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Home My WebLink About20143656.tiff 4 COPHE COLORADO CO 9 Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County-Clerk to the Board 1150 O St 758 PO Box Co 80632 RECEIVED November 18, 2014 NOV 2 1 2014 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On November 19, 2014, the Air Pollution Control Division will begin a 30-day public notice period for Metal Container Corporation - Windsor Can Plant. 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, 7; Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure • R,thri Kt-u114A-J N 2014-3656 /I',2, / 4300 Cherry Creek Drive S., Denver, CO 60246-1530 P 303-692-2000 www.mlorado.govicdphe John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer I ,, .+ CDPHE Air Pollution Control Division CO Notice Of A Proposed Renewal Title V Operating Permit Warranting Public Comment Website Title: Metal Container Corporation - Windsor Can Plant - Weld County Notice Period Begins: November 19, 2014 NOTICE is hereby given that an Operating Permit 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: Metal Container Corporation 1201 Metal Container Court Windsor, CO 80550-3309 Facility: Windsor Can Plant 1201 Metal Container Court Windsor, CO 80550-3309 Metal Container Corporation has applied for a Renewal Operating Permit for the Windsor Can Plant in Weld County, CO. This facility manufactures the bodies of 2 piece-aluminum beverage cans. A copy of the application, including supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit 96OPWE162 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. Based on the information submitted by the applicant, the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Joshua Jones of the Division at (303) 692-3207 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 wilt receive and consider the written public comments and requests for any hearing for thirty calendar days after the date of this Notice. V ownsuo 1 I ^ ir OF ' Col 0 SINE NtR�'�4 � Colorado Department of Public Health and Environment OPERATING PERMIT Metal Container Corporation — Windsor Facility First Issued: September 1 , 1998 Renewed: DATE AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: Metal Container Corporation OPERATING PERMIT NUMBER FACILITY ID: 123/0134 RENEWED: DATE 96OPWE162 EXPIRATION DATE: DATE MODIFICATIONS: See Appendix F of Permit Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et seq. and applicable rules and regulations. ISSUED TO: PLANT SITE LOCATION: Metal Container Corporation Metal Container Corporation 1201 Metal Container Court 1201 Metal Container Court Windsor, CO 80550-3309 Windsor,CO 80550-3309, Weld County INFORMATION RELIED UPON Operating Permit Renewal Application Received: June 29,2007 And Additional Information Received: Various dates; see Technical Review Document Nature of Business: Aluminum Beverage Can Manufacturing Primary SIC: 3411 RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON Name: Gene Bocis Name: Corey Hansen Title: Plant Manager Title: E-S Manager Phone: 970-686-1514 Phone: 970-686-1516 SUBMITTAL DEADLINES— First Semi-Annual Monitoring Period: TBD based on permit issuance Subsequent Semi-Annual Monitoring Periods: January l —June 30, July I — December 31 Semi-Annual Monitoring Reports: Due February 1, 2014 & August 1, 2014&subsequent years First Annual Compliance Period: TBD based on permit issuance Subsequent Annual Compliance Periods: January I — December 31 Annual Compliance Certification: Due February 1, 2014 &subsequent years 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. TABLE OF CONTENTS: SECTION I-General Activities and Summary 1 1. Permitted Activities 1 2. Alternative Operating Scenarios 2 3. Nonattainment Area 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 7 1. Fuel Burning Equipment: 7 2. Can Forming Operations: 10 3. Can Coating Operations 13 4. Aluminum Scrap 23 5. Insignificant Activities 26 6. Emergency Fire Pump Engine: One (1) Caterpillar 3406 TA Fire Pump Engine, Rated at 440 HP 27 SECTION III-Permit Shield 33 1. Specific Non-Applicable Requirements 33 2. General Conditions 33 3. Stream-lined Conditions 34 SECTION IV-General Permit Conditions(ver 5/22/2012) 35 1. Administrative Changes 35 2. Certification Requirements 35 3. Common Provisions 35 4. Compliance Requirements 39 5. Emergency Provisions 40 6. Emission Controls for Asbestos 40 7. Emissions Trading,Marketable Permits,Economic Incentives 40 8. Fee Payment 40 9. Fugitive Particulate Emissions 41 10. Inspection and Entry 41 11. Minor Permit Modifications 41 12. New Source Review 41 13. No Property Rights Conveyed 41 14. Odor 41 15. Off-Permit Changes to the Source 42 16. Opacity 42 17. Open Burning 42 18. Ozone Depleting Compounds 42 19. Permit Expiration and Renewal 42 20. Portable Sources 42 21. Prompt Deviation Reporting 42 22. Record Keeping and Reporting Requirements 43 23. Reopenings for Cause 44 24. Section 502(6)(10)Changes 44 TABLE OF CONTENTS: 25. Severability Clause 45 26. Significant Permit Modifications 45 27. Special Provisions Concerning the Acid Rain Program 45 28. Transfer or Assignment of Ownership 45 29. Volatile Organic Compounds 45 30. Wood Stoves and Wood burning Appliances 46 APPENDIX A-Inspection Information 48 1. Directions to Plant- 48 2. Safety Equipment Required: 48 3. Facility Plot Plan: 48 4. List of Insignificant Activities 48 APPENDIX B 51 Reporting Requirements and Definitions 51 Monitoring and Permit Deviation Report-Part I 55 Monitoring and Permit Deviation Report -Part II 56 Monitoring and Permit Deviation Report - Part III 58 APPENDIX C 59 Required Format for Annual Compliance Certification Reports 59 APPENDIX D 61 Notification Addresses 61 APPENDIX E 62 Permit Acronyms 62 APPENDIX F 64 Permit Modifications 64 Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 1 SECTION I- General Activities and Summary 1. Permitted Activities 1.1 Metal Container Corporation manufactures the bodies of 2 piece-aluminum beverage cans. The plant has two process lines(Lines No. 1 and 2)which have emissions from natural gas fired ovens/boilers,can forming equipment,surface coating operations and miscellaneous combustion sources. Each process line consists of front-end and back-end operations. The front-end includes cupping and bodymaking units,which form the cans from aluminum coil,followed by washers which clean the can bodies for decorating. The back-end comprises the surface coating operations. A portion of the cans made are basecoated before being routed to decorators where the exterior of the can is printed with high solid inks and roll-coated with a water-based overvamish and rim varnish. Cans that are not basecoated are routed directly to the decorators. The inside of the can is then sprayed with a water-based coating. The can coatings are cured following each stage of surface coating(basecoating;printing/vamishing; inside spray)by heating in natural gas-fired ovens. Following the coating operations,the cans are necked, reformed,tested,and palletized prior to warehousing for shipment. The boilers supply low pressure hot water for the washers. The miscellaneous combustion sources supply building heat. The facility is located southeast of Windsor on the north side of County Road 66 in the Windsor Industrial Park, Weld County. The area in which this facility is located is classified as attainment for all pollutants except ozone.It is classified as non-attainment for ozone and is part of the 8-hr Ozone Control Area as defined in Regulation No. 7,Section II.A.1. Wyoming is an affected state within 50 miles of the facility. Rocky Mountain National Park and the Rawah Wilderness Area are Federal Class I designated areas within 100 kilometers of the facility. 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: 95WE195. 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 II—Conditions 2.3.3,3.7.3,3.9,4.5.3; Section IV-Conditions 3.g(last paragraph), 14& 18 (as noted) . Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 2 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. 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. No separate operating scenarios have been specified. 3. Nonattainment Area 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 in a nonattainment area). Future modifications at this facility resulting in a significant net emissions increase(see Reg 3,Part D, Sections II.A.26 and 42)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 issuance 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.42 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 Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 3 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: Old. Cturent MRS APEII Polluuo4 5t AIRS Point c` Number point,y ; Igumber 1 °a D Ni�m1lrrl _ e Rff '- FUELBURNINGEQUIPMEN1 Cleaver Brooks,Model CB 700-300, 001 86WE191-1 S/N L83229,Natural Gas Fired Steam Boiler,rated at 12.553 MMBtu/hr. Boiler No. 1 Cleaver Brooks,Model CB 700-300, 002 86WE191-2 S/N L83228 Natural Gas Fired Steam 100 Boiler,rated at 12.553 MMBtu/hr. None 95WE195 Boiler No.2 Three(3)NaturalGas Fired,Makeup 026 Air Heaters with heat ratings of: 027 92WE1354 #1 10.3 MMBtu/hour 029 #2 10.3 MMBtu/hour #6 13.1 MMBtu/hour CAN FoRmeia SOURCES • Line No. 1 Standun Bodymakers,Model B318, Munters Unit S/Ns 72501-72506,one 004 86WE191-4 Standuo/Stolle Bodymaker,Model Oil Mist B518 and an Oil Mist Lubrication Elimination System for Beverage Can Body System Presses Line No.2 101 Standun Bodymakers,Model B318, Munters Unit 95WE195 022 92WE399-I S/Ns 725120,725110,725100' Oil Mist 725090,725080,72507,and Oil Mist Elimination Lubrication System for Beverage Can System Body Presses Two(2)- 023 92WE399-2 Can Elevators for Lines No. 1 and 2. Wet Can Inverter Mist Filters CAN COATING SOURCES 005 86WE191-5 Storage tank for bulk storage of basecoat 102 None 95WE195 006 86WE191-6 Storage tank for bulk storage of inside spray coating Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 4 Current Old Pollution AIRS Point AIRS APEN Description Control Construction Point Number Permit Number Device Number* 007 86 WE 191-7 Storage tank for bulk storage of overvamish coating Basecoat Surface Coating System: Basecoater rated at 10.5 gallons per hour. 012 86W E191-12 Natural Gas Fired drying/curing oven, rated at 1.450 MMBtu/hour. Oven emissions exhausted through two stacks. Line No. 1 Decorator System: Decorator printer rated at 1.0 gallons of ink per hour. Overvamish coater rated at 10.1 014 86WE191-I4 gallons per hour. 102 Natural gas fired drying/curing oven rated at 1.450 MMBtu/hour. Oven emissions exhausted through two stacks. Line No. 2 Decorator System: Decorator printer rated at 0.8 gallons of ink per hour. Overvarnish coater rated at 8.4 015 86WE191-15 gallons per hour. Natural gas fired drying/curing oven rated at 1.450 MMBtu/hour. Oven emissions exhausted through two stacks. Line 2A Decorator System: Ragsdale 8-color decorator/printer, rated at 0.8 gallons/hour ink throughput. Ragsdale overvamish unit rated at 8.4 gallons/hour. 013 86WE191-13 None Belvac varnish unit rated at 0.8 102 gallon/hour. 95 WE I95 Natural gas fired drying/curing oven rated at 1.450 MMBtu/hour. Oven emissions exhausted through two stacks. 016 86WE191-16 Line No. I Inside Spray&Bottom Overspray Varnish Surface Coating System: exhausted Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 5 Cuctent Old 4i AIRS Paint A�q AYr.47 Number Cmmtr ton Point Number Dtphm (`gmml Perm N®berg Delete. m. Seven(7)inside spray machines, through together rated at 20.2 gallons/hour. MikroPulsaire Bottom varnish rated at 1.0 baghouse gallon/hour. Natural gas fired drying/curing oven rated at 3.080 MMBtu/hour. Oven emissions exhausted through two stacks. Line No.2 Inside Spray&Bottom Varnish Surface Coating System: Six(6)inside spray machines, together rated at 16.4 gallons/hour. Overspray Bottom varnish rated at 0.8 exhausted 017 86WE191-17 gallon/hour. dough MikroPulsaire Natural gas fired drying/curing oven baghouse rated at 3.080 MMBtu/hour. Oven emissions exhausted through two stacks. 018 86WE191-18 Clean-up operations with various None solvents Respraying of defectively coated 102 cans: 020 86WE054 Baghouse Reynolds Model DG250 inside spray machine rated at 1.5 gallons/hour 021 90WE455-1 Five(5)Parts Cleaners None Process Emissions from the following each have their own stack Line No. 1 Basecoat Surface Coating 012 System. • 013 Line No. 1,2,and 2A Decorator 014 Systems. 015 102 016 Line No. 1 and 2 Inside Spray and 017 Bottom Varnish Surface Coating System. 020 Reynolds Inside Spray Machine 018 Clean-up Operations 030 96WE060 Aluminum Scrap Handling System Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 6 Old :::Pollution AIRS APEN Construction... AIRS Point Description Control Point Number Permit . ...:::..: .. . .... :::.::::.... . .Number. ,:.;:.: .Number* . .. :.. Device Caterpillar 3406TA 440 HP diesel 019 019 87WE328 fired internal combustion engine driving fire pump. *The AIRS point numbers have been changed to allow the source to group certain equipment together under one AIRS point. The old AIRS point numbers are listed here for reference. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 7 SECTION II- Specific Permit Terms 1. Fuel Burning Equipment: B001 and B002: Cleaver Brooks Boilers(2-12.553 MMBtu/hr) B003: Make-Up Air Heaters(2-10.3 MIVIBtu/hr, 1-13.1 MMBtu/hr) E v ° limitations Compliance Factor rir,CREMENrarttlifiiiitSir5 ,:t Facility-wide 45.0 tons per year 98 lb/MMscf NO. Facility-wide CO 38.0 tons per year 82 lb/MMscf Facility-wide 245 tons per year 5.4 lb/MMscf VOC Facility-wide 8.4 tons per year 7.5 lb/MMscf PMio Facility-wide PM 8.4 tons per year 7.5 lb/MMscf Record Benzene:0.0021 lb/MMscf keeping& 1.1 Calculation Monthly Dichlorobenzene:0.0012 12 month lb/MMscf rolling total Formaldehyde:0.075 9.9 tons per year lb/MMscf Facility-wide for any single HAP Hexane: 1.8 lb/MMscf HAP 20 tons per year Naphthalene:0.00061 for total HAPs lb/MMscf Toluene:0.0034 lb/MMscf And other factors listed in AP-42 Table 1.4-3&1.4-4 PM Standard 1.2 0.5(FI)-ote Fuel Restriction lb/MMBtu Natural Gas 1.3 912 MMscf/yr Record Monthly Consumption keeping Not to Exceed 20%,Except as Provided for in 1.4.2 For Startup-Not Opacity 1.4 to Exceed 30%,for Fuel Restriction a Period or Periods Aggregating More than Six(6) • Minutes in any 60 Consecutive Minutes SO2 1.5 2 tons/day See Condition 1.5 Operating Permit 96OPWE162 First Issued: September I, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OP WE 162 Page 8 1.1 Facility-Wide emissions of NOx,CO,VOC, PM, PM10,and HAP shall not exceed the limitations stated in the table above (Colorado Construction Permit 95WE195). Monthly emissions from all combustion units at this facility shall be calculated,by the end of the subsequent month,using the emission factors above(EPA Compilation of Air Pollution Emission Factors (AP-42),Tables 1.4-1 and 2, March 1998, adjusted for heating value of 1000 Btu/scf) and the facility-wide natural gas consumption(required by Condition 1.3)in the following equation: ton/mo=[Compliance Emission Factor(lb/MMscf)x monthly natural gas consumption(MMscf/mo)l 2000 lb/ton Monthly emissions from all combustion sources shall be summed with the monthly emissions from other emission units and a twelve month rolling total of facility-wide emissions will be maintained to verify compliance with the annual emission limitations. Each month, a new twelve month total 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. 1.2 Particulate Matter emissions from each unit shall not exceed the standard as stated in the above table. Allowable emissions of PM in lb/MMBtu were calculated using the following equation (Colorado Regulation No. 1, Section III.A.1.b): Allowable PE(lb/MMBtu)=0.5(Fuel Input in MMBtu/hr)-°26 In the absence of credible evidence to the contrary, compliance with the particulate matter emission limit is presumed since natural gas is the only fuel permitted for use in these units. 1.3 Natural gas consumption by all combustion sources in the facility is limited to 912 MMscf/yr. Natural gas consumption shall be recorded monthly. A twelve month rolling total of natural gas use shall be maintained to determine compliance with the annual limitation. 1.4 Opacity of emissions from fuel burning equipment shall not exceed the following: 1.4.1 Except as provided for in Condition 1.4.2 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 IIA.I)_ 1.4.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from start-up which is in excess of 30%opacity for a period or periods aggregating more than six (6)minutes in any sixty(60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). In the absence of credible evidence to the contrary, compliance with the above opacity standards shall be presumed since natural gas is the only fuel permitted for use in these units. 1.5 Sulfur Dioxide(SO2) emissions shall not exceed two (2)tons per day(Colorado Regulation No. 1, Section VI.B.5.a). In the absence of credible evidence to the contrary, compliance with the Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 9 sulfur dioxide emission limit is presumed since natural gas is the only fuel permitted for use in these units. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 10 2. Can Forming Operations: Permit Monitoring Parameter '.Condition s Limitations Compliance Number Emission Factor Method.. Interval. Record keeping Facility-wide PM 8.4 tons per year 0.20 pound per hour per &Calculation Monthly 12 month Facility-wide PM10 2.1 8.4 tons per year production line rolling total Hours of Operation Record keeping Monthly Control Equipment Good Maintenance and Maintenance& As Operation 2'2 Operating Procedures Record keeping Needed Not to Exceed 20%, Except as Provided for in 2.3.2 For Certain Operational Activities-Not to Exceed 30%,for a Period or Opacity 2.3 Periods Aggregating See Condition 2.3 More than Six(6) Minutes in any 60 Consecutive Minutes State Only Requirement: Not to Exceed 20% PM Emissions from Manufacturing 2.4 See Condition 2.4 See Condition 2.4 Processes 2.1 Facility-wide emissions of PM and PM10 shall not exceed the limitations stated in the table above (Colorado Construction Permit 95WE195). The hours of operation for these units shall be monitored monthly and recorded in a log that is available to the Division upon request. Monthly emissions from can forming operations shall be calculated,by the end of the subsequent month, using the emission factor above and the recorded hours of operation. Monthly emissions from these units shall be summed with the monthly emissions from other emission units and a twelve month rolling total of facility-wide emissions will be maintained to verify compliance with the annual emission limitations. Each month, a new twelve month total 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. 2.2 Routine maintenance and operation of the mist eliminators with filters and wet can inverter mist filters shall be performed in accordance with manufacturer's recommendations and good engineering practices. Specifically: 2.2.1 The mist eliminators with filters and wet can inverter mist filters shall operate when the oil mist lubrication systems and wet can elevators are in operation. Operating Permit 96OPWE I62 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 11 2.2.2 Process equipment and associated piping/duct work shall be maintained and operated so that there is no leakage of air contaminants to the atmosphere prior to treatment by the control equipment. 2.2.3 Records of control equipment and associated duct maintenance shall be kept. 2.3 Opacity of emissions from can forming operations shall not exceed the following: 2.3.1 Except as provided for in Condition 2.3.2 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). 2.3.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from start-up, 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(6)minutes in any sixty(60)consecutive minutes (Colorado Regulation No. 1, Section II.A.4). 2.3.3 State-Only Requirement: No owner or operator may discharge,or cause the discharge into the atmosphere of any particulate matter which is greater than 20%opacity (Colorado Regulation No. 6,Part B, Section III.C.3). This opacity standard applies at all times except during periods of startup, shutdown and malfunction(40 CFR Part 60 Subpart A§ 60.11(c),as adopted by reference in Colorado Regulation No. 6,Part B, Section I.A). Note that this opacity requirement is more stringent than the opacity requirement in Condition 2.3.2 during periods of process modifications and adjustment or occasional cleaning of control equipment. Compliance with these opacity limitations shall be monitored as follows: 2.3.4 A qualitative visual emissions observation shall be conducted monthly during operation for each emission point,for at least six minutes. Records of the results of the qualitative visual emissions observations shall be kept in a log and made available to the Division upon request. 2.3.5 When visible emissions persist for more than six(6)minutes,an EPA Reference Method 9 observation 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. 2.3.6 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 Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit# 96OPWE162 Page 12 9 reader's certificate shall be kept on site and made available to the Division upon request. 2.4 No owner or operator of a manufacturing process unit shall cause or permit emission of any particulate matter into the atmosphere during any consecutive sixty(60) minute period which is in excess of the following: For process equipment having process weight rates of 30 tons per hour or less,the allowable emission rate shall be determined by use of the equation: PE=3.59(P)o.62 Where: PE= Particulate Emission in lbs. per hour; P= Process weight rate in tons per hour (Colorado Regulation No. 1, Section III.C.I.a) In the absence of credible evidence to the contrary, compliance with this emission limit shall be presumed whenever the mist eliminators with filters and wet can inverter mist filters are operated in accordance with manufacturer's recommendations and good engineering practices as set forth in Condition 2.2. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 13 3. Can Coating Operations Permit dint I NItai .t 3� xr� garw N y Facility-wide VOC 245 tons per year Mass Balance Record keeping Monthly &Calculation 3.1 9.9 tons per year for Facility-wide HAP any single HAP Mass Balance Record keeping Monthly 20 tons per year for &Calculation total HAPs Facility-wide PM 8.4 tons per year Record keeping 3.2 As Defined in &Calculation; Monthly As Facility-wide PM10 8.4 tons per year Condition 3.2 Baghouse Defined Maintenance Material Usage 3.3 Record keeping Weekly NSPS Subpart WW 3.4 See Condition 3.4 NSPS Subpart As DefinedWW NSPS Subpart A, 3 5 NSPS General As Defined General Provisions Provisions Can production 3.6 Record keeping Daily Not to Exceed 20%, Except as Provided -for in 3.7.2 For Certain Operational Activities -Not to Exceed 30%, Opacity 3.7 for a Period or See Condition 3.7 Periods Aggregating More than Six(6) Minutes in any 60 -a.1):.' Consecutive Minutes State Only ' Requirement: Not to P' ,. Exceed 20% Odor 3.8 ,--,F,--4,,,!:-,7-..,, Record keeping I Annual Colorado 3.9 _ See Condition 3.9 Regulation No.7 PM Emissions from ""' ' ' . Manufacturing 3.10 See Condition 3.10 See Condition 3.10 Processes 3.1 Facility-wide emissions of VOC and HAPs shall not exceed the limitations stated in the table above(Colorado Construction Permit 95WE195 as modified under the provisions of Section I, Condition 1.3). The source shall record coating,ink,and cleanup material usage on a weekly basis. The weekly material usage and the percentage of VOC&HAP in each material(coatings, inks,and solvents)shall be used to calculate emissions based on mass balance calculations. Operating Permit 96OPWE162 - First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 14 VOC& HAP emissions shall be summed to determine monthly emissions. Monthly emissions from this emission unit shall be summed with the monthly emissions from other emission units and a twelve month rolling total of facility-wide emissions will be maintained to verify compliance with the annual emission limitations. Each month,a new twelve month total 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. 3.2 Facility-wide emissions of PM and PMio shall not exceed the limitations stated above(Colorado Construction Permit 95 WE 195). PM and PMio emissions from the inside spray operations shall be calculated with the equation below based on material consumption. PM(consisting 100%PM1o)=V x P x (1-transfer)x p x(I-�baghouse) Where: V= Volume of inside spray material used P= Volume of solids per volume of inside spray material rltransfer= Transfer Efficiency(80%- from AP-42 for airless spray on flat surfaces p= Density of solids (from MSDS data sheet) rlbaghouse= Baghouse control efficiency Monthly emissions from these units shall be summed with the monthly emissions from other emission units and a twelve month rolling total of facility-wide emissions will be maintained to verify compliance with the annual emission limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. 3.2.1 Routine maintenance and operation of the baghouse shall be performed in accordance with manufacturer's recommendations and good engineering practices. These maintenance and operation procedures shall be in written format and include a log detailing the activities conducted. The log shall be made available to the Division upon request. 3.2.2 The baghouse shall be internally inspected for bag integrity and overall mechanical efficiency semi-annually. The bags shall be internally inspected when a significant change in pressure occurs. Necessary repairs shall be made prior to bringing the equipment back on line. An adequate inventory of replacement bags and parts shall be maintained on site. 3.2.3 A baghouse control efficiency of 99% shall be applied to the emissions calculation above if Conditions 3.2.1 and 3.2.2 of this permit are met. 3.3 Consumption of each material used in this operation shall be monitored weekly and recorded in a log that is available to the Division upon request. Recorded data shall be used to calculate emissions according to Condition 3.1 and for determination of the need to file a revised APEN. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 15 3.4 This source is subject to the requirements of 40 CFR Part 60 Subpart WW, "Standards of Performance for the Beverage Can Surface Coating Industry",as adopted by reference in Colorado Regulation No. 6,Part A, including,but not limited to,the following: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart WW published in the Federal Register on 10/17/2000. However, if revisions to this Subpart are published at a later date,the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60, Subpart WW.] 3.4.1 No owner or operator subject to the provisions of this subpart shall discharge or cause the discharge of VOC emissions to the atmosphere that exceed the following volume- weighted calendar-month average emissions(§60.492): 3.4.1.1 0.29 kg of VOC per liter(2.42 pounds per gallon) of coating solids from each two-piece can exterior base coating operation, except clear base coat (§60.492(a)); 3.4.1.2 0.46 kg of VOC per liter(3.83 pounds per gallon)of coating solids from each two-piece can clear base coating operation and from each overvarnish coating operation(§60.492(b));and 3.4.1.3 0.89 kg of VOC per liter (7.42 pounds per gallon) of coating solids from each two-piece can inside spray coating operation. (§60.492(c)) 3.4.2 The owner or operator of an affected facility shall conduct a performance test each calendar month for each affected facility.(§60.493(b)) 3.4.2.1 The owner or operator shall use the following procedures for each affected facility that does not use a capture system and a control device to comply with the emission limit specified under Condition 3.4.1. The owner or operator shall determine the VOC-content of the coatings from formulation data supplied by the manufacturer of the coating or by an analysis of each coating, as received,using Method 24.The Division may require the owner or operator who uses formulation data supplied by the manufacturer of the coating to determine the VOC content of coatings using Method 24 or an equivalent or alternative method. The owner or operator shall determine from company records the volume of coating and the mass of VOC-solvent added to coatings. If a common coating distribution system serves more than one affected facility or serves both affected and exiting facilities, the owner or operator shall estimate the volume of coating used at each facility by using the average dry weight of coating, number of cans, and size of cans being processed by each affected and existing facility or by other procedures acceptable to the Division.(§60.493(b)(1)) a. Calculate the volume-weighted average of the total mass of VOC per volume of coating solids used during the calendar month for each affected facility, except as provided under Condition 3.4.2.1(d). The volume- Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OP WE 162 Page 16 weighted average of the total mass of VOC per volume of coating solids used each calendar month will be determined by the procedures in §60.493(b)(1)(i)(A)through(C). (§60.493(b)(1)(i)) b. For affected facilities that do not use a capture and control system to comply with applicable emission limits, the mass of VOC per volume of coating solids used is equal to the mass of VOC per volume of coating solids emitted to the atmosphere. (§60.493(b)(1)(ii)) c. Where the value of the volume-weighted average mass of VOC per volume of solids discharged to the atmosphere is equal to or less than the applicable emission limit specified under Condition 3.4.1, the affected facility is in compliance. (§60.493(b)(1)(iii)) d. If each individual coating used by an affected facility has a VOC content equal to or less than the limit specified under Condition 3.4.1, the affected facility is in compliance provided no VOC-solvents are added to the coating during distribution or application. (§60.493(b)(1)(iv)) 3.4.3 Section 60.8(d)does not apply to monthly performance tests and § 60.8(f)does not apply to the performance test procedures required by this subpart. (§60.493(a)) 3.4.4 The owner or operator of an affected facility shall comply with the reporting and record keeping requirements as stated in 40 CFR§60.495. Reporting under this section is to be fulfilled concurrently with Appendix B compliance monitoring reporting and shall be submitted to the Division. 3.4.5 The reference methods in appendix A to this part, except as provided in §60.8, shall be used to conduct performance tests. (§60.496(a)) 3.4.5.1 Method 24, an equivalent or alternative method approved by the Division, or manufacturers' formulation data from which the VOC content of the coatings used for each affected facility can be calculated. In the event of a dispute, Method 24 data shall govern. When VOC content of water-borne coatings, determined from data generated by Method 24, is used to determine compliance of affected facilities,the results of the Method 24 analysis shall be adjusted as described in Section 12.6 of Method 24. (§60.496(a)(1)) 3.4.5.2 For Method 24, the coating sample must be a 1-litre sample collected in a 1- litre container at a point where the sample will be representative of the coating material. (§60.496(b)) 3.5 This unit is subject to the requirements of 40 CFR 60 Subpart A,"General Provisions", as adopted by reference in Colorado Regulation No. 6,Part A, including,but not limited to, the following: 3.5.1 No owner or operator subject to the provisions of this part shall build, erect, install, or use any article,machine,equipment or process,the use of which conceals an emission which Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 17 would otherwise constitute a violation of an applicable standard. Such concealment includes,but is not limited to,the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (40 CFR§60.12) 3.5.2 Records of startups, shutdowns,and malfunctions shall be maintained,as required under 40 CFR§60.7 3.5.3 Performance tests shall be conducted as required under 40 CFR §60.8,and as per§60.493 (b)(1). 3.5.4 At all times,including periods of startup, shutdown,and malfunction,owners and operators shall,to the extent practicable,maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating 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,opacity observations,review of operating and maintenance procedures,and inspection of the source. (40 CFR§60.11 (d)) 3.6 Can production rate of this unit shall be monitored daily and recorded in a log that is available to the Division upon request. Recorded data shall be used to calculate emissions for determination of the need for a revised APEN. 3.7 Opacity of emissions from the inside spray operations shall not exceed the following: 3.7.1 Except as provided for in Condition 3.7.2 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). 3.7.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from start-up,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(6)minutes in any sixty(60)consecutive minutes (Colorado Regulation No. 1, Section II.A.4). 3.7.3 State-Only Requirement: No owner or operator may discharge,or cause the discharge into the atmosphere of any particulate matter which is greater than 20%opacity (Colorado Regulation No. 6,Part B, Section IlI.C.3). This opacity standard applies at all times except during periods of startup, shutdown and malfunction(40 CFR Part 60 Subpart A § 60.11(c),as adopted by reference in Colorado Regulation No. 6,Part B, Section I.A). Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 18 Note that this opacity requirement is more stringent than the opacity requirement in Condition 3.7.2 during periods of process modifications and adjustment or occasional cleaning of control equipment. Compliance with the above opacity limitations shall be monitored as follows: 3.7.4 A qualitative visual emissions observation shall be conducted monthly during operation for each emission point, for at least six minutes. Records of the results of the qualitative visual emissions observations shall be kept in a log and made available to the Division upon request. 3.7.5 When visible emissions persist for more than six(6)minutes, an EPA Reference Method 9 observation 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. 3.7.6 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. 3.8 This unit is subject to Colorado Regulation No. 2 Odor requirements (Colorado Construction Permit 95WE195). All Odor complaints shall be recorded and made available to the Division upon request. The source shall employ such measures and operating procedures as are necessary to minimize odor emissions. 3.9 [State-Only Enforceable] These sources are subject to the requirements of Colorado Regulation No. 7, including,but not limited to,the following: Can Coating Operations 3.9.1 Emissions of VOC from can coating operations shall not exceed those in the following table (Colorado Regulation No.7, Section TX.C.3): Can Coating Kg/Ic Lb/gc Sheet base coat (exterior and interior) and overvarnish two- 0.34 2.8 piece can exterior (base coat and overvarnish) Two-piece can interior body spray, 0.51 4.2 two-piece can Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 19 exterior end(spray or roll coat) Where: Kg/Ic= kilograms of solvent VOC per liter of coating(minus water and "exempt" solvents,as defined in Section II.B.) Lb/gc= (avoirdupois)pounds of solvent VOC per gallon of coating(minus water and"exempt" solvents,as defined in Section II.B.) 3.9.2 For each process specified in Condition 3.9.1,the emission limits designated for that process shall be achieved by use of coatings with proportions of VOC less than or equal to the maximums specified. (Colorado Regulation No. 7 Section IX.A.5.a) 3.9.3 Compliance with Condition 3.9.1 shall be determined on a daily basis. (Colorado Regulation No. 7 Section IX.A.10.a) 3.9.4 Compliance calculation procedures shall follow the guidance in"Procedure for Certifying Quantity of Volatile Organic Compounds Emitted by Paint,Ink,and Other Coatings," EPA-450/3-84/019. (Colorado Regulation No. 7 Section IX.A.10.b) 3.9.5 The owner or operator of any VOC source required to comply with Condition 3.9.1 shall, at their own expense,demonstrate compliance using EPA reference method 24 of 40 CFR Part 60 for surface coatings,or using the manufacturer's certification of the composition of the coatings according to Condition 3.9.8. (Colorado Regulation No. 7 Section IX.A.3.a) 3.9.6 The test protocol should be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty(30)days prior to testing.No test shall be conducted without prior approval from the Division. (Colorado Regulation No. 7 Section DX.A.3.b) 3.9.7 The Division may use independent tests to verify test data submitted by the source operator or owner. The test methods shall be those listed in Condition 3.9.5 above and the Division test results shall take precedence. (Colorado Regulation No. 7 Section IX.A.3.c) 3.9.8 The Division may accept, instead of the testing required in Condition 3.9.5,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 Condition 3.9.5. 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 above. (Colorado Regulation No. 7 Section IX.A.3.d) 3.9.9 When determining compliance with the emission limits of Condition 3.9.1 using the testing procedures of Condition 3.9.5, samples shall be taken from the coating as freshly Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit# 96OPWE162 Page 20 delivered to the reservoir of the coating applicator. (Colorado Regulation No. 7 Section IX.A.4) 3.9.10 Recordkeeping procedures shall follow the guidance in "Recordkeeping Guidance Document for Surface Coating Operations and the Graphic Arts Industry,"July 1989, EPA 340/1-88-003. (Colorado Regulation No. 7 Section IX.A.8.c) 3.9.11 No owner or operator of a source of VOCs subject to Colorado Regulation No. 7, Section IX shall operate, cause,allow or permit the operation of the source,unless the owner or operator does not cause, allow or permit the discharge into the atmosphere of any VOCs in excess of the specified emission limit, calculated as delivered to the coating applicator or as applied to the substrate, whichever is greater. (Colorado Regulation No. 7 Section IX.A.9) Storage and Transfer of Volatile Organic Compounds 3.9.12 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. (Colorado Regulation No. 7 Section III.A) 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 and monitoring shall be conducted as in Section VIII.C.3. (Colorado Regulation No. 7 Section LILA) 3.9.13 Except as otherwise provided in this regulation, all volatile organic compounds 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. (Colorado Regulation No. 7 Section III.B) Fugitive Emission Control 3.9.14 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): 3.9.14.1 Tight-fitting covers for open tanks (Colorado Regulation No. 7 Section IX.A.7.a.(0); 3.9.14.2 Covered containers for solvent wiping cloths (Colorado Regulation No. 7 Section IX.A.7.a.(ii)); 3.9.14.3 Proper disposal of dirty cleanup solvent. (Colorado Regulation No. 7 Section Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 21 IX.A.7.a.(iii)) 3.9.15 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) Use of Solvents for Degreasing and Cleaning 3.9.16 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) The source shall maintain records of all disposals and transfers of waste or used solvent in a log to be made available to the Division upon request. 3.9.17 Waste or used solvent shall be stored in closed containers unless otherwise required by law. (Colorado Regulation No.7 Section X.A.4) 3.9.18 All cold-cleaners shall have a properly fitting cover. (Colorado Regulation No.7 Section X.B.1.a.(i)) 3.9.19 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)) 3.9.20 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) 3.9.21 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) 3.9.22 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) 3.9.23 Cleaned parts shall be drained for at least 15 seconds and/or until dripping ceases. Any pools of solvent shall be tipped out on the clean part back into the tank.(Colorado Regulation No. 7 Section X.B.2.b) 3.10 No owner or operator of a manufacturing process unit shall cause or permit emission of any particulate matter into the atmosphere during any consecutive sixty(60)minute period which is in excess of the following: Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 22 For process equipment having process weight rates of 30 tons per hour or less,the allowable emission rate shall be determined by use of the equation: PE=3.59(13)0.62 Where: PE= Particulate Emission in lbs.per hour; P= Process weight rate in tons per hour (Colorado Regulation No. 1, Section III.C.1.a) In the absence of credible evidence to the contrary, compliance with this emission limit shall be presumed whenever the baghouses controlling emissions from the inside spray operations are operated in accordance with manufacturer's recommendations and good engineering practices as set forth in Condition 3.2. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 23 4. Aluminum Scrap Parameter Condition Limitations . tl Numb Interval rrc Facility-wide PM 8.4 tons per year 0.45 pound per 4.1 ton of Record keeping& Monthly Facility-wide PM10 8.4 tons per year aluminum scrap Calculation 12 month rolling Aluminum Scrap 4.2 5,500 tons per year total Monthly Throughput Equipment 4.3 Good Maintenance Maintenance& Operation 4.4 and Operating Record keeping As Needed Procedures Not to Exceed 20%, Except as Provided for in 4.5.2 For Certain Operational Activities -Not to Exceed 30%, 4.5 for a Period or Material Opacity Periods Aggregating Restriction None More than Six(6) Minutes in any 60 Consecutive Minutes State Only Requirement: Not to Exceed 20% PM Emissions from 4.6 See Condition 4.6 See Condition 4.6 Manufacturing Processes 4.1 Facility-wide emissions of PM and PMnc shall not exceed the limitations stated above(Colorado Construction Permit 95WE195). Monthly emissions from aluminum scrap operations shall be calculated,by the end of the subsequent month,using the above emission factor and the scrap aluminum throughput(required by Condition 4.2). Monthly emissions from this emission unit shall be summed with the monthly emissions from other emission units and a twelve month rolling total of facility-wide emissions will be maintained to verify compliance with the annual emission limitations. Each month, a new twelve month total 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. 4.2 Scrap aluminum throughput is limited to 5,500 TPY. (Colorado Construction Permit 95 WE 195 as modified under the provisions of Section I, Condition 1.3) Scrap aluminum throughput shall, be monitored monthly and recorded in a log that is available to the Division upon request. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 24 Recorded data shall be used to calculate emissions according to Condition 4.1 and for determination of the need to file a revised APEN. 4.3 Routine maintenance and operation of the cyclone shall be performed in accordance with manufacturer's recommendations and good engineering practices to minimize emissions and ensure compliance with particulate and opacity standards. (Colorado Construction Permit 95WE195) Specifically: 4.3.1 The cyclone and the exhaust fans for the cyclone shall be operated when the aluminum scrap systems are in operation. 4.3.2 Process equipment and associated piping/duct work shall be maintained and operated so that there is no leakage of air contaminants to the atmosphere. 4.3.3 Records of equipment and associated duct maintenance shall be kept. 4.4 At all times,including periods of start-up, shutdown,and malfunction,the facility and equipment shall, to the extent practicable,be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division,which may include,but is not limited to, monitoring results,opacity observations,review of operating and maintenance procedures, and inspection of the source. (Colorado Construction Permit 95WE195) 4.5 Opacity of emissions from the aluminum scrap operations shall not exceed the following: 4.5.1 Except as provided for in Condition 4.5.2 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). 4.5.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from start-up, 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(6)minutes in any sixty(60)consecutive minutes (Colorado Regulation No. 1, Section II.A.4). 4.5.3 State-Only Requirement: No owner or operator may discharge,or cause the discharge into the atmosphere of any particulate matter which is greater than 20%opacity (Colorado Regulation No. 6, Part B, Section III.C.3). This opacity standard applies at all times except during periods of startup, shutdown and malfunction(40 CFR Part 60 Subpart A § 60.11(c),as adopted by reference in Colorado Regulation No. 6,Part B, Section I.A). Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 25 Note that this opacity requirement is more stringent than the opacity requirement in Condition 4.5.2 during periods of process modifications and adjustment or occasional cleaning of control equipment. In the absence of any credible evidence to the contrary,compliance with the above opacity limits may be presumed based on the type of material processed,the method of operation,and compliance with Condition 4.3 above. 4.6 No owner or operator of a manufacturing process unit shall cause or permit emission of any particulate matter into the atmosphere during any consecutive sixty(60)minute period which is in excess of the following: For process equipment having process weight rates of 30 tons per hour or less,the allowable emission rate shall be determined by use of the equation: PE=3.59(p)o.62 Where: PE= Particulate Emission in lbs.per hour; P= Process weight rate in tons per hour (Colorado Regulation No. 1, Section I H.C.I.a) In the absence of credible evidence to the contrary, compliance with this emission limit shall be presumed whenever the cyclone is operated in accordance with manufacturer's recommendations and good engineering practices as set forth in Condition 4.3. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 26 5. Insignificant Activities Permit " , Monitoring Parameter Condition Limitations Compliance Number Emission Factor Method Interval VOC 5.1 Record keeping& Annual Calculation HAP 5.2 Record keeping& Annual Calculation 5.1 The source shall identify all insignificant activities that are sources of VOC emissions and calculate actual VOC emissions from the insignificant activities annually. If total facility-wide VOC emissions exceed 250 TPY,including VOC emissions from insignificant activities,the facility will exceed the emissions limit for minor status for the purposes of Prevention of Significant Deterioration. The emission factors and/or methodology used to estimate actual emissions shall be documented and made available to the Division upon request. 5.2 The source shall track HAP emissions from all insignificant activities on a yearly basis. This information shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount of HAP but does not require an Air Pollutant Emission Notice(APEN). If total facility-wide HAP emissions equal or exceed 10 WY(any single HAP)or 25 TPY (total HAPs), including HAP emissions from insignificant activities, the facility will exceed the emissions limit for synthetic minor status and certain MACT standards may apply. The emission factors and/or methodology used to estimate actual emissions shall be documented and made available to the Division upon request. Operating Permit 96OPWE 162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 27 6. Emergency Fire Pump Engine: One(1) Caterpillar 3406 TA Fire Pump Engine,Rated at 440 HP . Permit ' ttr3Mg .VP Conditi -Emz a trod . .. . .. ... APEN repotting is required Recordkeeping and Annually,if hours NOx 6.1 if annual hours of 0.031 lb/hp-hr of operation operation exceed 146 Calculation exceed 146 Hours of 6.2 Recordkeeping Annually Operation SO2 6.3 0.8 lb/MMBtu Fuel Restriction Only Diesel Fuel is Used as Fuel Not to Exceed 20%,Except as Provided for Below For Startup—Not to Opacity 6.4 Exceed 30%for a Period or ' EPA Method 9 See Condition 6.4 Periods Aggregating More than Six(6)Minutes in any 60 Consecutive Minutes Change Oil and Filter MALT 7772 6.5 Inspect Air Cleaner See Condition 6.5 Requirements Inspect all Hoses and Belts MACT General 6.6 ` See Condition 6.6 Provisions 6.1 APEN Reporting Requirements: The emission factors listed above(from AP-42 Table 3.3-1) have been approved by the Division and shall be used to calculate emissions from the fire pump engine if hours of operation for this engine exceed 146 hours in any calendar year. Annual emissions of Nitrogen Oxide(NOx), for purposes of APEN reporting and payment of annual fees,shall be determined using the above emission factor,the maximum horsepower(440 hp) and the hours of operation(as required by Condition 6.2)in the following equation: Tons lb ton \ Year = Emission Factor u ) x hrs operation x max horsepower x (zoao ib 6.2 Hours of operation for the fire pump engine shall be monitored annually and recorded in a log to be made available to the Division upon request. Recorded data shall be used to calculate emissions as required by Condition 6.1. 6.3 Sulfur Dioxide(SO2)emissions shall not exceed 0.8 lbs/MMBtu(Colorado Regulation No. 1, Section VI.B.4.b.(i)). In the absence of credible evidence to the contrary,compliance with the SO2 emission limitation shall be presumed since only diesel fuel is permitted to be used as fuel in this engine. The owner or operator shall maintain records that verify that only diesel fuel is used as fuel in this engine. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit# 96OPWE162 Page 28 6.4 Opacity of emissions shall not exceed the following: 6.4.1 Except as provided for in Condition 6.4.2 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). 6.4.2 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). Compliance with these limitations shall be monitored by conducting opacity observations in accordance with EPA Reference Method 9 as follows: 6.4.3 As specified in Condition 6.5.7 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 6.4.2. A record shall be kept of the date and time each engine was started and when it was shutdown. 6.4.4 An opacity observation shall be conducted annually(calendar year period)to monitor compliance with the opacity limit in Condition 6.4.1. If an engine is operated more than 250 hours in any calendar year period, a second opacity observation shall be conducted. If two opacity readings are conducted in the annual (calendar year)period, such readings shall be conducted at least thirty days apart. 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. 6.4.5 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. 6.5 [Federal-Only[ This engine is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ, "National Emissions Standards for Hazardous Air Pollutants 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 1/30/2013. 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.] [Note that as of the date of permit issuance [DATE],the requirements in 40 CFR Part 63 Subpart ZZZZ promulgated on March 3, 2010 have not been adopted into Colorado Regulation No. 8, Operating Permit 96OPWE 162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 29 Part E by the Division and are therefore not state-enforceable. In the event that the Division adopts these requirements,they will become both state and federally enforceable.] Compliance Date 6.5.1 If you have 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)) Emission Limitations, Operating Limitations, and Other Requirements 6.5.2 If you own or operate an existing stationary RICE located at an area source of HAP emissions,you must comply with the requirements in Table 2d to this subpart that apply to you. (§63.6603(a)) Note that this engine is not subject to emission or operating limitations but is subject to management practice requirements. The requirements in Table 2d of 40 CFR Part 63 Subpart ZZZZ that apply to this engine are as follows: 6.5.2.1 Change oil and filter every 500 hours of operation or annually, whichever comes first. (Table 2d,Item 4.a) 6.5.2.2 Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first,and replace as necessary. (Table 2d,Item 4.b) 6.5.2.3 Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first,and replace as necessary. (Table 2d, Item 4.c) Notwithstanding the above requirements,the following applies: 6.5.2.4 Sources have the option to utilize an oil analysis program as described in Condition 6.5.8 in order to extend the specified oil change requirement in Condition 6.5.2.1. (Table 2d,Footnote 1) 6.5.2.5 If an emergency engine is operating during an emergency and it is not possible to shut down the engine in order to perform the management practice requirements on the schedule required in Conditions 6.5.2.1 through 6.5.2.3, or if performing the management practice on the required schedule would otherwise pose an unacceptable risk under federal, state, or local law, the management practice can be delayed until the emergency is over or the unacceptable risk under federal, state, or local law has abated. The management 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 management practice on the schedule required and the federal, state or local law under which the risk was deemed unacceptable.(Table 2d,Footnote 2) Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit# 96OPWE162 Page 30 General Compliance Requirements 6.5.3 You must be in compliance with the emission limitations,operating limitations, and other requirements in this subpart that apply to you at all times. (§63.6605(a)) 6.5.4 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)) Monitoring, Installation, Operation and Maintenance Requirements 6.5.5 If you own or operate an existing emergency stationary RICE located at an area source of HAP emissions, 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) and(e)(3)) 6.5.6 If you own or operate 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)) 6.5.7 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. (§63.6625(h)) 6.5.8 If you own or operate a stationary CI engine that is subject to the work, operation or management practices in Condition 6.5.2, you have the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Condition 6.5.2.1. The oil analysis must be performed at the same frequency specified for changing the oil in Condition 6.5.2.1. The analysis program must at a minimum analyze the following three parameters: Total Base Number,viscosity,and percent water content. The condemning limits for these 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 Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 31 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)) Continuous Compliance Requirements 6.5.9 You must demonstrate continuous compliance with each requirement in Condition 6.5.2 that applies to you according to methods specified in Table 6 to this subpart (§63.6640(a)). The methods specified in Table 6 to Subpart ZZZZ are as follows: 6.5.9.1 Operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions (Table 6, Item 9.a.i);or 6.5.9.2 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. (Table 6,Item 9.a.ii) 6.5.10 If you own or operate an emergency stationary RICE,you must operate the emergency stationary RICE according to the requirements in Conditions 6.5.10.1 and 6.5.10.2. In order for the engine to be considered an emergency stationary RICE under this subpart, any operation other than emergency operation,maintenance and testing is prohibited. If you do not operate the engine according to the requirements in Conditions 6.5.10.1 and 6.5.10.2,the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines. (§63.6640(f)) 6.5.10.1 There is no time limit on the use of emergency stationary RICE in emergency situations. (§63.6640(f)(1)) 6.5.10.2 You may operate your emergency stationary RICE for the purpose specified in Condition 6.5.10.2.a for a maximum of 100 hours per calendar year. (§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 Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit it 96OPWE162 Page 32 maintenance and testing of emergency RICE beyond 100 hours per calendar year. (§63.6640(f)(2)(i)) Notifications and Records 6.5.11 The requirement to submit notifications according to §63.6645(a)does not apply if you own or operate an existing stationary emergency RICE, or an existing stationary RICE that is not subject to any numerical emission standards. (§63.6645(a)(5)) 6.5.12 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 if you own or operate an existing stationary emergency RICE. (§63.6655(e) and(e)(2)) 6.5.13 If you own or operate an existing emergency stationary RICE located at an area source of HAP emissions that does not meet the standards applicable to non-emergency engines, 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. (§63.6655(f) and(0(2)) 6.6 This engine is subject to the requirements in 40 CFR part 63 Subpart A"General Provisions",as adopted by reference in Colorado Regulation No. 8,Part E, Section I as specified in 40 CFR Part 63 Subpart ZZZZ § 63.6665. These requirements include, but are not limited to the following: 6.6.1 Prohibited activities in §63.4(a). 6.6.2 Circumvention in §63.4(b). Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 33 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. Ftnr¢efon Unit- . . . l?esapprnm& Applicable B001 and B002 Regulation No.6,Part A-New Source These units were existing sources as of the June Performance Standards,Subpart Dc-Small 9, 1989 applicability date ofNSPS Dc.Industrial-Commercial-Institutional Steam Generating Units 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. Operating Permit 96OPWE 162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OP WE 162 Page 34 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 1 Streamlined(Subsumed)Requirements Fuel Burning Equipment Section II,Condition 1.2 Colorado Regulation No.6,Part B,Section II.C.2[Particulate matter emissions not to exceed 0.5(FI)°26 where Fl=fuel input in MMBtu/hr],State-only Requirement Section II,Condition 1.4 Colorado Regulation No.6,Part B,Section II.C.3 [Emissions of particulate matter shall not exceed 20%opacity],State-only Requirement Can Forming Sources Colorado Regulation No.6,Part B,Section III.C.1 [Particulate matter emissions not to exceed Section Il,Condition 2.4 E=3.59(P)°M1'` where E=allowable emissions in lb/hr and P=process weight rate in tons/hr], State-only Requirement Can Coating Sources Colorado Regulation No.6,Part B,Section III.C.I [Particulate matter emissions not to exceed Section II,Condition 3.10 E=3.59(P)°6' where E=allowable emissions in lb/hr and P=process weight rate in tons/hr], State-only Requirement Aluminum Scrap Colorado Regulation No.6,Part B,Section III.C.1 [Particulate matter emissions not to exceed Section II,Condition 4.6 E=3.59(P)° 2 where E=allowable emissions in lb/hr and P=process weight rate in tons/hr], State-only Requirement • Operating Permit 96OPWE162 First Issued: September I, 1998 Renewed: DATE • Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 35 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,§1.8.1. 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.&&IILB.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 repotting 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 of condition. 3. Common Provisions Common Provisions Regulation,5 CCR 1001-2&&H.A..11.B..II.C..ILE..II.F..II.I,and ILL 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. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 36 b. Emission Monitoring Requirements The Division may require owners or operators of stationary air pollution sources to install,maintain,and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. c. Performance Testing The owner or operator of any air pollution source shall,upon request of the Division,conduct performance test(s) and furnish the Division a written report of the results of such test(s)in order to determine compliance with applicable emission control regulations. Performance test(s)shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves,in specific cases,the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance;or (iv) waives the requirement for performance test(s)because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes,Title 25,Article 7,and pursuant to regulations promulgated by the Commission. Compliance test(s)shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility.The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s).Operations during period of startup,shutdown,and malfunction shall not constitute representative conditions of performance test(s)unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present.The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division 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. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 37 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 plumed for,and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; • (iv) The amount and duration of the excess emissions(including any bypass)were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed,contemporaneous operating logs or other relevant evidence; (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. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 38 e. Circumvention Clause _. A person shall not build,erect,install,or use any article,machine,equipment,condition,or any contrivance,the use of which,without resulting in a reduction in the total release of air pollutants to the atmosphere,reduces or conceals an emission which would otherwise constitute a violation of this regulation.No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. f. Compliance Certifications For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in the Colorado State Implementation Plan,nothing in the Colorado State Implementation Plan shall preclude the use,including the exclusive use,of any credible evidence or information,relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.Evidence that has the effect of making any relevant standard or permit term more stringent shall not be credible for proving a violation of the standard or permit term. When compliance or non-compliance is demonstrated by a test or procedure provided by permit or 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. g. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during periods of startup and shutdown.To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement,the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of the evidence that: (i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and could not have been prevented through careful planning and design; (ii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation or maintenance; (iii) If the excess emissions were caused by a bypass(an intentional diversion of control equipment),then the bypass was unavoidable to prevent loss of life,personal injury,or severe property damage; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed,contemporaneous operating logs or other relevant evidence;and, (viii) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator,and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the Division verbally as soon as possible,but no later than two(2)hours after the start of the next working day,and shall submit written quarterly notification following the initial occurrence of the excess emissions.The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 39 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 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 (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. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 40 g. The permittee shall not knowingly falsify,tamper with,or render inaccurate any monitoring device or method required to be maintained or followed under the terms and conditions of the Operating Permit. 5. Emergency Provisions Regulation No.3,5 CCR 1001-5.Part C.$VII.E An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source,including acts of God,which situation requires immediate corrective action to restore normal operation,and that causes the source to exceed the technology-based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. "Emergency"does not include noncompliance to the extent caused by improperly designed equipment,lack of preventative maintenance,careless or improper operation,or operator error. An emergency constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology-based emission limitation if the permittee demonstrates,through properly signed,contemporaneous operating logs,or other relevant evidence that: a. an emergency occurred and that the permittee can identify the cause(s)of the emergency; b. the permitted facility was at the time being properly operated; c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards,or other requirements in the pennit;and d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency,and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency,any steps taken to mitigate emissions,and corrective actions taken. This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement. 6. Emission Controls for Asbestos Regulation No. 8,5 CCR 1001-10,Part B The perrnittee 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. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 41 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 pemtittee 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,§HI.D.1. 10. Inspection and Entry . Regulation No.3,5 CCR 1001-5.Part C,§V.C.16.b. Upon presentation of credentials and other documents as may be required by law,the permittee shall allow the Air Pollution Control Division,or any authorized representative,to perform the following: a. enter upon the pennittee'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.&Xl. 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 pemrittee 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.I l.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 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 42 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. 20. Portable Sources Regulation No.3,5 CCR 1001-5,Part C,§II.D. Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location. 21. Prompt Deviation Reporting Regulation No.3,5 CCR 1001-5,Part C, §V.C.7.b. The permittee shall promptly report any deviation from permit requirements,including those attributable to malfunction conditions as defined in the permit,the probable cause of such deviations,and any corrective actions or preventive measures taken. "Prompt"is defined as follows: Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 43 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. 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. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 44 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,§ 11.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 ADEN is valid for a period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires. Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by April 30 of the following year. Where a permit revision is required,the revised ADEN 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(6)(10)Changes Regulation No. 3,5 CCR 1001-5,Part C,6 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. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 45 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. 26. Significant Permit Modifications Regulation No.3,5 CCR 1001-5,Part C,S 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.88 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. 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 Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Metal Container Corporation Colorado Operating Permit Metal Container Corporation—Windsor Facility Permit#96OPWE162 Page 46 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 96OPWE162 First Issued: September 1, 1998 Renewed: DATE 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 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 48 APPENDIX A-Inspection Information 1. Directions to Plant: Metal Container Corporation's Windsor Facility is located southeast of Windsor on the north side of County Road 66 in the Windsor Industrial Park, Weld County. 2. Safety Equipment Required: Eye Protection, Hearing Protection, Steel Toed Shoes 3. Facility Plot Plan: The attached Figures (following pages) show the plot plan as submitted in the February 23, 1996 Title V Operating Permit Application. 4. 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: Lime Silo Ink Dot Identification System/Cleanup Oil Separation and holding tanks Hydraulic oil(bodymaker)bulk tank Bodymaker coolant storage tank Copper Lube Tank Washer chemical storage tank Propane cylinders Wastewater treatment tank Diesel storage tank Sulfuric Acid Bulk Tank Building heaters/water heaters Inker Cleaner Line No. 1 Drying/Curing Ovens, 1.45 MMBtu/hr(2),3.08 MMBtu/hr(I) Line No. 2 Drying/Curing Ovens, 1.45 MMBtu/hr(2),3.08 MMBtu/hr(I) Fourteen(14)natural gas heaters,rated less than 5 MMBtu/hr Two(2)can washers with natural gas dryers,rated at 3.17 MMBtu/hr Three(3)natural gas heaters for space heating,6.2 MMBtu/hr(2),7.4 MMBtu/hr(I) Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 49 ....... a u a ......-cc . i nllr c ' nm' :. 6 s - one, 1-- Ni F I y a 'W i l i 1 I _ 6 — I I I l I t _ - - - I _� --I�` , . --- „ M�•.' ET : Lii _� y.2 } I �- 1 1 R ±ig. . r... �- .. ITh._I -' $ t.1 • i I 1, ‘. i ~ �� Z, , _ ._ i e7' i I N ro f 1 ' 1 b1 1 fig y La --f' ■ / , h UI P! 8''.. I zl ' a'18 I N a 'E O g 5r QNI m tl Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 50 au�► l a . i t 13 =i 'III Jaecr s ES Z M i `+oi .I k ' I. • • `1 A_._......_.___ . �}� 1 1 I`-�-str� __. .• .-i( ._._..._ .571!11 Y �_C L�® u. n 5i !II } • •I. �j i It I -p ' r A- ` • • I t, � .;_; I.', 6.'ii ;el . r``.V @ RI .iw f W • /S= ®-....iR — l �L • y v 2r ..a s.e :i. +.n . ... .. f.. • ..o I I c ..rc i r: e I . I ,. S . i u r s r • )8 •E Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 51 APPENDIX B Reporting Requirements and Definitions with cedes ver 8/20/2014 Please note that,pursuant to 113(e)(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 tide 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 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 52 such deviations,and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit are required to be summarized or referenced in the annual compliance certification. For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions. Additional discussion on these conditions is provided later in this Appendix. For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or otherwise specifies a time frame for reporting deviations,that definition or time frame shall govern. For example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1, Section IV. In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes of this operating permit are any of the following: (1) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; (3) A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 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: When the requirement is an emission limit or standard 2=Process: When the requirement is a production/process limit 3 =Monitor: When the requirement is monitoring 4=Test: When the requirement is testing 5=Maintenance: When required maintenance is not performed 6=Record: When the requirement is recordkeeping 7=Report: When the requirement is reporting 8=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring(CAM)Rule) has occurred. 9=Other: 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 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 53 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 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 54 Startup, Shutdown, Malfunctions and Emergencies Understanding the application of Startup, Shutdown,Malfunctions and Emergency Provisions, is very important in both the deviation reports and the annual compliance certifications. Startup, Shutdown,and Malfunctions Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable Control Technology(MACT) standards that occur during Startup, Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or standards often do not apply unless specifically stated in the NSPS. Such exceedances must,however, be reported as excess emissions per the NSPS/MACT rules and would still be noted in the deviation report. In regard to compliance certifications,the permittee should be confident of the information related to those deviations when making compliance determinations since they are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available Control Technology(BACT) sources,but are not applied in the same fashion as for NSPS and MACT sources. Emergency Provisions Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense against enforcement action if they are properly reported. DEFINITIONS Malfunction(NSPS)means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment,process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. Malfunction (SIP)means any sudden and unavoidable failure of air pollution control equipment or process equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily caused by poor maintenance, careless operation, or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions. Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God,which situation requires immediate corrective action to restore normal operation,and that causes the source to exceed a technology-based emission limitation under the permit,due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation,or operator error. Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 55 Monitoring and Permit Deviation Report-Part I 1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations,or malfunction or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EER's or malfunctions)may be referenced and the form need not be filled out in its entirety. FACILITY NAME: Metal Container Corporation—Windsor Facility OPERATING PERMIT NO: 96OPWE162 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Deviations noted Malfunction/Emergenc Operating Permit Unit Unit Desch lion During Period?' Deviation Coder y Condition Reported ID p During Period? YES NO ay' "'-'l�?� ,uj', t YES NO Fuel Combustion Sources Can Fanning Sources Can Coating Sources Aluminum Scrap Fire Pump Engine Insignificant activities General Conditions - G: :' x aY Insignificant Activities ti '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: When the requirement is an emission limit or standard 2=Process: When the requirement is a production/process limit 3=Monitor: When the requirement is monitoring 4=Test: When the requirement is testing 5=Maintenance: When required maintenance is not performed 6=Record: When the requirement is recordkeeping 7=Report: When the requirement is reporting 8=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring(CAM)Rule)has occurred. 9=Other: When the deviation is not covered by any of the above categories Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 56 Monitoring and Permit Deviation Report -Part II FACILITY NAME: Metal Container Corporation—Windsor Facility OPERATING PERMIT NO: 960PWE162 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT)Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration(start/stop date&time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Malfunctions/Emergencies Reported(if applicable) Deviation Code Division Code QA: SEE EXAMPLE ON THE NEXT PAGE Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 57 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04-6/30/06 Is the deviation being claimed as an: Emergency Malfunction XX N/A (For NSPS/MACT)Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control-Unit XXX Operating Permit Condition Number Citation Section II,Condition 3.1 -Opacity Limitation Explanation of Period of Deviation Slurry Line Feed Plugged Duration START- 1730 4/10/06 END- 1800 4/10/06 Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Malfunction/Emergencies Reported(if applicable) 5/30/06 to J. Garcia,APCD Deviation Code Division Code QA: Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 58 Monitoring and Permit Deviation Report -Part III REPORT CERTIFICATION SOURCE NAME: Metal Container Corporation—Windsor Facility FACILITY IDENTIFICATION NUMBER: 123/0134 PERMIT NUMBER: 96OP WE 162 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 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix D Notification Addresses Page 59 APPENDIX C Required Format for Annual Compliance Certification Reports Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: Metal Container Corporation—Windsor Facility_ OPERATING PERMIT NO: 96OP WE 162 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 Deviations Mho g Was compliance continuous or er Permit Unit Unit Description Reported' Permit intermittent? ID Previous Current YES NO Continuous Intermittent Fuel Combustion Sources • Can Forming Sources Can Coating Sources Aluminum Scrap Fire Pump Engine Insignificant activities General Conditions Insignificant Activities 4 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 Operating Permit 96OPWEI62 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix D Notification Addresses Page 60 only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. NOTE: The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore,if a source 1)conducts all of the monitoring and recordkeeping required in its permit,even if such activities are done periodically and not continuously,and if 2)such monitoring and recordkeeping does not indicate non-compliance,and if 3)the Responsible Official is not aware of any credible evidence that indicates non-compliance,then the Responsible Official can certify that the emission point(s)in question were in continuous compliance during the applicable time period. 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 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix D Notification Addresses Page 61 APPENDIX D Notification Addresses 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B 1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Matt Burgett 2. United States Environmental Protection Agency Compliance Notifications: Office of Enforcement,Compliance and Environmental Justice Mail Code 8ENF-AT U.S.Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver,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 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 62 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 Lbs/mmBtu 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 PM10 - Particulate Matter Under 10 Microns Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 63 PSD- Prevention of Significant Deterioration PTE- Potential To Emit RACT- Reasonably Available Control Technology SCC- Source Classification Code SCF- Standard Cubic Feet SIC - Standard Industrial Classification SO2 - Sulfur Dioxide TPY- Tons Per Year TSP - Total Suspended Particulate VOC- Volatile Organic Compounds Operating Permit 96OPWE162 First Issued: September 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix H Permit Modifications Page 64 APPENDIX F Permit Modifications DATE OF TYPE OF SECTION NUMBER, DESCRIPTION OF REVISION REVISION REVISION CONDITION NUMBER • • Operating Permit 96OPWE162 First Issued: September 1, 1998 P g P Renewed: DATE COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT RENEWAL SUMMARY PERMIT NUMBER: 96OPWE162 AIRS ID#: 1230134 DATE: November 11, 2014 APPLICANT: Metal Container Corporation—Windsor Can Plant REVIEW ENGINEER:Joshua Jones SOURCE DESCRIPTION Metal Container Corporation has applied for renewal of their Operating Permit issued for the Windsor Can Plant located at 1201 Metal Container Court, in Weld County. This facility manufactures the bodies of two-piece aluminum beverage cans. The plant has two process lines which have emissions from natural gas fired ovens/boilers, can forming equipment, surface coating operations and miscellaneous combustion sources. The area in which the plant operates is designated as attainment for all pollutants except ozone. It is classified as non-attainment for ozone and is part of the 8-hr Ozone Control Area as define in Regulation No. 7, Section II.A.1. This source is categorized as a major stationary source with respect to the Non-Attainment New Source Review(NANSR) requirements and a minor stationary source with respect to Prevention of Significant Deterioration (PSD)requirements. Wyoming is an affected state within 50 miles of this facility. Rocky Mountain National Park and the Rawah National Wilderness Area are Federal Class I designated areas within 100 km of this facility. 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 using a pollution control device at this facility are subject to the Compliance Assurance Monitoring(CAM)requirements in 40 CFR Part 64 since pre-control emissions do not exceed the major source level. FACILITY EMISSION SUMMARY Pollutant Potential to Emit' Actual Emissions (TPY) (TPY) PM 8.4 3.55 PMia 8.4 3.55 NOx 45 5.25 CO 38 4.38 1/56 245.0 190.2 HAPS 9.9(any single HAP) 5.72(formaldehyde) 20 total 9.2 Total 'Potential to Emit is based on permitted emission limits. 2Actual emissions based on records submitted by the source for the May 2013 inspection for period April 2012—March 2013. EMISSION SOURCES The following discussion identifies the changes that were made in the renewal permit. Temporary Diesel Engine/Air Compressor Unit—The temporary compressor engine has been removed from the operating permit and the facility-wide emission limits have been reduced by the amount associated with this unit. The Division considers this unit a non-road engine as defined in Regulation No. 3, Part A, Section l.B.31.a.(iii). Therefore,this unit is not subject to stationary source permitting requirements. Aluminum Scrap Processing—The site-wide permit limit on aluminum scrap throughput was increased from 5,000 to 5,500 tons per year. No increase in facility-wide emissions of PM/PM10 was requested with this modification and no physical change was involved. Can Coating Operations—The requirements of Regulation No. 7 have been added to the permit. These requirements have become applicable since the latest revisions to the operating permit because the area is now designated as an ozone non-attainment area. Emergency Fire-Pump Engine—The applicable provisions of 40 CFR Part 63,Subpart 777Z for Reciprocating Internal Combustion Engines(RICE)have been added to the operating permit for this unit. ALTERNATIVE OPERATING SCENARIOS No alternative operations scenarios were identified for inclusion in this permit. INSIGNIFICANT ACTIVITIES APEN/permit exempt fuel burning sources were removed from the Summary of Emission Units in Section I,Condition 6 and added to Appendix A for insignificant activities. PERMIT SHIELD No requirements were added to the permit shield as specifically non-applicable to this facility. Streamlining information was added to identify less stringent requirements of Regulation No.6,related to general particulate matter limits,which were left out of the permit. TECHNICAL REVIEW DOCUMENT For DRAFT RENEWAL OF OPERATING PERMIT 96OPWE162 Metal Container Corporation —Windsor Facility Weld County Source ID 123/0134 February 2013 -July 2014 Operating Permit Engineer: Joshua Jones Operating Permit Supervisor review: Matt Burgett Field Services Unit review: Jeffrey Bishop I. Purpose 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 Metal Container Corporation —Windsor Facility (MCC). The previous Operating Permit for this facility was issued on September 1, 1998, was renewed on July 1, 2003, was last revised on September 1, 2006, and expired on July 1, 2008. However, since a timely and complete renewal application was submitted, under Colorado Regulation No. 3, Part C, Section IV.C all of the terms and conditions of the existing permit shall not expire until the renewal operating permit is issued and any previously extended permit shield continues in full force and operation. Subsequent to the submittal of the renewal application, the source submitted an application on April 10, 2009 requesting that the permit be modified to increase the site- wide aluminum scrap throughput from 5,000 tons/yr to 5,500 tons/yr. Though the Division has determined that this request qualifies as a minor modification under the provisions of Colorado Regulation No. 3, Part C, Section X (see Modifications section below), the source did not request that this modification be processed as a minor modification. 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 renewal application submitted on June 29, 2007, the modification application submitted on April 10, 2009, comments on the draft permit submitted on [DATE], previous inspection reports and various email correspondence. 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 123/0134 Page 1 of 15 Metal Container Corporation—Windsor Facility Operating Permit No.960PWE162 Technical Review Document—Renewal Operating Permit combined construction/operating permit for any such revision, and the permittee shall be allowed to operate under the revised conditions upon issuance of this operating permit without applying for a revision to this permit or for an additional or revised construction permit. II. Description of Source Metal Container Corporation manufactures the bodies of 2 piece-aluminum beverage cans. The plant has two process lines (Lines No. 1 and 2)which have emissions from natural gas fired ovens/boilers, can forming equipment, surface coating operations and miscellaneous combustion sources. Each process line consists of front-end and back- end operations. The front-end includes cupping and bodymaking units, which form the cans from aluminum coil, followed by washers which clean the can bodies for decorating. The back-end comprises the surface coating operations. A portion of the cans made are basecoated before being routed to decorators where the exterior of the can is printed with high solid inks and roll-coated with a water-based overvarnish and rim varnish. Cans that are not basecoated are routed directly to the decorators. The inside of the can is then sprayed with a water-based coating. The can coatings are cured following each stage of surface coating (basecoating; printing/varnishing; inside spray) by heating in natural gas- fired ovens. Following the coating operations, the cans are necked, reformed, tested, and palletized prior to warehousing for shipment. The boilers supply low pressure hot water for the washers. The miscellaneous combustion sources supply building heat. The facility is located southeast of Windsor on the north side of County Road 66 in the Windsor Industrial Park, Weld County. The area in which this facility is located is classified as attainment for all pollutants except ozone. It is classified as non-attainment for ozone and is part of the 8-hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. Wyoming is an affected state within 50 miles of the facility. Rocky Mountain National Park and the Rawah Wilderness Area are Federal Class I designated areas within 100 kilometers of the facility. This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC or NOx > 100 Tons/Year in a nonattainment area). Future modifications at this facility resulting in a significant net emissions increase (see Reg. 3, Part D, Sections II.A.26 and 42)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 issuance 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.42 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. Emissions The potential to emit(PTE)for the facility is shown in the table below. The PTE values have been reduced by the amount attributed to the temporary compressor engine, since 123/0134 Page 2 of 15 Metal Container Corporation—Windsor Facility Operating Permit No.96OPWE162 Technical Review Document—Renewal Operating Permit the requirements of this engine have been removed from the operating permit (See Section VI: Other Modifications, below). Pollutant Potential to Emit' Actual Emissions2 (TPY) (TPY) PM 8.4 3.55 PM10 8.4 3.55 NOx 45 5.25 CO 38 4.38 VOC 245.0 190.2 HAPS 9.9 (any single HAP) 5.72 (formaldehyde) 20 total 9.2 Total Potential to Emit is based on permitted emission limits. 2Actual emissions based on records submitted by the source for the May 2013 inspection for period April 2012—March 2013. Hazardous Air Pollutants (HAPs) This facility is a minor source of HAPs. Permit limits for HAPs (any single HAP and total HAPs) were added to the permit in a September 2006 revision to the first renewal. These limits were requested by the source in order to avoid major source MACT requirements; specifically for boilers (MACT DDDDD) and metal cans (MACT KKKK). Actual HAP emissions at this facility are significantly reduced compared to the previous renewal (July 2003) due to the de-listing of Ethylene Glycol Butyl Ether(EGBE) (69 FR 69320; November 29, 2004). Ill. Applicable Requirements Accidental Release 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). 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 Controlled emissions at this facility include particulate matter emissions from the can forming operations (bodymakers and wet can elevators) and inside spray operations. Uncontrolled emissions from all bodymakers and can elevators for the can forming operations are estimated at 11.8 tons/yr using a lubricant aerosol use rate of 44.8 lb/hr (11.2 lb/hr for each bodymaker and elevator) and a lubricant aerosol water content of 94%. Uncontrolled particulate matter emissions from the inside spray operations are 123/0134 Page 3 of 15 Metal Container Corporation—Windsor Facility tY Operating Permit No.960PWE162 Technical Review Document—Renewal Operating Permit estimated at 58.4 tons/yr using a total spray capacity of 38.1 gallons/hr(both lines and re- spray machine), a density 8.45 lb/gallon, a solids content of 20.7 weight percent, and an 80%transfer efficiency. Therefore, this facility has no emission unit with pre-control emissions that exceed the major source level. Greenhouse Gases The potential-to-emit of greenhouse gas (GHG)emissions from this facility is less than 100,000 TPY CO2e. Future modifications greater than 100,000 TPY CO2e may be subject to regulation (Regulation No. 3, Part A, 1.6.44). 40 CFR 60 Subpart Kb—Standards of Performance for Volatile Organic Liquid Storage Vessels The storage vessels at this facility(for bulk storage of basecoat/sizecoat, overvarnish, and inside spray)all have a capacity of 10,000 gallons and are therefore not affected facilities for Subpart Kb according to §60.110b(a) since they do not have a capacity greater than or equal to 75m3 (19,813 gallons). 40 CFR 60 Subpart IIII—Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Subpart 1111 applies to owners and operators of compression ignition engines that commenced construction after July 11, 2005. The fire pump engine at this facility was given an APEN exempt status in 1987 and constructed with the original facility in 1988. Therefore, this engine is not subject to the requirements of Subpart IIII. 40 CFR 63 Subpart 7777-National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines The fire pump engine, previously listed as an insignificant activity in Appendix A, became subject to Subpart 7777 with the promulgation of requirements for existing stationary compression ignition intemal combustion engines at area sources on March 3, 2010. This engine is classified as an existing (commenced construction before June 12, 2006) emergency engine and is therefore subject to management practices, including inspection/replacement of belts and hoses and oil/filter changes. See Section V: Emission Sources for additional information regarding the fire pump engine. 40 CFR 63 Subpart JJJJJJ— National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers at Area Sources This facility is exempt from the requirements of Subpart JJJJJJ per§63.11195(e), since all boilers at this facility are gas-fired boilers as defined in §63.11237. Colorado Regulation No. 1 The boilers and heaters at this facility are subject to the opacity requirements of Sections II.A.1 and 4. The Section II.A.4 (30% opacity) requirement has been included in the operating permit as applicable during start-up (See Section VI: Other Modifications below). These units are also subject to the Section III.A.1.b particulate matter emission- limit for fuel burning equipment and the Section VI.B.5.a requirement for new sources of 123/0134 Page 4 of 15 Metal Container Corporation—Windsor Facility Operating Permit No. 96OPWE162 Technical Review Document—Renewal Operating Permit sulfur dioxide (SO2 emissions shall not exceed 2 ton/day). The SO2 emission limit has been added to the operating permit. The Can Forming, Can Coating, and Aluminum scrap operations are subject to the opacity requirements of Section II.A.1 and 4. The Section II.A.4 (30% opacity) requirement has been included in the operating permit for these sources as applicable during start-up, process modification, and adjustment of control equipment (See Section VI: Other Modifications below). These sources are also subject to the Section III.C.1.a particulate matter(PM) emissions limit for manufacturing processes. The PM emission limit has been included in the operating permit. Colorado Regulation No. 6 The boilers and heaters at this facility are subject to the Part B - Section II.C.2 (PM limit based on heat input) and Section II.C.3 (20% opacity limit for PM emissions) requirements for fuel burning equipment. Both of these requirements have been streamlined for the more stringent requirements of Colorado Regulation No. 1 (See Section VI: Other Modifications below). The Can Forming, Can Coating, and Aluminum scrap operations are subject to the Part B, Section III.C.1 particulate matter emission limit and the Section III.C.3 PM opacity limit for new manufacturing processes. The Section III.C.1 particulate matter emission limit has been streamlined for the more stringent requirement of Colorado Regulation No. 1, Section III.C.1.a (See Section VI: Other Modifications below). The PM opacity limit has been included in the operating permit. Colorado Regulation No. 7 Since the issuance of the latest revision to this operating permit, the area in which the source operates has been classified as non-attainment for ozone (designated on November 20, 2007). It is located in the 8-hour ozone control area as defined in Section II.A.1, and not in the 1-hour ozone attainment/maintenance area, therefore, the Reg. 7 requirements are State-only enforceable requirements as they apply to this facility (Section I.A.1.b). As an existing source emitting greater than 100 tons/yr of VOC, MCC was required to submit a permit modification application including a revised APEN, and a RACT analysis, to the Division, by April 30, 2009 (Section II.C.1.c and II.C.1.c.(ii)). MCC submitted a RACT analysis on August 6, 2008 that evaluated the control of VOC emissions using a thermal oxidizer and determined that it was not economically feasible. MCC is also subject to Section IX of Reg. 7 for surface coating operations. The Section IX.C provisions for can coating operations place limits on VOC emissions in terms of weight of VOC emitted per volume of coating applied (minus water and exempt solvents). These VOC emission limits of Section IX shall be considered presumptive RACT for MCC. Existing sources in the 8-hr ozone control area but not the 1-hr ozone attainment/maintenance area were to comply with the requirements of Reg. 7 by February 1, 2009 per Section I.B.2.d.(ii). 123/0134 Page 5 of 15 Metal Container Corporation—Windsor Facility Operating Permit No.96OPWE162 Technical Review Document—Renewal Operating Permit The fugitive emission control techniques and work practices of Section IX.A.7 had been removed from the previous permit revision since, at the time;they were inapplicable. However, these are now State-only applicable provisions for sources in the 8-hr ozone control area. The solvent cleaning operations and parts cleaners at this facility are subject to the Reg. 7, Section X provisions for use of solvents for cleaning and degreasing. Metal Container uses only solvent cold-cleaners at the facility; the solvent in the cold cleaners is not heated or agitated, nor does it have a true vapor pressure greater than 15 torn This facility is also subject to the Reg. 7, Section III provisions for general requirements for storage and transfer of volatile organic compounds. IV. Modifications Requested by the Source A cancellation notice was submitted by MCC for the temporary diesel engine/air compressor unit (AIRS point 031) on June 25, 2014. The Division considers this unit a non-road engine, and advised MCC to submit a cancellation notice for the stationary AIRS point. (See Section VI: Other Modifications, below) In their modification application submitted on April 10, 2009, the source requested that the permit be revised to increase the site-wide aluminum scrap throughput from 5,000 tons/yr to 5,500 tons/yr. No increase in facility-wide emissions of PM/PM10 was requested with the modification and no physical change was involved. The actual increase in PM/PKo emissions due to the modification is 225 lbs/yr using the current emission factor for aluminum scrap throughput, with total potential emissions of 1.2 tons/yr. In correspondence with the Division related to the operating permit renewal issued on July 1, 2003, MCC indicated that, based on the nature of the material, it is believed that aluminum scrap processing does not create fine particulates that would become airborne. The Division accepted this position and concluded that the cyclone was part of the material processing and not provided for the control of particulate emissions. This modification is therefore not expected to increase emissions of PM2.5 above APEN significance levels. 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). Since this modification does not significantly change any existing permit condition or emission limitation,violate any applicable requirements, or seek to establish a limitation in order to avoid other applicable requirements, the Division has determined that this modification can be processed as a minor modification. The renewal application received on June 29, 2007 requested the following modifications: • Replacement of two bottom vamish units This action is considered to be a routine replacement and therefore does not meet the definition of modification. This replacement does not involve a physical change or change in the method of operation of the source, nor will it lead to an increase in 123/0134 Page 6 of 15 Metal Container Corporation—Windsor Facility Operating Permit No. 96OPWE162 Technical Review Document—Renewal Operating Permit the emission rate, since the varnish application rate will remain the same for the new units. • Operational flexibility for venting of emissions from the conveyor following the inside spray machines when one baghouse is down. The source stated in an email received on January 24, 2014 that this operating scenario was not currently desired. A new Form 2000-100 (Facility Identification Form)was submitted on January 24, 2014 to identify a new Responsible Official and permit contact for this facility. The source's requested modifications were addressed as follows: Page Following Cover Page • A new Responsible Official and facility contact person were identified according to information submitted by the source. Section II—Specific Permit Terms • Condition 4 (for Aluminum Scrap) o Increased the aluminum scrap throughput from 5,000 tons/yr to 5,500 tons/yr according to the modification received on April 10, 2009. V. Emission Sources With the promulgation of 40 CFR 63, Subpart ZZZZ requirements for existing stationary compression ignition internal combustion engines at area sources on March 3, 2010, the fire pump engine at this facility can no longer be considered an insignificant activity. This engine was previously considered an insignificant activity under the provisions of Colorado Regulation No. 3, Part C, Section II.E.3.nnn. Under the "catch-all" provisions of Colorado Regulation No. 3, Part C, Section II.E, exemptions from operating permit requirements for insignificant activities do not apply (including de minimis levels) if a source is subject to any specific federal or state requirement, including National Emissions Standards for Hazardous Air Pollutants. The fire pump engine is still exempt from APEN reporting and minor source construction permitting requirements based on actual emissions. A. Emergency Fire Pump Engine: One (1) Caterpillar 3406TA diesel fired internal combustion engine driving a fire pump, rated at 440 HP 1. Applicable Requirements: The applicability of the following requirements were evaluated for the fire pump engine: o APEN reporting requirements The APEN de minimis level for NOx for units at this facility is one (1)ton per year, since this facility is located in an ozone non-attainment area. Using an emission factor of 0.031 lb/hp-hr (from AP-42, Table 3.3-1; the largest emission factor given for diesel engines), and the rated horsepower, this 123/0134 Page 7 of 15 Metal Container Corporation—Windsor Facility Operating Permit No.960PWE162 Technical Review Document—Renewal Operating Permit engine would exceed one ton of NOx emissions if operated for more than 146 hours. Therefore, requirements have been included in the operating permit (Conditions 6.1 and 6.2)to monitor hours of operation and to calculate annual emissions for purposes of APEN reporting and annual fees when hours of operation exceed this level. o Construction permitting requirements The potential to emit for NOx for the fire pump engine, when calculated using maximum potential operating hours of 500 per year(the EPA default assumption for emergency engines), is below the 5 tons per year exemption level found in Colorado Regulation No. 3, Part B, Section II.D.1.c. Therefore this engine remains exempt from construction permitting requirements even at maximum potential operating levels. o Colorado Regulation No. 1 • This engine is subject to the 20% opacity standard of Section II.A.1 and the 30% opacity standard of Section II.A.4. The 20%standard is applicable at all times, except during certain operational conditions, during which the 30% standard applies. These operational conditions include building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications and adjustment or occasional cleaning of control equipment. The Division considers that start-up is the only operational condition of Section II.A.4 that applies to this engine. A Method 9 opacity observation will normally be required once a year, with a second observation required if the engine is operated for more than 250 hours. • Section VI.B.4.b.(i) includes an emission limitation for SO2 for oil-fired units with a heat input of less than 250 MMBtu/hr of 0.8 lb/MMBtu that is applicable to this engine. The uncontrolled emission factor for diesel-fired engines in AP-42 (Table 3.3-1, used to estimate emissions from this engine) is 0.29 lb/MMBtu, which is well below the 0.8 lb/MMBtu limit. In absence of credible evidence to the contrary, this engine may be presumed to be in compliance with the SO2 limit since they are only permitted to bum diesel fuel. o 40 CFR Part 63, Subpart 7777- Reciprocating Internal Combustion Engine (RICE) MACT Since this engine is an existing emergency engine it is only subject to management practices, including inspection/replacement of belts and hoses and oil/filter changes. These requirements have been designated as Federal- Only requirements since Colorado has not adopted the area source provisions of Subpart 7777. The provisions for engine operation during emergency demand response, voltage and frequency deviation, and non- emergency situations related to electricity generation have not been included in the operating permit since this engine is used solely as a fire pump engine, and is not configured as an electric generator. 123/0134 Page 8 of 15 Metal Container Corporation—Windsor Facility Operating Permit No. 96OPWE162 Technical Review Document—Renewal Operating Permit This engine is also subject to the requirements of 40 CFR Part 63, Subpart A; General Provisions. Since this engine is an existing unit that is not subject to any emission limitations or monitoring, notification or reporting requirements, the provisions of§63.5, 63.7, 63.8, 63.9 and 63.10 do not apply. In addition, Table 8 of Subpart ZZZZ indicates that the operation and maintenance requirements of§63.6(e) do not apply. Therefore, only the prohibition and circumvention requirements of§63.4 have been included in the operating permit. VI. 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 keep the same monitoring and compliance periods and report and certification due dates as were provided in the original permit. However, it should be noted that with this option, depending on the permit issuance date, the first monitoring period and compliance period may be short (i.e. less than 6 months and less than 1 year). Section I — General Activities and Summary • Revised the language in Condition 1.4 to include current conditions that are state- only enforceable. • Revised Condition 3 to identify the source as a major stationary source for Nonattainment area New Source Review (NANSR), since the area in which the plant operates is part of the 8-hour Ozone Control Area. • Condition 6 (Summary of Emission Units) o The APEN/permit exempt sources (heaters)were removed from this list. These are included in the list of insignificant activities in Appendix A. o The temporary compressor engine (point 031) was removed from the list since these engines have been classified as non-road engines. Section II — Specific Permit Terms • The facility-wide emission limits were revised throughout Section II to account for the reduction in emission limits associated with the removal of the temporary compressor engine (see below). VOC emission limits remained unchanged since 123/0134 Page 9 of 15 Metal Container Corporation—Windsor Facility Operating Permit No.96OPWE162 Technical Review Document—Renewal Operating Permit there was no increase in the VOC emission limit when the temporary compressor engine was added to the permit. The amounts removed from the facility-wide emission limits were: NOx—37.2 tons/yr; CO—8.0 tons/yr; PM/PM1e—2.6 tons/yr. • Condition 1 (Fuel Burning Equipment) o Removed the insignificant fuel burning sources from the facility description. o Condition 1.1 was revised to clarify that the emission limits in the summary table for Condition 1 are facility-wide emission limits and to be more consistent with emission limit conditions for other emission units at this facility and with recently issued permits. o The Colorado Regulation No. 1, Section II.A.4 30% opacity requirement, for certain operational activities, has been added to the 20% opacity limit of Condition 1.4 since this is an applicable requirement. The Division has concluded that the operational activities of building of a new fire, cleaning of fire boxes, soot blowing, any process modification, or adjustment or cleaning of control equipment do not apply to the fuel burning equipment at this facility. Therefore, only the start-up condition has been included in this requirement. Compliance with these opacity requirements will be presumed since natural gas is the only fuel permitted for use in these units. o The Colorado Regulation No. 1, Section Vl.B.5.a requirement for sources of sulfur dioxide has been added to the operating permit since this is an applicable requirement. Compliance with this requirement will be presumed since natural gas is the only fuel permitted for use in these units. • Condition 2 (Can Forming Operations) o The emission factor in the summary table for Condition 2 has been revised to 0.2 lb/hr per production line. The emission factors for the oil misting operations and can elevator operations were listed separately in the original operating permit and were each given an emission factor of 0.1 lb/hr per production line. These factors should have been summed when the point assignments and conditions were rearranged for the first renewal. o Condition 2.1 was revised to be more consistent with emission limit conditions for other emission units at this facility and with recently issued permits. o Condition 2.2.1 was revised to include the required operation of the wet can inverter mist filters when the wet can elevators are in operation. This condition previously only specified that the mist eliminators with filters shall operate when the oil mist lubrication systems were in operation. o The Colorado Regulation No. 1, Section II.A.4 30% opacity requirement, for certain operational activities, has been added to the 20% opacity limit of Condition 2.3 since this is an applicable requirement. The Division has determined that the operational activities of fire building, cleaning of fire boxes, and soot blowing do not apply to this source, therefore, the 30% opacity requirement will only include the operational activities of start-up, 123/0134 Page 10 of 15 Metal Container Corporation—Windsor Facility Operating Permit No. 96OPWE162 Technical Review Document—Renewal Operating Permit process modification, and adjustment or occasional cleaning of control equipment. The Colorado Regulation No. 6, Part B, Section III.C.3 20% opacity limit for particulate matter for new manufacturing processes has also been added to Condition 2.3 as an applicable requirement. Though this requirement is not applicable during startup, shutdown, and malfunction (per 40 CFR 60 Subpart A, §60.11(c), adopted by reference in Reg. 6, Part B, Section I.A), this requirement is more stringent than the Reg. 1 30% opacity requirement during the operational activities of process modification and adjustment or occasional cleaning of control equipment. A qualitative visual emissions observation will be required once a month to monitor compliance with the opacity limits, with a Method 9 reading required when visual emissions are observed for more than 6 minutes. No additional monitoring has been required to demonstrate compliance with the Reg. 1 30% opacity requirement, since, based on engineering judgment, these operational activities are not likely to cause an increase in opacity emissions for this source. o Condition 2.4 has been added to the operating permit to include the Colorado Regulation No. 1, Section III.C.1.a requirement for PM emissions from manufacturing processes since this is an applicable requirement. Compliance with this requirement shall be presumed when the oil mist elimination system and wet can inverter mist filters are operated and maintained according to Condition 2.2. • Condition 3 (Can Coating Operations) o Condition 3.1 was revised to be more consistent with emission limit conditions for other emission units at this facility and with recently issued permits. o Condition 3.3 (monitoring of material consumption) was revised to specify that recorded material consumption shall be used to calculate emissions according to Condition 3.1, as well as for determination of the need to file a revised APEN. This condition previously only specified that recorded data be used to determine the need to file a revised APEN. o Condition 3.4 (NSPS WW)was revised to include more of the requirements of this rule specific to the source. o The Colorado Regulation No. 1, Section II.A.4 30% opacity requirement, for certain operational activities, has been added to the 20% opacity limit of Condition 3.7 since this is an applicable requirement. The Division has determined that the operational activities of fire building, cleaning of fire boxes, and soot blowing do not apply to this source, therefore, the 30% opacity requirement will only include the operational activities of start-up, process modification, and adjustment or occasional cleaning of control equipment. The Colorado Regulation No. 6, Part B, Section III.C.3 20% opacity limit for particulate matter for new manufacturing processes has also been added to Condition 3.7 as an applicable requirement. Though this 123/0134 Page 11 of 15 Metal Container Corporation—Windsor Facility Operating Permit No.96OPWE162 Technical Review Document—Renewal Operating Permit requirement is not applicable during startup, shutdown, and malfunction (per 40 CFR 60 Subpart A, §60.11(c), adopted by reference in Reg. 6, Part B, Section I.A), this requirement is more stringent than the Reg. 1 30%opacity requirement during the operational activities of process modification and adjustment or occasional cleaning of control equipment. A qualitative visual emissions observation will be required once a month to monitor compliance with this opacity limit, with a Method 9 reading required when visual emissions are observed for more than 6 minutes. No additional monitoring has been required to demonstrate compliance with the Reg. 1 30% opacity requirement, since, based on engineering judgment, these operational activities are not likely to cause an increase in opacity emissions for this source. o Condition 3.9 has been added to the operating permit to include the applicable requirements of Colorado Regulation No. 7. These state-only enforceable requirements have become applicable since the latest revision to the operating permit because the area is now designated as an ozone non- attainment area. These requirements include VOC emission limits for can coating operations as well as maintenance, operating, and work practice requirements for VOC storage and transfer, fugitive emission control, and use of solvents. o Condition 3.10 has been added to the operating permit to include the Colorado Regulation No. 1, Section III.C.1.a requirement for PM emissions from manufacturing processes since this is an applicable requirement. • Condition 4 (Aluminum Scrap) o Condition 4.1 was revised to be more consistent with emission limit conditions for other emission units at this facility and with recently issued permits. o Condition 4.2 (monitoring of scrap aluminum throughput)was revised to specify that the recorded scrap aluminum throughput shall be used to calculate emissions according to Condition 4.1, as well as for determination of the need to file a revised APEN. This condition previously only specified that recorded data be used to determine the need to file a revised APEN. o The Colorado Regulation No. 1, Section II.A.4 30% opacity requirement, for certain operational activities, has been added to the 20% opacity limit of Condition 4.5 since this is an applicable requirement. The Division has determined that the operational activities of fire building, cleaning of fire boxes, and soot blowing do not apply to this source, therefore, the 30% opacity requirement will only include the operational activities of start-up, process modification, and adjustment or occasional cleaning of control equipment. The Colorado Regulation No. 6, Part B, Section III.C.3 20% opacity limit for particulate matter for new manufacturing processes has also been added to Condition 4.5 as an applicable requirement. Though this requirement is not applicable during startup, shutdown, and malfunction (per 40 CFR 60 Subpart A, §60.11(c), adopted by reference in Reg. 6, Part B, 123/0134 Page 12 of 15 Metal Container Corporation—Windsor Facility Operating Permit No. 96OPWE162 Technical Review Document—Renewal Operating Permit Section I.A), this requirement is more stringent than the Reg. 1 30% opacity requirement during the operational activities of process modification and adjustment or occasional cleaning of control equipment. Compliance with these opacity requirements will be presumed based on the type of material processed, the method of operation, and the required operation and maintenance of the cyclone in Condition 4.3. • Condition 5 (Insignificant Activities) o Condition 5.2 was revised to remove the limit on glycol ether emissions from insignificant activities. This facility's actual emissions of glycol ethers are no longer approaching the major source level of 10 tons/yr (single HAP); therefore the limit on glycol ether emissions from insignificant activities is unnecessary. HAP emissions from all insignificant activities (for all HAPs) are still required to be monitored to verify compliance with the 9.9 ton/yr limit on single HAP emissions. • The requirements for the temporary diesel engine/air compressor unit (formerly Condition 6) have been removed from the operating permit. The Division considers this unit a non-road engine. Diesel fuel fired air compressors are brought in to the facility on a temporary basis to back up electric air compressors when they break down or require servicing. These units are therefore transportable and meet the definition of a non-road engine found in Colorado Regulation No. 3, Part A, Section I.B.31.a.(iii). Non-road engines are exempt from APEN filing requirements per Colorado Regulation No. 1, Part A, Section II.D.1.dddd. An engine that remains or will remain at a location (any single site at a building, structure, facility, or installation)for more than twelve consecutive months will not be considered a non-road engine per Colorado Regulation No. 3, Part A, Section I.B.31.b.(iii). This facility may still be subject to non-road engine requirements for these temporary units if the aggregation of operating hours for engines with a site-rated horsepower of 1,200 or greater is more than 4,380 hours per year at the same location. (per Colorado Regulation No. 3, Part A, Section I.B.31.c) • Requirements for the emergency fire pump engine (current Condition 6) have been included in the operating permit. This engine can no longer be considered an insignificant activity and is subject to operating permit requirements since it is now subject to the area source provisions of MACT ZZZZ. (see Section V: Emission Sources above) Section III — Permit Shield • Condition 3—Streamlined Conditions o A summary table has been added to Condition 3 describing the streamlining of the following applicable requirements according to the justifications below: Fuel Burning Equipment 123/0134 Page 13 of 15 Metal Container Corporation—Windsor Facility Operating Permit No.96OPWE162 Technical Review Document—Renewal Operating Permit Opacity The fuel burning emission sources at this facility are subject to the Colorado Reg. 1 opacity requirements of 30% during certain operational activities (Reg. 1, Section II.A.4)and 20% at all other times (Reg. 1, Section II.A.1). These units are also subject to the state-only Colorado Reg. 6, Part B 20% opacity requirement for particulate matter(Reg. 6, Part B, Section II.C.3). Since the Reg. 6 opacity requirement is not applicable during periods of startup, shutdown, and malfunction (per 40 CFR 60 Subpart A, §60.11(c), adopted by reference in Reg. 6, Part B, Section I.A), and the Division has determined that startup is the only operational activity of the Reg. 1 30% opacity requirement that applies to these sources, the Reg. 1 opacity requirements are always equal to or more stringent than the Reg. 6 requirements, and the Reg. 6 requirements have been streamlined out of the permit. Particulate Matter Regulation No. 1 (Section III.A.1.b)and Regulation No. 6 (Part B, Section II.C.2)contain the same particulate matter emission requirements for fuel burning equipment: emissions of particulate matter shall not exceed 0.5(FIy °.26 where Fl =fuel input in MMBtu/hr. The Regulation No. 6, Part B requirement is a state-only requirement. Regulation No. 6, Part B, Section I.A, adopts, by reference, the 40 CFR Part 60 Subpart A general provisions. Although not specifically stated in the general provisions, the Division has concluded, after reviewing EPA determinations, that the NSPS standards are not applicable during startup, shutdown and malfunction, although any excess emissions during these periods must be reported in the excess emission reports. Therefore, the Division considers that the Regulation No. 6, Part B particulate matter requirements do not apply during periods of startup, shutdown, and malfunction. The Regulation No. 1 requirements are therefore more stringent than the Regulation No. 6 requirements, and the Regulation No. 6 requirements have been streamlined out of the permit. Can Forming, Can Coating, and Aluminum Scrap Operations Particulate Matter Colorado Regulation No. 1 (Section III.C.1.a) and No. 6 (Part B, Section III.C.1) contain the same particulate matt er emission limit for manufacturing 9 processes with design rates less than 30 tons/hr: emissions of particulate matter shall not exceed PE = 3.59(P)°.62, where PE = particulate emissions in lb/hr and P = process weight rate in tons/hr. The Regulation No. 6, Part B requirement is a state-only requirement. Regulation No. 6, Part B, Section I.A, adopts, by reference, the 40 CFR Part 60 Subpart A general provisions. Although not specifically stated in the general provisions, the Division has concluded, after reviewing EPA determinations, that the NSPS standards are not applicable during startup, shutdown and malfunction, although any excess emissions during these periods must be reported in excess emission reports. Therefore, the Division considers that the Regulation No. 6, Part B particulate 123/0134 Page 14 of 15 Metal Container Corporation—Windsor Facility Operating Permit No. 96OPWE162 Technical Review Document—Renewal Operating Permit matter requirements do not apply during periods of startup, shutdown, and malfunction. The Regulation No. 1 requirements are therefore more stringent than the Regulation No. 6 requirements, and the Regulation No. 6 requirements have been streamlined out of the permit. • 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. 123/0134 Page 15 of 15 , Anheuser-Busch N Packaging Group, Inc. ONE OF THE ANNEUSEA-SUSCH COMPANIES June 28, 2007 FedEx Tracking Number: 8613 2622 7828 Colorado Department of Public Health and Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Title V Permit Renewal Application Metal Container Corporation (Facility ID CO1230134) Windsor, CO Enclosed is the Title V renewal application for Metal Container Corporation's (MCC) facility located at 1201 Metal Container Court, Windsor, Colorado. MCC's current Title V.permit will expire on July 1, 2008 and this renewal application is being submitted one year prior to expiration as required. The application contains all information required by Regulation No. 3, 5 CCR 1001-5, Part C, Section III.B.6. (Operating Permit Application Requirements) which states that an application for 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. MCC received a revised Title V Operating Permit for its Windsor, Colorado facility on August 31, 2006 based on an application submitted November 17, 2005. The permit was revised to make the following changes: • Federally enforceable Hazardous Air Pollutant (HAP) limits were added to the operating permit to avoid Maximum Achievable Control Technology Requirements (MACT) in 40 CFR 63 Subpart ICICKK that were to become applicable on November 13, 2006. • Additional equipment included one new bodymaker and one new inside spray machine. This addition was a minor modification to the Title V Operating Permit because the potential emissions from the new equipment were less than 40 tons per year of Volatile Organic Compounds (VOC). • Modification to the aluminum scrap handling limit to increase from 4500 tons per year to 5000 tons per year. Ani.Euser-bLscr. Fs.oiazclru;7ou;... .I C 3636 Soul! Geyer I7oao Colorado Department of Public Health and Environment June 28, 2007 Page2of3 The following items should be highlighted for this application: 40 CFR Part 64—Compliance Assurance Monitoring(CAM) The CAM Me referenced in 40 CFR Part 64 and adopted by reference in Colorado Regulation No. 3, Part C, Section XIV is not applicable to MCC's Windsor, Colorado facility as there are no control devices at the facility which are used to achieve compliance. . Replacement of Two Bottom Varnish Units MCC has notified the Colorado:Department of Public Health and Environment(CDPHE) of its intention to replace two bottom varnish units with newer technology. The varnish application rate will remain the same and emission rates will not change with the new equipment. The units are being replaced instead of repaired due to the cost of replacing worn out parts on old machines. This replacement does not meet the definition of modification in Regulation No. 3 Part A, Section I.B.26., as no emissions will increase and the replacement is considered a routine replacement under Section I.B.26a. Operational Flexibility MCC operates two baghouses to control the overspray from Lines 1 and 2 inside spray machines. The baghouses pull mist away from the cans to avoid overspray onto the decoration and control particulate matter emissions. In addition, each line has a "camelback" conveying system in which the cans drop to a conveyor and air then pulls the can onto the conveyor and holds it there as the can moves to a vertical position prior to entering the inside bake oven. The air used to hold the can on the conveyor is also vented to baghouses. In the event that one baghouse malfunctions, MCC would like the operational flexibility to control particulate from the inside spray machines from both lines into the operating baghouse while exhausting the air from the camelback systems through the roof to avoid shutting down an entire line. Incorporation by Reference Since the significant modification to the Operating Permit in August 2006, there have been no other changes to the facility that would affect current permit conditions. A change in responsible official has been made and is reflected on Form 2000-100 of this renewal application. This renewal application includes all required information specified in Colorado Regulation No. 3, Part C, Section III.B.6., including a copy of any materials incorporated by reference, compliance plans, compliance schedules, and compliance certifications. MCC hereby requests to incorporate by reference the existing Title V Permit Number 96OPWE162 dated September 1, 2006 based on application dated Colorado Department of Public Health and Environment June 28, 2007 Page 3 of 3 November 17, 2005, including all permit conditions in sections I through IV of this permit. If you have any questions regarding the enclosed application, please contact me at 970-686-1514. Thank you for your assistance in this matter. Sincerely, ANHEUSER-BUSCH PACKAGING GROUP tes EHS Manager Enclosures Application Forms Existing Title V Permit cc: C. Banfield, MCC-WIN R. Lanham Operating Permit Application FACILITY IDENTIFICATION FORM 2000-100 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name and Name Metal Container Corporation mailing address Street or Route 1201 Metal Container Court .. City, State, Zip Code Windsor, CO 80550-3309 . 2. Facility location Street Address 1201 Metal Container Court (No P.O. Box) City,Caunty, Zip Code Windsor, Weld County, CO 80550-3309 3 Parent corporation Name Anheuser Busch Packaging Group Street or Route 3636 S, Geyer . • City, State, Zip Code St. Louis, MO 63127 Country (if not U.S.) 4. Responsible Name Pat Payne official Title Plant Manager Telephone 970-686-1514 5. Permit contact person Name Chris Banfield Title EHS Manager (If Different than 4) Telephone 970—686-1516 6. Facility SIC code: 3411 7. Facility identification code: CO 1 2 3 0 1 3 4 6. Federal Tax I. D. Number: 4 3 1 0 0 9 1 0 0 9. Primary activity of the operating establishment: Aluminum Beverage Can Manufacturing 10. Type of operating permit ONew O Modified El Renewal 11. Is the facility located in a "nonattafnment" area: ❑ Yes ® No If'Yes". check the designated "non-attainment" pollutant(s): O Carbon Monoxide O 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. Construction Permit 95WE195 (Facility-wide) Operating Permit 96OPWE162 (Last Revised August 31, 2006) Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division • SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name; Metal Container 2. Facility identification code; CO 1 2 3 0 1 3 4 Corporation 3. Stack identification code: All 4. Unit identification code: All Emission Units • 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ® We will continue to operate and maintain this Unit In compliance with all applicable requirements. ❑ Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. ❑ This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable • Requirement Corrective Actions . Deadline 1. • • 2. • 3. Progress reports will be submitted: • Start date: and every six (6) months thereafter 1 Operating Permit Application PLANT-WIDE COMPLIANCE PLAN FORM 2000-608 Colorado bepariment of Public Health and Environment COMMITMENTS AND SCHEDULE Rev 06-95 Air Pollution Control Division USE THIS FORM ONLY IF FORM 2000-607 USED SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Metal Container 2. Facility identification code: CO 1 2 3 0 1 3 4 Corporation 3. For facilities that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements under Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. • We will continue to operate and maintain this fadlity in compliance with all applicable requirements. ❑ Form 2000-607 includes new requirements that apply or will apply to this facility during the term of the permit. We will meet such requirements on a timely basis. 4. For facilities not presently fully in compliance, complete the following. ❑ This facility is in compliance with all applicable requirements except for those Indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional sheets.): Applicable Requirement Corrective Actions Deadline 2. 3. Progress reports will be submitted: Start date: and every six (6) months thereafter 1 Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility Name: Metal Container Corporation Facility Identification Code: CO 1 2 3 0 1 3 4 1. ADMINISTRATION This application contains the following forms: El Form 2000-100.Facility Identification ❑ Form 2000-101,Facility Plot Plan ❑ Forms 2000-102,-t02A.and-102B,Source and Site Descriptions II. EMISSIONS SOURCE Total Number DESCRIPTION of This Form This application contains the following forms O Form 2000-200,Stack Identification loon fnrm for each facility boiler nrintino ❑ Form 2000-300,Boiler or Furnace Operation ❑ Form 2000-301,Storage Tanks U Form 2000.302,Internal Combustion Engine ❑ Form 2000-303, Incineration LJ Form 2000-304. Printing Operations ❑ Form 2000-305.Painting and Coating Operations ❑ Form 2000-306,Miscellaneous Processes O Form 2000-307,Glycol Dehydration Unit III. AIR POLLUTION CONTROL Total Number SYSTEM of This Form This application contains the following forms: ❑ Form 2000-400. Miscellaneous ❑ Form 2000.401.Condensers ❑ Form 2000.402,Adsorbers CJ Form 2000-403,Catalytic or Thermal Oxidation U 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 Total Number DEMONSTRATION of This Form • This application contains the following forms O Form 2000-500.Compliance Certification-Monitoring and Reporting Inn.for each facility boiler. nrintinp ❑ 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 p xxa ❑ Form 2000-504, Monitoring Maintenance Procedures ❑ Form 2000-505.Stack Testing ❑ Form 2000-506.Fuel Sampling and Analysis O Form 200D-507,Recordkeeping ❑ Form 2000-508.Other Methods 1 V. EMISSION SUMMARY AND Total Namber COMPLIANCE CERTIFICATION of lids Form This application contains the following forms O Form 2000-600..Emission Unit H»xdous Air Pollutants quantifying'Missions.cerntying compliance with applicable requirements.and developing a compliance plan ❑ . Form 2000401.Emission Unit Criteria Air Pollutants ❑ Fare 2000402,Facility Hazardous Alt Pollutants ❑ Form 2000403•Facility Criteria Air Pollutants ❑ Form 2000-604.Applicable Requirements and Status of Emission Unit • O Farm 2000-605.Permit Shield Protection Identification - - ® Form 2000.606.Emission Unit Compllence Plan-Commitments and Sr,edWe- • l ❑ Form 2000407. Plant-Wide Applicable Requirements O Form 2000-608. Plan-Wide Compliance Plan-Commitments and Schedule 1 • VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS • A. STATEMENT OF COMPLETENESS • I have reviewed this application in its entirety and,based on information and belief formed 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-FEDERALJSTATE CONDMONS(check one box only) ® I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. O 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§25-7122.1, C.R.S. Printed or Typed Name Title Pat Payne Plant Manager Signature Date Signed LiZ5/2Go7 2 — Operating Permit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility Name: Metal Container Corporation Facility Identification Code: COI 22 3 00 1 3 4 VI. SIGNATURE OF RESPONSIBLE OFFICIAL-STATE ONLY CONDITIONS A. STATEMENT OF COMPLEI bNESS 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. • ❑ 1 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 Title Pat Payne Plant Manager Signature Date Signed '5/2 007 SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 3 Anheuser-Busch Packaging Group, Inc. ONE OF THE ANHEuSEH-SUSOH OOI/PANIES nt� April 27, 2009 ` - Mr. Roland Hey Permitting Unit Supervisor Colorado Department of Public Health & Environment Air Pollution Control Division — Regulatory Development APCD-SS-B1 4300 Cherry Creek Drive S. Denver, Colorado 80246-1530 RE: METAL CONTAINER CORPORATION (MCC) WINDSOR CAN PLANT FAC ID: 1230134 Dear Mr. Hey: As you are aware, Regulation 7 — Emissions of Volatile Organic Compounds was amended on December 12, 2008 and states: "II.C.1.c. (State Only) Existing sources with potential emissions equal to or greater than 100 tons per year of volatile organic compound emissions shall submit a permit modification application that includes a revised APEN (or APENs)and a RACT analysis,to the Division, as follows: II.C.1.c.(i) (State Only) By October 30, 1991 if located in what was previously designated as the Denver 1-hour ozone nonattainment or attainment maintenance area; or II.C.1.c.(ii)(State Only) By April 30, 2009 or within one year after the date on which the area is first designated as being in nonattainment for ozone,whichever comes later, if they are located in the 8-hour Ozone Control Area and outside of the Denver 1-hour ozone nonattainment or attainment maintenance area." While Metal Container Corporation has not made any modifications that would affect the amount of VOC emissions from this facility, in the pure technical sense I believe that we are in compliance with this amendment for the following reasons: 1)We submitted an application and APEN on April 7, 2009 requesting a modification to the amount of scrap aluminum throughput for the Windsor facility (copy attached). While we did not request any changes in VOC emissions, the regulation only states that an APEN and a request for a permit modification be submitted, not anything specific regarding VOCs. Additionally, I have included a check in the amount of$152.90 for processing the submitted APEN. Anheuser-Busch Packaging Group, Inc. 3636 South Geyer Road St.Louis. MO 63127-1218 2)The second point of the amendment concerns the submittal of a RACT analysis. We worked closely with Ms. Theresa Amorosa during the rule development phase. She requested that we prepare and submit a RACT analysis for our plant in 2008. The RACT analysis was submitted to CDPH on August 4, 2008 and I have attached a copy for your review. Nothing has changed at our facility since the analysis was completed, therefore the results/conclusions are still applicable. If you have any questions regarding this letter or the information submitted, please contact me at (314) 957-0769. Sincerely, ANHEUSER-BUSCH PACKAGING GROUP Abe Robert M. Lanham, P.E. Vice President, Environmental, Health, Safety and Security Enclosure • cc: T. Amoroso-CDPH M. Burgett-CDPH C Banfield - MCC-WIN a , ..� •,e ` Metal Container wl�V✓_,` • Corporation ONE OF TIE ANHEUSERBUSGH COMPANIES Certified Mall Receipt No. April 7,2009 Colorado Department of Public Health and Environment Air Pollution Control Division 4300 Cherry Creek Drive South,APCD-SS-Bl Denver,Colorado 80246-1530 Subject Metal Container Corporation—Windsor Can Plant Weld County—Source ID 1230134 Operating Permit 96O2Wh162 General APEN and Permit Application Form Dear Sir/Madam, Metal Container Corporation operates a can plant at Windsor,CO,and has coverage under CDPHE air permit#96OPWE162. We are seeking to increase the site-wide aluminum soap throughput from 5000 tons/yr to 5500 tons/yr(as specified in permit section 42). NQ physical changes to the plant are involved. The site-wide particulate emissions limit will remain unchanged at 11 tons/yr. We will continue to monitor scrap aluminum throughput monthly and record the amounts on a log that is available to the Division upon request In the plant,soap aluminum is conveyed to the bailer with particulate control provided by a cyclone. In the attached ADEN,the emissions were estimated and calculated in the same manner as was described the Title V permit application. If you have any questions,please contact me at 970/686-1516 or at ' rbrisbanReld@anheuser-busch.com. Sincerely, - TAL CONTAINER CORPORATION i�ti,411,1 . C Banfxeld EHS Manager cc: Neal Willging,ABPG Chris Reinhardt,CDPHE Jonas Berge,CDPHE Metal Container Corporation 3636 South Gcger Road St.Louis,MO USA 63127-1218 Air Pollution Control Division (APCD)-Construction Permit Application PLEASE READ INSTRUCTIONS ON REVERSE SIDE 4. Permit to be issued to: Metal Container Corporation 2. Mailing Address: 1201 Metal Container Court Windsor, Co 80550-3309 3. General Nature of Business: Two-piece beverage can manufacturer SIC code(if known) 3144 4. Air Pollution Source Description: Aluminum scrap system (List permit numbers if existing source, #960PWE162 attach additional pages if needed) Is this a Portable Unit? No 5. Source Location Address(Include Location Map) If portable,include the initial location and home base location 1201 Metal Container Court, Windsor, co 80550-3319 6. Reason for Application:(Check all that apply) ❑ New or Previously Unreported Source Administrative PermitAmardments ® Modification of Existing Source (tbroupapat divulge) ❑ Transfer of Ownership(Complete Section 9& 10 below) ❑ Request for Synthetic M Minor Permit ❑ Company Name Change(Complete Section 9 below) 0 ❑ OtherOther 7. Projected May 1, 2009 417400, Si of Legally Authorized Person of Company listed in Section 1 Date Signed son oder, Plant Manager 970/686-1514 Type or Print Name and Official Title of Person Signing Above Fax: 970/686-5761 8. Check appropriate box if yon want 0 Copy of preliminary analysis conducted by Division ® To review a draft of the permit prior to issuance • These sections are to be completed only if a company name change or transfer of ownership has occurred 9. Permit previously issued to: n.a. 10.Transfer of Ownership Information Effective Date of Permit Transfer n.a. As responsible party for the emission source(s)listed above,I certify that the business associated with this source has been sold,and agree to transfer the permit to said party. Signature of I Pgally Authorized Person of Company listed in Section 9 Date Signed Cason oder, Plant Manager Phone: 970/686-1514 Type or Print Name and Official Title of Person Signing Above Far 970/686-5761 Mail completed application,APENs,and filing fee to: Colorado Department of Public Health and Environment han://www.cdohe.state.co.us/aa/stationary.html Air Pollution Control Division Phone:(303)692-3150 4300(Reny Creek Drive South,APCD-SS-Bl Denver,Colorado 80246-1530 Revised August 2004 0 T « u 9 q y 0 m O u O N o f _ n a N o ee g 0. a n u O m T __ z py^p c� fn�n e ❑ 7.3 m W C m a P A g 32 A q _ s o m upp., 0 'O'O'o _ 7 zz « 2. 4 Z '.I c u 0 E en en R W d' o m « w' a 63 U Y 3 n m m 0 0 4 m p, re! r3 0 0 •o p a`1 e a [g e P. n m m .a oGG .u9 a W € .Lhe ea,. o` pR V a u P. 3 O. .Y t g ? m 5 h Ii] 33R (p7 it n m e w 8 m -`3 5 e g .'3 n q$ +. $ R7 do O a g O m a e e u Y s w v y m ^� N a e m y $ .°�' '$ R o m a 5 3 rS Y d7 �' n ht !� Cr s L C m C '= W " a 4 '3 m E N. fJ a Y.. 0 .. 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ONE OF THE ANHEUSER-BUSCH COMPANIES August 4, 2008 FedEx Tracking Number: 8646 7978 6361 Ms. Theresa Amoroso Colorado Department of Public Health & Environment Air Pollution Control Division—Regulatory Development APCD-SS-B1 4300 Cherry Creek Drive S. Denver, Colorado 80246-1530 RE: METAL CONTAINER CORPORATION (MCC) WINDSOR CAN PLANT FAC ID: 1230134 COST BENEFIT ANALYSIS Dear Ms. Amoroso: On May 21, 2008, the Colorado Department of Public Health and Environment (CDPHE) and Metal Container's Windsor Can Plant (MCC) met to discuss the development of Colorado's ozone State Implementation Plan (SIP). Specifically, CDPHE questioned how MCC may be of assistance in helping the Denver non-attainment area demonstrate compliance with USEPA's 1997 ozone standard. BACKGROUND On November 20, 2007, the Denver-metropolitan and Northern Front Range areas were designated as "nonattainment" with the 8-hour federal ozone National Ambient Air Quality Standard (NAAQS). The 8-hour nonattainment area consists of a nine county area — including the counties of Adams, Arapahoe, Boulder, Broomfield, Denver, Douglas, Jefferson, and a portion of Larimer and Weld. As a result, CDPHE is required to prepare a State Implementation Plan (SIP) to bring the Denver and Northern Front Range areas into attainment with the ozone NAAQS. The SIP must ensure that all affected sources in the non-attainment area are employing Reasonably Available Control Technology (RACT). In reducing the ozone emissions in the area CDPHE has developed a detailed list of VOC control strategies. The strategies are believed to yield significant, quantifiable reductions that are cost effective, technologically feasible, and/or implementable. One of the control strategies is to evaluate reducing VOC emissions from certain stationary sources in the nonattainment area. The Windsor Can Plant is one of the stationary sources. VOC CONTROLS CDPHE requested MCC to conduct a VOC control RACT analysis. RACT is defined as "technology that will achieve the maximum degree of emission control that a particular source is capable of meeting and that is reasonably available considering technological and economic feasibility". In a RACT analysis one must determine if controls are technically feasible and economically reasonable. Economically reasonable is based upon an annualized cost per ton of pollutant removed ($/ton). Anheuser-Busch Packaging Group,Inc. '3g Cni,tn favor Rnar In response to the CDPHE request, MCC has conducted a RACT analysis for controlling the VOC emissions from the facility with a thermal oxidizer (Ref. Attached). The estimated Total Capital Investment for a thermal oxidizer is approximately 7.3 million dollars, with an estimated annualized cost of 1.97 million dollars to remove 153 tons of VOC per year, resulting in an annualized cost of$12,911 per ton. Based on these costs, thermal oxidation is not considered economically feasible for VOC control. ADDITIONAL REDUCTIONS The Anheuser-Busch Packaging Group (ABPG) as well as MCC are constantly looking for ways to reduce emissions and our impact on the environment. Over the past 10 years at Windsor, we have been able to reduce our emissions per unit of production by more than 25% through the application of new technology and process control. MCC has achieved a recycling rate of 98% of all wastes that are generated at the plant which reduces our overall impact to the environment. More recently, we have worked with our suppliers to develop coatings which have reduced our HAP emissions by more than 70 tons per year. SUMMARY Metal Container's Windsor Can Plant was identified as a large-VOC source by CDPHE and was requested to complete a RACT analysis for VOC control. In response to CDPHE's request, MCC completed the attached VOC control analysis. The analysis demonstrates that the cost of VOC controls is beyond what can be considered 'reasonable'. After you have the opportunity to review the attachment, we would like to discuss the information in the spreadsheet either via a conference call or a meeting. If you have any questions regarding this letter please contact me at (314)957-0714 or Bob Lanham at(314) 957-0769. Sincerely, ANHEUSER-BUSCH PACKAGING GROUP 41/0994S0 Jeff Blaies EHS Manager Enclosure cc: C Banfield, MCC-MCC B. Lanham TABLE X COST ANALYSIS FOR THERMAL OXIDIZER Metal Container Corporation Windsor Can Plant Controlling VOC Emissions from Lines#1 &#2 CAPITAL COST FACTORS ANNUAL COST FACTORS Direct Costs Total Annual Operation 8,760 hr/yr Purchased Equipment Cost Equipment Cost A $2,576,701 Factor Unit Costs Annual Cost Instrumentation $713,054 Direct Costs Sales Tax $128,835 Operating Labor Freight Operator 0.5 hrs/shift $45.00/hr $24,638 Total Purchased Equipment Cost B I $3,418,591 I Supervisor 15%of operator $3,696 Direct Installation Costs Maintenance Foundations and Supports $148,082 Labor 0.5 hrs/shift $45.00/hr $24,638 Handling and Erection $150,382 Materials 0.0IB $34,186 Electrical $396,119 Piping $978,354 Utility Costs Insulation $259,673 Natural Gas 29,188 cft $9.75/1000 ft3 $284,579 Painting $18,473 Electricity 175 KW $0.065/kWh $99,645 Site Preparation $139,361 Buildings $480,844 Total Direct Costs I $471,381 I Total Other Direct Costs I $2,571,288 I Indirect Costs Overhead 80%of O&M cost $69,725 Total Direct Costs $5,989,879 Administrative 2%of TCI $146,773 Property Taxes 1%ofTCI $146,773 Insurance 1%of TCI $73,387 Indirect Installation Costs Total Indirect Cost I $436,658 Engineering and Supervision $266,230 Construction and Field Expenses $296,352 Capital Recovery $1,069,140 Contractor Fees $8,479 Startup TOTAL ANNUAL COSTS: $1,977,179 Performance Test 0.01B $34,186 Contingencies $743,537 Total Indirect Installation Cost I $1,348,784 I COST EFFECTIVENESS Total Capital Investment $7,338,663 Pre-Control Emissions(Baseline) 201.5 t/yr Annual Interest Rate(%): 7.50 Capture Efficiency 80% Equipment Life: 10 yrs Removal Efficiency 95% Calculated Capital Recovery Factor. 0.1457 Tons Removed 153.1 Total Annual Capital Recovery: $1,069,140 Cost per Ton Removed $12,911 COST DOES NOT INCLUDE CAPITAL AND/OR OPERATING EXPENSES ASSOCIATED WITH BAGHOUSE-need BH to control inside spray operations , 4 Metal Container : £am Corporation ONE OF THE ANHEUSER-EUSGN COMPAMES Certified Mail Receipt No. April 7,2009 Colorado Department of Public Health and Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 Subject: Metal Container Corporation—Windsor Can Plant Weld County— Source ID 1230134 Operating Permit 96OPWE162 General APEN and Permit Application Form Dear Sir/Madam, Metal Container Corporation operates a can plant at Windsor, CO, and has coverage under CDPHE air permit#96OPWE162. We are seeking to increase the site-wide aluminum scrap throughput from 5000 tons/yr to 5500 tons/yr (as specified in permit section 4.2). No physical changes to the plant are involved. The site-wide particulate emissions limit will remain unchanged at 11 tons/yr. We will continue to monitor scrap aluminum throughput monthly and record the amounts on a log that is available to the Division upon request. In the plant, scrap aluminum is conveyed to the bailer with particulate control provided by a cyclone. In the attached APEN, the emissions were estimated and calculated in the same manner as was described the Title V permit application. If you have any questions,please contact me at 970/686-1516 or at chris.banfield@anheuser-busch.com. 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General Nature of Business: Two-piece beverage can manufacturer SIC code(if known) 3144 4. Air Pollution Source Description: Aluminum scrap system (List permit numbers if existing source, #96OPWE162 attach additional pages if needed) Is this a Portable Unit? No 5. Source Location Address(Include Location Map) If portable,include the initial location and home base location 1201 Metal container court, windsor, CO 80550-3319 6. Reason for Application: (Check all that apply) ❑ New or Previously Unreported Source Administrative Permit Amendments • Modification of Existing Source (throughput change) ❑ Transfer of Ownership(Complete Section 9& 10 below) ❑ Request for Synthetic Minor Permit ❑ Company Name Change(Complete Section 9 below) ❑ Other: 9 Other: 7. ProjectedStartu te: May 1, 2009 /'LASign e of Legally Authorized Person of Company listed in Section 1 (( Date Signed ason Oder, Plant Manager 970/686-1514 Type or Print Name and Official Title of Person Signing Above Fax: 970/686-5761 8. Check appropriate box if you want: ❑ Copy of preliminary analysis conducted by Division ® To review a draft of the permit prior to issuance These sections are to be completed only if a company name change or transfer of ownership has occurred. 9. Permit previously issued to: n.a. 10. Transfer of Ownership Information Effective Date of Permit Transfer: n.a. As responsible party for the emission source(s)listed above, I certify that the business associated with this source has been sold,and agree to transfer the permit to said party. Signature of Legally Authorized Person of Company listed in Section 9 Date Signed 3aaon Oder, Plant Manager Phone: 970/686-1514 Type or Print Name and Official Title of Person Signing Above Fax: 970/686-5761 Mail completed application,APENs,and filing fee to: Colorado Department of Public Health and Environment http://www.cdphe.state.co.us/ap/stationary.html Air Pollution Control Division Phone: (303)692-3150 4300 Cherry Creek Drive South,APCD-SS-B 1 Denver, Colorado 80246-1530 Revised August 2004 General Facility Ouestions 1. It seems that the responsible official and the permit contact for MCC might have changed recently. If so.please submit a Form 2000-100(Facility Identification)to identify the new responsible official and permit contact and their contact information. Operating permit forms can be found at httn://www'.colorado.gov/es/Satellite/CDPHE- AP/CBONi 1 25 1 596446069. You can submit this by email. A Complete Form 20tH)-10(1 is attached • Also.could you please identify for me the facility billing contact and address to make sure that we have this correct l:ti Manager should he billing Contact on lik E5 Manager MCC' Windsor (201 Metal Container Court Windsor.CO 8055(1 2. Does MCC have an estimate of the CO2e emissions associated with this facility? The Division needs clarification from MCC as to whether the facility's potential-to-emit for greenhouse gas(GHG)emissions exceeds 100.000 tpy CO2e. Our calculated actual CO2 emissions in 2012 w ere 6,035 tons. the plant operated approximately 304)days in 2(113. It is reasonable to assume that we are well helow 100.000 tpy of(4)2e Related toshe basecoat,inside spray.and overvamish bulk storage tanks I have not seen anything in our files indicating whether the tanks at MCC(for basecoat,inside spray.and overvamish)had been evaluated for applicability to NSPS Kb. Please answer the following questions to help determine this. 3. Were these tanks constructed after July 23. 1984? Yes- i he plant was not built until 1987 to 1988 and new tanks were installed at that time. 4. Do any of the tanks have a capacity of greater than or equal to 75m3(19.813 gallons)? No • I he tanks that hold basecoat, Inside Spray.and Overt amish are 1(1.0(N)gallons. 5. If so.is the maximum true vapor pressure of the contents less than 3.5kPa(0.5 psi)for tanks greater than or equal to !50m3(39.627 gallons),or less than 15.0 kPa(2.18 psi)for tanks greater than or equal to 75m3 but less than I50m3? NA Related to curing oven by-product emissions 6. How were the formaldehyde oven by-product emission factors developed? In the 1990's. Metal Container Corporation(MCC)and others in the two-piece beverage container business came to understand that li>rmaldehyde was being formed in the hot/ones of the curing ovens. 7 o get a better understanding of what was incurring. in August '97,MCC conducted a test program at our MCC Ft.Atkinson can plant to determine formaldehyde emission rates during operating conditions, 'through the process,beverage cans are coated with epoxy coatings that are thermally cured in ovens. MUC'perti3rms the lid losting coating operations of cans: • basecoat: These are cans that are coated with white ink prior to going to the decorators. Not all cans recei►c basecoat. • Decoration and Ohervaanish: The can receives the ink decoration.and then they receive a coating of overvarnish. (kertarnish protects the graphics.and helps the can glide on the conveyors at the beverage filling locations. • 'inside spra.: I his is the liner inside the can that protects the beverage from the aluminum.and the aluminum front the be.eraec. MCC likes to express its emissions factors as: Ibs air contaminant per thousand cans processed. Because can plants make millions of containers per day.this has been found to work very well. Based on the results of the Ft.Atkinson test program. M(( developed the Billowing li'rmaldehy de emissions factors to estimate formed formmldehyde emissions. 1. Can decorating emissions(i.e.. from overvarnish): 0.t)03SIbs/I000cans decorated MCC evaluated the mass ol'the formaldehyde observed in the pin ovens. and allocated it per thousand cans decorated. 2. 13asecoat emissions: 0.00531bs/1000 cans basecoated 10 estimate hasecoat emissions. M('('starts w ith the can decorating emissions estimate(0.00351hs.I000cans decorated).The quantity of melamine resin in basecoat is generally I.5x the amount of melamine ruin in ovenarnis. Engineering judgment leads one to conclude that hasecoat emissions results in I.5 x 0.00351hs!I000can 0.0053lbs11(X)0cans. 3. Inside spray emissions: 0.00191bs/I000 cans sprayed When the testing was done in '97.MCC used an inside spray material that contained melamine resin ithe source ol'the formed formaldehyde). MCC engineering judgment lead the company to conclude that ''1 of the inside hake oven(Mu) )) li►rmed formaldehyde came from the melamine-containing inside spray.and the other hall'came from the re-hake of the overvarnish. (Overvarnish is not fully cured in the pin ovens,the comparatively hotter inside hake oven completes the cure of the overvarnish cure or"re-hake". Me re-hake creates the other half of the IRO's formed Ioi malJchyde.)Since the time of the f1. Atkinson testing.MCC migrated to a variety of inside spray that does not contain melamine resin. In '97.the quantity of 1BO limned ibrmaldehy de wits estimated to he 0.00381hs IM0 cans. No Iorntaldeh)Jc is firmed by the newer varieties of inside spray.as the) do not contain melamine resin. MCC concludes that the emissions from the 113O is 0.00l9lbs/1000eans(i.e..one half of the 0.(10381bsil(X)1)cans that was seen when the old- style inside spray was used) 7. Are there other emissions(such as CO)associated with the curing ovens? The only other emissions associated with the curing ovens are the normal by-products or natural gas combustion. Related to the emergency fire pump engine With the promulgation of area source requirements for NESHAP ZZZZ(in 2010),the emergency fire pump engine is now subject to this rule. It seems there are no exemptions for area source requirements that apply to MCC,therefore,this engine can no longer be considered an insignificant activity,and the appropriate applicable requirements must be included in the operating permit. However,since Colorado has not adopted the area source requirements of MACT ZZZZ.these requirements are federal only.and this engine may still be exempt from APEN reporting requirements. Please answer the following questions in order to determine the appropriate requirements for this engine. 8. Is this engine used solely to power an emergency fire pump? Does MCC have an emergency power generator that might be subject to MACT Z777 or NSPS Illl? Yes.this engine is used solely as an emergency power supply for a lire pump. MCC does not have an emergency power generator in use onsite. 9. Does MCC have an estimate of the emissions associated with this engine? if uncontrolled actual emissions of NOx arc above one(1)ton per year,this unit would require an APEN,since the facility is in a nonattainment area for ozone. Using the AP-42 emission factors for diesel fired engines(0.031 Ihihp-hrI multiplied times the size oldie engine(430 hp) gives us an emission rate of 13.33 lbs/hr. The emergency generator is run for 30 minutes each week to test for functionality. This totals 26 hours over the course of a year.resulting in approximately 347 lbs of NOx emissions.which is well below the .OPEN threshold. 10. I am assuming this is an existing engine for MACT ZZZZ,since it has been on the operating permit since before June 12,2006,and therefore not subject to NSPS llll. (Unless it has been reconstructed per the definition in Z777) Is this correct? This is an accurate assumption Related to e Can Coating Sources 1 i. It appears that the Colorado Regulation No.7.Section IX provisions for surface coating operations are now applicable to MCC;specifically the Section 1X.C requirements for can coating operations. This section contains VOC emission limits based on weight of VOC emitted per volume of coating solids applied,similar to the NSPS Subpart WW limits. However, the limits for inside coatings are below the limits of Subpart WW,and seem to be below what MCC is currently achieving. These requirements are state-only requirements that have become applicable to MCC with the designation of the of the 8-hr ozone control area. Our coatings are compliant with the pro%ision stated. 12. In the renewal application submitted on June 29,2007,MCC requested the operational flexibility to vent the particulate matter streams from both inside spray machines through a single baghouse,in the event that one baghouse malfunctions, while venting the stream from the"camelback"conveyor system to the atmosphere. Is this still a current operational request? At the present time. rte do not tt ish to pursue this operating scenario. It mas he requested in the future.if it is decided to he ncce_�t ssn. What PM emissions would be associated with this?(i.e. what portion of the ISS PM emissions are carried over to.and vented through,the conveyor system?) NA Also. I am assuming that one baghouse can sufficiently handle the flow from both 1SS vents and that this would not cause a change in pressure outside of the manufacturer's recommended range. Would this be correct? N,\ Related to the temporary compressor engine 13. The Division is considering classifying the temporary compressor engine as a non-road engine. It seems to fit the definition in Colorado Regulation No. 3, Pan A, Section I.B.3 I. As such these engines would be exempt from APEN reporting and permitting requirements. There are State-Only requirements for non-road engines:APEN reporting is triggered if engines above 1200 HP are operated for more than 4,380 hrs/yr(aggregate of all engines),and permitting is triggered if estimated actual emissions are above 100 tpy NOx or CO,or 40 tpy SO2. Records would need to be maintained to demonstrate that MCC didn't trigger these requirements.but it seems that it shouldn't. We are still running this by our inspections group(Field Services)to make sure they agree with this determination. VICC Vi IN :Tree,.ttOh this interpretation_There is no temporut compressor engine on site currency. When one is needed. an engine of le,. than 800 hp is rented.and operating hour:are log_ed. Let me know if you have any questions or need clarification on mine. • RE: Additional questions for Metal Container Corporation Title V Operating Permit 96OPWE162 General Facility Issues 1. Please submit a cancellation notice for the temporary compressor engine. Cancellation notices can be found here: http://www.colorado.gov/cs/Satellite/CDPHE-AP/CBON/1251596800297. Please include the AIRS ID# 123-0134-031 and specify that the Division has determined that this engine should be classified as a non-road engine. You can return this to me by email. I will revise the facility-wide emission limits to account for the removal of those that were associated with the temporary engine. According to our records the limits will be reduced as follows: Pollutant Previous Limit(tpy) Reduction(tpy) New Limit(tpy) NOx 82.2 37.2 45.0 CO 46.0 8.0 38.0 PM/PMIo 11.0 2.6 8.4 There was no increase in the VOC emission limit when this engine was added to the permit so VOC limits will remain the same. Can you help us understand the benefits of removing the temporary compressor from the air permit? Since we have the processes, procedures and calculation tools in place, it is our inclination to have the emissions reflected in the permit, unless there is a reason to remove them. 2. Are there any gasoline tanks at the facility used to dispense gasoline to other equipment?(for potential applicability to MACT CCCCCC)? We have no gasoline tanks at the facility. Related to Fuel Burning Sources 3. Can you confirm the heat input rate on the boilers? They were previously specified as 12.553 MMBtu/hr in the operating permit, but submitted APENs have always listed them as 14.65. Per the manufacturers plate, the MCC boilers are rated at 12.553 MMBTU. 4. Are the curing ovens direct-fired ovens,where fuel burning emissions are mixed with emissions from coating curing? This determines if the ovens are subject to the requirements for fuel burning equipment or manufacturing processes in Regulations 1 and 6. Either way compliance will be assumed for these requirements since they burn natural gas. The MCC pin ovens and inside bake ovens are direct fire, with a single exhaust stack for both combustion and curing. Related to the Can Forming Sources 5. The emission factor stated for these units in the current permit is 0.1 lb/hr per production line. It seems from a review of Division files and calculations submitted by MCC that this EF should be 0.2 lb/hr per production line. I believe the original development of these emissions associated 0.1 lb/hr f for each bodymaker unit(0.2 lb/hr total),and the wet can elevators(that share a common stack) were assumed to be equal to the bodymakers(another 0.2 lb/hr). Is this correct? Looking at historical documents, I believe the emission factors are accurate. To clarify, there are three Munters units in the facility. The first unit collects mist from all bodymakers, on Line 1 and Line 2. There is also a Munters Unit on the Line 1 wet can elevator, and another on the Line 2 wet can elevator. I would assume that since the first Munters collects mist from both lines, that it would have an emission factor of 0.2 lb/hr, and the latter two would have an EF of 0.1 lb/hr respectively. Related to the Can Coating Sources and Reg. 7 applicability There are a few provisions of Regulation No. 7 that apply to degreasing and cleaning operations. 6. From what I can tell MCC uses solvent cold-cleaners,and does not have/use any vapor degreasers or conveyorized degreasers(as defined in the rule,Section X.A.2; http://www.colorado.gov/cs/Satellite/CDPHE-Main/CBON/1251601911433) . Is this correct? We only use solvent cold-cleaners in the facility. There is an aqueous detergent cleaner at the site as well (it operates like a large dish washer) 7. Is the solvent in the cold-cleaners heated or agitated by an agitating mechanism or does it have a true vapor pressure>15 torr(0.3 psia) at 38°C(100°F)? The solvent in our cold cleaners is not heated,agitated, nor does it have a true vapor pressure >15 torr. The solvent used in our parts washers has a true vapor pressure of 0.27 torr. A copy of the MSDS for the solvent is enclosed separately. 8. Does the solvent in the cold-cleaners have a true vapor pressure>32 torr(0.62 psia) at 38°C (100°F)? The solvent used in our parts washers has a true vapor pressure of 0.27 torr. A copy of the MSDS for the solvent is enclosed separately. 9. Is the solvent in the cold-cleaners heated above 50°C(120'F)? The solvent in our cold cleaners is not heated above 50°C (120°F). Related to Insignificant Activities 10. It seems glycol ether emissions have gone down significantly since the latest revision to the operating permit. Is this due to changes in the glycol ether content of the coatings? I was assuming this but haven't been able to specifically confirm this from our records. I was planning on revising and/or eliminating Condition 5.2 of Section II (Insignificant Activities) if it is no longer relevant. There have been no process changes or significant coating formulation changes that would have a substantive affect on the plant. It is our understanding that the Insignificant Emission clause (Condition 5.2 of Section II) in the permit was a required permit condition based on the MACT requirements for HAP PTE,since our permitted HAP emissions are 9.9 TPY. There is a summary of this on page 3 of the Technical Review Document for the last Significant Modification dated January 2006. It is our inclination to leave the language included, as a precaution. Hello