.5.2.2 RTO2 Capture efficiency of 100% is met while the coating room to ambient
differential pressure is less than -0.007 inches water column. The coating room
differential pressure shall be interlocked to the coating operation such that if the
rolling 115 minute average is greater than the -0.007 inches water column set point,
coating cannot take place. An event log shall be maintained to document any such
occurrence and operational status of #292 Coating Line during such occurrence. The
log will be made available for the Division review upon request.
2.6 Volatile Organic Compound (VOC) emissions from the Coating Line are subject to the requirements in
Colorado Regulation No. 7, Section IX, as follows:
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 40
2.6.1 VOC emissions from the coating line shall not exceed 4.8 lbs/gallon of solids (Colorado
Regulation No. 7, Section IX.J, since a control device is used, the equivalent limit is included in
the permit as specified in Section IX.A.5.f)
2.6.2 Compliance with the emission limitations shall be determined on a daily basis (Colorado
Regulation No. 7, Section IX.A.10.a)
2.6.3 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. For
any day in which compliant coatings are not used, the Regenerative Thermal Oxidizer control
efficiency, as determined by Condition 2.5 may be used in the compliance calculations.
2.6.4 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 XI.A.4)
2.6.5 The owner or operator of any VOC source required to comply with this section shall, at their
own expense, demonstrate compliance using EPA reference method 24 of 40 CFR Part 60 for
surface coatings. (Colorado Regulation No. 7, Section XI.A.3.a)
2.6.6 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 this section 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 (Condition 2.6.5). 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 XI.A.3.d)
Note: KodakAlaris is the manufacturer of the coating KodakAlaris applies and shall conduct
initial sampling and testing in accordance with Condition 2.6.5 to determine VOC concentration
in lbs/gallon of solids.
2.6.6.1 After initial testing source shall retest and recertify coating VOC content within 30
days of modifying formulation of the coating. Testing and certification shall occur in
accordance with Condition 2.6.5 and 2.6.6.
2.6.7 The design, operation and efficiency of any capture system used in conjunction with any
emission control system shall be certified in writing by the source owner or operator and
approved by the Division. Unless the capture system meets the requirements for a total enclosure
as specified in the New Source Performance Standard for the Magnetic Tape Manufacturing
Industry, 53FR38892, October 3, 1988, or unless Division approved material balance techniques
are used to adequately determine overall VOC capture and destruction/recovery efficiency, the
efficiency of the capture system shall be determined by test methods approved as a revision to
the State Implementation Plan. Testing for capture efficiency shall be performed on a case -by -
case basis as required by the Division. When capture and control device efficiency must be
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 41
independently determined, the overall VOC emission reduction rate equals the (percent capture
efficiency X percent control device efficiency)/100. (Colorado Regulation No. 7, Section
XI.A.5.e)
Note: Capture systems for Coating Lines #291 and #292 have been determined to meet the
requirements for a total enclosure.
2.6.8 Sources which use add-on controls, crossline averaging, or an approved alternative control
strategy instead of low solvent technology to meet the applicable emission limit shall meet the
equivalent VOC emission limit, on the basis of solids applied (lb VOC/gal solids applied, or lb
VOC/lb solids applied, for graphic arts sources). (Colorado Regulation No. 7, Section XI.A.5.f)
2.6.9 The fugitive emission control requirements in Colorado Regulation No. 7, Section IX.A.7 apply,
as follows:
2.6.9.1 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.
2.6.9.2 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)
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 42
3. S030 Two Natural Gas Fired Boilers (157 mmbtu/hr each, AIRS # 051).
Parameter
Condition
Number
Limitation
Compliance
Emission
Factor
Monitoring
Method
Interval
PM
3.1
0.13 lbs/mmbtu
Fuel Restriction
Natural Gas
Only
NOx
3 2
*37.74 tons/yr
280 lbs/mmscf
Recordkeeping
& Calculation
Monthly
CO
*11.12 tons/yr
84 lbs/mmscf
Fuel Use for Each Boiler
3.3
Natural Gas: 134.8 mmscf/year
'
Fuel Meter
Monthly
Opacity
3.4
Not to exceed 20%, except as
provided for in 3.5
-
Fuel Restriction
Natural Gas
Only
3.5
For certain operational
activities:
Not to exceed 30%, for a period
or periods aggregating more
than six (6) minutes in any 60
consecutive minutes
MACT Subpart DDDDD
3.6
Tune-up every 5 years.
See Conditions 3.6
*Note: Emission limitations are NOT accounted for in the Facility Wide limit.
3.1 Particulate Matter (PM) emissions from each boiler shall not exceed the short term limitation as stated
in the Table 3 above (Colorado Construction Permit 10WE1280 and Colorado Regulation No. 1, Section
III.A.1.b). In the absence of credible evidence to the contrary, compliance with the particulate matter
limit shall be presumed since only natural gas is permitted to be used as fuel for these boilers.
Note that the numeric PM standards were determined using the design heat input for the boilers (157
mmBtu/hr) in the following equation:
PE = 0.5 x (FI)-o.26
lbs
PE = Particulate Standard in
mmBtu
mmBtu
Fl = Fuel Input in
hour
3.2 Nitrogen Oxide (NOx) and Carbon Monoxide (CO) emissions from both boilers together shall not
exceed the limits in Table 3 (Colorado Construction Permit l0WE1280, as modified under the
provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C,
Section III.B.7 based on requested emissions identified on the APEN submitted on 07/01/16). The
emission factors listed in Table 3 have been approved by the Division and shall be used to calculate
emissions from these units. 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. Monthly emissions shall be calculated using the monthly natural gas consumption (as
required by Condition 3.3) and the following equations:
tons lbs NOx mmscf 1 ton
NOx = 280 x Natural Gas Consumed x
month mmscf month 2000 lbs
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
tons lbs CO mmscf 1 ton
CO month = 84 mmscf x Natural Gas Consumed month x 2000 lbs
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 43
3.3 Natural gas consumption for each boiler shall not exceed the limitations listed in the Table 3 above
(Colorado Construction Permit 10WE1280, as modified under the provisions of Section I, Condition 1.3
and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7 based on requested
emissions identified on the APEN submitted on 07/01/16). Fuel usage shall be determined using fuel
meters and facility records as necessary. Monthly records of the actual consumption rate shall be
maintained by the applicant and made available to the Division for inspection upon request.
3.4 Except as provided for in Condition 3.5 below, opacity of emissions from each boiler shall not exceed
20% (Colorado Construction Permit 10WE1280 and Colorado Regulation No. 1, Section II.A.1). In the
absence of credible evidence to the contrary, compliance with the 20% opacity limit shall be presumed
since only natural gas is permitted to be used as fuel for these boilers.
3.5 Opacity of emissions from each boiler during fire building, cleaning of fire boxes, soot blowing, start-
up, process modifications, or adjustment or occasional cleaning of control equipment shall not exceed
30% for a period or periods aggregating more than six (6) consecutive minutes in any sixty (60)
consecutive minutes (Colorado Construction Permit 10WE1280 and Colorado Regulation No. 1, Section
II.A.4). In the absence of credible evidence to the contrary, compliance with the 30% opacity limit shall
be presumed since only natural gas is permitted to be used as fuel for these boilers.
3.6 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, this boiler is 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 11/20/2015. 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.]
3.6.1 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))
3.6.2 You must meet the notification requirements in §63.7545 according to the schedule in §63.7545
and in subpart A of this part. 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))
3.6.3 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))
3.6.3.1 You must meet each emission limit and work practice standard in Tables 1 through 3
and 11 through 13 of Subpart DDDDD of Part 63 that applies to your boiler or
process heater, for each boiler or process heater at your source, except as provided
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 44
under § 63.7522. (63.7500(a)(1)) These boilers are existing units designed to burn gas
1 fuels, and are also limited use boilers, only Table 3 is applicable. The work practice
standards in Table 3 that apply to this boiler is as follows:
a. For a limited use boiler or process heater you must conduct a tune-up of the boiler
or process heater every five years as specified in § 63.7540. (40 CFR Part 63
Subpart DDDDD: Table 3, Item 1)
Note: The boilers had not previously qualified as "limited use. " Kodak was
required to perform a one-time energy assessment as outlined in 40 CFR Part 63
Subpart DDDDD: Table 3, Item 3. The one-time energy assessment was
completed in August 2016.
3.6.3.2 At all times, you must operate and maintain any affected source (as defined in
§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))
3.6.4 As provided in §63.6(g), EPA may approve use of an alternative to the work practice standards
in §63.7500. (63.7500(b))
3.6.5 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.
(63.7510(e))
3.6.6 If your boiler or process heater has a heat input capacity of 10 million Btu per hour or greater,
you must conduct an annual tune-up of the boiler or process heater to demonstrate continuous
compliance as specified in paragraphs (a)(10)(i) through (vi) of §63.7540. You must conduct the
tune-up while burning the type of fuel (or fuels in case of units that routinely burn a mixture) that
provided the majority of the heat input to the boiler or process heater over the 12 months prior to
the tune-up. This frequency does not apply to limited -use boilers and process heaters, as defined
in §63.7575, or units with continuous oxygen trim systems that maintain an optimum air to fuel
ratio. (63.7540(a)(10))
3.6.6.1 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))
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed. DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 45
3.6.6.2 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))
3.6.6.3 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))
3.6.6.4 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))
3.6.6.5 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))
3.6.6.6 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))
3.6.7 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))
3.6.8 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))
3.6.9 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))
3.6.10 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
specified in paragraphs (e)(1) through (8) of §63.7545, as applicable. (63.7545(e)) 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.
3.6.11 Unless the EPA Administrator has approved a different schedule for submission of reports under
§63.10(a), you must submit each report, according to paragraph (h) of §63.7550, by the date in
Table 9 of Subpart DDDDD of Part 63 and according to the requirements in paragraphs (b)(1)
through (4) of §63.7550. For units that are subject only to a requirement to conduct subsequent
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 46
annual, biennial, or 5 -year tune-up according to §63.7540(a)(10), (11), or (12), respectively, and
not subject to emission 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 §63.7550, instead of a semi-annual compliance report. (63.7550(b))
3.6.12 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))
3.6.12.1 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))
3.6.13 You must keep the following records:
3.6.13.1 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))
3.6.13.2 For units in the limited use subcategory, you must keep a copy of the federally
enforceable permit that limits the annual capacity factor to less than or equal to 10
percent and fuel use records for the days the boiler or process heater was operating.
(63.7555(a)(3))
3.6.14 Records shall be kept in the form and for the duration specified in § 63.7560.
3.6.15 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:
3.6.15.1 Prohibited activities in § 63.4.
3.6.15.2 Compliance with Standards and Maintenance Requirements in §63.6(a), (b)(1) -(b)(5),
(b)(7), (c)
3.6.15.3 Notification requirements in § 63.9.
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
4. E01, E02 Two Cummins Emergency Fire Pump Engines (HP 240 each)
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 47
Parameter
Condition
Number
Limitation
Monitoring
Method
Interval
SO2
4.1
0.8 lb/MIVIBtu
Fuel Restriction
See Condition 4.1
Opacity
4.3
Not to Exceed 20% Except as Provided for Below
For Startup — Not to Exceed 30%, for a Period or Periods
Aggregating More than Six (6) Minutes in any 60
Consecutive Minutes
EPA Method 9
Annually
MACT Subpart ZZZZ
4.4
Change Oil and Filter
Inspect Air Cleaner
Inspect all Hoses and Belts
Install a Non-resettable Hour Meter
See Condition 4.4
Hours of Operation
4.4.16
Recordkeeping
Monthly
Note: 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 Emissions of SO2 shall not exceed the limitation stated above (Colorado Regulation No. 1, Section
VI.B.4.b.(i)). In the absence of credible evidence to the contrary, compliance with the above SO2
limitation shall be presumed since only diesel fuel is permitted to be used as fuel in this engine.
4.2 Engine startup shall not exceed 30 minutes. An engine startup period of less than 30 minutes shall not
require an opacity observation to monitor compliance with the opacity limit in Condition 4.3.2 (30%
opacity requirement). A record shall be kept of the date and time the engine started and when it was
shutdown.
4.3 Opacity of emissions from this engine shall not exceed the following:
4.3.1 Except as provided for in Condition 4.3.2 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).
4.3.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant resulting from startup 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
Regulation No. 1, Section II.A.4).
4.3.3 Method 9 opacity observation shall be conducted to monitor compliance with the opacity limit in
Condition 4.3.1. Method 9 opacity observations shall be conducted once per calendar year.
Opacity readings shall be at least four months apart.
4.3.4 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 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.
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 48
4.3.5 All opacity observations shall be performed by an observer with current and valid Method 9
certification. Results of Method 9 readings and a copy of the certified Method 9 reader's
certificate shall be kept on site and made available to the Division upon request.
4.4 This source is subject to the National Emissions Standards for Hazardous Air Pollutants requirements of
Regulation No. 8, Part E, Subpart ZZZZ (40 CFR Part 63, Subpart ZZZZ), for Stationary Reciprocating
Internal Combustion Engines, including, but not limited to, the following:
[The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart
ZZZZ published in the Federal Register on 2/27/2014. 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 ZZZZ.]
4.4.1 If you have an existing non -emergency CI stationary RICE with a site rating of more than 500
brake HP located at a major source of HAP emissions, an existing stationary CI RICE with a site
rating of less than or equal to 500 brake HP located at a major source of HAP emissions, or an
existing stationary CI RICE located at an area source of HAP emissions, you must comply with
the applicable emission limitations, operating limitations, and other requirements no later than
May 3, 2013. (63.6595(a)(1))
4.4.2 If you own or operate an affected source, you must meet the applicable notification requirements
in §63.6645 and in 40 CFR part 63, subpart A. (63.6595(c))
4.4.3 If you own or operate an existing stationary RICE with a site rating of equal to or less than 500
brake HP located at a major source of HAP emissions, you must comply with the emission
limitations and other requirements in Table 2c to Subpart ZZZ7 which apply to you. (63.6602)
4.4.3.1 You must meet the following requirement, except during periods of startup: (Item 1,
Table 2c to Subpart ZZZZ of Part 63)
a. Change oil and filter every 500 hours of operation or annually, whichever comes
first.
b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes
first, and replace as necessary.
c. Inspect all hoses and belts every 500 hours of operation or annually, whichever
comes first, and replace as necessary.
4.4.3.2 During periods of startup you must minimize the engine's time spent at idle and
minimize the engine's startup time at startup to a period needed for appropriate and
safe loading of the engine, not to exceed 30 minutes, after which time the non -startup
emission limitations apply. (Item 1, Table 2c to Subpart ZZZZ of Part 63)
4.4.3.3 Notwithstanding the above requirements , the following applies:
a. If an emergency engine is operating during an emergency and it is not possible to
shut down the engine in order to perform the work practice requirements on the
schedule required in Table 2c of Subpart ZZZZ, or if performing the work
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 49
practice on the required schedule would otherwise pose an unacceptable risk
under federal, state, or local law, the work practice can be delayed until the
emergency is over or the unacceptable risk under federal, state, or local law has
abated. The work practice should be performed as soon as practicable after the
emergency has ended or the unacceptable risk under federal, state, or local law
has abated. Sources must report any failure to perform the work practice on the
schedule required and the federal, state or local law under which the risk was
deemed unacceptable. (Footnote 1, Table 2c to Subpart ZZZZ of Part 63)
b. Sources have the option to utilize an oil analysis program as described in
§63.6625(i) or (j) in order to extend the specified oil change requirement in Table
2c of Subpart ZZZZ. (Footnote 2, Table 2c to Subpart ZZZZ of Part 63)
c. Sources can petition the Administrator pursuant to the requirements of 40 CFR
63.6(g) for alternative work practices. (Footnote 3, Table 2c to Subpart ZZZZ of
Part 63)
4.4.4 You must be in compliance with the emission limitations, operating limitations and other
requirements in Subpart ZZZZ that apply to you at all times. (§ 63.6605(a))
4.4.5 At all times you must operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and
good air pollution control practices for minimizing emissions. The general duty to minimize
emissions does not require you to make any further efforts to reduce emissions if levels required
by this standard have been achieved. Determination of whether such operation and maintenance
procedures are being used will be based on information available to the Administrator which
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.
(63.6605(b))
4.4.6 You must operate and maintain the stationary RICE and after -treatment control device (if any)
according to the manufacturer's emission -related written instructions or develop your own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. (63.6625(e))
4.4.7 If you own or operate an existing emergency stationary RICE with a site rating of less than or
equal to 500 brake HP located at a major source of HAP emissions or an existing emergency
stationary RICE located at an area source of HAP emissions, you must install a non-resettable
hour meter if one is not already installed. (63.6625(f))
4.4.8 If you operate a new, reconstructed, or existing stationary engine, you must minimize the
engine's time spent at idle during startup and minimize the engine's startup time to a period
needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time
the emission standards applicable to all times other than startup in Tables la, 2a, 2c, and 2d to
Subpart ZZZZ apply. (63.6625(h))
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 50
4.4.9 If you own or operate a stationary CI engine that is subject to the work, operation or management
practices in items 1 or 2 of Table 2c to Subpart ZZZZ, you have the option of utilizing an oil
analysis program in order to extend the specified oil change requirement in Tables 2c to Subpart
ZZZZ. The oil analysis must be performed at the same frequency specified for changing the oil
in Table 2c to Subpart ZZZZ. The analysis program must at a minimum analyze the following
three parameters: Total Base Number, viscosity, and percent water content. The condemning
limits for theses parameters are as follows: Total Base Number is less than 30 percent of the Total
Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from
the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. If all
of these condemning limits are not exceeded, the engine owner or operator is not required to
change the oil. If any of the limits are exceeded, the engine owner or operator must change the
oil within 2 business days of receiving the results of the analysis; if the engine is not in operation
when the results of the analysis are received, the engine owner or operator must change the oil
within 2 business days or before commencing operation, whichever is later. The owner or
operator must keep records of the parameters that are analyzed as part of the program, the results
of the analysis, and the oil changes for the engine. The analysis program must be part of the
maintenance plan for the engine. (63.6625(i))
4.4.10 You must demonstrate continuous compliance with each emission limitation, operating
limitation, and other requirements in Table 2c to Subpart ZZZZ that apply to you according to
methods specified in Table 6 to Subpart ZZZZ. (63.6640(a))
4.4.10.1 Complying with the requirement of work or management practices: (Item 9, Table 6 to
Subpart ZZZZ of Part 63)
a. Operating and maintaining the stationary RICE according to the manufacturer's
emission -related operation and maintenance instructions; or
b. Develop and follow your own maintenance plan which must provide to the extent
practicable for the maintenance and operation of the engine in a manner consistent
with good air pollution control practice for minimizing emissions.
4.4.11 You must report each instance in which you did not meet each emission limitation or operating
limitation in Table 2c to Subpart ZZZZ that applies to you. These instances are deviations from
the emission and operating limitations in Subpart ZZZZ. These deviations must be reported
according to the requirements in §63.6650. (63.6640(b))
4.4.12 You must also report each instance in which you did not meet the requirements in Table 8 to
Subpart ZZZZ that apply to you. (63.6640(e))
4.4.13 If you own or operate an emergency stationary RICE, you must operate the emergency stationary
RICE according to the requirements in paragraphs (0(1) through (4) of this section. In order for
the engine to be considered an emergency stationary RICE under Subpart ZZZZ, any operation
other than emergency operation, maintenance and testing, emergency demand response, and
operation in non -emergency situations for 50 hours per year, as described in paragraphs (f)(1)
through (4) of this section, is prohibited. If you do not operate the engine according to the
requirements in paragraphs (0(1) through (4) of this section, the engine will not be considered an
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak. Alaris, Inc.
Kodak Alaris Colorado
Page 51
emergency engine under Subpart ZZZZ and must meet all requirements for non -emergency
engines. (63.6640(f))
4.4.13.1 There is no time limit on the use of emergency stationary RICE in emergency
situations. (63.6640(f)(1))
4.4.13.2 You may operate your emergency stationary RICE for any combination of the
purposes specified in paragraphs (f)(2)(i) through (iii) of this section for a maximum
of 100 hours per calendar year. Any operation for non -emergency situations as
allowed by paragraphs (f)(3) and (4) of this section counts as part of the 100 hours per
calendar year allowed by this paragraph (f)(2). (63.6640(f)(2))
a. Emergency stationary RICE may be operated for maintenance checks and
readiness testing, provided that the tests are recommended by federal, state or
local government, the manufacturer, the vendor, the regional transmission
organization or equivalent balancing authority and transmission operator, or the
insurance company associated with the engine. The owner or operator may
petition the Administrator for approval of additional hours to be used for
maintenance checks and readiness testing, but a petition is not required if the
owner or operator maintains records indicating that federal, state, or local
standards require maintenance and testing of emergency RICE beyond 100 hours
per calendar year. (63.6640(f)(2)(i))
b. Emergency stationary RICE may be operated for emergency demand response for
periods in which the Reliability Coordinator under the North American Electric
Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and
Energy Emergencies (incorporated by reference, see §63.14), or other authorized
entity as determined by the Reliability Coordinator, has declared an Energy
Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-
3. (63.6640(f)(2)(ii))
c. Emergency stationary RICE may be operated for periods where there is a
deviation of voltage or frequency of 5 percent or greater below standard voltage
or frequency. (63.6640(f)(2)(iii))
4.4.13.3 Emergency stationary RICE located at major sources of HAP may be operated for up
to 50 hours per calendar year in non -emergency situations. The 50 hours of operation
in non -emergency situations are counted as part of the 100 hours per calendar year for
maintenance and testing and emergency demand response provided in paragraph (f)(2)
of this section. The 50 hours per year for non -emergency situations cannot be used for
peak shaving or non -emergency demand response, or to generate income for a facility
to supply power to an electric grid or otherwise supply power as part of a financial
arrangement with another entity. (63.6640(f)(3))
4.4.14 You must keep a copy of each notification and report that you submitted to comply with Subpart
ZZZZ, including all documentation supporting any Initial Notification or Notification of
Compliance Status that you submitted, according to the requirement in §63.10(b)(2)(xiv).
(63.6655(a)(1))
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 52
4.4.15 You must keep records of the maintenance conducted on the stationary RICE in order to
demonstrate that you operated and maintained the stationary RICE and after -treatment control
device (if any) according to your own maintenance plan. (63.6655(e))
4.4.16 You must keep records of the hours of operation of the engine that is recorded through the non-
resettable hour meter. The owner or operator must document how many hours are spent for
emergency operation, including what classified the operation as emergency and how many hours
are spent for non -emergency operation. If the engine is used for the purposes specified in
§63.6640(f)(2)(ii) or (iii) or §63.6640(f)(4)(ii), the owner or operator must keep records of the
notification of the emergency situation, and the date, start time, and end time of engine operation
for these purposes. (63.6655(f))
4.4.17 Records shall be kept in the form and for the duration specified in § 63.6660.
4.4.18 Table 8 of Subpart ZZZZ shows which parts of the General Provisions in §§63.1 through 63.15
apply to you. (§ 63.6665) The general provisions that apply to these engines include, but are not
limited to the following:
4.4.18.1 Prohibited activities in § 63.4(a).
4.4.18.2 Circumvention in § 63.4(b).
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
5. Degreasing Unit: Building C-29
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 53
Parameter
L
Permit Condition Number
Limitation
Reg 7, Section X.A — Transfer and Storage of Waste & Solvents
5.1 & 5.2
See Conditions 5.1 and 5.2
Reg 7, Section X.B — Control Standards
5.3 — 5.9
See Conditions 5.3 through 5.9
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.
5.1 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).
5.2 Waste or used solvent shall be stored in closed containers unless otherwise required by law. (Colorado
Regulation No. 7, Section X.A.4)
5.3 All cold -cleaners shall have a properly fitting cover. (Colorado Regulation No. 7, Section X.B.1.a(i))
5.3.1 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)):
5.3.1.1 Solvent true vapor pressure is greater than 15 tort. (0.3 psia) at 38°C (100°F).
(Colorado Regulation No. 7, Section X.B.1.a(ii)(A))
5.3.1.2 The solvent is agitated by an agitating mechanism. (Colorado Regulation No. 7,
Section X.B.1.a(ii)(B))
5.3.1.3 The solvent is heated. (Colorado Regulation No. 7, Section X.B.1.a(ii)(C))
5.4 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 tort. (0.62 psia) measured at 38°C (100°F) either:
5.4.1 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))
5.4.2 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))
5.5 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)
5.6 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 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.'
Kodak Alaris Colorado
Page 54
5.7 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:
5.7.1 A freeboard ratio greater than or equal to 0.7. (Colorado Regulation No. 7, Section X.B.1.d(i))
5.7.2 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))
5.8 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)
5.9 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 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado. Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 55
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 modifications 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, as adopted by reference in
Colorado Regulation No. 8, Part E
Permittee 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
Permittee 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
Permittee 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
Permittee 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 27 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
P029, P29B
40 CFR Part 60, Subpart Kb, as adopted by reference in
Colorado Regulation No. 6, Part A
All VOL storage tanks are all less than 40 m3 in size
P29B
40 CFR Part 60, Subpart QQ, as adopted by reference in
Colorado Regulation No. 6, Part A
The Rotogravure process is used for coating operations and
is therefore not an affected facility under this regulation
40 CFR Part 60, Subparts K and Ka, as adopted by
reference in Colorado Regulation No. 6, Part A
No petroleum storage tanks exist in Building 29B
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 56
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.
Permit Condition _ Streamlined (Subsumed) Rquirement
Section II, Condition 2.5.1
Colorado Regulation No. 7, Section IX.A.8.a
Section II, Condition 2.5.2
Colorado Regulation No. 7, Section IX.A.8.b
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 57
SECTION IV - General Permit Conditions (ver 5/22/2012)
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 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
3. Common Provisions
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 58
Common Provisions Regulation, 5 CCR 1001-2 &§ ILA., ILB., ILC., ILE., 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
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 59
Division may waive the thirty day notice requirement provided that arrangements satisfactory to
the Division 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;
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 60
(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;
(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.
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 61
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.
g.
When compliance or non-compliance is demonstrated by a test or procedure provided by permit
or 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.
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 62
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.
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
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 63
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, 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
g.
(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 me4ns 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
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 64
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.
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.
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 65
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
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 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 66
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, §§ 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 by reference must be included with the application.
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
20. Portable Sources
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 67
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 96OPWE128
First Issued: September 1, 1999
Renewed DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 68
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
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 69
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 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 960PWE128 ' First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 70
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 non -attainment 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. maintenance). Such opening, actuation, or use shall be limited so as to minimize
vapor loss.
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air. Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE128
Kodak Alaris, Inc.
Kodak Alaris Colorado
Page 71
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 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Appendices
OPERATING PERMIT APPENDICES
A - INSPECTION INFORMATION
B - MONITORING AND PERMIT DEVIATION REPORT
C - COMPLIANCE CERTIFICATION REPORT
D - NOTIFICATION ADDRESSES
E - PERMIT ACRONYMS
F - PERMIT MODIFICATIONS
*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 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
Appendix A
Page 73
APPENDIX A - Inspection Information
1. 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 mile, turn left onto Eastman Park Drive.
1. Safety Equipment Required:
Eye Protection; Hard Hat; Safety Shoes; Hearing Protection; Conductive Shoes
2. Facility Plot Plan:
Figure 1 (page 75) shows the plot plan as submitted on November 8, 2016.
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
Appendix A
Page 74
3. 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:
Description
Location r- Classification
Reg. 3 Part C Exemption
Chemical Storage
Bldg. C-17; C-28; C-29 (Central
Shops); Outside Marshalling
Area
Total Chemical storage in
closed containers is less than
5,000 gal
*Section II.E.3.mm
Forklifts
Bldg. C-15; C-17; C-28;
C-29
Forklift
Section II.E.3.kkk
ARC Welding Machines
Bldg. C-28
Welding Operations
Section II.E.3.r
Welding Area
Bldg. C-29
(Central Sops)
Portable Welding Device
Quality Control Lab
Bldg. C-29
Room 101
Quality Control / Assurance
Lab
Section II.E.3.i.(i)
Dry Laboratory
Room 120
Cylinder Storage Room
Bldg. C-29
(Rooms 117, 118)
Aerosol Can Usage
g
Section II.E.3.0
Maintenance Aerosol Can
Usage
Electric Furnace
Bldg. C-29 (Central Shops)
Electric Oven
Section II.E.3.vv
Sandblast Booth
Bldg. C-29 (Central Shops)
Blast Cleaning Equipment
Section II.E.3.www
Adhesive Use
Bldg. C-29 (Central Shops)
Adhesive use not related to
production
Section II.E.3.y
Saw Table
Bldg. C-29 (Carpenter Shop)
Sawing Operations
Section II.E.3.ii
S.C.U.D. Housekeeping
Bldg. C -29B
Vacuum Cleaning System
Section II.E.3.v
Central Product Distribution
Warehouse
Bldg. C-15
Individual emission point in
nonattainment area having
uncontrolled actual emissions
of any criteria pollutant of less
than 1 ton/yr
*Section II.E.3.a
Cooling Tower South of
Building
Bldg. C-17
Cooling Tower East of
Building
Bldg. C-28
Paint Booth (Non -Aerosol
Can Painting)
Bldg. C 29 (Central Shops)
TMM Products Finishing
Area
Bldg. C-29
Waste Balers/Compactors
Bldg. C-29
Coating Room Floor Sweeps
Bldg. C -29B
Vacuum Collection System
Bldg. C-29
*Note: Source must maintain sufficient record keeping verifying that the exemption applies.
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
Appendix A
Page 75
NOTE: MAGENTA SHAPED AREAS SHOW KODAK ALARIS PROPERTY
HOWRD 9diTH At£
LAW DITCH
1? o
-CS2C
HOWARD SMITH
PGURE TRA.I... €
WINDSOR a:::r' " ij
UFT STAI!ON II
A
&IC34
ria
KODAK alaris
TRAILER
MARSHALLING
AREA
PAK DR.
CS7M
f / .73
3La /:
tC..........;
ij
Ii
ii
C)
S
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
APPENDIX B
Reporting Requirements and Definitions
with codes ver 8/20/14
Appendix B
Page 76
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.
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
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 77
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 W.
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 40CFR 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 40CFR Part 64 (the
Compliance Assurance Monitoring (CAM) Rule) has occurred.
When the deviation is not covered by any of the above categories
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
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 78
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.'
• 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 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Startup, Shutdown, Malfunctions and Emergencies
Appendix B
Page 79
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 96OPWE128 First Issued: September 1, 1999
Renewed: DR> T
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Monitoring and Permit Deviation Report - Part I
Appendix B
Page 80
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: Kodak Alaris Inc./Kodak Alaris Colorado Division
OPERATING PERMIT NO: 96OPWE 128
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
Operating Permit Unit
ID
Unit Description
Deviations noted
During Period?1
Deviation Code
2
Malfunction/Emergency Condition
Reported During Period?
YES
NO
M
YES
NO
Facility Wide Limit
c
P030
Backup Boilers
P29B
#291 Coating Machine
P29C
#292 Coating Machine
E-01, E-02
Emergency Fire Pump Engines
Degreasing Unit
General Conditions
Insignificant Activities
1 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 40CFR Part 64 (the
Compliance Assurance Monitoring (CAM) Rule) has occurred.
When the deviation is not covered by any of the above categories
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Monitoring and Permit Deviation Report - Part II
FACILITY NAME: Kodak Alaris Inc./Kodak Alaris Colorado Division
OPERATING PERMIT NO: 96OPWE128
REPORTING PERIOD:
Is the deviation being claimed as an:
Appendix B
Page 81
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 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
EXAMPLE
FACILITY NAME: Acme Corp.
OPERATING PERMIT NO: 96OPZZXXX
REPORTING PERIOD: 1/1/04 - 6/30/06
Appendix B
Page 82
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 J. Garcia, APCD
Deviation Code Division Code QA:
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Monitoring and Permit Deviation Report - Part III
Appendix B
Page 83
REPORT CERTIFICATION
SOURCE NAME: Kodak Alaris Inc./Kodak Alaris Colorado Division
FACILITY IDENTIFICATION NUMBER: 123/0003
PERMIT NUMBER: 96OPWE128
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 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
APPENDIX C
Appendix C
Page 84
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: Kodak Alaris Inc./Kodak Alaris Colorado Division
OPERATING PERMIT NO: 96OPWE 128
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.
Operating
Permit Unit
ID
Unit Description
Deviations Reported
Monitoring Method
per Permit?2
Was compliance continuous or
intennittent?3
Previous
Current
YES
NO
Continuous
Intermittent
Facility Wide Limit
P030
Backup Boilers
P29B
#291 Coating Machine
P29C
#292 Coating Machine
E-01, E-02
Emergency Fire Pump Engines
Degreasing Unit
General Conditions
Insignificant Activities °
' 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 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.
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix C
Page 85
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.
Compliance status for these sources shall be based on a reasonable inquiry using readily available information.
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 is is not in compliance with all the
requirements of section 112(r).
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 96OPWE128
First Issued: September 1, 1999
Renewed DRAFT
Air Pollution Control Division
Colorado Operating Permit
Notification Addresses
Appendix D
Page 86
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-B1
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-T
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, Colorado 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, Colorado 80202-1129
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit Acronyms
Appendix E
Page 87
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
PM - Particulate Matter
PMio - Particulate Matter Under 10 Microns
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit Acronyms
Appendix E
Page 88
PSD -
PIE -
RACT
SCC -
SCF -
SIC -
SO2 -
TPY -
TSP -
VOC-
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 96OPWE128 First Issued: September 1, 1999
Renewed: DRAF"I'
Air Pollution Control Division
Colorado Operating Permit
Permit Modifications
Appendix F
Page 89
APPENDIX F
Permit Modifications
DATE OF
REVISION
TYPE OF
REVISION
SECTION NUMBER,
CONDITION NUMBER
DESCRIPTION OF REVISION
Operating Permit 96OPWE128
First Issued: September 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit Modifications
Appendix G
Page 90
APPENDIX G
Equipment List
Building
Location
AIRS ID
Equipment
Number
Description
C-29
Chem Mfg
104
C29-4
Chemical Mfg. Reactor Room
Chem Mfg
106
C-29
Fugitive Emissions
C -29B
TMM
103
#291 Coating Machine
Chemical Making Area
TMM
TMM
Regenerative Thermal Oxidizer
C -29C
TMM
108
#292 Coating Machine
TMM
Regenerative Thermal Oxidizer
C-32
Pumphouse
Two (2) Diesel Emergency Fire Pump Engines
C-30
Boiler House
050
C-30
Two (2) 157 mmBtu/hour boilers, #35 and #36,
used as back-up only
Operating Permit 96OPWE128 First Issued: September 1, 1999
Renewed: DRAFT
TECHNICAL REVIEW DOCUMENT
For
DRAFT RENEWAL OF OPERATING PERMIT 96OPWE128
Kodak Alaris, Inc. - Kodak Alaris Colorado
Weld County
Source ID 123/0003
September 2016 — November 2017
Operating Permit Engineer:
Operating Permit Supervisor review:
Compliance Monitoring:
I. Purpose
Ramazan Spencer
Matt Burgett
Christopher Reinhardt
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 Kodak Alaris Colorado (KAC) facility. The initial
Operating Permit for this facility was issued on September 1, 1999, was renewed on November
1, 2004 and was last revised on November 21, 2006 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.
Prior to submittal of the renewal application on November 3, 2008, the source submitted an
application on March 5, 2008 requesting that the permit be modified to update the compliance
temperature and destruction efficiency of Regenerative Thermal Oxidizer associated with #291
Coating Line (RTO1) based on the most recent Performance Test conducted.
Subsequent to the submittal of the renewal application, the source submitted applications on
March 26, 2010, March 7, 2016, and July 1, 2016. Application submitted on March 26, 2010
requested that the permit be modified to remove Boiler Houses C-30 and C-70 from the Title V
Permit in anticipation of a transfer of ownership. The Boiler Houses have since then been
issued Construction Permits, 10WE1279 (C-70) and 10WE1280 (C-30). Application submitted
on March 7, 2016 requested the Permit to be modified to update the Responsible Official and
Permit Contact Person. The application submitted on July 1, 2016 requested to decrease the C-
30 Boilers annual throughput and emission limits to be able to qualify as limited use boilers as
described in MACT DDDDD. Since this modification involves reducing a permit limit to
avoid additional MACT requirements, the modification must beprocessed as a significant
modification as required by Colorado Regulation No. 3, Part C, Section I.A.7.c. A significant
modification is 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 modification with the renewal.
Additionally the source submitted an Amendment to the 2008 renewal application. The
amendment, received on June 6, 2017, requests a modification of the methodology used to
calculate VOC emissions from C-29 Chemical Manufacturing.
123/0003 Page 1 of 12
Kodak Alaris, Inc. — Kodak Alaris Colorado
Operating Permit No. 96OPWE128
Technical Review Document — Second 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 March 5, 2008, comments on the
draft permit submitted on October 16, 2017, previous inspection reports and various email
correspondence, as well as telephone conversations with the applicant. Please note that copies
of the Technical Review Document for the original permit and any Technical Review
Documents 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.
H. Description of Source
This facility consists of several buildings containing a variety of equipment used to
manufacture photographic supplies. Building C-29 contains a small chemical manufacturing
reactor room for producing various aqueous polymers. In Buildings C -29B and C -29C, the
company produces thermal media which customers use in color printers to transfer color and
clear laminate onto paper or other surfaces. Dry dye powder is weighed and dissolved in
solvents. The coating solutions are piped to a coating machine where they are applied to plastic
substrate material. Two natural gas -fired boilers (Building C-30), each rated at 157
MN/Btu/hour, are used as back-up steam sources only, as process steam is purchased from and
provided by an external source.
The facility is located in Weld County, near Windsor, an attainment area for all pollutants. The
facility is located in the 8 -Hour Ozone Control Area, as defined in Regulation No. 7, Section
II.A.1.
This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC or
NOx > 100 Tons/Year). 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 (i.e. a Potential to Emit 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 PSD as of the issue date of this permit. Any future modification which is
major by itself (Potential to Emit 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.
123/0003 Page 2 of 12
Kodak Alaris, Inc. — Kodak Alaris Colorado
Operating Permit No. 96OPWE128
Technical Review Document — Second Renewal
Emissions at the facility are as follows: (Unless otherwise specified emission data extracted
from Inspection Report submitted on 7/6/2016)
Facility Wide Emissions (Excluding C-30 Boilers)
Pollutant
Potential to Emit (tons/yr)
Actual Emissions (tons/yr)
NOx
7.15
2.1
CO
6.06
1.8
VOC
169.7
39.5 '
HAPs
Pollutant
Vinylidene Chloride
Toluene
Methanol
Actual Emissions (lbs/yr)
800
Source of Emission Data
APEN Received on May 1, 2013 (AIRS ID 123-0003-100)
28,000
18,500
APEN Received on May 17, 2010 (AIRS ID 123-0003-108)
C-30 Boilers
Pollutant
Potential to Emit (tons/yr)
I
Actual Emissions (tons/yr)
NOx
37.74
2.1
CO
11.12
1.8
"IL 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 (CAM)
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:
The two RTOs, AIRS 107 & 108, are not subject to the CAM requirements. For more detailed
discussion please reference the Technical Review Document issued in September 2003.
Hazardous Air Pollutants (HAPs)
This facility is a major source for HAPs.
123/0003 Page 3 of 12
Kodak Alaris, Inc. — Kodak Alaris Colorado
Operating Permit No. 96OPWE128'
Technical Review Document — Second Renewal
Miscellaneous Organic Chemical Manufacturing (MON) MACT 40 CFR Part 63 Subpart
FFFF)
The provisions of the MON MACT apply to all miscellaneous organic chemical manufacturing
process units (MCPU) at a major source for HAP emissions. An MCPU includes all
equipment which collectively functions to produce a product or an isolated intermediate.
Equipment such as any assigned storage tanks and transfer racks; equipment in open systems
that is used to convey or store water having same concentration and flow characteristics as
wastewater; and components such as pumps, compressors, agitators, pressure relief devices,
sampling connection systems, open ended valves or lines, valves, connectors, and
instrumentations systems. The chemical manufacturing operation housed in building C-29
falls under the definition of an MCPU. The operation manufactures polymer and latex coating
ingredients. The polymers and latex are manufactured from monomers that include organic
HAPs. The affected sources consist of Group 2 Batch Process Vents and Group 2 Wastewater.
The MACT requirements consist of work place practices, which include a leak detection
program and development of monitoring program for heat exchange system leaks. The
appropriate requirements from the MON MACT will be included in the permit.
Note that the chemical manufacturing operation of building C-29 commenced construction
prior to April 4, 2002, and is considered an existing source.
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 157
mmBtu/hr each are subject to the requirements of MACT DDDDD. The boilers are natural gas
fired only and fall under "unit designed to burn gas 1 subcategory." The modification
received July 1, 2016 reduced the annual fuel limit for each boiler to qualify as a limited use
boiler. A limited -use boiler is defined as any boiler that has an annual capacity factor of no
more than 10 percent. Since the boilers fall in the limited use category the source is required to
comply with Work Practice Standards listed in Table 3 to Subpart DDDDD, specifically item
1. Item 1 of Table 3 requires a tune up to be conducted every 5 years.
Reciprocating Internal Combustion Engines (40 CFR Part 63 Subpart ZZZZ)
There are two diesel fired Cummins emergency fire pump engines located at the Kodak Alaris
facility (Model #: 6CTA8.3-F2, SN: 46031463 & 45545437, HP: 240 site, 270 max). The
engines have been in service since 2000. EPA promulgated revisions to the RICE MACT on
March 3, 2010 which apply to existing (commenced construction or reconstruction before June
12, 2006) compression ignition engines of 500 hp or less located at major sources of HAP
emissions. The emergency fire pump engines are less than 500 hp and were first placed in
service prior to June 12, 2006. Therefore, are subject to the March 3, 2010 revisions to the
RICE MACT and can no longer be considered an insignificant activities. Although the units
cannot be considered an insignificant activity the engines are still exempt from APEN
reporting and construction permit requirements provided actual uncontrolled emissions are less
123/0003 Page 4 of 12
Kodak Alaris, Inc. — Kodak Alaris Colorado
Operating Permit No. 96OPWE128
Technical Review Document — Second Renewal
than the APEN de minimis level (1 ton/yr). The appropriate applicable requirements will be
included in the renewal permit. These requirements include installation of a none-resettable
hour meter and following" management practices. Management practice consists of change of
oil and filter as well as regular inspection of hoses, belts, and air filters.
Regulation Number 7, Section IX. Surface Coating Operations
The source has become subject to the regulation since the last 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. Section I.A.1.b of Colorado Regulation No. 7 states "All
provisions of this regulation apply to any ozone nonattainment area, which includes areas
designated nonattainment for either the 1 -hour or 8 -hour ozone standard, unless otherwise
specified..." The surface coating operation, performed by Coating Machines #291 and #292,
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) or 4.8 lbs VOC per
gallon of solids.
Regulation Number 7, Section X. Use of Solvents for Degreasing and Cleaning
The cold cleaner vat degreasers are 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 included in the renewal permit; these includetransfer and
storage of waste/used solvents requirements.
Regulation Number 7, Section X.E. Industrial Cleaning Solvents RACT
On November 17, 2016 Section X.E. was added to Regulation Number 7. This section
specifies RACT requirements for any industrial solvent cleaning operation with total combined
uncontrolled actual VOC emissions equal to or greater than 3 tons per calendar year. KAC has
performed an analysis and indicated that the P'I'E from their industrial solvent cleaning
activities is below 3 tons per year. Therefore the requirements of Regulation Number 7,
Section X.E. do not apply.
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) withuncontrolled 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. KAC is a listed existing major source for VOC only in Section XIX.A
and therefore not subject to the requirements of Section XVI.
IV. Modifications Requested by the Source
123/0003 Page 5 of 12
Kodak Alaris, Inc. — Kodak Alaris Colorado
Operating Permit No. 96OPWE128
Technical Review Document — Second Renewal
In their modification application submitted on March 5, 2008, the source requested that the
permit be revised to update the compliance temperature and destruction efficiency of
Regenerative Thermal Oxidizer associated with #291 Coating Line (RTO1) based on the most
recent Performance Test conducted. In their application, the source 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). There are no changes to
recordkeeping or monitoring requirements there is also no change in emission limits.
Therefore, since the requested change does not result in a significant increase in the rate of
emissions or a relaxation of recordkeeping and reporting, the Division determines that this
modification can be processed as a minor modification.
The renewal application received on November 3, 2008 requested the following modifications:
• Inclusion of Construction Permit 90WE0466. The lithographic printing plate
manufacturing facility located at 1 Lithoplate Drive in Windsor, Colorado is no longer
operational and the Construction Permit has been cancelled since the submission of the
renewal application. Construction Permit 90WE0466 will not be included in the Title
V Permit.
• VOC emission calculations for C-29 Chemical Manufacturing. The source requests
that the emission calculations developed during determination of group status as
required by MACT FFFF be used for estimating VOC emissions. The current
calculation method specified in the Permit is VOC emissions = VOC consumed, except
as specified for vinylidene chloride, methyl acrylate, acrylonitrile, glacial acrylic acid,
and methyl methacrylate. For those compounds the VOC emission estimation is VOC
emissions = 1% of weight of consumption. The source requests that the emission
factors developed during determination of MON MACT applicability and requirements
be used. The requested permit language for calculating VOC emissions is as follows:
VOC emissions = Number of Batches of Product X produced per month * Product X
Emission factor. As cyclohexane was not addressed by the MON MACT emission
calculations the source proposes the following equation to estimate the emissions: VOC
emissions = Cyclohexanone replaced — Cyclohexanone shipped off -site for
disposal*0.99. Cyclohexanone is used for cleaning latex vessels. The material is added
to the reactor vessel when excess hardened latex has accumulated. The Cyclohexanone
is stirred in the vessel to break up the hardened latex. This is performed as needed, the
typical frequency of Cyclohexanone cleaning is once every 5 batches of Latex SD and
used repeatedly until it becomes is no longer effective. Once spent, the Cyclohexanone
is sent off site for disposal. Chemical analysis of the spent Cyclohexanone solution
showed that the Cyclohexanone solution consists of 99.5% Cyclohexanone. The
Division modified the language to the following: VOC Emitted lbs = Cyclohexanone
Initial Batch Weight (lbs) — Cyclohexanone Spent Batch Weight (lbs)*0.99.
123/0003 Page 6 of 12
Kodak Alaris, Inc. — Kodak Alaris Colorado
Operating Permit No. 96OPWE128
Technical Review Document — Second Renewal
• The amendment, received on June 6, 2017, modifies the original renewal application's
requested methodology for calculation of VOC emissions associated with C-29
Chemical Manufacturing. The requested language is as follows: Facility -wide
emissions of VOC shall not exceed the limitations stated in the table above. The source
shall record total chemical product batches on a monthly basis. The number of batches
and the quantity of VOC, to be determined by method described in 40 CFR Part 63
Subpart FFFF Paragraph 63.2460(b), that volatizes in each batch shall be used to
calculate emissions following a mass balance calculation. VOC emissions shall be
summed to determine monthly emissions. VOC monthly emissions from this emission
unit shall be summed with the VOC monthly emissions from other emission units and a
twelve month rolling total of facility wide VOC emissions will be maintained to verify
compliance with the annual emission limitations. Each month, a new twelve month
total of facility -wide VOC emissions shall be calculated using the previous twelve
months data. Records of the calculations and compliance determinations shall be
maintained and made available for Division review upon request." KAC will record
and retained the following information from Chemical Manufacturing: _
o Total number of batches for each product.
o Name and quantity of chemical raw materials containing VOC and HAPs
consumed on a monthly basis.
o Safety Data Sheets for chemical raw materials containing VOC and HAPs.
o Calculated VOC and HAP emissions (lbs) on a monthly basis.
o 12 -month rolling total calculations for VOC emissions (tons/yr) aggregated with
other facility VOC emissions to compare against facility wide VOC limit.
o 12 -month rolling total calculations for HAP emissions (lbs/yr) to compare
against MON MACT emission thresholds for Group 2 batch process vents.
The source's requested modifications were addressed as follows:
Page Following Cover Page
• Company name changed from Eastman Kodak Company to Kodak Alaris Inc.
• Facility name changed from Kodak Colorado Division to Kodak Alaris Colorado
• Changed Responsible Official designation to Stephen Kozak, Site Manager
• Changed Permit Contact Person to Keli Sharpee , HSE Coordinator
Section I - General Activities and Summary
• Removed references to C-70 Boiler house in Condition 1.1 which describes the
permitted activities at the site.
• Removed the C-70 Boiler discussion as it pertains to PSD status in Condition 2.1.
• Removed references to C-70 Boilers from Table 6.1.
123/0003 Page 7 of 12
Kodak Alaris, Inc. — Kodak Alaris Colorado
Operating Permit No. 96OPWE128
Technical Review Document — Second Renewal
Section II — Specific Permit Terms
• Reduced facility wide emission limit for VOC from 174.7 tons per year to 169.7 tons
per year. This reduction is attributed to the sale of the C-70 Boilers and the split of the
C-30 Boilers' emission limit from the facility wide limit.
• Modified language concerning calculation of VOC emitted from C-29 Chemical
Manufacturing as requested.
• Removed Particulate limits (PM and PMio). PTE for particulates below 2 ton ADEN
reporting threshold. This reduction is attributed to the sale of the C-70 Boilers and the
split of the C-30 Boilers' emission limit from the facility wide limit.
• Reduced NOx facility wide emission limit from 223 tons per year to 7.15 tons per year.
This reduction is attributed to the sale of the C-70 Boilers and the split of the C-30
Boilers' emission limit from the facility wide limit.
• The source requested a reduction of the facility wide emission limit for CO from 200
tons per year to 5.6 tons per year. The requested emission was miscalculated and
should be 6.01 tons per year. The limit was calculated as follows:
tons mmscf lbs
CO = (RTO Fuel limit ) x (AP42 Table 1.4 1 emission factor x 1 ton
year
ear year mmscf 2000 Os
tons mmscf lbs 1 ton
6.01 CO —=(143 )x(84 )x
year year mmscf 2000 lbs
• Removed all requirements associated with C-70 boilers as they are no longer owned or
operated by the source. The modification received on March 26, 2010 also requested
the removal of the C-30 boilers. Since the source maintained ownership and still
operates the boilers on an emergency backup basis the boilers were not removed from
the Permit. The C-30 boiler emission limits were segregated from the facility wide
emission limits. All requirements associated with the C-30 boilers have been moved to
Condition 3.
• Source requested annual fuel throughput limit for the C-30 boilers to be reduced from a
combined total of 596.0 mmscf of natural gas (NG) per year to 134.8 mmscf of NG per
year each. The throughput limit of 134.8 mmscf of NG for each both boiler, which is
10 percent of maximum consumption, was chosen in order to qualify the boilers as
limited use under MACT DDDDD.
Maximum NG consumption was calculated as follows:
mmbtu
Each boiler is rated at 157
hr
mmbtu hr 1 scf NG Maximum Consumption = 157 hr x 8760 x — 1348.35 mmscf NG
yr 1020 btu _
10 percent of maximum consumption = 1348.35 mmscf NG x 0.1 = 134.8 mmscf NG
123/0003 Page 8 of 12
Kodak Alaris, Inc. — Kodak Alaris Colorado
Operating Permit No. 96OPWE128
Technical Review Document — Second Renewal
Annual emission limits updated as requested for C-30 boilers. Emission limits
calculated as follows:
NOx emission limit was calculated using the NG throughput limit of 134.8 mmscf and
emission factor from AP42 Table 1.4-1 for large boilers.
tons lbs 1 ton tons
NOX = 134.8 mmscf x 280 x x 2 boilers = 37.74 NOX—
yr mmscf 2000Ibs yr
CO emission limit was calculated using the NG throughput limit of 134.8 mmscf and
emission factor from AP42 Table 1.4-1 for large boilers.
tons lbs 1 ton tons
CO = 134.8 mmscf x 84 x x 2 boilers = 11.12 CO
yr mmscf 20001bs yr
VOC emissions calculated below reporting threshold and therefore not included. VOC
emission limit was calculated using the NG throughput limit of 134.8 mmscf and
emission factor from AP42 Table 1.4-2.
tons lbs 1 ton tons
VOC = 134.8 mmscf x 5.5 mmscf x
yr 20001bs x 2 boilers = 0.74 VOC yr
PM/PMto emissions calculated below reporting threshold and therefore not included.
PM/PM10 emission limit was calculated using the NG throughput limit of 134.8 mmscf
and emission factor from AP42 Table 1.4-2.
tons lbs 1 ton tons
PM/PMlo = 134.8 mmscf x 7.6 x x 2 boilers = 1.02 PM/PMio
yr mmscf 20001bs yr
• Added applicable MACT DDDDD requirements including a tune up every five years.
• Updated operational parameters for RTO1. Combustion chamber temperature
requirement was changed from 1419°F to 1387°F as per the most recent performance
test conducted on January 30, 2008.
• Updated RTO1 destruction efficiency from 97.6% to 98.8%, as per the most recent
performance test conducted on January 30, 2008.
V. Other Modifications
In addition to the source 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 source may request to
123/0003 Page 9 of 12
Kodak Alaris, Inc. — Kodak Alaris Colorado
Operating Permit No. 96OPWE128
Technical Review Document — Second Renewal
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).
• Modified the language concerning postmarked dates for report submittals to reflect the
Division's current standard language.
Section I — General Activities and Summary
• Revised the language in Condition 1.4 include current conditions that are state -only
enforceable.
• Table 6 updated to include emergency fire pump engines and cold solvent degreasing
units.
Section II — Specific Permit Terms
• Requirements associated with specific operations at facility have been segregated based
on operation and applicability. Condition 1 now addresses all applicable requirements
associated with the Chemical Manufacturing Building C-29. These include MACT
FFFF requirements, emission calculations and limits. Condition 2 now addresses all
applicable requirements associated with operations housed in buildings C -29B and C -
29C. These operations include Chem Mix and Thermal Media Manufacturing, which
are subject to the requirements of MACT KK.
• MACT FFFF requirements added in Condition 1.2. These requirements include:
Determination of Group status for process vents. Source has determined process vents
associated with the chemical operation in building C-29 fall under Group 2 batch
process. There are no emission limits required by MACT FFFF for Group 2 batch
process vents.
Equipment leaks. Source indicated compliance with MACT UU to satisfy the leak
detection requirements of MACT FFFF. The requirements of MACT UU include
instrument and sensory monitoring for leaks of various components. Conditions 1.2.15
through 1.2.31 address the applicable requirements of MACT UU.
Waste water streams. MACT FFFF references §§63.132 through 63.148 of MACT G
for compliance requirements. MACT G requires determination of Group status for
waste water stream. The source indicated that the current waste water streams fall
under Group 2. MACT G requirements include redetermination of Group status for the
waste water stream if there is a process change made that could change the stream to
Group 1. Conditions 1.2.34 through 1.2.38 address the applicable requirements of
MACT G.
Heat exchange systems. MACT FFFF references §63.104 of MACT F for compliance
requirements. MACT F requires the source to develop and implement a monitoring
plan that documents the procedures that will be used to detect leaks of process fluids
into the cooling water. The source has indicated that a pressure test is conducted on
123/0003 Page 10 of 12
Kodak Alaris, Inc. — Kodak Alaris Colorado
Operating Permit No. 96OPWE128
Technical Review Document — Second Renewal
vessels on a quarterly basis to ensure there are no leaks. Conditions 1.2.42 through
1.2.47 address the applicable requirements of MACT F.
• Updated MACT KK language to be more consistent with other permits.
• Added a combined fuel consumption limit for RTO1 and RTO2.
• Regulation Number 7, Section IX. Surface Coating Operations requirements added in
Condition 2.7. These include daily compliance calculations to demonstrate compliance
with emission limitation specified in Colorado Regulation No. 7, Section IX.J (4.8
lbs/gallon of solids) and work place practices. Work place practices to mitigate fugitive
emissions include tight fitting covers for open tanks, covered container for solvent
wiping cloths and proper disposal of dirty cleanup solvent. Since MACT KK already
addresses monitoring requirements to ensure capture and destruction efficiency, the
Reg 7 monitoring requirements would be redundant and would not add any significant
value. Additionally the monitoring frequency stipulated by Reg 7 is lower than that
required by MACT KK. At this time the Division does not plan on adding monitoring
requirements of Regulation Number 7, Section IX.A.8.a and IX.A.8.b.
o KAC manufactures the coating applied, testing will be conducted initially to
determine the VOC concentration in accordance with EPA Method 24 of 40
CFR Part 60. Batch formulation records will be used as supporting
documentation to establish that no change in VOC concentration has occurred
since the initial determination. If formulation of the coating changes KAC shall
retest the coating and determine the new VOC concentration.
• Added Condition 4: Condition 4 addresses applicable requirements for the emergency
fire pump engines.
o Regulation No.1 Section VI.B.4.(i) SO2 limitation of 0.8 lb/mmbtu. Compliance
presumed since only diesel fuel is permitted to be used as fuel in this engine.
o Opacity requirements of Regulation No. 1, Section II.A.1 and Section II.A.4.
Section II.A.4 limits opacity to no more than 30% and is only applicable during
start-up, any process modification, or adjustment. Section II.A.1 limits opacity
to no more than 20% and is applicable at all times except as outlined above.
Compliance shall be determined with an annual Method 9 observation.
o MACT ZZZZ requirements added. Reference Section III of this Technical
Review Document.
• Added Condition 5: Condition 5 addresses applicable Reg 7 requirements for
degreasing units.
Section III— Permit Shield
• Updated the Reg 3 Citation for the permit shield
• Permit Shield Table updated to reflect area's current non -attainment status.
123/0003 Page 11 of 12
Kodak Alaris, Inc. — Kodak Alaris Colorado
Operating Permit No. 96OPWE128
Technical Review Document — Second Renewal
o "Colorado Regulation No. 7, except for Sections V, VI.B.1 and VII.C", was
removed from the Table since Windsor Colorado 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.
o "General Condition 29.a of this permit" has also been removed from the table as
this provision applies to sources in ozone nonattainment areas.
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 (8/20/2014).
• EPA's mailing address was revised (Appendix D).
• Cleared the list of modifications from Appendix F related to the previous issuance.
• Updated Appendix G.
• Updated facility plot plan.
• Updated insignificant activities list.
123/0003 Page 12 of 12
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
OPERATING PERMIT RENEWAL SUMMARY
PERMIT NUMBER: 96OPWE128
AIRS ID #: 123/0003 DATE: November 13, 2017
APPLICANT: Kodak Alaris, Inc. — Kodak Alaris Colorado
REVIEW ENGINEER: Ramazan Spencer
SOURCE DESCRIPTION
This facility consists of several buildings containing a variety of equipment used to manufacture photographic supplies.
Building C-29 contains a small chemical manufacturing reactor room for producing various aqueous polymers. In Buildings
C -29B and C -29C, the company produces thermal media which customers use in color printers to transfer color and clear
laminate onto paper or other surfaces. Dry dye powder is weighed and dissolved in solvents. The coating solutions are
piped to a coating machine where they are applied to plastic substrate material. Two natural gas -fired boilers (Building C-
30), each rated at 157 MMBtu/hour, are used as back-up steam sources only, as process steam is purchased from and
provided by an external source.
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. 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
alto Emit ton !t;:33�,, 333.fi
( �
7
..,.._ :� r L'l .-
1 , 3e,
-
_ y[��_-.-
,,,, a .
Facility Wide Emissions (Excluding C-30 Boilers)
7.15
169.7
6.06
14
C-30 Boilers
37.74
--
11.12
--
x`..,3333 '7733))33 Q
Total
44.89
I......
169.7 I
17.18 I 14
EMISSION SOURCES
The following discussion identifies the changes that were made in the renewal permit.
Facility Wide Reauirements — Regulation Number 7, Section IX: Surface Coating Operations applicable requirements
added.
Chemical Manufacturing Building C-29 (AIRS # 100) — MAC FFFF applicable requirements added. Emission calculation
methodology modified.
Two Natural Gas Fired Boilers (157 mmbtu/hr each, AIRS # 051)— Reduced fuel consumption limits. Emission limits
reduced to reflect the change in fuel consumption. MACT DDDDD applicable requirements added.
Two Cummins Emergency Fire Pump Engines (HP 240 each) — MACT ZZZZ applicable requirements added. Colorado
Regulation No. 1 applicable opacity and SO2 limitations added.
Degreasing Unit — Regulation Number 7, Section X: Use of Solvents for Degreasing and Cleaning applicable requirements
added.
ALTERNATIVE OPERATING SCENARIOS
No changes were made to the alternative operations scenarios.
INSIGNIFICANT ACTIVITIES
Removed the two Cummins Emergency Fire Pump Engines and the Degreasing Unit.
PERMIT SHIELD
Removed all Permit Shield entries based on attainment status of the area.
Kodak
November 3, 2008
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: Renewal Air Operating Permit 96OPWE128
Dear Mr. Burgett:
Enclosed please find our application package for renewal of Title V Operating Permit number
96OPWE128 for Kodak Colorado Division (KCD).
Except for the proposed modifications identified in the attached "Supporting Documentation",
KCD is not requesting any changes to the existing permit. All other terms in our existing
operating permit are incorporated by reference into this renewal application.
KCD is aware of the Division's proposed amendments to Regulation No. 3 and Regulation No. 7.
When those amendments are finalized 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.
Please contact Mr. Eric Petersen, Environmental Engineer, with any questions or concerns
regarding this renewal application by phone at (970) 686-4014 or email at
eric.petersen@kodak.com.
Sincerely,
4
Robert K. Gray
Site Manager, Kodak Colorado Division
9952 Eastman Park Drive
Windsor, CO 80551-1590
Enclosed:
Forms 2000-100,602, 603, 800 & Attachments
cc: Ms. JoAnn Gould, Eastman Kodak Company
Mr. Eric Petersen
Eastman Kodak Company
9952 Eastman Park Drive
Windsor, CO 80551
Kodak
WORLDWIDE
PARTNER
Supporting Documentation
for the Kodak Colorado Division
Title V Operating Permit Renewal Application
(96OPWE128)
November 3, 2008
Primary Change — Inclusion of Construction Permit 90WE0466:
As a significant permit modification in August of 2005, Kodak Colorado Division (KCD)
put forth the intent to incorporate the Construction Permit issued to Kodak Polychrome
Graphics (90WE0466) into the existing KCD Title V Permit (96OPWE128). Recall that
Kodak Polychrome Graphics became a wholly owned subsidiary of Eastman Kodak
Company on April 1, 2005. The driver for the significant modification was to combine
the sources owned by Kodak into a single site -wide permit with limits that would clarify
the continuing Synthetic Minor status (for VOC) under PSD.
KCD believes that the Division is in possession of all necessary information to combine
these two permits because a draft was ready to go to public notice in August of 2006.
KCD requested that the draft be withheld from public notice at the 11th hour to facilitate a
sudden and significant transfer of ownership of a portion of the permitted facility to
ONEX. On November 21, 2006 the KCD Title V Permit (96OPWE128) was revised and
no longer included the Health Group portion of the facility, which was issued a separate
Title V Permit (06OPWE288). On May 1, 2007, the newly formed Carestream Health,
Colorado assumed ownership of the Health Group facility and it associated Title V
Operating Permit (06OPWE288).
The Plate Manufacturing Operation (formerly Kodak Polychrome Graphics) has
continued to operate under its Initial Approval Construction Permit (90WE0466),
pending incorporation of the sources into the KCD Title V Permit (96OPWE128). As
you are aware, the area has since been deemed nonattainment for ground -level ozone.
Given this change, obtaining synthetic minor status for VOC under PSD is no longer an
option for the KCD facility, which will now need to operate under NSR regulations.
However, KCD would like to continue the effort to combine all Kodak -owned operations
on -site into a single Title V Operating Permit.
VOC Emissions Calculations for C-29 Chemical Manufacturing:
The current permit (96OPWE128) identifies a set of calculations to be used to estimate
VOC emissions from the Chemical Manufacturing Operation in Building C-29. These
calculations use the general approach of VOC used = VOC emitted except for some
specific chemicals that are treated differently because the monomers are polymerized into
polymers that are none volatile in the C-29 process.
Since these calculations were developed, new regulation has become effective to the
operation — specifically the Miscellaneous Organic Chemical Manufacturing MACT (40
C.F.R. 63, Subpart FFFF). As part of the MON, detailed emissions estimates are
required to determine group status of batch process vents. These detailed calculations
consider every chemical and every step of the process necessary to produce each product
and result in a very accurate estimation of the true process emissions. To provide a safety
factor, the estimate for each product is multiplied by a factor of 3 to ensure that minor
variations in the process do not result in an actual emission greater than the calculated
value. In the event that a non-standard batch occurs, a revised emission estimate is
created.
Even with this conservative approach to the MON calculations, KCD has only Group 2
batch process vents in the chemical manufacturing operation. KCD would like to utilize
these estimates in the Title V Permit. The suggested approach would be to track the
number of batches made and apply the MON emissions factor to determine the emissions
associated with that batch. The total batch emissions would then be rolled -up for each
month and a new 12 -month rolling total calculated for C-29 VOC.
The only VOC not addressed by the MON emissions calculations is Cyclohexanone used
for cleaning latex vessels. This material is purchased and used repeatedly until it
becomes too "dirty" to re -use for cleaning. Once spent, the cyclohexanone is sent for off -
site disposal. The existing approach requires that any cyclohexanone used by the process
be reported as an emission, which is a gross overestimate in this case. To support a more
reasonable estimate, the spent cyclohexanone has been chemically analyzed and
determined to consist of 99.5% cyclohexanone by weight. Therefore, KCD proposes to
use a mass balance approach to determining the cyclohexanone emitted during the month.
Suggested language is as follows:
VOC Emissions:
Building C-29:
Except for Cyclohexanone, the following calculation shall be used to
estimate emissions:
VOC emissions = The Sum for each product "X" of [Batches of Product
"X"]* [Product "X" Emission Factor]
For Cyclohexanone, the following calculation shall be used to estimate
emissions:
VOC emissions = Cyclohexanone replaced — Cyclohexanone shipped off -
site for disposal*0.99
Operating Permit Application FACILITY IDENTIFICATION
Colorado Department of Public Health and Environment
Air Pollution Control Division
FORM 2000-100
Rev 06-95
SEE INSTRUCTIONS ON REVERSE SIDE
1.
Facility name and
mailing address
Name Kodak Colorado Division
Street or Route
City, State, Zip Code
9952 Eastman Park Drive
Windsor, Colorado 80551-1590
2. Facility location
(No P.O. Box)
Street Address
City,County, Zip Code
9952 Eastman Park Drive
Windsor, Colorado 80551-1590
3. Parent corporation
Name
Street or Route
City, State, Zip Code
Country (if not U.S.)
Eastman Kodak Company
343 State Street
Rochester, NY 14650
4. Responsible
Official
Name
Title
Telephone
Robert K. Gray
Site Manager, Kodak Colorado Division
and Vice President, Consumer Digital
Imaging Group
(970) 686-4121
5. Permit contact person Name
Title
(If Different than 4) Telephone
Eric Petersen
Environmental Engineer
(970) 686-4014
Facility SIC code: 3861
7. Facility identification code: CO 1 2 3 0 0 0 3
8. Federal Tax I. D. Number: 1 6 0 4 1 7 1 5 0
9. Primary activity of the operating establishment: Manufacturer of photographic material & supplies.
10. Type of operating permit ❑ New
❑ Modified ■ Renewal
11. Is the facility located in a "nonattainment" area: I Yes ❑ No
If "Yes", check the designated "non -attainment" pollutant(s):
❑ Carbon Monoxide • Ozone
O 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.
**
96OPWE128 11/01/04 Kodak Site -Wide Operating Permit S029, S29B, S29C, S070, S030
**90WE0466 05/14/04 Kodak Polychrome Graphics (formerly) S060
THE KODAK POLYCHROME GRAPHICS OPERATION BECAME A WHOLLY OWNED SUBSIDIARY OF EASTMAN
KODAK COMPANY ON APRIL 1, 2005. AN APPLICATION FOR A SIGNIFICANT PERMIT MODIFICATION
TO INCORPORATE THE KODAK POLYCHROME GRAPHICS CONSTRUCTION PERMIT (90WE0466) INTO THE
EXISTING KODAK COLORADO DIVISION TITLE V OPERATING PERMIT (96OPWE128) [WITHOUT AN
INCREASE IN EXISTING EMISSION LIMITS] WAS SUBMITTED ON AUGUST 29, 2005.
1
Operating Permit Application PLANT -WIDE HAZARDOUS AIR POLLUTANTS
Colorado Department of Public Health and Environment
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
FORM 2000-602
Rev 06-95
1. Facility name: Kodak Colorado Division
2. Facility identification code: CO 1 2 3 0 0 0 3
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 ❑
Pollutant CAS
Common or Generic
Pollutant Name
Actual emissions
Allowable OR Potential
to emit
Quantity
Units
Quantity
Units
108883
Toluene
PTE < Site VOC
Limit
TPY
67561
Methanol
PTE < Site VOC
Limit
TPY
75354
Vinylidene Chloride
PTE < Site VOC
Limit
TPY
80626
Methyl Methacrylate
PTE < Site VOC
Limit
TPY
107131
Acrylonitrile
PTE < Site VOC
Limit
TPY
79107
Glacial Acrylic Acid
PTE < Site VOC
Limit
TPY
75092
Methylene Chloride
< 1
TPY
7664939
Sulfuric Acid
8
(per Const Permit)
TPY
7647010
Hydrochloric Acid
8
(per Const Permit)
TPY
7697372
Nitric Acid
8
(per Const Permit)
TPY
78933
Methyl Ethyl Ketone
8
(per Const Permit)
TPY
111773
Dowanol DM (Glycol ether)
8
(per Const Permit)
TPY
TPY
TPY
TPY
TPY
TPY
TPY
TPY
TPY
TPY
TPY
TPY
NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit.
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: Kodak Colorado Division
2. Facility identification code: CO 1 2 3 0 0 0 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
12.3
12.3
Nitrogen oxides
223.0
223.0
Volatile organic compounds
174.7
174.7
Carbon monoxide
200.0
200.0
Lead
N/A
N/A
Sulfur dioxide
Backup Fuel
Backup Fuel
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
)rides
N/A
N/A
10
Operating Permit Application
Colorado Department of Health
Air Pollution Control Division
Facility Name: Kodak Colorado Division
I. ADMINISTRATION
TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800
09-94
Facility Identification Code: CO 1 2 3 0 0 0 3
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. nrintine
❑ 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 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. nrintine 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
❑ 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
11
V. EMISSION SUMMARY AND
. COMPLIANCE CERTIFICATION
Total Number
of This Form
This application contains the following forms
quantifying emissions, certifying compliance
wii icable requirements, and developing a
col ce plan
❑
Form 2000-600, Emission Unit Hazardous Air Pollutants
❑
Form 2000-601, Emission Unit Criteria Air Pollutants
•
Form 2000-602, Facility Hazardous Air Pollutants
1
•
Form 2000-603, Facility Criteria Air Pollutants
1
❑
Form 2000-604, Applicable Requirements and Status of Emission Unit
El
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
■ 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
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
Robert K. Gray
Title
Site Manager, Kodak Colorado Division and
Vice President, Consumer Digital Imaging Group
Signature 6
gl.-<--/K-
Date Signed
November 3, 2008
12
Operating Permit Application
Colorado Department of Health
Air Pollution Control Division
Facility Name: Kodak Colorado Division
CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800
09-94
Facility Identification Code: CO 1 2 3 0 0 0 3
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 after reasonable inquiry, I certify that
the statements and information contained in this application are true, accurate and complete.
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY 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
Signature
Robert K. Gray
Title
Site Manager, Kodak Colorado Division and
Vice President, Consumer Digital Imaging Group
Date Signed
November 3, 2008
SEND ALL MATERIALS TO:
COLORADO DEPARTMENT OF HEALTH
APCD-SS-B 1
4300 CHERRY CREEK DRIVE SOUTH
DENVER, CO 80246-1530
13
Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION
Colorado Department of Public Health and Environment
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
FORM 2000-302
Rev 06-95
1. Facility name: Kodak Alaris Inc.
2. Facility identification code: CO 1230003
3. Stack identification code:
4. Engine (Unit) code: E01
4a. Date first placed in service: 2000
Date last modified:
5. Engine use: Emergency Fire Pump
6. Engine Features:
2 -Cycle
4 -Cycle
Standard rich burn
Air/fuel ratio controller
Low-NOx design
Spark -ignition
Standard lean burn
Turbocharger
Other(Describe):
Diesel
7. Emission controls: T No
Non -Selective catalytic reduction
Selective catalytic reduction
Oxidation catalyst
Yes- Attach control device form
Three-way catalyst
Ammonia injected
Other:
8. Manufacturer: Cummins
9. Model No: 6CTA8.3-F2
S/N: 46031463
10. Max Fuel Design Rate: 1.89 MMBtu/hr
(based on 13.5 gal/hr @ 140 MMBtu/1,000 gal)
11. Horsepower
Max Design: 270 Site: 240
12. Heat Rate: Unknown
13. Operating Temp: Min. N/A
Max. 1,056 °F
14. Fuels:
Primary Fuel
Backup Fuel #1
Fuel Type:
No. 2 Diesel
None
Heating Value MMBtu/gallon
0.140
N/A
Sulfur Content (Wt. %)
0.0015
N/A
Ash Content, (Wt. %)
N/A
N/A
Moisture Content
(%)
N/A
N/A
Maximum Hourly Consumption (gal)
13.5
N/A
Maximum Yearly Consumption (gal)
NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration
1,350
N/A
Identify; the method of compliance demonstration by completing Form 2000-500, *****
DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE.
Attach Form 2000-500 to this form.
*** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. *****
Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION
Colorado Department of Public Health and Environment
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
FORM 2000-302
Rev 06-95
1. Facility name: Kodak Alaris Inc.
2. Facility identification code: CO 1230003
3. Stack identification code:
4. Engine (Unit) code: E02 -
4a. Date first placed in service: 2000
Date last modified:
5. Engine use: Emergency Fire Pump
6. Engine Features:
2 -Cycle
4 -Cycle
Standard rich burn
Air/fuel ratio controller
Low-NOx design
Spark -ignition
Standard lean burn
Turbocharger
Other(Describe):
Diesel
7. Emission controls: J No 1
Non -Selective catalytic reduction
Selective catalytic reduction
Oxidation catalyst
Yes- Attach control device form
Three-way catalyst
Ammonia injected
Other:
S. Manufacturer: Cummins
9. Model No: 6CTA8.3-F2
S/N: 45545437
10. Max Fuel Design Rate: 1.89 MMBtu/hr
(based on 13.5 gal/hr @ 140 N MBtu/1,000 gal)
11. Horsepower
Max Design: 270 Site: 240
12. Heat Rate: Unknown
13. Operating Temp: Min. N/A
Max. 1,056 °F
14. Fuels:
Primary Fuel
Backup Fuel #1
Fuel Type:
No. 2 Diesel
None
Heating Value MMBtu/gallon
0.140
N/A
Sulfur Content (Wt. %)
0.0015
N/A
Ash Content, (Wt.%o)
N/A
N/A
Moisture Content (%)
N/A
N/A
Maximum Hourly Consumption (gal)
13.5
N/A
Maximum Yearly Consumption (gal)
NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration
1,350
N/A
Identify, the method of compliance demonstration by completing Form 2000-500, *****
DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE.
Attach Form 2000-500 to this form.
***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. *****
2
Kodak
Hand Delivered
March 4, 2008
Mr. Matthew S. Burgett, P.E.
Operating Permits Unit, Stationary Sources Program
Colorado Department of Public Health & Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Re: Minor Permit Modification Request for Kodak Colorado Division
#291 RTO Destruction Efficiency Update, Permit #96OPWE128
Dear Matt,
As you are aware, Kodak Colorado Division (KCD) recently contracted ERM to conduct
a Performance Test on the #291 Regenerative Thermal Oxidizer (RTO) to verify the.
control system's destruction efficiency following the replacement of the burner units in
December 2007. Per your February 15, 2008 letter, a minor permit modification is
required to update the Title V permit with the new compliance temperature and
destruction efficiency. This submission should include everything required for the minor
permit modification application.
Description: The #291 Machine is one of two solvent coating lines at KCD that together
constitute an affected source under the Printing and Publishing MACT. As required, the
volatile organic carbon (VOC) and hazardous air pollutant (HAP) emissions from these
coating lines are controlled by a dedicated RTO for each line. The #291 RTO has been in
service for 13 years and recently underwent some maintenance including replacement of
both the ceramic media and the burner units. In an email dated November 8, 2006, the
Division determined that a stack test would not be required for the like -for -like media
exchange. Regarding the subsequent burner unit replacement, in a letter dated October 5,
2007, the Division determined that a stack test would be required to verify the destruction
efficiency only. The burner units were replaced on December 20, 2007. ERM conducted
the stack test on January 30, 2008 and the results of the test define a destruction
efficiency of 98.8% at a 3 -hour average combustion chamber temperature of 1387°F
(please see attached test report). This current destruction efficiency is higher than the
previous 97.6% measured at an average temperature of 1419°F. Therefore, no additional
emissions will occur as a result of this modification and less natural gas will be required
to maintain the compliance temperature.
Suggested Language: No changes to the equipment list are required and no equation
changes will be necessary to account for emissions from the #291 RTO. The following
sentence exists in Section 11.3.3 of the current permit:
Eastman Kodak Company
9952 Eastman Park Drive
Windsor, CO 80551
Kodak
WORLD WIDE
PARTNER
Mr. Matthew S. Burgett
March 4, 2008
Minor Permit Modification Application - #291 RTO Performance Test
For purposes of this Condition 3.3, the performance test indicated that a control
efficiency of 97.6% is met at a temperature greater than or equal to 1419°F (3 -
hour average) and when the RTO main fan is operating.
The following sentence is proposed to replace the preceding sentence in Section II.3.3 of
the permit:
For purposes of this Condition 3.3, the performance test indicated that a control
efficiency of 98.8% is met at a temperature greater than or equal to 1387°F (3 -
hour average) and when the RTO main fan is operating
Note that only text in RED above has been changed.
A revised Air Pollution Emission Notice (APEN) for the VOC and HAP emissions
associated with the #291 RTO and building C -29B has also been included. Note that the
emissions estimate calculations can also be submitted electronically but have been
thoroughly reviewed by the Division for 2005, 2006, and part of 2007. The annual
emission estimates used to deteiuiine APEN values were December 2007 12 -month
rolling total emissions quantities.
Should you have any questions regarding the above permit modification request or the
attachments, please contact me at 970-686-4014 or eric.petersen@kodak.com. kodak.com. Thank
you for your consideration.
Sincerely,
Ea ii a i Kodak Companolorado Division
nc Petersen'----'
Environmental Services
Attachments
Mr.. Matthew S. Burgett
March 4, 2008
Minor P,ermit Modification Application- #291 RTO Performance Test
Certification
I have reviewed this permit modification request in its entirety and, based on
information and belief formed after reasonable inquiry, I certify that the statements
and information contained in this request are true, accurate and complete. Kodak
believes this modification meets the requirements of a minor modification and can
be processed under the minor modification procedures (Reg 3, Part C, Section X).
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 § 25-7122.1, C.R.S.
John R. Beni for Robert K Gray
Printed or Typed Name
Ope .tiermit Number: 96OPWE128
ignature of Responsible Official
Site Manager, Kodak Colorado Division &
Vice President, Consumer Digital Imaging Group
Title
Mr. Matthew S. Burgett
March 4, 2008
Minor Permit Modification Application - #291 RTO Performance Test
Revised APEN:
Mr. Matthew S. Burgett
March 4, 2008
Minor Permit Modification Application - #291 RTO Performance Test
Referenced Correspondence:
History:
"MATT S Burgett "
<msburget @smtpgate . dphe.s
tate.co.us>
02/15/2008 03:23 PM
To <eric.petersen@kodak.com>, <matt.burgett@state.co.us>
cc
bcc
Subject
<david.andre@kodak.com>, <joann.gould@kodak.com>,
"Christopher Reinhardt"
<Csreinha@smtpgate.dphe.state.co.us>, "Jeremy Murtaugh"
Re: KCD Performance Test, Administrative Amendment
Application
This message has been forwarded.
Eric,
Attached is a letter regarding the modification to your T5 permit to account
for the RTO control and temperature established during your recent stack
testing. The Division would consider this a Minor Modification, not an
Administrative Modification. 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)
> <eric.petersen@kodak.com> 2/7/2008 5:17 PM
Matt,
>>>
Thanks for taking the time to work through this with me again over the
phone this afternoon.
Our thought process is pretty well defined in the attached letter:
(See attached file: Administrative Permit Amendment Application Letter.doc)
If you would like a signed version of this on
send one. As I mentioned on the phone and in
to meet with you to discuss the best approach
beneficial.
Regards,
Eric Petersen
Environmental Services
Eastman Kodak Company, Colorado Division
(970) 686-4014 Office
(970) 686-4194 Fax
minor modification Itr FiT0 temp.pdf
letterhead I'll be happy to
the letter, we would be happy
if you feel that would be
History:
"Thomas. E. Lovell"
<TELOVELL @S MTPGATE .D
PHE.STATE.CO.US>
11/08/2006 08:44 AM
To <eric.petersen@kodak.com>
cc
bcc
Subject Re: Fw: Record of our RTO Media Exchange discussion
11/1/06
This message has been replied to and forwarded.
Eric,
As we discussed, a stack test will not be required as long as the RTO
media is replaced with identical media. Should the operational
parameters (e_ g. temperature) of the RTO change a test may still be
required.
Let me know if you have any questions.
Tom Lovell
>>> <eric.petersen@kodak.com> 11/06/06 10:02 AM >>>
Eric Petersen
Environmental Services
Eastman Kodak Company, Colorado Division
(970) 686-4014 Office
(970) 686-4194 Fax
Forwarded by Eric Petersen/487222/EKC on 11/06/2006 10:02 AM
.Eric
Petersen/487222/E
KC
11/03/2006 05:33
cc
PM
Subject
tomas.lovell@co.state.gov
Record of our RTO Media Exchange
discussion 11/1/06
Tom,
Per our conversation on November 1, 2006, I'm writing this letter as a
foiiu
of documentation regarding the outcome of our conversation. I called
you
to verify my understanding that exchanging our current RTO media with
new
material of the exact same make and dimension (like -for -like) would
not
constitute a change in operational parameters that would, in and of
itself,
drive a performance re -test. Over the phone, you concurred with my
assessment and agreed to respond by email if I drafted this sort of
record.
In addition, KCD agreed to notify you at least 30 days prior to
actually
replacing the RTO media.
Would you mind replying by email to affirm the accuracy of this
assessment?
Please feel free to add anything that we discussed if I've neglected
to
include it here.
I sincerely appreciate your willingness to discuss issues like this in
person - I realize your often out of the office and we all have a lot
to
get done during the week.
Thank you for your cooperation and consideration in this request.
Eric Petersen
Environmental Services
Eastman Kodak Company, Colorado Division
(970) 686-4014 Office
(970) 686-4194 Fax
"Elizabeth Pilson "
<eapilson @smtpgate .dphe.st
ate.co.us>
10/05/2007 03:11 PM
To <eric.petersen@kodak.com>
cc
bcc
Subject
"ROBERT Jorgenson" <bjorgens@cdphe.state.co.us>, "Paul
Carr"<Pmcarr@smtpgate.dphe.state.co.us>
Kodak Burner Exchange Request for 291 RTO
Eric,
The Division has reviewed the letter dated 10/4/07 regarding replacing
the burners in Kodak's #291 RTO. The Division has determined that
replacing the burners will require a performance re -test for destruction
efficiency only, due to the following reasons:
1. The Division does not agree that replacing the Maxon OVENPAK burners
with the Maxon KINEMAX burners constitutes a like -for -like. replacement.
2. The destruction efficiency may change with the burner replacement.
3. The last performance test was in 2001; it is not unreasonable to
require a re -test to ensure compliance six years later.
The required re -test should befor destruction efficiency only; no
re -test for capture efficiency is required.
Please let me know if you have any questions.
Thank you,
Beth Pilson
Air Pollution Control Division
CO Department of Public Health and Environment
Phone: 303-692-3247 Fax: 303-782-0278
elizabeth.pilson@state.co.us
Mailing address:
APCD-SSP-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Mr. Matthew S. Burgett
March 4, 2008
Minor Permit Modification Application - #291 RTO Performance Test
ERM Test Report:
Kodak
March 26, 2010
Mr. 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
Hand Delivered
MAR 26 ana
- _ APCD
`� Sfatinnri ;.
+n1!r'Cfc�
Re: Boiler Permitting Changes for Kodak Colorado Division,
Permit #96OPWE128
Dear Matt:
As you're aware from recent meetings and discussions, Kodak would like to separate the
Boilers in building C-70 from the existing Kodak Title V Permit. This change is being
requested to facilitate an anticipated transfer of ownership from Kodak to Carestream
Health, Inc. Following our discussions, we're requesting this change be made as an
administrative permit amendment because the change will not result in an emissions
increase. All boilers at the facility currently operate under the Kodak Title V Permit No.
96OPWE128 and limitations are applied to `Boilers The proposed approach is to
replace the Boilers section of the Kodak Title V with two Construction -Permits (one for
each boilerhouse). Kodak hopes to have these Construction Permits issued in advance of
the anticipated change in ownership, which may occur on or about April 27, 2010.
To enable issuance of the Construction Permits, the following documents are included in
this package:
➢ Construction Permit Application for building C-70,
➢ General APEN Form for building C-70,
➢ Construction Permit Application for building C-30, and
➢ General APEN Form for building C-30.
➢ Redlined version showing requested changes to the existing Title V Permit
The redlined version of the current permit identifies expected administrative changes
associated with this boiler permitting change. Changes associated with AIRS numbers,
Common Provisions, Insignificant Activities, or Appendices have not been proposed in
the redline but may be necessary.
Note that a Transfer of Ownership Form/APEN is not being submitted with this package.
The Transfer of Ownership is expected to be initiated as a separate effort because we
would like to identify one of the Construction Permits generated by this request to
execute that transfer.
These documents include gas use and emissions limitations that sum to the existing
limitations as the existing limits have been divided according to steam allocations
Eastman Kodak Company
9952 Eastman Park Drive
Windsor, CO 80551
Kodak
WORLDWIDE
PARTNER
Q99
historically provided to the respective manufacturing operations. This was done to
ensure that no net increase would occur as a result of this permitting change.
Given the total emissions were reviewed under the Construction Permit and this total
quantity is merely being divided it is our understanding that the change does not meet the
definition of a Modification and can be conducted under an Administrative Change.
Further, Kodak understands the following activities are not required for an
Administrative Change:
➢ An Actual to Potential Evaluation,
Full Public Review (and its associated timeline), or
➢ Full EPA Review (and its associated timeline).
In generating the emissions estimates supporting these documents, the calculations and
emissions factors from the existing Kodak Title V Permit were applied. The source -
specific emissions factors for building C-70 were determined by stack testing conducted
in April of 2005. The remaining factors are based on AP -42, which have not changed
since the most recent Title V revision in November of 2006. •
Kodak supports the approach where the rolling 12 -month numbers (for either fuel or
individual pollutants associated with an individual source) will be inherited from the
existing Kodak 12 -month rolling total moving forward.
Kodak understands that the APCD is in support of dropping the limitation that would
require one of the C-70 boilers to be down if either of the C-30 boilers are in operation
given that the total fuel consumption limitation will be divided but the sum will not
exceed the existing limitation.
Kodak supports and has proposed a fuel oil use limitation, which has not been specified
in the APEN for C-70 because the limit is proposed to be the maximum quantity of fuel
oil that could be burned before the activity exceeded an APEN threshold. This quantity is
82.5 kgal/year, which would generate 0.99 tpy NOx using currently applicable emissions
factors.
Should you have any questions regarding the request detailed above or any of the
attachments, please contact me at 970-686-4014 or eric.petersen@kodak.com. Thank
you for your consideration and cooperation regarding this request.
Sincerely,
Kodak Com
c Petersen
Environmental Engineer
KCD Regulatory Services
C i lorado Division
cc: Jim King, CDPHE-APCD Permits Unit
Dave Pusey, CHC HSE Manager
Karen Murphy, CHC Environmental Engineer
John Beni, KCD Facilities Manager
Attachments
Proposed changes to Sections I and II of Permit No 96OPWE128
Kodak Title V Operating Permit
SECTION I - General Activities and Summary
1. Permitted Activities
1.1 This facility consists of several buildings containing a variety of equipment used to
manufacture photographic supplies. Building C-29 contains a small chemical
manufacturing reactor room for producing various aqueous polymers. In Buildings C -
29B and C -29C, the company produces thermal media which customers use in color
printers to transfer color and clear laminate onto paper or other surfaces. Dry dye powder
is weighed and dissolved in solvents. The coating solutions are piped to a coating
machine where they are applied to plastic substrate material. The Boiler House (Building
C 70) consists of two dual fuel fired steam generators, each rated at 206 mmBtu/hour,
which provide steam for building and process heat throughout the facility. Natural gas is
used as the primary fuel and No. 2 fuel oil is used as the back up fuel for these units. Two
natural gas fired boilers (Building C 30), each rated at 157 MMBtu/hour, are used as
back up steam sources only when one or both of the C 70 boilers are down.
The facility is located in Weld County, near Windsor, an attainment area for all pollutants
except Ozone. The facility is located in the 8 -Hour Ozone Control Area, as defined in
Regulation No. 7, Section II.A.16.
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.
1.3 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.
1.4 All conditions in this permit are enforceable by the US Environmental Protection
Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents,
and citizens unless otherwise specified. State -only enforceable conditions are: Conditions
14 (Odor) and those portions of Colorado Regulation No. 15, as identified in Condition
18 (Ozone Depleting Compounds) of Section IV of this permit.
1.5 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. Prevention of Significant Deterioration
2.1 Based on information provided by the applicant, this facility is not categorized as a
major stationary source (no single criteria pollutant emissions with a Potential to Emit
>250 Tons/Year) as of the date of this permit. The facility therefore is not subject to the
PSD review requirements of 40 CFR 52.21. The boilers are a listed source for PSD
purposes and therefore are categorized as a major source for PSD purposes (PTE >.100
tons/year). (Colorado Regulation No. 3, Part B, Section IV.D.3).
Future modifications to this facility which are major by themselves will result in the
application of the PSD review requirements. In addition, future modifications at this
facility may result in the facility being classified as a major stationary source. Once that
threshold is exceeded, future modifications at this facility resulting in a significant net
emissions increase (see Regulation No. 3, Part A, Section I.B.37 and 58) for any pollutant
as listed in Regulation No. 3, Part A, Section I.B.58 or a modification which is major by
itself may result in the application of the PSD review requirements.
Future modifications at the boilers resulting in a significant nct emissions increase (see
Reg 3, Part A, Section I.B.37 and 58) for any pollutant as listed in Regulation No. 3, Part
A, Section I.B.58 or a modification which is major by itself may result in the application
of the PSD review requirements.
2.2 The following Operating Permit is associated with this facility for purposes of
determining applicability of PSD regulations: 06OPWE288 for Kodak Colorado Division
Health GroupCarestream Health.
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:
I (Table not shown) Please remove reference to boilers (S070 & S030) -
Appendix G lists specific equipment in each of the Buildings and associated AIRS
Identification Numbers.
Sources listed in bold face are sources for which specific permit terms are listed in this
Operating Permit.
4.2 Equipment Replacement
This permit covers only the specific existing equipment listed in Appendix G of this
permit.
4.3 Alternate Operating Scenarios
No alternate operating scenarios were requested for this facility.
5. Compliance Assurance Monitoring (CAM)
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. (MACT standards and sources with continuous monitoring devices are not subject
to CAM requirements.)
SECTION II - Specific Permit Terms
1. Facility Wide Limit
See Equipment List, Appendix G
(Table not shown, Please make the following changes)
> Reduce the allocation for VOC to 169.7 tpv
> Remove the allocation for PM
> Remove the allocation for PM10
> Reduce the allocation for NOx to 7.15 tpy
> Reduce the allocation for CO to 5.60 tpy
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-29:
Except for the separately listed chemicals, mass balance shall be used to
estimate emissions using the following equation:
VOC emissions = VOC consumption.
For vinylidene chloride, methyl acrylate, acrylonitrile, glacial acrylic acid,
and methyl methacrylate:
Emissions = 1% weight of consumption.
Note: Acrylamide is used in the process, but is not emitted.
Building C -29B:
Chemical Making and #291.Coating Line: Mass balance shall be used to
estimate emissions using the following equation:
VOC Emissions = [Amount of Coating Solvents Used for #291M x (1 -
Control Efficiency RTO #291M)]
Chemical Making Area VOC Emissions = (Total Vented Volume) x
(Solvent Vapor Density)
VOC Emissions (RTO#291M Gas Combustion) = 5.5 lb/mmscf x monthly
natural gas usage (mmscf/month) x tons/2000 lb
Building C -29C:
#292 Coating Line: Mass balance shall be used to estimate emissions
using the following equation:
VOC Emissions = [Amount of Coating Solvents Used for #292M x (1
Control Efficiency RTO #292M)]
VOC Emissions (RTO#292M Gas Combustion) = 5.5 lb/mmscf x monthly
natural gas usage (mmscf/month) x tons/2000 lb
Building C 30:
VOC emissions — 5.5 lb/mmscf x monthly natural gas use (mmscf/month)
x ton/2000 lb
Building C 70:
VOC Emissions (Gas) — 5.5 lb/mmscf x monthly natural gas use
(mmscf/month) x ton/2000 lb
VOC Emisfions (Oil) — 0.2 lb/kgai x monthly fuel oil use (kgal/month)-x
ton/2000 lb
PM/PM Emissions:
Building C 29B:
PM/PMEmissions — 7.6 lb/mmscf x monthly natural gas use
�
(mmscf/month) x ton/2000 lb
Building C 29C:
PM/PM Emissions — 7.6 lb/mmscf x monthly natural gas use
(mmscf/month) x ton/2000 lb
Building C 30:
PM/PMEmissions — 7.6 lb/mmscf x monthly natural gas use
(mmscf/month) x ton/2000 lb
Building C 70:
PM/PMEmissions (Gas) - 7.6 lb/mmscf x monthly natural gas use
4-0-
(mmscf/month) x ton/2000 lb
PM/PMEmissions (Oil) — 3.3 lb/kgal x monthly oil usage (kgal/month)
4-0-
X ton/2000 lb
CO Emissions:
Building C -29B:
CO Emissions = 84 lb/mmscf x monthly natural gas use (mmscf/month) x
ton/2000 lb
Building C -29C:
CO Emissions = 84 lb/mmscf x monthly natural gas use (mmscf/month) x
ton/2000 lb
Building C 70:
CO Emissions (Gas) — 160 lb/mmscf x monthly natural gas usage (mmscf)
x ton/2000 lb
CO Emissions (Oil) —
lb
Building C 30:
5 lb/kgal x monthly fuel oil usage (kgal) x ton/2000
CO Emissions — 84 lb/mmscf x monthly natural gas use (mmscf/month) x
ton/2000 lb
NOx Emissions:
Building C -29B:
NOx Emissions = 100 lb/mmscf x monthly natural gas use (mmscf/month)
x ton/2000 lb
Building C -29C:
NOx Emissions = 100 lb/mmscf x monthly natural gas use (mmscf/month)
x ton/2000 lb
Building C 70:
K-
NOx Emissions (Gas) — 220 lb/mmscf x monthly natural gas use
(mmscf/month) x ton/2 000 lb
NOx Emissions (Oil) — 21 lb/kgal x monthly fuel oil use (kgal/month) x
ton/2000 lb
Building C 30:
NOx Emissions — 2801b/mmscf x monthly natural gas use (mmscf/month)
x ton/20001b
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).
See Conditions 2.5 and 2.6 for monitoring procedures for the boilers. The remaining PM
emission sources located at this facility are the regenerative thermal oxidizers. 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.
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,
and off -site waste shipment information, as necessary in order to estimate emissions as
set forth in Section II, Condition 1.1. These records shall be kept on site for Division
inspection upon request. (Colorado Regulation No. 3, Part B, III.A.4 and IV.E.)
2. P070 Boiler House
#71 and #72 Babcock &Wilcox, 206 mmBtu/hour each
Natural Gas Fired (Primary Fuel)
No. 2 Fuel Oil Fired (Backup Fuel)
P030 #35 and #36,157 mmBtu/hour each
Natural Gas Fired
(Table not shown)
In addition to the applicable requirements contained in Section II.
following requirements apply to the boilers.
2.1 PM emissions shall not exceed the limitation as stated in
(Colorado Regulation No. 1, Section II.A.1.b). In this equation, PE
(lbs/mmBtu) and FI — fuel input (mmBtu/hour).
1 of this permit, the
the above equation
— the particulate limit
In the absence of credible evidence to the contrary, compliance with this emission limit
shall be presumed whenever natural gas is used solely as a fuel at this facility.
When No. 2 fuel oil is used in either boiler #71 or #72, compliance with this standard
shall be demonstrated on a semi annual basis using the manufacturer's maximum rated
fuel input for the boiler (FI) and the emission factors for fuel oil combustion, divided by
the heat content of the fuel. Records of the calculations shall be maintained and made
available for inspection upon request.
Fuel shall be sampled on occasions when No. 2 fuel oil is added to the storage tank, to
determine the heat content and weight percent sulfur. Fuel shall be sampled and analyzed
using appropriate ASTM methods or equivalent, if approved in advance by the Division.
Alternatively, vendor receipts, invoices, contracts, or other information may be used to
provide the values for sulfur and heat content. Records of all analyses results or vendor
information shall be maintained and made available for inspection upon request.
2.2 Total consumption of natural gas for boilers #35, #36, #71, and #72 shall not exceed
1800 x 10 scf/year (Construction Permit 96WE473, revised in accordance with Section I,
Condition 1.3 of this permit). Compliance with this annual limit shall be determined on a
rolling twelve month total. By the 15th day of the close of each month a new twelve
month total is calculated using the previous twelve months' data. Fuel usage shall be
determined using fuel meters and facility records as necessary. Natural gas usage shall be
monitored monthly and recorded and maintained for Division inspection upon request.
2.3 No. 2 fuel oil shall be used as a back up fuel only, for the #71 and #72 boilers.
(Construction Permit 96WE473, revised in accordance with Section I, Condition 1.3 of
this permit). Fuel use shall be determined using fuel meters and facility records as
necessary. The permittee shall record the actual monthly amount of fuel oil used, and the
dates and reasons for using fuel oil. Such records shall be maintained and made available
for inspection upon request. Emissions shall be included on APENs as necessary.
2.4 Boilers #35 and #36 shall not operate unless, -one or both of the #71 or 1`72 boilers are
down (Construction Permit 96WE473).
The permittee shall maintain records of the times the #35 and #36 boilers are used, and
the operating status of the #71 and #72 boilers during use of boilers #35 and 436. Such
records shall be maintained and made available for inspection upon request.
2.5 SO emission shall not exceed 1.5 lbs/mmBtu heat input (Construction Permit
96WE473 and Colorado Regulation No. 1, IV.B.2). Compliance with this requirement
shall be demonstrated on a semi-annual basis using the actual sulfur content and heat
content of the fuel oil, as determined under Condition 2.1. The permittee shall maintain
records of compliance calculations for inspection upon request.
2.6 Except as provided in Condition 2.7, 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. This standard is based on 21 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 (10 CFR
Part 60, Appendix A (July 1992)) in all subsections of Section 11 of Regulation No. 1.
(Construction Permit 96WE473, and Colorado Regulation No 1, Section II.A.1).
In the absence of credible evidence to the contrary, compliance with this opacity limit
shall be presumed whenever natural gas is used as a fuel at this facility. When fuel oil is
used, the following procedures apply:
Compliance with this requirement shall be demonstrated by conducting emissions
observation in accordance with EPA Method 9 on the frequency described herein. I€
applicable, a reading shall be conducted within 24 hours of completion of any of the
activities described under Condition 2.7 (start up, etc.). Readings shall be conducted
quarterly (minimum of six week separation), during normal operations, when fuel oil is
combusted.
If any observation indicates an exceedance of the limit, additional observations shall be
performed. 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 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. The
permittee shall maintain records of the days on which fuel oil is used. These records,
results of Method 9 readings, and a copy of the Method 9 reader's certification, shall be
maintained and made available to the Division for inspection upon request. Copies of
observations exceeding the applicable standard shall be submitted with the next
scheduled report.
2.7 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.1).
In the absence of credible evidence to the contrary, compliance with this opacitylimit
shall be presumed whenever natural gas is used solely as a fuel at this facility. When fuel
oil is used, the following procedures apply:
If fuel oil is used during fire building, cleaning of fire boxes, soot blowing, start up,
process modifications or adjustment of control equipment, compliance with this
requirement shall be demonstrated as follows:
Compliance shall be demonstrated by conducting visual emission observations in
accordance with EPA Method 9, if any of the above activities occurs continuously for
one hour or more. A reading shall be conducted within one hour and ten minutes of
commencement of any of the above activities and every 24 hours thereafter during the
activity.
If any observation indicates an exceedance of the limit, additional observations shall be
performed. 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 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.
The permittee shall maintain records of the days on which fuel oil is used during fire
building, cleaning of fire boxes, soot blowing, start up, process modifications or
adjustment of control equipment. These records, results of Method 9 readings, and a copy
of the Method 9 reader's certification, shall be maintained and made available to the.
Division for inspection upon request. Copies of observations exceeding the applicable
standard shall be submitted with the next scheduled report.
32. P29B - Thermal Media Manufacturing, Building C -29B
#291 Coating Machine
(Table not shown, No Changes Requested - except for condition number)
In addition to the applicable requirements contained in Section II.1 of this permit, the
following requirements apply to the #291 Coating Machine m Building C -29B.
32.1 The permittee shall comply with all requirements of 40 CFR Part 63, Subpart KK -
National Emission Standards for the Printing and Publishing Industry (as adopted by
reference in Colorado Regulation No. 8, Part E), including the following.
32.1.1 The permittee shall limit emissions to no more than five (5) percent
of the organic HAP applied for each month. The permittee shall operate a
capture system and control device to demonstrate an overall organic HAP
control efficiency of at least 95 percent for each month (§63.825).
The permittee shall follow the monitoring requirements set forth in
§63.828. The permittee shall install, calibrate, operate, and maintain a
temperature monitoring device equipped with a continuous recorder. The
device shall have an accuracy of + 1 percent of the temperature being
monitored in °C or + 1 °C, whichever is greater. The thermocouple or
temperature sensor shall be installed in the combustion chamber at a
location in the combustion zone. Any excursion from the required
operating parameters which are monitored, unless otherwise excused, shall
be considered a violation of the emission standard.
The permittee shall follow the reporting requirements set forth in §63.830.
The semi-annual MACT summary report and the start-up, shutdown and
malfunction reports required under §63.830 may be submitted with the
semi-annual permit monitoring and peixnit deviation reports specified in
this permit.
32.1.2 Compliance with the National Emission Standards for the Printing
and Publishing Industry emission reduction, monitoring, recordkeeping,
and reporting requirements shall be demonstrated using the procedures set
forth in Subpart KK:
32.2 Emissions of volatile organic compounds shall not exceed 77.59 tons per year.
Compliance with the annual limit shall be determined on a rolling twelve (12) month
th
total. By the 45 day after the close of each month a new twelve month total shall be
calculated based on the previous twelve months' data. The permittee shall calculate
monthly emissions using_ the procedures described in Section II, Condition 1.1, above.
(Construction Permit 96WE473)
32.3 The permittee may use a control efficiency higher than 95% for estimating HAP and
VOC emissions for compliance and APEN and fee purposes, provided that:
The permittee performs a stack test on the thermal regenerative incinerator to establish
the control efficiency and associated parameters to be monitored to demonstrate that the
higher control efficiency is met. Such test shall be conducted in accordance with Division
policies and guidelines.
The higher control efficiency may be used for estimating HAP and/or VOC emissions for
any given month, if monitoring demonstrates that the higher efficiency was met at all
times during that month.
For purposes of this Condition 32.3, the performance test indicated that a control
efficiency of 998.8% is met at a temperature greater than or equal to 14191387°F (3 -
hour average) and when the RTO main fan is operating. The permittee shall operate the.
main fan of the control device (RTO) and shall continuously record the operational status
of the fan.
(Construction Permit 96WE473)
43. P29C - Thermal Media Manufacturing, Building C -29C
#292 Coating Machine
(Table not shown, No Changes Requested — except for condition number)
In addition to the applicable requirements contained in Section II.1 of this permit, the
following requirements apply to the #292 Coating Machine in Building C -29C.
43.1 The permittee shall comply with all requirements of 40 CFR Part 63, Subpart KK -
National Emission Standards for the Printing and Publishing Industry (as adopted by
reference in Colorado Regulation No. 8, Part E), including the following.
43.1.1 The permittee shall limit emissions to no more than five (5) percent
of the organic HAP applied for each month. The permittee shall operate a
capture system and control device to demonstrate an overall organic HAP
control efficiency of at least 95 percent for each month (§63.825).
The permittee shall follow the monitoring requirements set forth in
§63.828. The permittee shall install, calibrate, operate, and maintain a
temperature monitoring device equipped with a continuous recorder. The
device shall have an accuracy of + 1 percent of the temperature being
monitored in °C or + 1 °C, whichever is greater. The thermocouple or
temperature sensor shall be installed in the combustion chamber at a
location in the combustion zone. Any excursion from the required
operating parameters which are monitored, unless otherwise excused, shall
be considered a violation of the emission standard.
The permittee shall follow the reporting requirements set forth in §63.830.
The semi-annual MACT summary report and the start-up, shutdown and
malfunction reports required under §63.830 may be submitted with the
semi-annual permit monitoring and permit deviation reports specified in
this permit.
43.1.2 Compliance with the National Emission Standards for the Printing
and Publishing Industry emission reduction, monitoring, recordkeeping,
and reporting requirements shall be demonstrated using the procedures set
forth in Subpart KK.
43.2 The permittee may use a control efficiency higher than 95% for estimating HAP and
VOC emissions for compliance and APEN and fee purposes, provided that:
The permittee performs a stack test on the thermal regenerative incinerator to establish
the control efficiency and associated parameters to be monitored to demonstrate that the
higher control efficiency is met. Such test shall be conducted in accordance with Division
policies and guidelines.
The higher control efficiency may be used for estimating HAP and/or VOC emissions for
any given month, if monitoring demonstrates that the higher efficiency was met at all
times during that month.
For purposes of this Condition 43.2, the performance test indicated that a destruction
efficiency of 98.9% is met at a temperature greater than or equal to 1578°F (3 -hour
average) and that a capture efficiency of 100% is met when the machine room to ambient
differential pressure is more negative than -0.007 inches water column. An overall
organic HAP control efficiency of 98.9% is achieved when these two parameters are met
(3 -hour average). The permittee shall continuously record the RTO combustion chamber
temperature and machine room to ambient differential pressure.
(Construction Permit 96WE473)
54. Emission Factors
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 can not 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.
Kodak_ ()la
ris
June 5, 2017
Raz Spencer
APCD-SS-B1
Operating Permits Unit, Air Pollution Control Division
Colorado Department of Public Health & Environment
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
RE: Kodak Alaris Colorado, Operating Permit No. 96OPWE128
Amendment to 2008 Renewal Application
Dear Mr. Spencer:
Kodak Alaris Colorado (KAC), formerly operating as Eastman Kodak, Colorado Division, submitted documentation on
November 3, 2008 as part of the Title V Operating Permit renewal application, which included a proposed volatile organic
compound (VOC) emission calculation methodology associated with Chemical Manufacturing in Building C -2g" (Chem
Manufacturing).
Since this submittal, KAC has developed a mufti -step compliance emission estimation tool to determine emissions from the
Chem Manufacturing operations. The emission estimation tool is based on material balances and complex engineering
calculations which incorporate environmental conditions of the manufacturing process, quantities of chemicals used, and
associated chemical reactions to estimate VOC emissions for each product.
This estimation tool is similar and consistent with the mass balance methodologies used to determine compliance in other
areas of the facility's operation that are required by the current Title V operating permit (i.e., overall facility wide emission
for VOC and HAP and the Printing & Publishing MACT). As such, KAC intends to use the aforementioned emission
estimation tool to demonstrate compliance with 40 CFR 63, Subpart FFFF (MON MACT) as part of the Title V Operating
permit moving forward.
KAC intends to amend the previous proposed emission calculation methodology included in the. November 2008 application.
and implement the new estimation tool to quantify VOC emissions from Chem Manufacturing. KAC requests the following
permit language be adopted for determining VOC emissions from Chem Manufacturing:
Facility -wide emissions of VOC shall not exceed the limitations stated in the table above. The source shall record
total chemical product batches on a monthly basis. The number of batches and the quantity of VOC, to be
determined by method described in 40 CFR Part 63 Subpart FFFF Paragraph 63.2460(b), that volatizes in each
batch shall be used to calculate emissions following a mass balance calculation. VOC emissions shall be summed
to determine monthly emissions. VOC monthly emissions from this emission unit shall be summed with the VOC
monthly emissions from other emission units and a twelve month rolling total of facility -wide VOC emissions will be
maintained to verify compliance with the annual emission limitations. Each month, a new twelve month total of
facility -wide VOC emissions shall be calculated using the previous twelve months data. Records of the calculations
and compliance determinations shall be maintained and made available for Division review upon request.
Under this new proposed method, KAC will record and retain the following information from Chem Manufacturing for
compliance with the proposed permit condition stated above and the MON MACT:
1. Total number of batches per month for each product.
2. Name and amount of chemical raw materials containing VOC and HAPs consumed on a monthly basis.
3. Safety Data Sheets for chemical raw materials containing VOC and HAPs.
4. Calculated VOC and HAP emissions (pounds) on a monthly basis.
KODAK ALARIS IS_THE TRADE NAME OF 111616 OPCO (DELAWARE) INC_
9952 EASTMAN PARK DRIVE ' WINDSOR, CO 80551
Kodak alaris
5. 12 -month rolling total calculations for VOC emissions (tons per year) aggregated with other facility VOC
emissions to compare against facility wide VOC limit.
6. 12 -month rolling total calculations for HAP emissions (pounds per year) to compare against MON MACT
emission thresholds for Group 2 batch process vents.
The proposed emissions estimation tool, in conjunction with the current leak detection and repair (LDAR) program, will be
used to show continuing compliance with applicable sections of the MON MACT.
In addition, documentation was submitted in November of 2008 requesting specific methodology be used to calculate
Cyclohexanone emissions from Chem Manufacturing during the cleaning process for latex vessels. Kodak is not requesting
a change to the methodology proposed in that documentation. Therefore, emission calculation methodology would be as
follows:
Cyclohexanone Emissions = Weight Replaced — (Weight Shipped Off -Site for Disposal * 0.99]
For further information on this request please contact Keli Sharpee, HSE Coordinator at 970-686-4348 or
keli.sharpee@kodakalaris.com.
Sincerely,
Stephen J. K
Kodak Alaris Colorado
Site-
Manager
KODAK ALARIS IS THE TRADE NAME OF 111616 OPCO (DELAWARE) INC.
9952 EASTMAN PARK DRIVE WINDSOR. CO 80551
Operating Permit Application FACILITY IDENTIFICATION
Colorado Department of Public Health and Environment
Air Pollution ControlDivision
SEE INSTRUCTIONS ON REVERSE SIDE
FORM 2000-100
Rev 06-95
1. Facility name and Name Kodak Alaris Colorado
mailing address Street or Route
City, State, Zip Code
9952 Eastman Park Drive
Windsor, Colorado 80551-1590
2. Facility location
(No P.O. Box)
Street Address
9952 Eastman Park Drive
City,County, Zip Code Windsor, Colorado 80551-1590
3. Parent corporation Name
Street or Route
City, State, Zip Code
Country (if not U.S.)
Kodak Alaris, Inc.
2400 Mt. Read Blvd.
Rochester, New York 14615
4. Responsible Name
Official Title
Telephone
Stephen Kozak
Site Manager, Kodak Alaris Colorado
(970) 686-4015
5. Permit contact person Name
Title
(If Different than 4) Telephone
Kell Sharpee
HSE Coordinator, Kodak Alaris Colorado
(970) 686-4348
Facility SIC code: 3861
7. Facility identification code: CO 1230003
8. Federal Tax I. D. Number: 1 6 0 4 1 7 1 5 0
9. Primary activity of the operating establishment: Manufacturer of photographic material & supplies.
10. Type of operating permit 0 New
• Modified 0 Renewal
11. Is the facility located in a "nonattainment" area: ■ Yes 0 No
If "Yes", check the designated "non -attainment" pollutant(s):
0 Carbon Monoxide ■ Ozone
(specify)
0 PM10 0 Other
Operating Permit Application
Colorado Department of Health
Air Pollution Control Division
Facility Name: Kodak Alaris Colorado
I. ADMINISTRATION
TABULATION OF PERMIT APPLICATION FORMS
Facility Identification Code: CO 1230003
FORM 2000-800
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. nrintine
❑
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:
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. nrintine oneration.
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
0
Form 2000-505, Stack Testing
❑
Form 2000-506, Fuel Sampling and Analysis
❑
Form 2000-507, Recordkeeping
❑
Form 2000-508, Other Methods -
89
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
❑
Form 2000-602, Facility Hazardous Air Pollutants
❑
Form 2000-603, Facility Criteria Air Pollutants
0
Form 2000-604, Applicable Requirements and Status of Emission Unit
o
Form 2000-605, Permit Shield Protection Identification
❑
Farm 2000-606, Emission Unit Compliance Plan - Commitments and Schedule
❑
Farm 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
the statements and information contained in this application are true, accurate
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE
• 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):
belief formed after reasonable inquiry, I certify that
and 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,
a 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
or certification in, or omits material information from this application is guilty of
accordance with the provisions of § 25-7 122.1, C.R.S.
Printed or Typed Name
Stephen Kozak
Title
Site Manager
Signature
4��
Date Signed
6 —
90
Operating Permit Application
Colorado Department of Health
Air Pollution Control Division
Facility Name: Kodak Alaris Colorado
CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800
09-94
Facility Identification Code: CO 1230003
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
the statements and information contained in this application are true, accurate
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):
belief formed after reasonable inquiry, I certify that
and 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,
a 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
or certification in, or omits material information from this application is guilty of
accordance with the provisions of § 25-7 122.1, C.R.S.
Printed or Typed Name
Stephen Kozak
Title
Site Manager
Signature
Date Signed
SEND ALL MATERIALS TO:
COLORADO DEPARTMENT OF HEALTH
APCD-SS-Bl
4300 CHERRY CREEK DRIVE SOUTH
DENVER, CO 80246-1530
91
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