STATE OF MISSOURI

~ DEPARTMENT OF NATURAL RESOURCES

MISSOURI AIR CONSERVATION COMMISSION

PERMIT TO CONSTRUCT Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to construct the ~ir contaminant source(s) described below, in accordance with the laws, rules and conditions as set forth herein.

Permit Number: 1 2 2 0 1 6 _ 0 0 7 Project Number: 2016-02-047 Installation Number: 099-0044

Parent Company: Anheuser-Busch Companies Inc.

Parent Company Address: 1 Busch Place, St. Louis, MO 63118

Installation Name:

Installation Address:

Location Information:

Metal Container Corporation

42 Tenbrook Industrial Park, Arnold, MO 63010

Jefferson County, S28, T43N, R6E

Application for Authority to Construct was made for: Increase production on Lines 5 and 6 and removal of permanent total enclosures. This review was conducted in accordance with Section (7) of Missouri State Rule 10 CSR 10-6.060, Construction Permits Required.

D Standard Conditions (on reverse) are applicable to this permit.

~ Standard Conditions (on reverse) and Special Conditions are applicable to this permit.

0Mviffva ~ Prepared by Alana Hess New Source Review Unit

Director or' esignee Department of Natural Resources

DEC 2 1 2016 Effective Date

STANDARD CONDITIONS:

Permission to construct may be revoked if you fail to begin construction or modification within 18 months from the effective date of this permit. Permittee should notify the Enforcement and Compliance Section of the Air Pollution Control Program if construction or modification is not started within 18 months after the effective date of this permit, or if construction or modification is suspended for one year or more.

You will be in violation of 10 CSR 10-6.060 if you fail to adhere to the specifications and conditions listed in your application, this permit and the project review. In the event that there is a discrepancy between the permit application and this permit, the conditions of this permit shall take precedence. Specifically, all air contaminant control devices shall be operated and maintained as specified in the application, associated plans and specifications.

You must notify the Enforcement and Compliance Section of the Department's Air Pollution Control Program of the anticipated date of startup of these air contaminant sources(s). The information must be made available within 30 days of actual startup. Also, you must notify the Department's St. Louis Regional Office within 15 days after the actual startup of these air contaminant source(s).

A copy of the permit application and this permit and permit review shall be kept at the installation address and shall be made available to Department's personnel upon request.

You may appeal this permit or any of the listed special conditions to the Administrative Hearing Commission (AHC), P.O. Box 1557, Jefferson City, MO 65102, as provided in RSMo 643.075.6 and 621.250.3. If you choose to appeal, you must file a petition with the AHC within 30 days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed. If it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the AHC.

If you choose not to appeal, this certificate, the project review and your application and associated correspondence constitutes your permit to construct. The permit allows you to construct and operate your air contaminant sources(s), but in no way relieves you of your obligation to comply with all applicable provisions of the Missouri Air Conservation Law, regulations of the Missouri Department of Natural Resources and other applicable federal, state and local laws and ordinances.

The Air Pollution Control Program invites your questions regarding this air pollution permit. Please contact the Construction Permit Unit using the contact information below.

Contact Information: Missouri Department of Natural Resources

Air Pollution Control Program P.O. Box 176

Jefferson City, MO 65102-0176 (573) 751-4817

The regional office information can be found at the following website: http://dnr.mo.gov/regions/

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Project No. 2016-02-047 Permit No.

122016-007 SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

The special conditions listed in this permit were included based on the authority granted the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643. 07 5) and by the Missouri Rules listed in Title 10, Division JO of the Code of State Regulations (specifically 10 CSR 10-6. 060). For specific details regarding conditions, see IO CSR I 0-6. 060(12)(A) 10. "Conditions required by permitting authority. "

Metal Container Corporation Jefferson County, S28, T43N, R6E

1. Superseding Condition The conditions of this permit supersede all special conditions found in Construction Permits 052012-016, 032014-003, and 032014-003A previously issued by the Air Pollution Control Program.

2. HAP Emission Limitations A. Metal Container Corporation shall emit less than 10.0 tons individually and 25.0

tons combined of HAPs in any consecutive 12-month rolling period from the entire installation as listed in Table 1.

Table 1: All HAP Emission Sources at Metal Container Corporation Emission ·.··•

Point HAP Emission Source Description

8001 (9) Make-up Air Units, 40.9 MMBtu/hr total natural gas 8002 Fire Water Heater, 1. 75 MM Btu/hr natural gas 8003 (3) Boilers, 6.3 MMBtu/hr each natural gas 8004 Water Heater, 2.6 MMBtu/hr natural gas 8504 Line 5 Water Heater, 2.6 MMBtu/hr natural gas 8604 Line 6 Water Heater, 2.6 MMBtu/hr natural gas 8005 Lines 1 - 4: Catalytic Oxidizer, 13.5 MMBtu/hr natural gas 8006 (21) Space Heaters, 2.5 MM Btu/hr total natural gas

...

8508 Line 5 Regenerative Thermal Oxidizer, 2.2 MMBtu/hr natural gas 8608 Line 6 Regenerative Thermal Oxidizer, 2.2 MMBtu/hr natural gas E001 Emergency Fire Pump Engine, 310 HP diesel P003 Lines 1 - 4: Can Washer Oven, 1.16 MMBtu/hr natural gas P503 Line 5 Can Washer Oven, 1.16 MMBtu/hr each natural gas P603 Line 6 Can Washer Oven, 1.16 MMBtu/hr each natural gas

P004 Lines 1 - 4: (3) Basecoaters and (3) Basecoater Ovens, 2.52 MMBtu/hr each natural gas

P504 Line 5 Basecoater and Basecoater Oven, 2.52 MM Btu/hr

P005 Lines 1 - 4: (5) Decorator Ovens, 2.52 MMBtu/hr each natural gas

P505 Line 5 Varnisher and Decorator Oven, 2.52 MMBtu/hr natural gas

P605 Line 6 (2) Varnishers and (2) Decorator Ovens, 2.52 MMBtu/hr each natural gas

P006 Lines 1 - 4: (5) Varnishers, (4) Inside Spray, Respray, and (4) Inside Spray Ovens, 3.43 MMBtu/hr each, natural gas

P506 Line 5 Inside Spray and Inside Spray Oven, 3.43 MMBtu/hr natural gas

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..

~·-

SPECIAL CONDITIONS:

Project No. 2016-02-047 Permit No.

122016-007 The permittee is authorized to construct and operate subject to the following special conditions:

P606 Line 6 Inside Spray and Inside Spray Oven, 3.43 MMBtu/hr

natural gas P508 Line 5 Rinser Oven, 0.4 MMBtu/hr natural gas P608 Line 6 Rinser Oven, 0.4 MMBtu/hr natural gas F001 All lines: Cleanup Solvents T002 10,000 gallon Basecoat Bulk Tank

T002A 500 gallon Basecoat Day Tank T003 10,000 gallon Varnish Bulk Tank

T003A (2) 500 gallon Varnish Day Tanks T004 10,000 gallon Inside Spray Bulk Tank

T004A (3) 500 gallon Inside Spray Day Tanks T501 7,200 gallon Varnish Tank T601 7,200 gallon Varnish Tank

- 900 gallon Diesel Storage Tank - 1,000 gallon Diesel Storage Tank - Formaldehyde Formation in Ovens

B. Attachments A, B, and C or equivalent forms, such as electronic forms, approved by the Air Pollution Control Program shall be used to demonstrate compliance with Special Condition 2.A.

3. Lowest Achievable Emission Rate (LAER) Capture Requirements A. Metal Container Corporation shall design, construct, operate, and maintain

equipment to capture VOC and HAP emissions from P504 Basecoater and Basecoater Oven, P505 Printer, Varnisher, and Decorator Oven, P605 Printers, Varnishers, and Decorator Ovens, P506 Inside Spray and Inside Spray Oven, and P606 Inside Spray and Inside Spray Oven.

8. The overall capture efficiency of Line 5 shall be greater than or equal to 74.6%.

C. The overall capture efficiency of Line 6 shall be greater than or equal to 75.1 %.

D. Metal Container Corporation shall determine the overall capture efficiency of each line during each RTO destruction efficiency test according to the performance testing requirements in Special Condition 11.

E. Metal Container Corporation shall create an operating and maintenance manual for the capture systems. The operating and maintenance manual shall: 1) Identify each capture system pickup point; 2) List all maintenance activities, with inspection schedule, repair actions,

and replacements, etc.; and 3) List all SSM hours, with date, start time, end time, and duration of event.

F. Metal Container Corporation shall install static pressure monitoring devices at each of the capture system pick-up points. Measurements shall be taken at least once every 15 minutes. Metal Container Corporation shall record each measurement. The static pressure shall be negative at each pickup point.

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SPECIAL CONDITIONS:

Project No. 2016-02-047 Permit No.

122016-007

The permittee is authorized to construct and operate subject to the following special conditions:

4. LAER Control Device Requirements - Regenerative Thermal Oxidizers (RTOs) A. Metal Container Corporation shall control voe and HAP emissions from P504

Basecoater and Basecoater Oven, P505 Printer, Varnisher, and Decorator Oven, P605 Printers, Varnishers, and Decorator Ovens, P506 Inside Spray and Inside Spray Oven, and P606 Inside Spray and Inside Spray Oven using regenerative thermal oxidizers as specified in the permit application.

B. The destruction efficiency of each of the regenerative thermal oxidizers shall be greater than or equal to 98% 1.

C. Metal Container Corporation shall monitor and record the combustion chamber operating temperature of each RTO at least once every 15 minutes. The combustion chamber temperature shall be monitored in the firebox of the thermal oxidizer. Each temperature measurement device shall be installed, calibrated, and maintained according to the manufacturer's specifications. The device shall have an accuracy of 0. 75% of the temperature being measured, expressed in degrees Celsius, or ±2.5°C, whichever is greater.

D. The three-hour rolling average operating temperature shall be maintained at a value greater than or equal to the three-hour average operating temperature during the most recent Air Pollution Control Program approved stack test.

E. Metal Container Corporation shall maintain an operating and maintenance log for the regenerative thermal oxidizers which shall include the following: 1) Maintenance activities, with inspection schedule, repair actions, and

replacements, etc.; and 2) SSM hours, with date, start time, end time, and duration of event.

5. LAER VOC Limitations A. Metal Container Corporation shall not discharge voe emissions to the

atmosphere from the RTOs that exceed the following limitations: 1) 0.11 kilogram of voe per liter of coating solids from each basecoat

material. 2) 0.35 kilogram of voe per liter of coating solids from each varnish

material. 3) 0.20 kilogram of voe per liter of coating solids from each inside spray

material.

B. Metal Container Corporation shall demonstrate compliance with Special Condition 5.A according to §60.493.

C. Metal Container Corporation shall emit less than 169.67 tons of VOC in any consecutive 12-month rolling period from Lines 5 and 6 (see Table 2).

1 In cases of insufficient loading to an RTO, compliance with a high destruction efficiency is unachievable.

If such a situation exists, Metal Container Corporation may comply with an alternative standard of less than or equal 30 ppm VOC in the RTO outlet exhaust stream.

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SPECIAL CONDITIONS:

Project No. 2016-02-047

Permit No. l 2 2 l D. ·O o'"'007

The permittee is authorized to construct and operate subject to the following special conditions:

Table 2: Lines 5 and 6 voe Emission Sources Emission voe Emission Source Description · .. · Point .. ·

8504 Line 5 Water heater, 2.6 MMBtu/hr natural gas 8604 Line 6 Water heater, 2.6 MMBtu/hr natural gas 8508 Line 5 Regenerative Thermal Oxidizer, 2.2 MMBtu/hr natural gas 8608 Line 6 Regenerative Thermal Oxidizer, 2.2 MMBtu/hr natural gas P503 Line 5 Can Washer Oven, 1.16 MMBtu/hr natural gas P603 Line 6 Can Washer Oven, 1.16 MMBtu/hr natural gas P504 Line 5 Basecoater and Basecoater Oven, 2.52 MMBtu/hr

P505 Line 5 Printer, Varnisher, and Decorator Oven, 2.52 MMBtu/hr

natural gas

P605 Line 6 (2) Printers, (2) Varnishers, and (2) Decorator Ovens,

2.52 MMBtu/hr each natural gas

P506 Line 5 Inside Spray and Inside Spray Oven, 3.43 MMBtu/hr

natural gas

P606 Line 6 Inside Spray and Inside Spray Oven, 3.43 MMBtu/hr

natural gas P507 Line 5 UV Bottom Coater P607 Line 6 UV Bottom Coater P508 Line 5 Rinser Oven, 0.4 MMBtu/hr natural gas P608 Line 6 Rinser Oven, 0.4 MMBtu/hr natural gas F001 Lines 5 and 6 Cleanup Solvents F002 Lines 5 and 6 Coders T501 7,200 gallon Varnish Tank T601 7,200 gallon Varnish Tank T502 7,200 gallon Inside Sprav Tank T602 7,200 gallon Inside Spray Tank

- Formaldehyde Formation in Ovens

D. Attachments C and Dor equivalent forms, such as electronic forms, approved by the Air Pollution Control Program shall be used to demonstrate compliance with Special Condition 5.C.

6. Control Device Requirement - Mist Eliminators A. Metal Container Corporation shall control particulate emissions from P502

Bodymaker Process and P602 Bodymaker Process using mist eliminators as specified in the permit application.

8. The mist eliminators shall be operated and maintained in accordance with the manufacturer's specifications. The mist eliminators shall be equipped with a gauge or meter, which indicates the pressure drop across the control device. These gauges or meters shall be located such that Department of Natural Resources' employees may easily observe them.

C. Replacement mesh pads for the mist eliminators shall be kept on hand at all times. The mesh pads shall be made of fibers appropriate for operating

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SPECIAL CONDITIONS:

Project No. 2016-02-047 Permit No.

122016-007

The permittee is authorized to construct and operate subject to the following special conditions:

conditions expected to occur (i.e. temperature limits, acidic and alkali resistance, and abrasion resistance).

D. Metal Container Corporation shall monitor and record the operating pressure drop across the mist eliminators at least once every 24 hours. The operating pressure drop shall be maintained at greater than or equal to 0.2 in. H20. If the operating pressure drop is less than 0.2 in. H20, Metal Container Corporation shall take corrective action within eight hours. Corrective action may include any of the following: 1) Filter replacement 2) Repair leaks in hoses and drain lines

E. Metal Container Corporation shall maintain an operating and maintenance log for the mist eliminator which shall include the following: 1) Incidents of malfunction, with impact on emissions, duration of event,

probable cause, and corrective actions; and 2) Maintenance activities, with inspection schedule, repair actions, and

replacements, etc.

7. Control Device Requirement- Baghouses A. Metal Container Corporation shall control particulate emissions from P506 Inside

Spray Process, P606 Inside Spray Process, P508 Necker Process, and P608 Necker Process using baghouses as specified in the permit application.

B. The baghouses shall be operated and maintained in accordance with the manufacturer's specifications. The baghouses shall be equipped with a gauge or meter, which indicates the pressure drop across the control device. These gauges or meters shall be located such that Department of Natural Resources' employees may easily observe them.

C. Replacement filters for the bag houses shall be kept on hand at all times. The filters shall be made of fibers appropriate for operating conditions expected to occur (i.e. temperature limits, acidic and alkali resistance, and abrasion resistance).

D. Metal Container Corporation shall monitor and record the operating pressure drop across the baghouses at least once every 24 hours. The operating pressure drop shall be maintained at greater than or equal to 0.2 in. H20. If the operating pressure drop is less than 0.2 in. H20, Metal Container Corporation shall take corrective action within eight hours. Corrective action may include any of the following: 1) Bag house replacement 2) Component replacement (if plugged or worn) 3) Repair leaks in housing, ducts, and hoods 4) Repair fan

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SPECIAL CONDITIONS:

Project No. 2016-02-047 Permit No.

122016· ... 007

The permittee is authorized to construct and operate subject to the following special conditions:

E. Metal Container Corporation shall maintain an operating and maintenance log for the baghouses which shall include the following: 1) Incidents of malfunction, with impact on emissions, duration of event,

probable cause, and corrective actions; and 2) Maintenance activities, with inspection schedule, repair actions, and

replacements, etc.

8. Alternative Inks/Coatings/Solvents/Cleaning Materials A. When considering the use of an alternative material for Lines 5 and 6 that is

different from the materials listed in the Application for Authority to Construct, Metal Container Corporation shall calculate the potential emissions of all individual hazardous air pollutants in the alternative material and combine those potential emissions with all other potential emissions of that individual HAP associated with Lines 5 & 6.

B. Metal Container Corporation shall seek approval from the Air Pollution Control Program prior to using an alternative material if the potential individual HAP emissions from Lines 5 & 6 combined while using the alternative material are greater than or equal to the SMAL. A listing of SMALs can be obtained at: http://dnr.mo.gov/env/apcp/docs/cp-hapraltbl6.pdf and are also available in Attachment F.

C. Attachment E or an equivalent form, such as an electronic form, approved by the Air Pollution Control Program shall be used to demonstrate compliance with Special Condition 9.A.

9. Operational Requirement- Inks/Solvents/Coatings Metal Container Corporation shall keep all inks, solvents, cleaning materials, and coatings in sealed containers or tanks whenever the materials are not in use. Metal Container Corporation shall provide and maintain suitable, easily read, permanent markings on all ink, solvent, cleaning material, and coating containers used by Lines 5 and 6.

10. Record Keeping and Reporting Requirements A. Metal Container Corporation shall maintain all records required by this permit for

not less than five years and shall make them available immediately to any Missouri Department of Natural Resources' personnel upon request. These records shall include SOS for all materials used.

B. · Metal Container Corporation shall report to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, no later than 10 days after the end of the month during which any record required by this permit shows an exceedance of a limitation imposed by this permit.

11. Performance Testing - Lines 5 & 6 Capture Systems and RTOs A. Metal Container Corporation shall conduct performance testing to determine the

destruction efficiency of the RTOs (for compliance with Special Condition 4.8) and to establish the minimum three-hour rolling average RTO operating

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Project No. 2016-02-047

Permit No.1 2 2 0 1 6 - 0 0 7 SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

temperature (for Special Condition 4.D). Initial testing shall occur no later than 60 days after achieving maximum production of each line, but no later than 180 days after the initial startup of each line. Subsequent testing shall occur once per year no later than 365 days after the most recent test.

B. Metal Container Corporation shall conduct performance testing to verify that the average formaldehyde emission rate from both RTOs combined does not exceed 1.18 x 10-5 lb/can. If the average formaldehyde emission rate exceeds 1.18 x 10-6

lb/can, Metal Container Corporation shall apply for an amendment to this permit no later than 180 days after the stack test date. The amendment application shall include formaldehyde modeling demonstrating that formaldehyde emissions from Lines 5 and 6 combined do not exceed Missouri's formaldehyde RAL.

C. During each RTO performance test, Metal Container Corporation shall determine the capture efficiency of each capture system (for compliance with Special Conditions 3.8 and 3.C) by: 1) Determining the potential uncontrolled VOC emissions (lb/hr) from each

lines' basecoater, printers, varnishers, and inside spray machines by: a) Recording the amount of each material used by each basecoater,

printer, varnisher, and inside spray machine during each RTO performance test run.

b) Calculating the potential uncontrolled VOC emissions during each RTO performance test run using the VOC contents from the SOS for each material used.

2) Determine the capture efficiency of the line by dividing the RTO inlet VOC emissions by the sum of all potential uncontrolled VOC emissions from the lines' basecoater, printer(s), varnisher(s), and inside spray machine.

3) The average capture efficiency for each line from all three performance test runs shall be used to determine compliance.

D. Metal Container Corporation shall determine the appropriate EPA test method for determining their voe emissions by conducting a pre-survey using Method 18, Method 207, or other approved test method, to ensure that the ratio of known voe peak area to total voe peak area is at least 95%.

E. A completed Proposed Test Plan Form (enclosed) shall be submitted to the Air Pollution Control Program 30 days prior to the proposed test date so that the Air Pollution Control Program may arrange a pretest meeting, if necessary, and assure that the test date is acceptable for an observer to be present. The Proposed Test Plan may serve the purpose of notification and shall be approved by the Director prior to conducting the required emission testing.

F. One electronic report of the performance test results shall be submitted to the Director within 30 days of completion of any required testing. The report must include legible copies of the raw data sheets, analytical instrument laboratory data, and complete sample calculations from the required U.S. EPA Method for at least one sample run.

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SPECIAL CONDITIONS:

Project No. 2016-02-047 Permit No.

122016-007

The permittee is authorized to construct and operate subject to the following special conditions:

G. The test report is to fully account for all operational and emission parameters addressed both in the permit conditions as well as in any other applicable state or federal rules or regulations, including: 1) The quantity of cans produced by each line during each performance test

run.

12. VOC Offsets A. Metal Container Corporation shall obtain VOC offsets in the amount of 157.63

tons.

8. Prior to removal of the permanent total enclosures on Lines 5 and 6 and exceedance of the 40.0 tons per VOC limit established by Construction Permit 032014-003A, Metal Container Corporation shall have an approved Notice of Intent to Use Emissions Reduction Credits (ERC) for the amount of VOC offsets indicated in Special Condition 12.A.

13. Fuel Restriction Metal Container Corporation shall exclusively combust pipeline-grade natural gas in the water heaters (8504 & 8604), thermal oxidizers (8508 & 8608), can washer ovens (P503 & P603), basecoater oven (P504), decorator ovens (P505 & P605), inside spray ovens (P506 & P606), and rinser ovens (P508 & P608).

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REVIEW OF APPLICATION FOR AUTHORITY TO CONSTRUCT AND OPERATE SECTION (7) REVIEW

Installation Address: Metal Container Corporation 42 Tenbrook Industrial Park Arnold, MO 63010

Project Number: 2016-02-047 Installation ID Number: 099-0044

Permit Number: 122016-007 Parent Company: Anheuser-Busch Companies Inc. 1 Busch Place St. Louis, MO 63118

Jefferson County, S28, T43N, R6E

REVIEW SUMMARY

• Metal Container Corporation has applied for authority to increase production on Lines 5 and 6 and remove the permanent total enclosures around the basecoater, printers, varnishers, and inside spray machines and their associated ovens.

• The application was deemed complete on September 14, 2016.

• HAP emissions are expected from the proposed equipment. HAPs will be emitted from the coating operations and natural gas combustion.

• 40 CFR Part 60, Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 is not applicable to installation. The four new tanks permitted for installation by this project (T501, T601, T502, and T602) each have a capacity of 7,200 gallons (27.3 m3

) which is less than the applicability threshold of 75 m3 at §60.11 Ob(b).

• 40 CFR Part 60, Subpart WW - Standards of Performance for the Beverage Can Surface Coating Industry is applicable to each exterior basecoating, overvarnish, and inside spray operation at the installation. The LAER requirements in this permit for Lines 5 and 6 are more stringent than 40 CFR Part 60, Subpart WW; therefore, for Lines 5 and 6, Metal Container Corporation only needs to comply with §60.493, §60.495 (except all references to voe limits in §60.492 shall be replaced by the voe limits in Special Condition 5.A), and §60.496.

• 40 CFR Part 63, Subpart T - National Emission Standards for Halogenated Solvent Cleaning is not applicable to the installation. The parts washer is not permitted to use a solvent containing methylene chloride (75-09-2), perchloroethylene (127-18-4), trichloroethylene (79-01-6), 1, 1, 1-trichloroethane (71-55-6), carbon tetrachloride (56-23-5), or chloroform (67-66-3).

• 40 CFR Part 63, Subparts KK, KKKK, and DDDDD - are not applicable to the installation at this time as the installation has been complying with a synthetic minor HAP limit in their Part 70 operating permit and will remain a synthetic minor HAP source after this permit due to Special Condition 2.

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• 40 CFR Part 63, Subpart HHHHHH - National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources is not applicable to the installation at this time as the coating materials in the permit application do not contain compounds of chromium, lead, manganese, nickel, or cadmium. Special Condition 8 allows for the use of alternative coatings; therefore, this regulation may become applicable in the future.

• RTOs are being used to control VOC and HAP emissions from P504 Basecoater and Basecoater Oven, P505 Printer, Varnisher, and Decorator Oven, P605 Printers, Varnishers, and Decorator Ovens, P506 Inside Spray and Inside Spray Oven, and P606 Inside Spray and Inside Spray Oven. Mist eliminators are being used to control particulate emissions from P502 Bodymaker Process and P602 Bodymaker Process. Baghouses are being used to control particulate emissions from P506 Inside Spray Process, P606 Inside Spray Process, P508 Necker Process, and P608 Necker Process.

• This review was conducted in accordance with Section (7) of Missouri State Rule 10 CSR 10-6.060 Construction Permits Required. The installation is an existing major source in a nonattainment area and potential project VOC emissions are above the significant emission rate/de minimis level.

• This installation is located in Jefferson County, a nonattainment area for the 2008 eight-hour ozone standard and the 1997 PM2_5 standard and an attainment area for all other criteria pollutants. Part of Jefferson County is a nonattainment area for the 1978 and 2008 lead standards and the 2010 S02 standard; however, this installation is not located in that part of Jefferson County.

• Ambient air quality modeling was not performed for this review. No model is currently available which can accurately predict ambient ozone concentrations caused by this installation's VOC emissions. Project emissions of each individual HAP are below their respective SMALs; therefore, no ambient air quality modeling of HAPs was required.

• Emissions testing is required by Special Condition 11 to demonstrate compliance with the project's LAER capture and destruction efficiencies.

• A Part 70 operating permit renewal application is required to be submitted by no later than May 30, 2016. The installation shall update the renewal application to include the provisions of this Nonattainment New Source Review (NNSR) permit no later than 90 days after the issuance date of this permit.

• Approval of this permit is recommended with special conditions.

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~' . ,

INSTALLATION DESCRIPTION

Metal Container Corporation produces aluminum beverage containers in Arnold, Missouri. The installation consists of six production lines -four 12 oz. can lines and two 16 oz. bottle lines. Operations include can/bottle forming, coating, drying, and curing. Coating operations include bottom coat, basecoat, ink, overvarnish, and inside spray. The four can lines produce the bottom section of two-piece beverage cans. The two bottle lines produce the bottom section of two-piece aluminum beverage bottles. The installation does not produce can tops or bottle caps and does not fill the cans/bottles they produce.

The installation is an existing major stationary source of VOC and NOx for both Title V and NSR purposes. The installation is an existing major stationary source of PM10, PM2.s, and CO for Title V purposes only.

The following New Source Review permits have been issued to Metal Container Corporation by the Air Pollution Control Program.

T bl 3 P a e ·t H" t erm1 IS Ory

Permit Number Description 0279-001 to

PSD permit for the installation of three can lines (Lines 1, 2, and 3) 0279-017 0486-001 Minor permit for the installation of one can line (Line 4)

0287-001 to NNSR permit for the installation of one can line (Line 5) [Never constructed] 0287-004

0589-001A Minor permit for the replacement of Line 3's inside spray equipment

0789-003 Minor permit for the installation of cartridge filters on the inside spray equipment

1291-001 Minor permit for the installation of a lime storage silo 0893-028 Minor permit for the installation of two inside spray machines on Line 4 0494-010 Minor permit for the installation of bulk varnish storaoe tanks 0495-018 Minor permit for the installation of an ink dot identification system

052012-016 Synthetic minor permit for the installation of Line 5 032014-003 Synthetic minor permit to increase the production capacity of Line 5

032014-003A Amendment allowing increased production to occur through the installation of Line 6 rather than an expansion of Line 5

PROJECT DESCRIPTION

Metal Container Corporation has requested to increase the production capacity of Lines 5 and 6 and remove the permanent total enclosures required by Construction Permit 032014-003A.

Lines 5 and 6 Permitting History

Line 5 was originally permitted by Construction Permit 052012-016 to produce 1,440 16 oz. aluminum bottles per minute. Line 5 was limited to 40 tons per year of VOC emissions to avoid NNSR permitting. The installation believed that they could achieve their desired production rate and demonstrate compliance with the 40 tons per year VOC limit by using permanent total enclosures on the basecoat, inside spray, and decorator processes.

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The production capacity of Line 5 was increased to 2,250 bottles per minute by Construction Permit 032014-003. Line 5 was again limited to 40 tons per year of voe emissions to avoid NNSR permitting. The installation still believed that they could achieve their desired production rate and demonstrate compliance with the 40 tons per year VOC limit by using permanent total enclosures on the basecoat, inside spray, and decorator processes.

Instead of increasing the capacity of Line 5, the installation decided it would be easier to install two bottle lines (Lines 5 and 6) each with a production capacity of 1, 125 bottles per minute in Construction Permit 032014-003A. Lines 5 and 6 combined were again limited to 40 tons per year of VOC emissions to avoid NNSR permitting. The installation believed that they could achieve their desired production rate and demonstrate compliance with the 40 tons per year voe limit by using permanent total enclosures on the basecoat, inside spray, and decorator processes.

Lines 5 and 6 Current Status

Both Lines 5 and 6 have been constructed and production-for-sale (i.e. start-up) of Line 5 occurred in November of 2013; however, startup has not yet occurred on Line 6.

The resealable aluminum bottle being produced by the installation is the first of its kind in the world. As with any new process to manufacture such a complex container, the installation was faced with operational challenges and technological advances during the design and startup of the facility. In addition, demand for the product far exceeded expectations requiring quick decisions on how to best move forward with expanding the operational capacity of the facility. The installation realized early on that the two biggest challenges to operations were the permanent total enclosures around the printing operations and the speed of the bottle can making equipment that creates the twist off feature of the bottle. The permanent total enclosures created a room where the odor of the overvarnish applied to the bottle was overpowering. This prevented workers from working continuously in the room to monitor the running conditions and make necessary adjustments to equipment. The installation worked with its supplier to reduce, or change the odor of the overvarnish, with no success. The installation increased the exhaust flows in the room, fresh air intake, and increased air changes, which had no impact on the odor that was contained within the room during operation of the decorator.

The buildup of heat and odor resulted in product quality issues and employee discomfort; therefore, the installation has requested that the requirement to operate permanent total enclosures be removed. The removal of the requirement to operate the permanent total enclosures means that the facility will be unable to meet their production goals while limiting voe emissions to less than 40 tons per year; therefore, the installation of Lines 5 and 6 no longer qualifies for a minor source permit and is required to obtain this NNSR Permit.

In the NNSR permit application, the line speeds were modified to better align with the true operational capability of the equipment. The facility has worked with the equipment manufacturer on design improvements since Line 5 started up that have provided a better understanding of the consistent line speeds that can be maintained to support production targets.

Lines 5 and 6 Operational Description

Each line begins with the cupper process. Lubricant is flow coated onto the sheets of raw aluminum. The lubricant contains no VOCs or HAPs. Cuppers cut out disks from the lubricated

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raw aluminum and form the disks into cups. Lines 5 and 6 each have two cuppers. Recovered lubricant is stored in T001 a 10,000 gallon tank2

.

After the cupper process, the cups move to the bodymaker processes, P502 and P602, where coolant is applied and the bodymakers draw and iron out the cups to produce the bodies of the bottles. The coolant contains hexa-hydro-1,3,5 tris (2-hydroxyethnaol) s-triazine (4719-04-4) which emits formaldehyde when at temperature of 297°F or greater; however, no formaldehyde emissions are expected as the bodymakers will operate at a temperature of 110°F. Trimmers cut off excess aluminum so that all of the bodies are the correct height. Elevators transport the bottles to washers. Each line has five bodymakers, five trimmers, and one elevator. Each line has a maximum hourly design rate of 1,320 bottles per minute. Particulate emissions from the bodymakers, trimmers, and elevators are controlled by oil mist eliminators (as required by Special Condition 6). All collected coolant is reused. Aluminum scrap generated by the bodymaker process is combined with the aluminum scrap from the cupper process. The scrap aluminum is compressed into briquettes and sent off-site for recycling. All of the scrap aluminum from the cuppers and bodymakers is larger than 100 µm; therefore, no particulate emissions are expected from the handling of scrap aluminum from these sources.

After the bodymaker process, the bottles are washed. The washers remove lubricant from the bottles using hot water supplied by the water heaters, 8504 and 8604. The bottles are then dried by the washer ovens, P503 and P603. Each line has its own water heater, washer, and oven. Each water heater is rated at 3.6 MM8tu/hr natural gas. Each washer oven is rated at 1.16 MM8tu/hr natural gas. The concentrated washing fluid contains 30 wt% hydrofluoric acid. The washing fluid is diluted during use.

After washing and drying, the bottles are sent to a bottom coater, P507 and P607, where the bottom rim of each bottle is coated. The bottom coat is cured with ultraviolet (UV) light. Each line has one bottom coater. The bottom coat is applied by rollers at a rate of 0.06 gallons per hour per line. As the bottom coat is not spray applied, no particulate emissions are expected. The bottom coat has a density of 9.18 lb/gal and contains 0.2 wt% VOC. The bottom coat does not contain any HAPs.

After bottom coating, the bottles on Line 5 are sent to a basecoater, P504, where a white basecoat is applied to each bottle's exterior surface. The basecoat is dried in a basecoat oven, also P504. Line 5 has one basecoater and one basecoat oven. The basecoat is applied by rollers at a rate of 6.47 gallons per hour. As the basecoat is not spray applied, no particulate emissions are expected. The basecoat has a density of 11 lb/gal and contains 8.55 wt% VOC, 1.2 wt% xylene, and 0.6 wt% glycol ethers. The basecoat oven is rated at 2.52 MM8tu/hr natural gas. VOC and HAP emissions from the basecoating process (both the basecoater and oven) are required to be captured and routed to Line 5's RTO (as required by Special Conditions 3 and 4). The capture system is required to achieve a minimum capture efficiency of 65%. For additional discussion of the capture efficiency, please refer to the LAER analysis.

After basecoating (for Line 5) and bottom coating (for Line 6), the bottles are sent to the decorator processes, P505 and P605, where the bottles are printed and then coated with an overvarnish. Line 5 has one printer, one varnisher, and one decorator oven while Line 6 has two printers, two varnishers, and two decorator ovens. Maximum ink usage is 1. 77 gallons per hour per line. The printers are flexographic; therefore, no particulate emissions are expected. The inks being used are constantly changing due to label redesigns; therefore, a theoretical worst-

2 As the lubricant contains no VOCs or HAPs, T001 is not considered an emission source.

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case ink was analyzed for the project. The worst-case ink contains 1.83 lb/gal VOC, 0.054 lb/gal HAP, 0.013 lb/gal formaldehyde, 0.013 lb/gal methanol, 0.00025 lb/gal 1,4-dioxane, 0.026 lb/gal ethylene glycol, 0.00025 lb/gal ethylene oxide, 0.000042 lb/gal hexachlorobenzene, 0.011 lb/gal propylene oxide, and 0.054 lb/gal glycol ethers. Varnish is applied by rollers at a rate of 10.44 gallons per hour per line. As the varnish is not spray applied, no particulate emissions are expected. The varnish has a density of 8.8 lb/gal and contains 25. 7 wt% voe and 0.3 wt% xylene. Each decorator oven is rated at 2.52 MMBtu/hr natural gas. VOC and HAP emissions from the decorator process (which includes the printers, varnishers, and decorator ovens) are required to be captured and routed to each line's RTO (as required by Special Conditions 3 and 4). The capture system is required to achieve a minimum capture efficiency of 65%. For additional discussion of the capture efficiency, please refer to the LAER analysis.

After decorating, the bottles are sent to the inside spray process, P506 and P606, where a protective coating is spray applied to the inside of each bottle. Each line has one inside spray machine and one inside spray oven. Inside spray is applied at a maximum rate of 29.04 gallons per hour per line. The inside spray has a density of 8.45 lb/gal and contains 13.9 wt% voe and 20.6 wt% solids. A transfer efficiency of 80% was deemed conservative for the inside spray process. Material is applied by a wand which is inserted into the bottle. The wand has openings which spray air-atomized coating onto the interior of the bottle. Particulate emissions from the inside spray process are controlled by a baghouse as required by Special Condition 7. voe emissions from the inside spray process (which includes the inside spray machines and inside spray ovens) are required to be captured and routed to each line's RTO (as required by Special Conditions 3 and 4). The capture system is required to achieve a minimum capture efficiency of 83%. For additional discussion of the capture efficiency, please refer to the LAER analysis.

Formaldehyde is formed in the basecoat oven, decorator ovens, and inside spray ovens as a result of chemical reactions involved in the polymerization of the basecoat, decorator ink, and varnish. The inside spray does not produce formaldehyde; however, the basecoat, decorator ink, and varnish are still curing in the inside spray oven resulting in formaldehyde emissions.

After the inside spray process, the bottles are marked with codes for quality control and testing purposes. Each line has one video jet and one ink dot printer which apply the codes. None of the materials used by the coders, F002, contain HAPs. Each video jet printer uses ink, make-up, and wash. The video jet ink has a maximum usage rate of 0.0006 gallons per hour per line. The video jet ink has a density of 7.08 lb/gal and contains 87 wt% VOC. The video jet make-up has a maximum usage rate of 0.0012 gallons per hour per line. The video jet make-up has a specific gravity of 0.81 and contains 50 wt% VOC. The video jet printers and ink dot printers use the same wash. Maximum wash usage is 0.0023 gallons per hour per line. The wash has a specific gravity of 0.805 and contains 100 wt% voe. Each ink dot printer uses ink, make-up, and wash. The ink dot ink has a maximum usage rate of 0.0006 gallons per hour. The ink has a density of 7.08 lb/gal and contains 99 wt% VOC. The ink dot make-up is used at a maximum rate of 0.0012 gallons per hour. The ink dot make-up has a density of 6.66 lb/gal and contains 100 wt% VOC. Emissions from the coders, F002, are vented directly to the atmosphere.

After the coders the bottles enter the necker process, P509 and P609, where the neck of the bottle is formed, flanged, and trimmed. Particulate emissions from the necker process are controlled by a baghouse (as required by Special Condition 7).

After the necking process the bottles are complete. The bottles are rinsed to remove any remaining material from the necking process. Each line has its own rinser and rinser oven. Each rinser oven is rated at 0.4 MMBtu/hr natural gas.

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Captured emissions from P504 Basecoater Process, P505 & P605 Decorator Processes, and P506 & P606 Inside Spray Processes are routed to RTOs. Each RTO is equipped with a 2.2 MMBtu/hr natural gas burner. The RTOs are required to achieve a minimum destruction efficiency of 98%. For additional discussion of the destruction efficiency, please refer to the LAER analysis.

Four new 7,200 gallon vertical fixed roof storage tanks will be installed as part of this project. Two of the tanks will contain varnish while the other two tanks will contain inside spray.

Solvents are used on both lines in cleanup operations, F001. Press cleaning is performed using isopropanol. Maximum isopropanol usage was estimated based on past actual usage on Lines 1 through 4 to be 0.17 gallons per hour. lsopropanol is a VOC with a density of 6.57 lb/gal. Parts cleaning is performed in a parts washer. Maximum parts washer solvent usage was also estimated based on past actual usage on Lines 1 through 4 to be 0.04 gallons per hour. The parts washer solvent contains 6.58 lb/gal voe and no HAPs.

A buildup of varnish and basecoat occasionally requires the wheels of the decorators and basecoater to require retooling. The installation sends the wheels off-site for retooling. When the wheels return they require some grinding. Grinding is performed using a lathe in the installation's tool and dye shop. Particulate emissions from grinding are reported under M001 Grinding. Historically, operation of Lines 1 - 4 have required the grinding of- 60 wheels per year. Although, the production increase for Lines 5 and 6 associated with this project will result in a quicker buildup of varnish and basecoat on the wheels of Lines 5 and 6, the particulate emission increase from M001 Grinding is negligible based on the frequency of past lathe usage.

Metal Container Corporation has requested the flexibility to use alternative materials in the future without revising this permit. In order to ensure that any alternative material meets all necessary permitting requirements the following provisions have been included in this permit:

• Special Condition 2 ensures that the use of the alternative material would not result in the installation becoming a major source of HAPs.

• Special Condition 5.A ensures that the alternative material meets LAER. • Special Condition 5.C ensures that the alternative material does not increase project

VOC emissions (i.e. that additional offsets are not required). • Special Condition 8 ensures that the use of the alternative material would not require

HAP modeling. • Special Condition 11 ensures that the capture systems and RTOs are still meeting LAER

while using the alternative coating.

Per Missouri's SIP-approved NNSR regulation, 10 CSR 10-6.060(7), Metal Container Corporation is required to:

• Obtain sufficient offsets prior to commencing operation. Offsets shall be obtained in accordance with the offset and banking procedures in 10 CSR 10-6.410 (see Special Condition 12).

• Provide documentation establishing that all installations owned or operated by the applicant in the state of Missouri are in compliance with all applicable requirements.

o The applicant has provided their 2015 annual compliance certifications for Metal Container Corporation and the Anheuser-Busch St. Louis Brewery indicating that both installations are in compliance with all applicable requirements.

• Comply with LAER (see LAER analysis and Special Conditions 3.8. 3.C, 4.8, 5.A, 5.C, and 13).

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• Provide an alternative site analysis addressing: o The potential and real adverse environmental effects of the proposed project

have been avoided to the maximum extent possible; • The project will be complying with LAER for voe emissions. The voe

controls also control VOC HAPs such as formaldehyde and glycol ethers. A mist eliminator will control particulate emissions from the bodymaker processes. Baghouses will control particulate emissions from the inside spray processes and necker processes. The project is required to comply with all applicable state and federal regulations. Raw materials stored in tanks will minimize spills to the environment. The tanks will either be located indoors, implement secondary containment, or both. The facility will minimize storm water impacts through the implementation of a storm water plan and controls. Personnel will be routinely trained to identify spill or leaks and to respond appropriately.

o That the social and economic benefits of the project outweigh the environment impact costs.

• 250 temporary construction jobs were created as a result of this project. • Metal Container Corporation hired 137 new employees to operate the

new bottle lines. • Metal Container Corporation invested over$ 290,000,000 on the project.

o Alternative projects or alternative sites or mitigating measures which would offer more protection to the environment than the proposed project without unduly curtailing non-environmental benefits to the extent applicable.

• This proposed project is to expand the facility's existing bottle manufacturing operation. The original bottle line (Line 5) was installed and became operational in 2014. Due to unforeseen technical and operational issues, Line 5 was not able to operation at its maximum rated design. In an attempt to rectify this problem, the facility obtained a permit to reduce Line S's speed and add a second line (Line 6). The existing line will share similar resources such as infrastructure, personnel, equipment,

utilities, etc. with Line 6 as well as the other existing lines (Line 1 through 4). The existing infrastructure encourages location of this project at the existing site. To locate the new lines at another site would require additional resources that would negatively impact environmental resources due to duplication and the need to share resources with the existing plant in its current location.

• In addition, there is an insignificant benefit in having a single bigger line to product the bottles versus multiple smaller production lines. For example, the same amount of coating will be used in either scenario. The facility is seeking to produce the bottles as efficiently as possible, while still maintaining quality and production rates. In that, they are employed what they view as state-of-the-art technology.

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EMISSIONS/CONTROLS EVALUATION

Project emissions were determined to be the sum of the potential-to-emit of Line 6 per §52.21 {a)(2)(iv)(d) and the emissions increase from Line 5 per §52.21 (a)(2)(iv)(c)3. The baseline period was determined to be January 2014 through December 2015. Baseline actual emissions from Line 5 are provided in Table 4.

3 The installation chose to only calculate baseline actual emissions of voe from Line 5; however, they could have calculated baseline actual emissions of PM, PM10, PM2.s, SOx, NOx, and CO as well.

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,'

T bl 4 L. 5 voe B r A t I E . . a e me ase me c ua m1ss1ons (t ons per year ) · .. ·· 2014Actual 2015 Actual Baseline Actual

. Emission Source Emissioms Emissions Emissions . . .

P506 Inside Spray and Inside 4.37 13.19 8.78 Spray Oven

P505 Printer, Varnisher, and 13.03 22.00 17.51

Decorator Oven P507 UV Bottom Coater 0.01 0.01 0.01

F002 Coders 0.04 0.09 0.07 Line 5 Total 17.45 35.29 26.37

Baseline emissions of PM, PM10, PM2.5, HAP, NOx, SOx, CO, and C02e from Line 5 were not submitted as part of the application and were not included in project emissions calculations.

Particulate emissions from the bodymaker process (P502 & P602) were based on mist eliminator controlled stack test data from a sister facility in Jacksonville, FL. Emissions are controlled by mist eliminators as required by Special Condition 6. The applicant estimated the control efficiency of the mist eliminators to be 85% which is in line with AP-42 Table B.2-3's control efficiencies of 90% for high velocity mist eliminators and 75% for low velocity mist eliminators.

Emissions from the combustion of natural gas in the water heaters (8504 & 8604), RTOs (8508 & 8608), washer ovens (P503 & P603), basecoater oven (P504), decorator ovens (P505 & P605), inside spray ovens (P506 & P606), and rinser ovens (P508 & P608) were determined using emission factors obtained from AP-42 Section 1.4 "Natural Gas Combustion" (July 1998).

Emissions from bottom coating (P507 & P607), coding (F002), and cleanup solvents (F001) were determined using a mass balance approach and assuming 100% emission of voes.

Uncontrolled emissions from basecoating (P504), decorating (P505 & P605), and inside spraying (P506 & P606) were determined using a mass balance approach. The minimum capture and control efficiencies from the LAER analysis (Special Conditions 3 and 4) were used to determine the controlled emission rate. Emissions from the formulation of formaldehyde in the ovens were determined using data provided by Metal Container Corporation for a sister facility; however, given the age of the data it was determined that the RTOs need to be tested for formaldehyde to verify the controlled emission factors and ensure that the project remains below Missouri's formaldehyde SMAL (see Special Condition 11 ). Project emissions are based on a maximum of 240 hours of RTO downtime (i.e. uncontrolled emissions) per year.

Emissions from the four new storage tanks were estimated using TANKS4.0.9d. As the worst­case VOC in both the varnish and inside spray is butanol (71-36-3), TANKS4.0.9d was conservatively run assuming each tank contained 100% butanol. The TANKS4.0.9d results were then scaled down using the actual VOC contents of the materials (inside spray: 13. 9 wt% voe, varnish: 25. 7 wt% voe, 0.3 wt% xylene).

Particulate emissions from the necker process (P509 & P609) were determined to be 1 lb/ton of aluminum in the installation's previous Part 70 Operating Permit OP2006-041; however, the basis of the emission factor could not be determined. Emissions are controlled by bag houses as required by Special Condition 7. The applicant estimated the control efficiency of the baghouses to be 95% which is conservative when compared to AP-42 Table 8.2-3's control efficiencies of 99.5%. Although this emission factor could not be verified no performance testing is required as

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PM2.5 emissions from the necker process would have to be 25 times higher than estimated before the project would exceed the PSD significance level.

The following tables provide an emissions summary for this project. Existing potential emissions were taken from Part 70 Operating Permit OP2011-0574 as potential emissions in Construction Permits 052012-016, 032014-003, and 032014-003A include potential emissions from sources included in this project. Existing actual emissions were taken from the installation's 2014 EIQ. Potential emissions of the application represent the potential of the new equipment, assuming continuous operation (8,760 hours per year). The project emissions increase includes the baseline actual emissions from Line 5.

Table 5: Emissions Summary (tpy)

Regulatory Existing Existing Potential Project New Actual Emissions lnstallatic>o

Pollutant DeMinimis Potential Emissions of the Emissions Conditioned

Levels Emissions (2015 EIQ) Project Increase Potential

PM 25.0 N/0 N/0 5.24 5.24 N/A PM10 15.0 27.78 1.87 6.24 6.24 N/A PM2.5 10.0 18.50 1.87 6.24 6.24 N/A SOx 40.0 1.52 0.09 0.10 0.10 N/A NOx 40.0 68.42 14.57 17.41 17.41 N/A voe 40.0 973.11 137.37 169.67 143.30 N/A co 100.0 45.90 8.84 14.63 14.63 N/A

C02e 75,000 60,701.40 N/0 20,942.74 20,942.74 N/A HAPs 25.0 <25.0 9.52 4.37 4.37 <25.0

N/A = Not Applicable; N/0 = Not Determined

4 An error was found in the PTE calculations for Part 70 Operating Permit OP2011-057 and has been corrected in Table 5: the emergency fire pump was evaluated at 8,760 hours of annual operation, but should have been evaluated at 500 hours of annual operation due to its emergency-use only status.

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T bl 6 I d" "d I HAP E . . S a e : n IVI ua m1ss1ons ummary (tons per year)

CAS Existing Actual Project New Installation

Pollutant No.

SMAL Emissions PTE5 PTE

·:···· .-.·· ·.· (2015 EIQ)

Xylene 1330-

10 0.94 2.34 <10.0 20-7

Glycol Ethers 20-10-0 5 5.33 1.03 <10.0 Formaldehvde 50-00-0 2 1.05 0.66 <10.0

Hexane 110-54-

10 N/D 0.31 <10.0 3

Methanol 67-56-1 10 0.02 0.08 <10.0

Ethylene Glycol 107-21-

10 2.21 0.15 <10.0 1

Propylene Oxide 75-56-9 5 N/D 0.06 <10.0 Hydrogen 7664-

0.1 0.03 0.09 <10.0 Fluoride 39-3

N/A = Not applicable; N/D = Not Determined

PERMIT RULE APPLICABILITY

This review was conducted in accordance with Section (7) of Missouri State Rule 1 O CSR 10-6.060, Construction Permits Required. The installation is an existing major source in a nonattainment area and potential project VOC emissions are above the significant emission rate/de minimis level.

APPLICABLE REQUIREMENTS

Metal Container Corporation shall comply with the following requirements applicable to the emission sources contained in this project. The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping, monitoring, and reporting requirements. Compliance with these emission standards, based on information submitted in the application, has been verified at the time this application was approved. For a complete list of applicable requirements for your installation, please consult your operating permit.

GENERAL REQUIREMENTS

• 10 CSR 10-6.065 Operating Permits o Metal Container Corporation is required to update their Part 70 operating permit

renewal application, Project 2016-06-013, to include the provisions of this permit no later than 90 days after the issuance date of this permit.

5 Project potential emissions are based on the materials contained within the application. Special Condition 8 allows the installation to switch materials on Lines 5 & 6 provided project emissions remain below the SMAL for each individual HAP; therefore, project potential emissions may be different in the future.

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• 10 CSR 10-6.11 O Submission of Emission Data, Emission Fees and Process Information o The installation is required to submit a full EIQ each year.

• 10 CSR 10-6.165 Restriction of Emission of Odors

• 10 CSR 10-6.170 Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin

• 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants o Metal Container Corporation shall not discharge into the atmosphere from any

source any visible emissions greater than 20% opacity. o Exception: Metal Container Corporation may for a period not aggregating to more

than six minutes in any 60 minute period emit up to 40% opacity.

SPECIFIC REQUIREMENTS

• 10 CSR 10-5. 300 Control of Emissions From Solvent Metal Cleaning o Metal Container Corporation shall ensure that the parts washer associated with

F001 Cleanup Solvents uses a solvent that has a vapor pressure of less than or equal to 1.0 mmHg at 20°C.

• 10 CSR 10-5.330 Control of Emissions From Industrial Surface Coating Operations o Metal Container Corporation shall not discharge into the ambient air VOC

emission in excess of: • 2.8 pounds of VOC per gallon of coating (minus water and exempt

compounds) from each basecoat material. • 4.2 pounds of VOC per gallon of coating (minus water and exempt

compounds) from each inside spray material. • 4.2 pounds of voe per gallon of coating (minus water and exempt

compounds) from each bottom coat material.

• 10 CSR 10-5.340 Control of Emissions From Rotogravure and F/exographic Printing Operations

o Metal Container Corporation shall not use or permit the use of a flexographic printing press unless the press is equipped with a control device. The control device shall remove, destroy, or prevent the emission of VOCs into the ambient air by at least 60 percent by weight of the uncontrolled VOC emissions on a daily weighted basis.

o The press cleaning solvents shall be kept in tightly-covered tanks or containers during transport and storage.

o The used cleaning cloths contaminated with the cleaning solvents shall be placed in tightly-closed containers while awaiting offsite transportation. The cleaning cloths shall be properly cleaned and disposed of.

• 10 CSR 10-6.070 New Source Performance Regulations o 40 CFR Part 60, Subpart WW - Standards of Performance for the Beverage Can

Surface Coating Industry • Metal Container Corporation shall not discharge or cause the discharge of

VOC emissions to the atmosphere that exceed the following volume­weighted calendar-month average emissions:

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• 0.29 kilograms of voe per liter of coating solids from each two­piece can exterior base coating operation, except clear base coat;

• 0.46 kilograms of voe per liter of coating solids from each two­piece can clear base coating operation and from each overvarnish coating operation; and

• 0.89 kilograms of VOC per liter of coating solids from each two­piece can inside spray coating operation.

• 10 CSR 10-6.075 Maximum Achievable Control Technology Regulations o 40 CFR Part 63, Subpart HHHHHH - National Emission Standards for

Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources

• Metal Container Corporation shall begin complying with this regulation immediately if they begin spray application of coatings containing compounds of chromium, lead, manganese, nickel, or cadmium.

LAER ANALYSIS

Applicability and Scope

Metal Container Corporation is an existing major stationary source located in a marginal ozone nonattainment area. Project potential emissions exceed 40 tons per year of VOC; therefore, LAER requirements apply to VOC. Project potential emissions for all other pollutants are less than the significant emission rates.

Per 51.165(a)(1 )(xiii), lowest achievable emission rate (LAER) means, for any source, the more stringent rate of emissions based on the following:

(A) The most stringent emissions limitation which is contained in the implementation plan of any State for such class or category of stationary source, unless the owner or operator of the proposed stationary source demonstrates that such limitations are not achievable; or (8) The most stringent emissions limitation which is achieved in practice by such class or category of stationary sources. This limitation, when applied to a modification, means the lowest achievable emissions rate for the new or modified emissions units within a stationary source. In no event shall the application of the term permit a proposed new or modified stationary source to emit any pollutant in excess of the amount allowable under an applicable new source standard of performance.

RACT/BACT/LAER Clearinghouse {RBLC)

A review of the RBLC was performed, the following four permits were found for aluminum can manufacturing operations:

1.Metal Container Corporation's PSD Permit (PSD-FL-433) for the installation of a new aluminum 16 oz. bottle coating line at their existing facility in Jacksonville, FL.

2.Ball Metal Beverage Container Corporation's NNSR Permit (3290 and N130) for the installation of a new 16 oz. or 24 oz. can manufacturing line at their existing facility in Fort Worth, TX.

3. Rocky Mountain Metal Container's PSD Permit (01 JE0643) for the modification of three existing can manufacturing lines to increase production at their existing facility in Golden, CO.

4.Sonoco Products' PSD Permit (0290-0BPC) for the modification of the existing composite can end manufacturing plant to increase production.

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In Metal Container Corporation's Jackonsville permit, VOC BACT was established to be: • An RTO with a minimum design destruction efficiency of 95%. • Capture/collection systems on the basecoaters, printer/decorators, and inside spray

lines to route emissions to the RTO. Where each capture/collection system is required to achieve a minimum capture efficiency of:

o 65% from the basecoaters and printer/decorators o 80% from the inside spray operations

• A 12-month rolling total voe emissions limit of 156.2 tons. • voe limits of:

o 0.11 kilograms of VOC per liter of coating solids from each exterior basecoating operation.

o 0.35 kilograms of VOC per liter of coating solids from each overvarnish coating operation; and

o 0.20 kilograms of VOC per liter of coating solids from each inside spray operation.

• Combustion of natural gas in the basecoater ovens, printer pin ovens, and inside bake ovens.

Metal Container Corporation (the parent company for the Jacksonville, FL and the Arnold, MO plant) has not yet completed construction of their Jacksonville plant; therefore, it is not possible to definitively state that the installation will be able to achieve the BACT limits in their PSD permit. Metal Container Corporation has indicated that the new bottle line at Jacksonville, FL while not identical in every way to the new bottle lines being constructed under this NNSR permit are very similar in nature. Metal Container Corporation is confident that their Jacksonville, FL plant will achieve compliance with its BACT limits and that the Arnold, MO plant would also be able to achieve compliance with these limits.

In Ball Metal Beverage Container Corporation's permit, voe LAER was established to be: • A thermal oxidizer with a destruction efficiency of 98% or greater. • A planned maintenance, startup, and shutdown limit for the thermal oxidizer of 240 hours

per 12-month rolling period. • Ventilation systems on the inside spray machines, internal bake ovens, and the pin

ovens. The ventilation systems are required to achieve an overall capture efficiency of 80%.

• Combustion of natural gas in the ovens, water heaters, and thermal oxidizer. • All coatings are required to comply with 30 TAC Chapter 115, Subchapter E, Division 2,

Surface Coating Processes and 40 CFR Part 60, Subpart WW - Standards of Performance for the Beverage Can Surface Coating Industry.

• 12-month rolling total VOC emissions limits of: o 0.15 tons per year from the washer dryers o 1. 75 tons per year from the D and I Cyclones and Trim Ring Cyclone o 0.08 tons per year from Storage Tanks o 27.85 tons per year from Inside Sprayers, Inside Spray Ovens, Printer, and Parts

Washer Fugitives o 4.20 tons per year from Overvarnish Coaters o 8. 10 tons per year from Thermal Oxidizer o 21 . 79 tons per year from Inside Spray Elevators o 0.07 tons per year from Washer Oven o 0.30 tons per year from Water Heaters o 16.51 tons per year from 180 Fugitives

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/1

.. :"

o 7.42 tons per year from Printer Fugitives o 5.15 tons per year from Printer Stack o 5.50 tons per year from 180 Conveying Hood o 0.44 tons per year from New Cyclone o 0.30 tons per year from Bypass Inside Spray Line o 2.11 tons per year from 180 Bypass (MSS) o 1.30 tons per year from PO Bypass (MSS)

Ball Metal Beverage Container Corporation conducted capture and destruction efficiency testing to demonstrate compliance with their LAER limits on October 31st and November 1st of 2012. The results, which were approved by TCEQ Region 4, indicate that the thermal oxidizer achieved a destruction efficiency of 98. 7% at a set point of 1,550°F. The capture systems achieved an overall efficiency of 86.2%.

In Rocky Mountain Metal Container's permit, VOC BACT was established to be: • A 12-month rolling total voe limit of 257.4 tons. • 40 CFR Part 60, Subpart WW compliant coatings. • Sheet basecoat (exterior and interior) and overvarnish two-piece can exterior (base coat

and overvarnish) voe limits 0.34 kilograms per liter of coating. • Two and three-piece can interior body spray, two-piece can exterior end (spray and roll

coat) voe limits of 0.51 kilograms per liter of coating. • Fugitive emissions were limited by requiring tight fitting covers for open tanks, covered

containers for solvent wiping cloths, and proper disposal of dirty cleanup solvent. • Overvarnish was limited to 0.08 kilograms of VOC per liter of solids (controlled). • Internal coating was limited to 0.21 kilograms of VOC per liter of solids (controlled). • Ink was limited to less than or equal to 20% VOC content by weight (uncontrolled). • Cleaning solvents were limited to less than or equal to 50% VOC content by weight. • Thermal oxidizers were required to reduce uncontrolled VOC emissions by at least 76%

(overall capture and control efficiency).

As the overall capture and control efficiency for Rocky Mountain Metal Container is less than the overall capture and control efficiency realized by Ball Metal Beverage Container Corporation it was deemed unnecessary to obtain documentation from Colorado indicating if Rocky Mountain Metal Containers was able to achieve their BACT limits in practice.

Sonoco Products never constructed the modifications in PSD Permit 0290-08PC. As construction was not commenced within 18 months after the issuance of the permit, the

modifications cannot occur without the issuance of a new PSD permit. None of the limitations in this permit were deemed relevant to this LAER analysis as the limitations have not been shown to be achievable in practice.

Comparing the three relevant permits in the RBLC and considering the guidance given to the Colorado Department of Health by EPA regarding the never issued LAER analysis for Coors Container Corporation6

, LAER for this project should consist of the following: 1. Capture and control efficiency requirements for the main coating operations:

6 From EPA's New Source Review Policy and Guidance Document Index (https://www.epa.gov/nsr/new-source-review-policy-and-guidance-document-index). A February 6, 1990 letter addressed to Brad Beckham, Director of Colorado Department of Health's Air Pollution Control Program, from Douglas M. Skie, Air Programs Branch Chief.

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basecoating, decorating, and inside spray. 2. Coating restrictions on a normalized basis. 3. Restrictions on fuel type. 4. Restrictions on SSM emissions.

Capture Efficiency

Applicant Proposal: 65% for the basecoating and decorating operations and 80% for the inside spray operations.

Metal Container Corporation's Jacksonville, FL plant's BACT: 65% for the basecoating and decorating operations and 80% for the inside spray operations.

Ball Metal Beverage Container Corporation's stack test confirmed LAER: 86.2% from the inside spray operations.

The applicant's proposed capture efficiency of 65% for basecoating and decorating operations is considered LAER as no more stringent emissions limitation has been found or been demonstrated to be achievable by a similar operation.

The applicant's proposed capture efficiency of 80% for inside spray operations is less stringent than Ball Metal Beverage Container Corporation's documented capture efficiency of 86.2%. Because Ball Metal Beverage Container Corporation produces 16 oz. or 24 oz. beverage cans rather than the 16 oz. beverage bottles produced by the applicant there are physical differences in how the inside spray machines operate which may result in 86.2% capture being unachievable for the applicant. The Air Pollution Control Program believes that LAER for Metal Container Corporation is a capture efficiency of 83% from the inside spray operations.

As multiple coating operations are routed to a single thermal oxidizer on each line, determining the actual capture efficiency of each coating operation was determined to be inappropriate for the following reasons:

• Finding locations that meet stack testing requirements in the capture system ductwork after each coating operation but prior to the mixing of captured emissions from another coating operation is not possible given the current design of the ductwork.

• Captured emissions could be lost after the stack testing point before the RTO inlet. It was determined that compliance with LAER capture efficiency for each coating operation should be demonstrated by calculating an overall capture efficiency for each line. Where the

overall capture efficiency of each line was determined using a mass balance approach to determine total VOC emissions from each coating operation, applying the LAER capture efficiencies (65% for basecoating and decorating operations and 83% for inside spray operations), summing each lines' captured emissions, and then dividing by the sum of each lines' total voe emissions. Using this calculation methodology the overall capture efficiency for Line 5 was determined to be 74.6% (see Special Condition 3.8) and the overall capture efficiency for Line 6 was determined to be 75.1% (see Special Condition 3.C).

Control Efficiency

Applicant proposal: 97% destruction efficiency by a regenerative thermal oxidizer (RTO). Metal Container Corporation's Jacksonville, FL plant's BACT: 95% destruction by an RTO.

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••. ~ - •. ·. . .

Ball Metal Beverage Container Corporation's stack test confirmed LAER: 98. 7% destruction by a thermal oxidizer.

The applicant's proposed destruction efficiency of 97% is less stringent than Ball Metal Beverage Container Corporation's documented destruction efficiency of 98. 7%. Because Ball Metal Beverage Container Corporation and the applicant use different coatings and some VOCs are easier than others to destroy, 98. 7% destruction efficiency may not be achievable by the applicant. The Air Pollution Control Program believes that LAER for Metal Container Corporation is a destruction efficiency of 98%. This LAER requirement can be found in Special Condition 4.8.

Coating Limitations

Applicant proposal: NSPS WW and 10 CSR 10-5.330 compliant coatings.

Metal Container Corporation's Jacksonville, FL plant's BACT: 0.11 kilograms of voe per liter of coating solids from each exterior basecoating operation, 0.35 kilograms of voe per liter of coating solids from each overvarnish coating operation; and 0.20 kilograms of VOC per liter of coating solids from each inside spray operation.

Ball Metal Beverage Container Corporation's LAER: NSPS WW and 30 TAC Chapter 115, Subchapter E compliant coatings.

The applicant's proposed coating limitations are less stringent than those contained in their Jacksonville, FL plant's BACT analysis. As the Jacksonville plant and the Arnold plant will be using the same coatings, the Air Pollution Control Program believes that LAER is 0.11 kilograms of VOC per liter of coating solids from each exterior basecoating operation, 0.35 kilograms of VOC per liter of coating solids from each overvarnish coating operation; and 0.20 kilograms of VOC per liter of coating solids from each inside spray operation. These LAER requirements can be found in Special Condition 5.A.

Additionally, the UV bottom coating shall comply with 10 CSR 10-5.330, the parts washer shall comply with the solvent restrictions in 10 CSR 10-5.300, and the inks and press cleaning solvents shall comply with 10 CSR 10-5.340.

Fuel Limitations

Applicant proposal: all combustion sources operate exclusively using natural gas.

Metal Container Corporation's Jacksonville, FL plant's BACT: all ovens are limited to combusting natural gas.

Ball Metal Beverage Container Corporation's LAER: the ovens, water heaters, and thermal oxidizer are limited to combusting natural gas.

The Air Pollution Control Program believes that LAER for this project is the combustion of natural gas in all combustion sources. This LAER requirement can be found in Special Condition 13.

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SSM Limitations

Applicant proposal: the applicant did not account for SSM emissions in their application.

Metal Container Corporation's Jacksonville, FL plant's BACT: limited to 156.2 tons of VOC per 12-month rolling period.

Ball Metal Beverage Container Corporation's LAER: limited to 240 hours of thermal oxidizer SSM time per 12-month rolling period.

The Air Pollution Control Program believes that LAER for this project is 169.67 tons of VOC per 12-month rolling period. This limit was calculated based on the voe contents of the materials presented in the application (which comply with all state and federal regulations and the LAER coating restrictions), the capture efficiency of 65% for basecoating and decorating operations, the capture efficiency of 83% for the inside spray operations, and the destruction efficiency of 98% for the RTO for 8,520 hours per year (i.e. 240 hours per year of uncontrolled SSM emissions). This LAER requirement can be found in Special Condition 5.C.

STAFF RECOMMENDATION

On the basis of this review conducted in accordance with Section (7) of Missouri State Rule 10 CSR 10-6.060 Construction Permits Required, it is recommended that this permit be granted with special conditions.

PERMIT DOCUMENTS

The following documents are incorporated by reference into this permit:

• The Application for Authority to Construct form, dated February 22, 2016, received February 24, 2016, supplemented March 21, 2016, supplemented and revised May 20, 2016, supplemented and revised June 25, 2016 designating Anheuser-Busch Companies Inc. as the owner and operator of the installation.

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.

Attachment A - Installation-wide Combined HAP Compliance Worksheet

Metal Container Corporation Jefferson County, S28, T43N, R6E Project Number: 2016-02-047 Installation ID Number: 099-0044 Permit Number:

This sheet covers the month of _____ in the year of _____ _

.. . · .. .· .. Storage Tanks. - Working Losses · .. ··. .

Name of Monthly Emission Emission Description Material Usage Factor7

Point ··.

Stored (Mgal) (lb/Mgal) .·.·

T002 10,000 Qallon Basecoat Bulk Tank T003 10,000 gallon Varnish Bulk Tank T004 10,000 gallon Inside Spray Bulk Tank Diesel 1,000 gallon Tank Tanks 900 Qallon Tank

T002A 500 gallon Basecoat Day Tank

T003A (2) 500 gallon Varnish Day Tanks T004A (3) 500 gallon Inside Spray Day Tanks T501 7,200 gallon Varnish Tank 7.99E-04 T601 7,200 Qallon Varnish Tank 7.99E-04

Storage Tanks -- Breathing Losses

Emission · Name of HAP Emissions7

Description Material Point

Stored (lb/yr)

T002 10,000 Qallon Basecoat Bulk Tank T003 10,000 Qallon Varnish Bulk Tank T004 10,000 gallon Inside Spray Bulk Tank Diesel 1,000 gallon Tank Tanks 900 Qallon Tank T002A 500 gallon Basecoat Day Tank T003A (2) 500 gallon Varnish Day Tanks T004A (3) 500 gallon Inside Spray Day Tanks T501 7,200 Qallon Varnish Tank 1.48E-02 T601 7,200 Qallon Varnish Tank 1.48E-02

HAP Emissions8

(lb/month)

HAP Emissions9

(lb/month)

7 Tank emission factors shall be obtained from EPA's TANKS 4.0.9d for the chemical stored/used. The permittee shall maintain a copy of the TANKS 4.0.9d detailed annual emissions report printout for each tank so that the emission factors can be verified. 8 HAP Emissions (lb/month) = Monthly Usage (Mgal) x HAP Emission Factor (lb/Mgal). 9 HAP Emissions (lb/month) = HAP Emissions (lb/yr) / 12 (months/yr)

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Surface Coating Operations ·: Overan SS.NI Time 14 Name Monthly HAP I: HAP

Emission of Usage Density11 Content Control (% of Qperating· Emission$15

Point10 (lb/gal) Efficiency13 Material (gal} 12(wt%)

(%) •time) (lb/month) .•

10 The permittee shall use this section of the tracking sheet to track HAP emissions from each surface coating

material used by P004 Basecoaters; P504 Basecoater; P505 Printer and Varnisher; P605 Printers and Varnishers; P006 Printers, Varnishers, Inside Spray, and Respray; P506 Inside Spray; P606 Inside Spray; and F001 Cleanup Solvents. 11

As obtained from the SOS for the material. If the specific gravity (s.g.) is listed, the density can be obtained from the following equation: Density (lb/gal) = specific gravity x 8.33 lb/gal. 12

As obtained from the SOS for the material. If multiple HAPs are listed, the combined HAP content (wt%) is the sum of each individual HAP's content (wt%). If the HAP content is listed as a range of values, the highest value in the range shall be used to demonstrate compliance. 13

As obtained from the most recent Air Pollution Control Program approved stack test. Emissions from P004 and P006 are captured and routed to a catalytic thermal oxidizer. The currently approved overall control efficiency for P004 Basecoating and P005 Inside Spray is 72% (80% capture and 90% destruction) and for P006 Printers and Varnishers is 45% (50% capture and 90% destruction). Emissions from P504, P505, P605, P506, and P606 are captured and routed to regenerative thermal oxidizers. The currently approved overall control efficiency for P504 is 63. 7% (65% capture and 98% destruction), for P505 and P605 is 63. 7% (65% capture and 98% destruction), and for P506 and P606 is 81.34% (83% capture and 98%destruction). Emissions from F001 are uncontrolled. 14 As obtained from Attachment C. 15

HAP Emissions (lb/month)= Monthly Usage (gal) x Density (lb/gal) x HAP Content (wt%) x [1 - Overall Control Efficiency(%) x (1 - SSM Time(% of operating time))]

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.·

I

:.·: Formaldehyde Formation Monthly Formation Destruction SSM Time14 HAP

Line Production Factor16 Efficiency17 (% of operating Emissions 18

(Mean) (lb/Mean) (%) time) (lb/month) 1 0.0214 2 0.0214 3 0.0214 4 0.0214 5 0.0214 6 0.0108

Diesel Combustion HAP Emission Monthly Fuel Usage HAP Emission Factor19

Description Emissions20 Point (Mgal) (lb/Mgal)

(lb/month)

E001 Emergency Fire 0.53068 Pump Engine ..

Natural Gas Combustion '

HAP Monthly Fuel Usage HAP Emission Factor21 Emission Points Emissions22

(MMscf) (lb/MMscf) (lb/month)

8001, 8002, 8003, 8004, 8504 8604, 8005, 8006, 8508, 8608, P003, P503, P603, P004, P504, 1.8885 P005, P505, P605, P006, P506,

P606, P508, &P608 Installation-wide Monthly HAP Emissionsz;s (lb/month):

Installation-wide Monthly HAP Emissionsz4 (tons/month): . Installation-wide 12-Month Rolling Total HAP Emissionsz:1 (tons):

16 This emission factor is based on testing conducted at a sister facility and shall be replaced with the formaldehyde emission factor obtained from stack testing required by Special Condition 11. Lines with basecoaters shall use the formaldehyde emission factor obtained from Line 5 stack test results. Lines without basecoaters or lines not operating their basecoater shall use the formaldehyde emission factor obtained from Line 6 stack test results. 17 As obtained from the most recent Air Pollution Control Program approved stack test. The currently approved destruction efficiency for Lines 1 - 4 is 90%. The currently approved destruction efficiency for Lines 5 and 6 is 98%. 18 HAP Emissions (lb/month)= Monthly Production (Mean) x Formation Factor (lb/Mean) x [1 - Destruction Efficiency(%) x (1 - SSM Time(% of operating time))] 19 Sum of Individual HAP emission factors in AP-42 Table 3.3-2 (October 1996) and a diesel heating value of 137 MMBtu/Mgal from AP-42 Appendix A (September 1985). 20 HAP Emissions (lb/month) = Monthly Fuel Usage (Mgal) x HAP Emission Factor (lb/Mgal). 21 Sum of Individual HAP emission factors in AP-42 Tables 1.4-2, 1.4-3, and 1.4-4 (July 1998). 22 HAP Emissions (lb/month) = Monthly Fuel Usage (MMscf) x HAP Emission Factor (lb/MMscf). 23 Installation-wide Monthly HAP Emissions (lb/month) = the sum of all HAP Emissions (lb/month) from storage tank working and breathing losses, surface coating operations, formaldehyde formation, diesel combustion, and natural gas combustion. 24 Installation-wide Monthly HAP Emissions (tons/month)= Installation-wide HAP Emissions (lb/month) x 0.0005 ~ton/lb).

5 Installation-wide 12-Month Rolling Total HAP Emissions (tons)= the sum of the 12 most recent Installation-wide Monthly HAP Emissions (tons/month). Installation-wide 12-Month Rolling Total HAP Emissions of less than

- 32 -

Attachment B- Installation-wide Individual HAP Compliance Worksheet

Metal Container Corporation Jefferson County, S28, T43N, R6E Project Number: 2016-02-047 Installation ID Number: 099-0044 Permit Number:

This sheet covers the month of _____ in the year of _____ _

HAP Name: _____ CAS No.: _______ _

Storage Tanks - Working Losses Name of Monthly Emission

Description Material Usage Point Stored (Mgal)

T002 10,000 gallon Basecoat Bulk Tank T003 10,000 aallon Varnish Bulk Tank T004 10,000 aallon Inside Spray Bulk Tank Diesel 1,000 aallon Tank Tanks 900 gallon Tank

T002A 500 gallon Basecoat Day Tank

T003A (2) 500 gallon Varnish Day Tanks T004A (3) 500 gallon Inside Spray Day Tanks

Storage Tanks - Breathing Losses

Emission Factor26

(lb/Mgal) .. ··.

Emission Name of HAP Emissi,;,ns26

Description · Material Point Stored

(lb/yr) ·.

T002 10,000 oallon Basecoat Bulk Tank T003 10,000 aallon Varnish Bulk Tank T004 10,000 gallon Inside Spray Bulk Tank Diesel 1,000 gallon Tank Tanks 900 aallon Tank T002A 500 aallon Basecoat Day Tank T003A (2) 500 gallon Varnish Dav Tanks T004A (3) 500 gallon Inside Spray Day Tanks

HAP Emissions2!

1

·· · (lb/ntonttO

.

HAP Emissions28

(lb/month)·

25.0 tons indicates compliance with Special Condition 2.A. 26

Tank emission factors shall be obtained from EPA's TANKS 4.0.9d for the chemical stored/used. The permittee shall maintain a copy of the TANKS 4.0.9d detailed annual emissions report printout for each tank so that the emission factors can be verified. 27 HAP Emissions (lb/month) = Monthly Usage (Mgal) x HAP Emission Factor (lb/Mgal). 28 HAP Emissions (lb/month) = HAP Emissions (lb/yr) / 12 (months/yr)

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·.

. Surface Coatiria Operations

Name Monthly HAP Overall SSM Time33 HAP Emission Density30 Control

Poi11t29 ·. of Usage (lb/gal) Content31

Efficiency32 (% of operating Emissions34

Material (gal) (wt%) (%) time) · (lb/month) :. ..

29 The permittee shall use this section of the tracking sheet to track HAP emissions from each surface coating material used by P004 Basecoaters; P504 Basecoater; P505 Printer and Varnisher; P605 Printers and Varnishers; P006 Printers, Varnishers, Inside Spray, and Respray; P506 Inside Spray; P606 Inside Spray; and F001 Cleanup Solvents. 30 As obtained from the SDS for the material. If the specific gravity (s.g.) is listed, the density can be obtained from the following equation: Density (lb/gal) = specific gravity x 8.33 lb/gal. 31 As obtained from the SDS for the material. If the HAP content is listed as a range of values, the highest value in the range shall be used to demonstrate compliance. 32 As obtained from the most recent Air Pollution Control Program approved stack test. Emissions from P004 and P006 are captured and routed to a catalytic thermal oxidizer. The currently approved overall control efficiency for P004 Basecoating and P005 Inside Spray is 72% (80% capture and 90% destruction) and for P006 Printers and Varnishers is 45% (50% capture and 90% destruction). Emissions from P504, P505, P605, P506, and P606 are captured and routed to regenerative thermal oxidizers. The currently approved overall control efficiency for P504 is 63.7% (65% capture and 98% destruction), for P505 and P605 is 63.7% (65% capture and 98% destruction), and for P506 and P606 is 81.34% (83% capture and 98%destruction). Emissions from F001 are uncontrolled. 33 As obtained from Attachment C. 34 HAP Emissions (lb/month)= Monthly Usage (gal) x Density (lb/gal) x HAP Content (wt%) x [1 - Overall Control Efficiency(%) x (1 - SSM Time(% of operating time))]

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.·

Formaldehyde Formation"° ' ' '

HAP Monthly Formation Destruction SSMTime;,;,

Line Production Factor36 Efficiency37 (% of operating Emissions~8

(Mean) (lb/Mean) (%) time) (lb/month)

1 0.0214 2 0.0214 3 0.0214 4 0.0214 5 0.0214 6 0.0108

'

Diesel Combustion HAP

Emission Monthly Fuel Usage HAP Emission Factor39

Description Emissions40

Point (Mgal) (lb/Mgal) (lb/month) ,'

E001 Emergency Fire Pump Engine

Natural Gas Combustion ' .....

' <•'•' ' •• ", ' ',,,,, .,,

', ..

HAP ''

Monthly Fuel Usage HAP Emission Factor41 '

Emissions42 , Emission Points

(MMscf) (lb/MMscf) ,•(lb/montM 8001, 8002, 8003, 8004, 8504 8604, 8005, 8006, 8508, 8608, P003, P503, P603, P004, P504, P005, P505, P605, P006, P506,

P606, P508, & P608 Installation-wide Monthly HAP Emissions,G (lb/month):

Installation-wide Monthly HAP Emissions44 (tons/month): Installation-wide 12-Month Rolling Total HAP Emissions'"' (tons}:

35 Only complete this section for the individual HAP formaldehyde, for all other individual HAP leave this section blank. 36 This emission factor is based on testing conducted at a sister facility and shall be replaced with the formaldehyde emission factor obtained from stack testing required by Special Condition 11. Lines with basecoaters shall use the formaldehyde emission factor obtained from Line 5 stack test results. Lines without basecoaters or lines not operating their basecoater shall use the formaldehyde emission factor obtained from Line 6 stack test results. 37 As obtained from the most recent Air Pollution Control Program approved stack test. The currently approved destruction efficiency for Lines 1 - 4 is 90%. The currently approved destruction efficiency for Lines 5 and 6 is 98%. 38 HAP Emissions (lb/month)= Monthly Production (Mean) x Formation Factor (lb/Mean) x [1 - Destruction Efficiency(%) x (1 - SSM Time(% of operating time))] 39 To be obtained from AP-42 Table 3.3-2 (October 1996). Use a diesel heating value of 137 MMBtu/Mgal from AP-42 Appendix A (September 1985) to convert the lb/MMBtu emission factor to lb/Mgal. 40 HAP Emissions (lb/month)= Monthly Fuel Usage (Mgal) x HAP Emission Factor (lb/Mgal). 41 To be obtained from AP-42 Tables 1.4-2, 1.4-3, and 1.4-4 (July 1998). 42 HAP Emissions (lb/month) = Monthly Fuel Usage (MMscf) x HAP Emission Factor (lb/MMscf). 43 Installation-wide Monthly HAP Emissions (lb/month)= the sum of all HAP Emissions (lb/month) from storage tank working and breathing losses, surface coating operations, formaldehyde formation, diesel combustion, and natural gas combustion. 44 Installation-wide Monthly HAP Emissions (tons/month)= Installation-wide HAP Emissions (lb/month) x 0.0005 iton/lb).

5 Installation-wide 12-Month Rolling Total HAP Emissions (tons)= the sum of the 12 most recent Installation-wide

- 35 -

''

Attachment C - SSM Time Tracking Sheet

Metal Container Corporation Jefferson County, S28, T43N, R6E Project Number: 2016-02-047 Installation ID Number: 099-0044 Permit Number:

This sheet covers the month of _____ in the year of _____ _

Production Monthly Hours of Hours of Line(s) Operation

Control Device SSM46

,' ', ',

1-4 8005 Catalytic Oxidizer

5 8508 Regenerative Thermal Oxidizer

6 8608 Regenerative Thermal Oxidizer

SSM Time4'

(% of Operating Time)

Monthly HAP Emissions (tons/month). Installation-wide 12-Month Rolling Total HAP Emissions of less than 10.0 tons indicates compliance with Special Condition 2.A for this individual HAP. 46 For the catalytic oxidizer, an hour is considered an SSM hour if any of the following conditions are met: the temperature of the gas entering the catalyst bed is less than or equal to 650°F, the temperature of the gas exiting the catalyst bed is greater than 1350°F, the catalytic oxidizer is bypassed/offline, or the capture equipment is malfunctioning. For the regenerative thermal oxidizers, an hour is considered an SSM hour if any of the following conditions are met: the three-hour average operating temperature of the RTO is below the three-hour average operating temperature during the most recent Air Pollution Control Program approved stack test, the RTO is bypassed/offline, or the capture equipment is malfunctioning. 47 SSM Time(% of Operating Time)= H Hour~~ss~ x 100%. ours o pera 10n

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'

Attachment D - Lines 5 and 6 voe Compliance Worksheet

Metal Container Corporation Jefferson County, S28, T43N, R6E Project Number: 2016-02-047 Installation ID Number: 099-0044 Permit Number:

This sheet covers the month of _____ in the year of, _____ _

Storage Tanks - Workina Losses

Emission Name of Monthly Emi$sion

Description Material Usage Factor48

Point Stored (Mgal) Ub/Mgal) T501 7,200 oallon Varnish Tank 6.48E-02 T601 7,200 oallon Varnish Tank 6.48E-02 T502 7,200 gallon Inside Spray Tank 1.33E-02 T602 7,200 gallon Inside Spray Tank 1.33E-02

Storage Tanks - Breathina Losses ·.

~

Name of Emission

Description Material voe Emissiqns48

Point Stored

(lb/yr)

T501 7,200 gallon Varnish Tank 1.27 T601 7,200 gallon Varnish Tank 1.27 T502 7,200 gallon Inside Spray Tank 6.87E-01 T602 7,200 gallon Inside Soray Tank 6.87E-01

·.voe Emissions49

· (11>/monttl)

. ..

... .. voe

Emissions~ Ob/month)

48 Tank emission factors shall be obtained from EPA's TANKS 4.0.9d for the chemical stored/used. The permittee shall maintain a copy of the TANKS 4.0.9d detailed annual emissions report printout for each tank so that the emission factors can be verified. 49 VOC Emissions (lb/month)= Monthly Usage (Mgal) x voe Emission Factor (lb/Mgal). 50 voe Emissions (lb/month) = voe Emissions (lb/yr) / 12 (months/yr)

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••. ~ - •. ·. . .

·. · .. . · ... Formaldehyde Formation

... .·· IVlonthly Formation Destruction SSM Time0;, voe

· Line Production Factor51 Efficiency52 (% of operating Emissions~ (Mean) (lb/Mean) (%) time) (lb/month)

5 0.0214 6 0.0108 . Surface Coating O ~erations .

t::.· Name Monthly voe Overall

SSM Time53 voe Emission Density56 Control

Point'~ of Usage (lb/gal) Content57

Efficiency58 (% of operating Emissions59

Material (gal) (wt%) (%) time) (lb/month) .... .· ...

51 This emission factor is based on testing conducted at a sister facility and shall be replaced with the formaldehyde emission factor obtained from stack testing required by Special Condition 11. Line 5 shall use the formaldehyde emission factor obtained from Line 5 stack test results for all periods of time during which basecoating is conducted. Line 5 may use the formaldehyde emission factor obtained from Line 6 stack test results during periods of time during which no basecoating is being conducted. Line 6 shall use the formaldehyde emission factor obtained from Line 6 stack test results. 52 As obtained from the most recent Air Pollution Control Program approved stack test. The currently approved destruction efficiency for Lines 5 and 6 is 98%. 53 As obtained from Attachment C. 54 voe Emissions (lb/month) = Monthly Production (Mean) x Formation Factor (lb/Mean) x [1 - Destruction Efficiency(%) x (1 - SSM Time(% of operating time))] 55 The permittee shall use this section of the tracking sheet to track voe emissions from each surface coating material used by P504 Basecoater; P505 Printer and Varnisher; P605 Printers and Varnishers; P506 Inside Spray; P606 Inside Spray; P507 Bottom Coaters; P607 Bottom Coaters; F001 Cleanup Solvents; and F002 Coders. 56 As obtained from the SOS for the material. If the specific gravity (s.g.) is listed, the density can be obtained from the following equation: Density (lb/gal) = specific gravity x 8.33 lb/gal. 57 As obtained from the SOS for the material. If the voe Content is provided in lb/gal rather than wt%, the voe Content in lb/gal can be used in place of Density (lb/gal) x voe Content (wt%) for the equation in Footnote 59. 58 As obtained from the most recent Air Pollution Control Program approved stack test. Emissions from P504, P505, P605, P506, and P606 are captured and routed to regenerative thermal oxidizers. The currently approved overall control efficiency for P504 is 63.7% (65% capture and 98% destruction), for P505 and P605 is 63.7% (65% capture and 98% destruction), and for P506 and P606 is 81.34% (83% capture and 98%destruction). Emissions from P507, P607, F001, and F002 are uncontrolled. 59 VOC Emissions (lb/month)= Monthly Usage (gal) x Density (lb/gal) x voe Content (wt%) x [1 - Overall Control Efficiency(%) x (1 - SSM Time(% of operating time))]

- 38 -

Natural Gas Combustion - - -- - -

··-----_ _. --

voe Monthly Fuel Usage voe EmissiQn Fac:tor6°

Emission Points Erriissions81

(MMscf) (lb/MMscf) -

(lb/month> 8504, 8604, 8508, 8608, P503, P603, P504, P505, P605, P506, 5.5

P606, P508, & P608 Lines 5 & 6 Monthly voe Emissions62 (lb/month):

Lines 5 & 6 Monthly voe Emissions63 (tons/month): Lines 5 & 612-Month Rolling Total voe Emissions64 (tons):

6° From AP-42 Table 1.4-2 (July 1998). 61 voe Emissions (lb/month) = Monthly Fuel Usage (MMscf) x voe Emission Factor (lb/MMscf). 62 Lines 5 & 6 Monthly voe Emissions (lb/month) = the sum of all voe Emissions (lb/month) from storage tank working and breathing losses, surface coating operations, formaldehyde formation, and natural gas combustion. 63 Lines 5 & 6 Monthly voe Emissions (tons/month) = Lines 5 & 6 voe Emissions (lb/month) x 0.0005 (ton/lb). 64 Lines 5 & 6 12-Month Rolling Total voe Emissions (tons) = the sum of the 12 most recent Lines 5 & 6 Monthly voe Emissions (tons/month). Lines 5 & 6 12-Month Rolling Total voe Emissions of less than 169.67 tons indicates compliance with Special Condition 5.C.

- 39-

,·.

Attachment E -Alternative Coatings Worksheet

Metal Container Corporation Jefferson County, S28, T43N, R6E Project Number: 2016-02-047 Installation ID Number: 099-0044 Permit Number:

This sheet covers the month of _____ in the year of _____ _

HAP Name: _____ CAS No.: _______ _

Storage Tanks - Working Losses

Emis~i<>n Name of Potential Annual

Description Material Usage65

Point .. Stored (Mgal) .

T501 7,200 oallon Varnish Tank T601 7,200 gallon Varnish Tank T502 7,200 gallon Inside Spray Tank T602 7,200 gallon Inside Sorav Tank

Storage Tanks - Breathing Losses

Emission Description Name of Material Stored Point

..

T501 7,200 oallon Varnish Tank T601 7,200 gallon Varnish Tank T502 7,200 gallon Inside Spray Tank T602 7,200 gallon Inside Spray Tank

65 As input into TANKS 4.0.9d.

HAP Emissions66

(lb/yr)

HAP Emissions66

(lb/yr)

66 Tank emissions shall be obtained from EPA's TANKS 4.0.9d for the chemical stored/used. The permittee shall maintain a copy of the TANKS 4.0.9d detailed annual emissions report printout for each tank so that the emission factors can be verified.

- 40-

Formaldehyde Formation1111 : ·.- .. ·

Potential Average S$,N1 ii HAP Formation Destruction Line Annual Factor68 Efficiency69 Time 10, -··.. . .. '·- Emissions11

(% ofoperating . Production .· (lb!Ytl (Mean) (lb/Mean) (%) - time> · - · · .. _-. . __

5 693,792 0.0214 6 693,792 0.0108

Surface Coating Operations . ... ..:-:: ·. . -•·

: ··-· _. ·.· -·· --.. - •.

. · Overall . ·.·Averjge·::_.··.

._

· .. · •.: . ' Potential SS111Time7Q ·. .HAP.·••.· Name HAP Emission of Annual Density73

Content74 Control (%f>f Errti11sio11s76

Point72 Usage (lb/gal) Efficiency75

Material (gal) (wl°/o) (%)

operating (lb/yr)· tirne)

67 Only complete this section for the individual HAP formaldehyde, for all other individual HAPs leave this section blank. 68 This emission factor is based on testing conducted at a sister facility and shall be replaced with the formaldehyde emission factor obtained from stack testing required by Special Condition 11. Line 5 shall use the formaldehyde emission factor obtained from Line 5 stack test results for all periods of time during which basecoating is conducted. Line 5 may use the formaldehyde emission factor obtained from Line 6 stack test results during periods of time during which no basecoating is being conducted. Line 6 shall use the formaldehyde emission factor obtained from Line 6 stack test results. 69 As obtained from the most recent Air Pollution Control Program approved stack test. The currently approved destruction efficiency for Lines 5 and 6 is 98%. 70 Obtained as the average of the 12 most recent Monthly SSM Time (% of Operating Time) from Attachment C. 71 HAP Emissions (lb/yr) = Potential Annual Production (Mean) x Formation Factor (lb/Mean) x (1 - Destruction Efficiency(%) x (1 -Average SSM Time(% of operating time))] 72 The permittee shall use this section of the tracking sheet to calculate potential HAP emissions from each surface coating material used by P504 Basecoater; P505 Printer and Varnisher; P605 Printers and Varnishers; P506 Inside Spray; P606 Inside Spray; P507 Bottom Coater; P607 Bottom Coaters; F001 Cleanup Solvents; and F002 Coders. 73 As obtained from the SOS for the material. If the specific gravity (s.g.) is listed, the density can be obtained from the following equation: Density (lb/gal)= specific gravity x 8.33 lb/gal. 74 As obtained from the SOS for the material. If the HAP content is listed as a range of values, the highest value in the range shall be used to calculate the potential to emit. 75 As obtained from the most recent Air Pollution Control Program approved stack test. Emissions from P504, P505, P605, P506, and P606 are captured and routed to regenerative thermal oxidizers. The currently approved overall control efficiency for P504 is 63.7% (65% capture and 98% destruction), for P505 and P605 is 63.7% (65% capture and 98% destruction), and for P506 and P606 is 81.34% (83% capture and 98%destruction). Emissions from P507, P607, F001, and F002 are uncontrolled. 76 HAP Emissions (lb/yr)= Potential Annual Usage (gal) x Density (lb/gal) x HAP Content (wt%) x (1 - Overall Control Efficiency(%) x (1 -Average SSM Time(% of operating time))]

- 41 -

.. ·:

.

.

Natural Gas Combustion

8504, 8604, 8508, 8608, P503,

Potential Annual Fuel Usage

MMsc

P603, P504, P505, P605, P506, 348.22 P606, P508, & P608

Lines 5 & 6 Potential HAP. Emissions

HAP Emission Factor77

(lb/MMscf)

77 To be obtained from AP-42 Tables 1.4-2, 1.4-3, and 1.4-4 (July 1998).

HAP Emissions78

lb/ r

78 HAP Emissions (lb/yr) = Potential Annual Fuel Usage (MMscf) x HAP Emission Factor (lb/MMscf). 79 Lines 5 & 6 Potential HAP Emissions (lb/yr) = the sum of all HAP Emissions (lb/yr) from storage tank working and breathing losses, surface coating operations, formaldehyde formation, and natural gas combustion. 80 Lines 5 & 6 Potential HAP Emissions (tpy) = Lines 5 & 6 Potential HAP Emissions (lb/yr) x 0.0005 (ton/lb). The use of this alternative coating is approved if Lines 5 & 6 Potential HAP Emissions (tpy) are below the SMAL for this individual HAP. 81 As obtained from: http://dnr.mo.gov/env/apcp/docs/cp-hapraltbl6.pdf or Attachment F.

-42-

Chomioal

ACET.t,LOEHYDE

ACET.,\/,.UDE

ACETCN !TRILE

ACETOPHENONE

ACETYLAMINCFL'JCRI NE. [2·]

ACROLEIN

ACRY.AMICE

ACRYJCACID

ACRYLONITTULE

.~ LL Y'. CHLORIDE

AMINOBl:PHENYc., [-<-]

ANILJNE

AMSIDINE, !OR~O-]

ANTHRACENE

ANTIMONY OOMPO/JNDS

ANTIMONY PENTAFLliORIDE

ANTIMONY POTASSIUM TARTI1A TE

ANTIMONY rn1a,;10E

ANTIPIONYTRISlLF!DE

ARSEN'IC CCMPDUNDS

ASBESTOS

BENZ(A)ANTHRACENE

BE,Ju:ENE

BE,'IIZIDINE

BENZOIA)PYRENE

BENZOlB)FLUORANTHDIE

BENZOiKJFLUOPA'ITHENE

BENZOTRICHLORIDE

BENZ'fl. GHLORLDE

BERYLLIUM CCMPOONDS

BER\'LLIUM SAL TS

BIPHEN'l'L, (1,1-]

815lGHLOflOETHYL)ETHER

BIS(CttlCROMETH\'LiEWER

BROWFORM

BROl.-l::lMETf'.AllE

BUTADIENE, [ 1,3-]

BUJOX'IETHANOL A,CETATE, [2-]

BUffiENE OXJ[)E. ;1,2·]

CADMUM COMPOUNDS

CALCIUM CYANA~IDE

GAPRQl.ACTAM ,:0.1,ae,dJ

CAPTAN

Png;i: ~ o.i2

Attachment F Screening Model Action Levels (SMALs) cis, &.11.l

{tr:i,n~~P") 0~ vcc ?M 'C!»mioai

.'5-iJ}':} y N IGARSAA\'L

W-35-S. y 1, I Cil.RBC1'1 DISULRDE

75-J:-~ y N I CARllCN ,ET,!ACHCRTDE

<Ja-31'< y ,, I CARECN',t. SVLFIDE

SJ-9€-;:J :JJ05 y V ICi\-:-E~HO~

,,r,.J;z.g Ct..04 y N ICHLOAAM3EN

79·(}£- • D.!)2 y N I CHLORD,IJJE

79-lC-7 0.8 y N !CHLORINE

1m-1:H 0.3 y N IGHLOROACETICACID

1G7-0E·! y N ICHLOROAGETOPHENONE, /2·]

92~T?-; V y '4 ICHLOROBENZENE

132-Sl-l y N ICHLOROaENZILA TE

·.&04-0 y N IGHLOROFCRM

1Z.::~12-7 0.01 'I y N ICHLORO'A=THYL ME"fH'iL ElliER

H N Y ICHLOROPRENE

7733--;m.2 0.1 f-i N '! ICHRG'MIUMJW CCMPClJNOS

2!130{:--74,-5 H N Y I CHAQ/\fllJM CcttPOUNDS

1~-4 t"'. N Y ICHRYSENE

13il.5-Q4-S O.i H N Y ICoaAL T COMl'w"\JNDS

G->J05 N y ICOKE ovrn EMMS!ONS

!33.C-::n-.: o A N v I GREf.C-L, fMETA-j

56-S5-3 D.Ct~ V Y N ICAESCL (OR"HO.)

ll~--2 2 Y N I CRESCL (PARA-]

~..g'l-!:: o.ooro V Y N I CAEoC'LS (MIXED ISOMERS)

5:J-3:1-9 0.01 'J Y N ICUMENE

:ms-99-2 -0.01 Y N !CYANIDE C0,.1'DUNOS

207.t::9-9 -0.0i ., Y N IDOE

93-07-7 Q_,JQ6 Y N I Dl•'.2-ETHYLHEXYL) PHTHAI.A TE (DEl-'PI

10044-7 0.1 Y N I DIA MINO TOLUENE, [2,4-j

,rnoa J N Y [DIAZOMETHANE

O.OJOO:? N Y I D1BENZ(A..H)AN1'HRACENE

92-52·4 1 o V Y N I OIOX!N5'1'URANS

111~.!44 0-1)8 Y N I DIBEJ.IZOFURAN

5<2-8l!-1 0.0~1)3 Y N IDIBROMG-3.CHLORCPROPANE. [1.2-J

75--25.·2: 10 Y N I DIBROl.f.JETHANE, [1,2-l

74...gs..9 10 Y N ID1BU1YLPHTHALATE

106--99-0 D.07 'f N IDICRCROBENZENE. (1.4-J

11'2,-07-2 5 P Y N I DICHLCROBENZIDENE, [3-J-]

100-B!Fl 1 Y N /DIGHLOROETHANE. [t, 1-J

Ct01 N Y IDIC!'.LOAOEThANE [1.2-j

15e-82:-? 10 y Y IDICHWROETHYLE~ {1.1-J

,~2: OIGHLOROMETH.ANE

1JJ..JE.-2 10 y Y I DICHLCROPHENQXV ACETIC ACID. e!,4-]

- 43-

CAS~ SMA., r,,...,. ·roe ""' {lontfr.l 0 Gl10mioaf

@-2S.2 10 'J Y Y IDICHLOROPRCPANE. [1.2-:

:?5-15-0 ~· N ID1Cr.LOROP8CPENE, [1,J·i

Sc-Z.3-5 Y N ID1CHLOFWCS

,c5-5B-1 Y N IDIE '1-.A',CU UINE

120-!!0-9 Y N IDIETl"YL SULF.~ 'E

1J3...f0-4 '{ IDIEThYLENE G. YCCt lb:JNOBLJ:YL ETl'ER

57-7J...9 U.D':. Y Y l!JIMETHO< 'IBDIZIOiN E ['1.3-j

7782-50-5 O.i N N /DIMETHYL 3ENZ!CiNE. f:l,3-]

7g...;,.g 0.1 y N !DIMETHYL GAflilA.WJYL CHLORIDE

SJ2-27 ·4 CtCi6 y N IDIMETfiYL i'OR~V.MIDE

1@-00-7 10 Y N /DIMETH'YL HYDRAZINE, [,.1-J

5i0-t5-·6 0.4 Y Y !DIMETHYL PHTHALA TE

&l'"--66-3 o.s Y N I DIMETHYL SUcf,HE

1G1<W-2 0.1 Y N ID1METHYLAMINQl,Z08E."'2ENE [<·]

12e .. oo-s Y N 1D~,1EThYlANILINE. [N-i'l-j

C.De:2 N V IDINlTRQ-0.CRESOL, [4,&j 1JJc1ie 6)

N Y /DINITRCPHENOL, [2,"-l

2H!-t<t-9 o..o.o. V Y N IDINITROlT'..JLLtENE, [2.-i-J

0.1 M N Y IDIO.XANE,[1.4·]

0000'-45-2 D.oo N V N IDIPHENYLHYDRAZJNE, [1,2-]

,c;i-39-4 B Y N IDIPHENYLMETHANE DIISOCYANATE f4,<-j

!l6-48-7 8 Y N IEPICHLOAOHYDRIN

,c-.,.5 8 Y N IFTHOXVETH,\NJL £2·]

1319-'7-3 8 Y N IETHa<YETHYLAGET"fE. [2-]

OO-B2·8 10 Y N IETrlYLACRYLATE

0.1 0 V N IEThNL BENZENE

11'-56-~ D.D1 V Y Y IETiiYL CHLORIDE

, 17-B-i-7 s V N IE-rnYLEN:E GL YCCl

95-l!0-7 0.02 Y N [ETHYLENE GL YCCl MONOOUT'rl ETHER U)e,ls1a<!)

31!4,,!W Y N IEnlYLENE GL 'iCCL MO.'>lCI-IEXYL ETHER

5:!-70-~ 0.01 V Y N !ETHYLENE 1M1NE (AZtRJDIN'E]

sE-07 D,V V N /ETHYLENE OXIDE

132-64·9 5 V Y N IETlrlYLENE ThlOC'AEA

96-12-9 0.01 Y N IFCflMALIJEHYDE

1c~w.... 0.1 \' N IGLYCCLETHER(ETH\'LENEGcYCOLETHIRS:1

114-74-2 1 o y y IGL YC,.,"'l ETHER (DtETH't'LENE Gl YCOL ETHERS;

1 00-46-7 3 V N /HEPTACHLDR

91-94-1 o .2 V Y Y IHEXACHLORCBENZENE

76-:!4-3 t V N !HEYACHLOROBUTADIEN~

1f'ii-nG-2 o.a. Y N IHEXACHLOW'...CYGLOHEXANE, f\LPHA-]

75-36-4 0..4 Y N /HEXACHLORCCYCLOHEXANE. [BETA-j

?5-00-2 10 N N jHEXACHlOAOGYCLOHEXANE. [DELTA-]

94.75-7 10 C y y IHEXACHLClPJOCYCLOhB<ANE, [TECHNICAL]

CAS# ··sw.··. ~ ~ PU fa:ms':m , ID

713-~-s y N

542•]:rf;, y N

J3.2•7'2r7 02 y N

111-4.2-2 y N

64-87·5 y N

112:-S4,.:5 p y N

1~£:.ro.4 0.1 V y V

119-93-7 c.cca \f y y

79-.W.-7 O.C::2 y N

ES-12<2 y N

57-14-7 O.CIJ8 y N

1-31-n-3 10 y N

7F!F:,·'l 0.1 y N

ro-t 1-7 y N

1.:.>1-~ y N

~< 0.1 E y y

5,i-2~5 y N

12'Fi4-2 O.D.2 y N

123-9'!-1 f., y N

122-03-7 O.D9 'I y

1D1·"61::-G: 0.1 V Y N

1C&B9-B 2 y N

1:Q.00-5 10 p y N

111-1E-g. 5 P y N

140-00-5 y N

lb0-41-4 10 y N

75-C-0-2. 10 y N

107-21-'1 10 y N

111-76-2

112-26-4 5 p y N

151-03-4 C.003 y N

75-2.H? 0.1 y N

-00-4.S-7 0)3 y y

60-00-0 2 y N

p y N

p y N

76-4•H~ 0.02 y N

11&-74·1 O.D,; y N

97-68-3 0.9 y N

319,-.84.-6 O.Di F Y N

:31-~7 0.0~ F Y N

.31s.G6-B 0.0~ F Y N

<iC&-13-1 0.0': F y N

J:Jia» tr.al.M: C~U-S.'2012~ R,;riwn 1v

a,;;~· HEXAC-1-c.OROCYC ,OPENTAOI i'Nf

HEXACRDROETHANE

HEXAMEiH'I\.EtlE. -1 ,6.0IISCCYA!tlt TE

HEXJ\I\IETif\'1.PHOSPHORAIIIIDE

HEXANE. [N-[

H'IDRAZINE

H'\'DRCGEN CHLORIDE

HYORCGEN FcUOAmE

HYOROOUIN~E

INDHK)(1,2,3CD IPYAENE

ISOPHORONE

LEAD COMPOUNDS

LINDANE [GAMMi\-HEXACHLCIRO:YCLO!-EXA'<E!

MALEC A \!HYDRIDE

MANGANESE COMPOUNDS

MERCUR\' COMPOUNDS

METuANct

METHOXYCHLOA

METkOXYE:HAND'-. [2·!

MET!,'¥\. CHLOfllOE

MET1''1'1.. E7 HYL KE70NE (L'E'lilSl!!dj

MElliYL H\'DR~ZINE

MET!''I\. ICOIDE

METr.\'L l.S03l:T''L KHOt.E

METuYL I.SOCY.a.NATE

MEWYL MEIB4<CRY'cATE

METH¥\. TEAT -Ell; •YL ETHER

METl-'I\.CYCLCCPEN,ADIPIYc MANG,.NESE

METflLE'IIE ;;1s:2-CHl OROANI.J"IE). [•.<-!

MET!'YLENEDl.\NIUNE. [4.4·]

MEWYLNAJ>HH~LEN£.. [2·)

MINEAI\L FlBERS

Ni\PJ-:•HALEN.f

NAi>rTHYU\.MINE. [AYHA -)

Ni\~rTHY~~MINE. (BET~-]

NIC<:EL CA RBD'<IYL

NIO<EL COMPOUNDS

NICKEL REFINER''' DUST

N!C,,:EL SlJBSL FIDE

N!TRCBE.>IZEt,E

f~TK:BIP•iENYL [ 4·]

Nrffi(JPHENC,;_, i•·J NITP.<..JPRODANE .. ,>·)

p~~c-~;

CAS>l . ;~-t ~·~····•;.; """"") D .. ,

?7-.i.7-.4 0.1 Y N INITT!OSOOIMETHYLAAflNE, ]N-,

Ei?-7:2-1 Y !l ]NITROSO!i.lORP'HO!.JNE, ]N-j

S;22..;)6-C D.0.2 y N I NITROSO.N-ME IB\'UIREA., [111-]

e:st).31-:t 0.01 y N IOCTAGHLCflONAPTl'.ALENE

~-1~6~-, 10 Y N I PARA THK)N

:](12-01-2 (t004 N N I PCB {POL YCHLORINA lEll B!PIIENYLS]

7f.il.7-Ci1-li 10 N N IP'ENTACHlORO!<ITAOBENZENIE

71:F..i-4"39-2 0.1 N N IPENTi\CHlORa>HENOL

~23-31-9 y N li>HrnGI..

193..J9-5 U.01 y N I PHENYLENEOIA.!.INE, (PARA-]

19-5g..1 10 y N IJ>HCSGENE

C•.4:·1 Q N Y I J>HC6Pli1NE

S94l~S 'C-:D~ f y N IPHOSPHOOOUS,YEUOW OR WHITE)

~ae-31-6 y N IPHTf'k...K:ANtlYDRIDE

0.8 R N Y I POL YCYLC ORGANC MA TiH!

o~c,1 s N N !PFlOPA.'<E SllLTONE. [1,3-]

67-5E-1 10 y N I J>P/OPIOJo.GWNE. [BETA-]

7'2~3-5 10 V y Y I PFICPIOl,IALDEHYDE

"'.~E:-4 10 p y N I PRCPOXUA [3A YOON]

7•~-3 10 Y N I PROPYLENE OXIDE

78·9:3-3 P!FlOPYLENElMINE. [1,2-J

00-3'!1·4 ::'.!:DB y 'I l<:ll.1NO..J1'!E

1,-99.4 y ~ !Ol.iNONE

·.oe-1,r;..; 10 V N I R>\DIONUCLIOES

824-83~ 0.1 y ,; I SELENIUM COMPOI.JNDS

00,6,-£ 10 y fl !STYRENE

1634-0.ti-~ 10 y N !STYRENE OXIDE

12109·13·.'3 0.1 R N Y ITETR~C+<LCAOOIBENZO·l'LDIOXN.[2,3,7il]

":01·1~-4 0.2 \' y Y ITETRAGriLOflOEThA..NE. [i.1.2.2-)

·01-77-9 V N ITETR:.CHLOAOEihYLfNE

91·5"?-t C\V1 'I y 11 ITTTAI\IIUM TETR~CHLORIDE

N Y IT<XUENE

9l-2:J..J 10 V y ~ ITU.lJENE Dl1SOCYANATE. [2,4-J

~3~-32-:' CJ.:-:- V y 'I ITO:..UIDINE. [OAThO-;

91-5·;..B ::,:c-1 V y 'I ITOXADHENE

1"3463-:r:;...'.! 0.1 IJ N Y !TRICHcOROilENZENE. [1,2,<-]

u N Y ITRICJ-!c..OAOElliANE. !i,1,1-]

O.fr:E- u N Y !TRICHLOROETt<.A~E. !1 .. 1.2-]

1:::!135·7~·2 0:04 u N Y ITRJCHlOAOETiiVLE!.lE

93-9S-J. 1J ICRJCH~OROPPENOl.., \2.4,5-)

gz..g3.::;: V y N l:RIGH,GflOPHENOL [2.4,6-)

"OG--02-7 y N ITRIECh'YLAMINE

79-,:.5.; ~J l:A!FLURALIN

-44 -

~~Ii - ,tiri.ui;' ~l E l'OC FM . t;1,,,;;.;.;..f ,· '· ·•,S!,11.L .,,. , CI\St: , ~ ~· VOC. 1',1/j

-62-7~~B C.Oi:J1

Sg...139-2

6S4--'93,-6 D.OD02

2234,.13-'l o.m V

56-3B-2. 0.1

133B-J&-5 o.ooe X

!!2-£B-B 0.3

87..,9&5- 0 . .7

lCG-'!&2 0.1

10&-50-3 10

75-44-5 0.1

790::: ..... s~-2

7728--14-0 0.1

BS-.4-9 5

cun V

1120,.7-;-4 0.03

57-57-B 0.1

12S-3e-6 5,

,,..,.2&-:: rn

75-56-9 5

7S-56,-B C.00~

'91-22-6 0.000

100-5-1-4

Nol!> 1 Y

Y t. !TRIMETH'I\.PHITANE, [2,2.'-j

Y N IURET\i."'NE [ETHYl CARBMIJ\ 7E]

Y N I\JINYLACETJ\lE

Y N IVIN'/1.. BRO!AIDE

y y !VINYL CHLORIDE

y y !XYLENE. [META-]

Y N !XYLENE. [OOTHO.J

y N IXY'cENE. [PAAA-]

Y N IXYLENES !MlXED ISOMERS)

y tl

y N

N N

N N

y N

y N

Gioup 10

A

Legend

/\ggrogel!> Group Name

Asbs-stos

540-94-~

5!!-7fH:i Oil

1~4

593-60-2 CL6

7S-G1·4 0.2

Hli!·:le<-3 10

95-47-6 10

106--42·3 10

1330-.0-7 10

y ~ 3 Cre-5ols/Gesyic /too ftsome-rs and mO'..ruaeS,J

y N C ,:,< · D, Satts and Esr,rs.

y N D Di1>!ffizoiLt£ans. Ditrafl.::odtoxins:

y y E 4, 6 Dlnitro-o-cresot &Id Salts.

y N Lmdaoo t:al isomers)

y N G x~-6 (8Jlisomeir6 600 mixbJre,s;,

y N H Arrtimoff;' Compounds

y N A.rseaic -Comi:o.md5-

N v Be-~lium Campo.irids.

y N

y N

v· N

v· N

y N

G V N

G V N

G Y N

G Y N

0 .. 1 W N Y K Cadmir.m Co.mpc:~.mds

1-D0-42-6 y N - y N

t74f..-0::-6 sE-07 D, V Y Y

7;..-34.5- 0 . .3 y N

1V'·lB-4 10 N N

755(~£~0 0;1 N ti

1:::G-BS-·S JO y N

584,,.B4,.9 o", y N

95-S:>4 4 y N

~:xn-ss.z c.01 y N

1.2CH!2-; iO y N

71-5£-6. 10 N N

7,-:;o.5 y N

7g...o;.6 ·rn y N

95~-g.&.4 y N

!!.B-t:6-,2 y N

,z,-44.:, 10 y ti

:5B2-G9·B g )' y

M

N

0

?

C

A

s

u

VI

X

No"',

Chn:rniornCom!XllJnds

Coba."t Compolll!OO.s

Coks C\•en Emissions

Qrankie C~pound.;

G!}t:cl El!:lera

Lead C:>.,,pc<.1nds (exc,;pl elem,;mal Le.ad)

Me.rgane-90 Compounas.

ME-rmrr Cor.!ipoonds

Fine- Mi.-»ral Flt.ere

Ni:l<el Co.1lX>unds

P:>i,•ci•t:11e ()gani:: Man,,,

&!ErnJ:r:1 Compoonds

P01j,0ct1i:lrnaood 3ipn.,enfls -A .. rccloraJ

Radt:mucb::tes

Notes

T.7-! SM.i\L far ra.dion:~.u:.idas is O:·:iTE·d as bi2" e-fu-Ctn·e dose eC!.ffi.·81-:n: to C..:! mil!r.er.is c.eryear kif 7 ),<ears S-);pc.sl;.Jra- aE.;1,..10:atec wm a ee.~ r.sk of 1 i~ 1 mmon

C.m ~allild. O~fOJ.'3:112 P.o¥dcill ~O

APPENDIX A Abbreviations and Acronyms

% ............ percent

~F .... ........ degrees Fahrenheit

acfm ....... actual cubic feet per minute

BACT ...... Best Available Control Technology

BMPs ...... Best Management Practices

Btu .......... British thermal unit

CAM ....... Compliance Assurance Monitoring

CAS ........ Chemical Abstracts Service

CEMS ..... Continuous Emission Monitor System

CFR ........ Code of Federal Regulations

CO .......... carbon monoxide

CO2 ......... carbon dioxide

C02e ....... carbon dioxide equivalent

COMS ..... Continuous Opacity Monitoring System

CSR ........ Code of State Regulations

dscf ........ dry standard cubic feet

EIQ ......... Emission Inventory Questionnaire

EP ........... Emission Point

EPA ........ Environmental Protection Agency

EU ........... Emission U11it

fps .......... feet per second

ft ............. feet

GACT ..... Generally Available Control Technology

GHG ....... Greenhouse Gas

gpm .. ...... gallons per minute

gr ............ grains

GWP ....... Global Warming Potential

HAP ........ Hazardous Air Pollutant hr ............ hour

hp ........... horsepower lb ............ pound

lbs/hr ...... pounds per hour

MACT ..... Maximum Achievable Control Technology

µg/m3 ...... micrograms per cubic meter

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m/s ......... meters per second

Mgal ....... 1,000 gallons

MW ......... megawatt

MHDR. .... maximum hourly design rate

MM Btu ... Million British thermal units

MMCF ..... million cubic feet

MSDS ..... Material Safety Data Sheet

NAAQS .. National Ambient Air Quality Standards NESHAPs National Emissions Standards for Hazardous Air Pollutants

NOx ......... nitrogen oxides

NSPS ...... New Source Performance Standards

NSR ........ New Source Review

PM .......... particulate matter

PM2.5 ....... particulate matter less than 2.5 microns in aerodynamic diameter

PM10 ....... particulate matter less than 10 microns in aerodynamic diameter

ppm ........ parts per million

PSD ........ Prevention of Significant Deterioration

PTE ........ potential to emit

RACT ..... Reasonable Available Control Technology

RAL ........ Risk Assessment Level

sec ........ Source Classification Code

scfm ....... standard cubic feet per minute

SDS ........ Safety Data Sheet

SIC ......... Standard Industrial Classification

SIP .......... State Implementation Plan

SMAL ..... Screening Model Action Levels

SOx········· sulfur oxides 502 ......... sulfur dioxide

tph .......... tons per hour

tpy .......... tons per year

VMT ........ vehicle miles traveled

voe ........ Volatile Organic Compound

Response to Public Comments on the Non-Attainment New Source Review Permit for

Metal Container Corporation (099-0044) Project 2016-02-047

... ~ - •. ·. . .

The draft Non-Attainment New Source Review Permit, Project 2016-02-047, for Metal Container Corporation (099-0044) was placed on public notice as of September 23, 2016, for a 40-day comment period. The public notice was published on the Department of Natural Resources' Air Pollution Control Program's web page at: http://www.dnr.mo.gov/env/apcp/PermitPublicNotices.htm and in the Arnold-Imperial Leader on Thursday, September 22, 2016.

On October 21, 2016, the Air Pollution Control Program received comments from Mark A. Smith, Air Permitting and Compliance Branch Chief for EPA Region VII. The Air Pollution Control Program did not receive any other comments on the draft Non-Attainment New Source Review Permit while it was on public notice. The comments from EPA are addressed below.

EPA Comment#1: First, Special Condition 12. A., in the draft New Source Review (NSR) Permit, requires Metal Container Corporation (MCC) to obtain volatile organic compound (VOC) offsets in the amount of 143.30 tons. MCC's NSR Permit Application states, in Section 7.5.1 (Project NSR Applicability), that this projects VOC emissions increase is 148.75 tons per year (tpy), which is a significant increase of a regulated air pollutant and subject to review. It is unclear to EPA how MDNR determine an offsets in the amount of 143.30 tons for a facility that indicates its increase is 148. 75 tons per year. The ambient air quality, in the area around the MCC-Arnold facility, has been classified as "marginally nonattainment" for ozone and VOC is one of the contributors to the formation of ozone and therefore this project is subject to NNSR for ozone. Once a facility has determined it is subject to NNSR, it must apply for a NNSR permit which includes, but is not limited to, the installation of Lowest Achievable Emission Rate (LAER) technology and the "offsetting" of new emissions with creditable emission reductions at an offset ratio dependent upon the ambient air quality designation for the area. Neither the draft permit or the emissions / controls section (permit fact sheet) nor Special Condition 12 (VOC Offsets) provide an explanation as to the basis of the determination of the 143.30 tons of offsets; and whether or not the offsets have already been secured; and whether or not MACC is using direct VOC offsets or is relying on inter-pollutants offsets.

On the issue of offsets, the draft permit indicates that MCC must obtain offsets before they remove the permanent enclosures. For a modification that hasn't already occurred, the offsets must be secured prior to beginning of actual construction. Where MCC has already undertaken the addition of the VOC-emitting equipment, they should be required to obtain the offsets immediately. The permit fact sheet should discuss where the offsets were or will be obtained from, in what amount, if any offset ratios applied and whether any inter-pollutant trading is involved.

Based on earlier discussions, MDNR was considering whether to allow MCC to use NOx reduction in the St. Louis nonattainment area to offset the increase in VOC emissions from the

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MCC project. At the time, EPA expressed concern that both Missouri's state rules and the EPA-approved SIP, found at 10 CSR 10-6.410(3)(B)5.E, seem to disallow the use of inter­pollutant trading (e.g. NOx reductions may not be exchanged for volatile organic compound (VOC) increases, or vice-versa). If MCC is relying on anything other than VOC offsets, MDNR should describe how an offset using other pollutants satisfies the offset requirements.

MDNR's Response: The project emission rate included by Metal Container Corporation in their application was based on a 97% DRE for the RTOs and failed to account for SSM emissions. This permit states that LAER is 98% DRE for the RTOs and limits SSM emissions to 240 hours per year. Potential VOC emissions from Lines 5 and 6 were determined by MDNR to be 169.67 tons per year (the 169.67 tons per year VOC limit in Special Condition 5.C is based on 8,520 hours of controlled emissions and 240 hours of uncontrolled emissions per year). Project emissions are 143.30 tons and were determined as the potential VOC emissions from Lines 5 and 6 (169.67 tons per year) minus baseline VOC emissions from Line 5 (26.37 tons per year).

MDNR erroneously included the calculated project emission rate (143.30 tons per year) in Special Condition 12.A. The amount of VOC offsets required is actually 157.63 tons per year based on a 1: 1.1 offset ratio for marginal nonattainment areas. Special Condition 12.A has been revised.

Lines 5 and 6 have already been constructed as indicated in the Lines 5 and 6 Permitting History beginning on page 14 of the permit. While operating with permanent total enclosures the installation has been complying with a 40 tons per year VOC emission limit (Construction Permit 032014-003A Special Condition 2.A). The only construction occurring as a result of this permit is the removal of the permanent total enclosures, thus Special Condition 12.B ensures that the VOC offsets are obtained prior to project construction occurring.

Metal Container Corporation has not yet obtained the offsets for this project; however, they plan to obtain them from Anheuser-Busch, Inc. St. Louis Brewery (510-0003). The St. Louis Brewery recently discontinued the use of their coal-fired boilers and will be banking offsets generated from August 2015 through July 2016. The banking request has not yet been reviewed and approved, but MDNR believes there will be more than enough emissions credits generated to cover this project. Special Condition 12.B requires the installation to continue to operate the permanent total enclosures and comply with their existing 40 tons per year VOC limit until their Notice of Intent to Use Emissions Reduction Credits has been approved.

Metal Container Corporation will be purchasing NOx emissions credits to offset their VOC emissions increase. The attached documentation demonstrates that NOx emissions reductions are more effective in reducing ozone emissions in the Jefferson County ozone nonattainment area.

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. I

EPA Comment #2: Second, Special Condition 3 provides specific requirements MCC shall maintain to justify their Lowest Achievable Emission Rate (LAER) capture requirements for VOC emission control. Based on the LAER discussion included in the draft permit emission I controls evaluation (fact sheet), maintaining capture efficiency is a critical component of achieving the VOC emission limits. However, in Special Condition 3. F., MDNR requires MCC to monitor and record the static pressure at each capture system pick-up point at least once each calendar quarter (emphasis added). With capture efficiency critical to VOC emission limitation compliance, EPA believes that once each calendar quarter monitoring and recording requirement to be insufficient. Therefore, EPA recommends MDNR require MCC install continuous monitoring and recording of static pressure at each of the capture system pick-up points.

MDNR's Response: Special Condition 3.F has been revised to include continuous static pressure monitoring of each point as recommended by EPA.

EPA Comment #3: Third, Special Condition 6. D. and Special Condition 7. D. require MCC to monitor and record the pressure drop across each mist eliminator and each baghouse, respectively, at least once every 24 hours. Special Conditions 6. D. and 7. D. require the operating pressure drop to be greater than or equal to 0.2 inches of water. However, neither Special Condition 6 nor Special Condition 7 describe the actions MCC shall undertake when the pressure drop falls below the required operating set point. EPA recommends MDNR incorporate the corrective action(s) MCC shall take when the mist eliminator and bag house pressure drop falls below the operating set point.

MDNR's Response: Special Conditions 6.D and 7.D have been modified to require corrective action within eight hours. Some of the common corrective actions for mist eliminators and bag houses have been included in the permit as well. Other corrective actions may be acceptable if specifically indicated in the operations and maintenance manual provided by the control device manufacturer. Metal Container Corporation is not required to conduct all corrective actions listed. Metal Container Corporation is only required to conduct whatever corrective action restores the control equipment back to proper working order.

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Justification for Use of NOx Credits for voe Offsets in St. Louis Area October 30, 2015

Issue: Metal Container Corporation (MCC) located in Jefferson County, a marginal nonattainment area for ozone, has asked about the availability of nitrogen oxides (NOx) credits to be used for volatile organic compounds (VOC) offsets. MCC obtained a construction permit in May 2012 from Missouri Department of Natural Resources for a new aluminum can line shaped like a bottle, Line 5, at a production rate of 1440 bottles per minute (bpm) and then later obtained another permit (#032014-003) for Line 5 increasing the production rate to 2,250 bpm. In April of 2015, they amended the later permit in order to split the production of 2,250 bpm into two lines, Line 5 and Line 6. This change in design allowed them to make the same number of bottles, but with the added benefit of increasing operational flexibility.

Because MCC is a major source for VOC and is located in a nonattainment area, MCC took a 40 ton of VOC per year limitation in #032014-003A for both Line 5 and Line 6. In order to achieve emission levels below 40 tpy, MCC had to enclose most of the can manufacturing line and route the emissions to a thermal oxidizer.

At this time, only Line 5 has been constructed. Because the production of the aluminum bottles is a new process that has not been achieved anywhere in the world, MCC has had to make process improvements to achieve the desired quality and production rates. However, ongoing issues associated with excessive heat and odor remain with the permanent total enclosure. MCC has attempted to redesign Line 5 by increasing exhaust air flow and modifying supply air. However, they have been unable to find a solution that doesn't involve decreasing the capturing efficiency from 100%. As a result, MCC is seeking to increase voe emissions above 40 tpy (i.e. reduce the required capture efficiency) and undergo Nonattainment New Source Review (NNSR).

Offsets Needed: Since ozone is not emitted directly from stationary sources and is instead formed by the precursor pollutants NOx and VOC, NNSR is required for new major sources of NOx or VOC and for major sources of NOx or VOC making major modifications for those pollutants. One portion of NNSR is to obtain emission reductions (offsets) for the increase of emissions that are expected to incur as a result of the project. MCC has estimated the net emissions increase associated with decreasing the capture efficiency to the point where quality and production issues are minimized while achieving Lowest Achievable Emission Rate (LAER) control to be approximately 178 tons per year. Jefferson County is considered a marginal nonattainment area for ozone. For marginal nonattainment areas, the company is required to obtain offsets of the nonattainment pollutant from other sources which impact the same area as the proposed source. The offset ratio for marginal areas is 1.1 to 1. Therefore, if the net emissions increase remains at 178 tpy, then MCC will have to obtain 196 tpy in offsets.

Inter-pollutant Offset Substitution MCC has requested to use NOx credits that they can acquire from Anheuser Busch (AB) in south St. Louis City. Preliminary estimates suggest that 265 tons per year of NOx credits will be available due to

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the fuel conversion in their boilers from coal to natural gas. EPA allows for the establishment of emissions offset trading ratios for ozone precursors (NOx and VOCs) that would provide at least equivalent ozone reduction benefits [40 CFR 51.165(a)(ll)]. Under this approach, NOx emissions reductions may satisfy voe offset requirements, and vice versa. The appropriate inter-pollutant ratios are determined by the state. If the Missouri Air Pollution Air Program were to approve a NOx to voe trading ratio of 1 to 1, then the available NOx credits would be able to cover the 196 tons per year of required offsets.

Support for NOx to voe Trading Ratio of 1 to 1

... ~. •. ·. . .

Ozone formation can be controlled by reducing either emissions of NOx or VOCs, depending on which is the limited reagent.82 In order to determine the regime, one must estimate the total VOC reactivity in comparison to total reactive nitrogen. When this ratio of HCHO (surrogate used for VOC reactivity) to NOy is high, the regime is considered NOx limited. Recently, St. Louis has shifted to more NOx­limited conditions, but with some days that are VOC-limited.83 What this implies is that there has been a general increase in the ratio of HCHO to NOx in the St. Louis area. As shown in Table 5-1 and A-1, anthropogenic NOx emissions have continued to decrease with increase of required controls required as a result of local, state and federal regulations. However, although voe emissions have continued to decrease as a whole, the biogenic VOC emissions which are largely out of the control of regulators remains a large contribution to the total voe emissions. The ability to reduce total voe emissions through decreases of anthropogenic VOC emissions has lessened. According to the St. Louis Air Quality Management Plan's Final Technical Report (September 30, 2013), the large amount of biogenic VOC emissions to the south and southeast of the nonattainment area contribute significantly to the formation of ozone in St. Louis. These emissions are generated from the large oak and pine forests of south-central and southeastern Missouri. Sixty percent of the biogenic emissions in the nonattainment area are emitted from Franklin and Jefferson County, Missouri. In 2002, the average of the biogenic voe emissions for all the episodes in the attainment demonstration from the nonattainment area is 309.53 tons per day (tpd) for Missouri and 135.73 tpd for Illinois. Table A-2 shows that the biogenic voe emissions in 2011 are estimated at 369 tpd for Missouri.

Table 5-1. 2008 VOC and NOx Emissions for the Missouri Side of the 1997 St. Louis 8-Hour Ozone Nonattainment Area (tons per ozone season day)84

Source Category· .· NOx voe Point Sources 88.84 18.0 Area Sources 6.52 98.74 On-Road Mobile Sources 160.38 58.53 Off-Road Mobile Sources 60.85 46.44

Total 316.59 221.71

82 Duncan, Bryan N., et al. The Sensitivity of U.S. Surface Ozone Formation to NOx and voes as Viewed from Sf.ace 8 St. Louis Air Quality Management Plan's Final Technical Report, Appendix A (issued September 30, 2013) 84 Taken from Missouri's State Implementation Plan, Supplement I Revision to the Redesignation Demonstration and Maintenance Plan for the 1997 8-Hour Ground Level Ozone National Ambient Air Quality Standard, April 2014

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Table A-1 2011 Anthropogenic Emissions Inventory Summary for the Missouri Portion of the Nonattainment Area (tons/ozone season day)85

Source Category NOx voe .

Point Sources 90.69 14.58 Area Sources 5.6 72.77 On-Road Mobile Sources 124.20 38.00 Off-Road Mobile Sources 47.55 39.03 Total 268.04 164.38

Table A-2 2011 Wildfire and Biogenic Emissions Inventory Summary for the Missouri Portion of the Nonattainment Area (tons/ozone season day)86

Source Category NOx voe Wild Fires (Event) 0.01 0.16 Biogenic Sources 3.47 368.71 Total 3.48 368.87

* Note: Figures may not total exactly due to rounding.

Following are excerpts from Illinois Environmental Protection Agency, St. Louis 8-Hour Ozone Technical Support Document that support the reduction of NOx emissions having a greater effect on ozone reduction.

• Based on the model's response to sensitivity analyses, the final attainment demonstration, and an Ozone Source Apportionment Technology (OSAT) scenario, elevated ozone concentrations in St. Louis are responsive to NOx emission control. Upwind and local NOx emission controls are beneficial to reduce ozone in the area.87

• For the St. Louis source regions, the preponderance of ozone is formed under NOx-limited (81%) rather than VOC-limited (19%) conditions. For nearly all of the rest of the source regions, most of the ozone is formed under NOx-limited conditions.88

• The results of the FIVE States Stakeholder OSAT analysis suggest that local controls in Missouri and Illinois would be most cost-effective ... In addition, the results clearly indicate that NOx is a primary contributor to elevated ozone concentrations in the St. Louis area ...

Other Related Notes:

• In order to control ozone from upwind sources, Missouri developed the 10 CSR 10-6.345 Control of NOx Emissions From Upwind Sources adopted in August of 2006. The rule applied to sources of NOx that emitted over 900 tons in an ozone season. The rule sunsetted after 5 years. Notably, the rule addressed NOx emissions and did not address voe emissions, presumably, because NOx reductions have a greater effect on ozone than voes.

85Modified Table A-1 from Missouri's State Implementation Plan, Appendix A of the Marginal Area Plan for the Missouri Portion of the St. Louis Nonattainment Areafor the 2008 8-H.our Ground Level Ozone National Ambient Air Quality Standard (NAAQS), September 2014 86 Modified Table A-2 from same source as 2. 87 Illinois Environmental Protection Agency, St. Louis 8-Hour Ozone Technical Support Document (issued March 26, 2007), pp2. 88 Id, pp109

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• Many other states have allowed for the use of inter-pollutant trading at a 1:1 ratio of NOx to VOC.

Although we did not do an exhaustive search, following are some of the examples that we did find.

o According to information we have received, Maryland allowed the use of severe voe credits in

place of NOx credits at a ratio of 1.69 tons voe to each ton of NOx. Pennsylvania obtained

USEPA Region Ill's approval to use the same ratio in the Philadelphia nonattainment area.

o New Hampshire DES said that the only time a model is required to justify a trading ratio is when

the ratio is something other than 1:1.

Conclusion:

Previous SIP submittals and studies show that the St. Louis area is NOx-limited and therefore reduction

of NOx would produce the same or arguable higher benefit to ozone reduction than an equal amount

of voe reduction. As a result, Missouri's Air Pollution Control Program is approving the use of a 1:1 NOx to voe inter-pollutant offset ratio with EPA's concurrence.

Document Links: 1 http://ntrs.nasa.gov/archive/nasa/casi. ntrs. nasa. gov/20090027650. pdf 2 http://dnr.mo.gov/env/apcp/docs/agmp-final-tech-report-9-30-13-append ix-a. pdf 3 http://d n r. mo. gov/env/apcp/docs/Completesu bmittal-Adoption RevSTL03MaintPlanand RedesReq4-9-14: pdf 4•5 http://dnr.mo.gov/env/apcp/ozone/su bm ittal-without-append ices-STL-2008-03-marg in al. pdf

6 http://www.epa.state.il.us/air/sip/stlouis-8hr-o3-tsd

Further Justification for Use of NOx Credits for voe Offsets in St. Louis Area November 16, 2015

Issue To further support the use of NOx credits in lieu of voes for the project outlined in the previous justification, dated October 31 51

, 2015, EPA has asked us to look further into the voe profile associated with the proposed increase in voes at the Metal Container facility. The purpose of the inquiry is to determine the reactivity of the voe emissions being emitted.

voe Speciation Table 1 below contains a summary provided by Metal Containers Corporation (MCC) of the main VOCs and amounts expected from both Lines 5 & 6 without 100% capture:

Please note that the speciated emissions rates do not 100% match up to the VOC emission rate. This is because the MSDSs at times give a range. For example, VOC emissions from inside spray on Line 5 is estimated to be 50.18 TPY ... (This number is most accurate because the vendor provides a lbs voe/ gal coat) While the sum of the speciated voe calcs is 54.15 TPY. Again, this is because the MSDS data is provided as a range versus an exact number (Technical data sheets for the coatings may tell exactly what the lbs voe/ gal coat is but they do not always get an exact VOC breakdown). The difference is insignificant and is skewed on the high side for this exercise.

Reactivity When looking at what drives local ozone production, one can look at reaction rates among the contaminants in the ozone mix. Looking at the voe part of the equation, not all voes are created equal - some voes make ozone much more effectively than others. We can define reactivity as the potential of a given compound to make ozone. 89 Maximum Incremental Reactivity (MIR) is a reactivity scale used to measure the maximum amount of

89 Thomas, Ron, Texas Commission on Environmental Quality, et al, Emissions Modeling of Specific Highly Reactive Volatile Organic Compounds (HRVOC) in the Houston-Galveston_Brazoria Ozone Nonattainment Area

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ozone that can be formed by adding an incremental amount of a particular voe to a mixture of NOx-rich air. The higher the number, the more reactive. According to Carter's MIR scale90

, MIR values range from -1.27 to 20.1. The Texas Commission on Environmental Equality (TCEQ) focused on a subset of highly reactive VOC (HRVOC) for ozone control in the Houston area. These compounds all had Ml Rs of 9 and higher.

T bl 1 T voe E ·tt d f a e op s m, e rem p repose d p . ro1ect at MCC Compound Max Amount MIR

Emitted (tpy) Butyl Cellosolve 67.31 2.9 N-Butyl Alcohol 37.57 2.7 DPM Glycol Ether 27.44 2.21 N, N-Dimethylethanolamine 26.84 5.62 Proprietary VOCs 21.09 N/0 VM&P Naptha 14.35 1.75 2, Propanol 4.77 2.3 Weighted average* 178.28 3.05 *The weighted average is an approximation of the reactivity of voes expected to be emitted and does not take into account the proprietary voe since their chemical structure is not known at this time.

Conclusion It is worth noting that isoprene which is the main constituent of the biogenic VOCs in the St. Louis area has a MIR value of 10.61. This natural and abundant source ofVOC emissions is much more reactive than the main VOCs expected to be emitted by MCC. In addition, none of the compounds listed above are contained in lists by EPA or TCEQ as being considered among the HRVOCs.

9° Carter, W.P.L., Air Pollution Research Center and College of Engineering Center for Environmental Research and Technology University of California, Riverside, SAPRC Atmospheric Chemical Mechanisms and VOC Reactivity Scales

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DEC 2 1 2016 Ms. Cheryl Rogers Plant Manager Metal Container Corporation 42 Tenbrook Industrial Park Arnold, MO 63010

Jeremiah W Qay) Nixon, Governor • Harry D. Bozoian, Director

T OF NATURAL RESOURCES dnr.mo.gov

RE: New Source Review Permit - Project Number: 2016-02-047

Dear Ms. Rogers:

Enclosed with this letter is your permit to construct. Please study it carefully and refer to Appendix A for a list of common abbreviations and acronyms used in the permit. Also, note the special conditions on the accompanying pages. The document entitled, "Review of Application for Authority to Construct," is part of the permit and should be kept with this permit in your files. Operation in accordance with these conditions, your new source review permit application, and a revision of your operating permit renewal application is necessary for continued compliance. The reverse side of your permit certificate has important information concerning standard permit conditions and your rights and obligations under the laws and regulations of the State of Missouri.

This permit may include requirements with which you may not be familiar. If you would like the department to meet with you to discuss how to understand and satisfy the requirements contained in this permit, an appointment referred to as a Compliance Assistance Visit (CAV) can be set up with you. To request a CAV, please contact your local regional office or fill out an online request. The regional office contact information can be found at the following website: http://dnr.mo.gov/regions/. The online CAV request can be found at http://dnr.mo.gov/cav/compliance.htm.

If you were adversely affected by this permit decision, you may be entitled to pursue an appeal before the administrative hearing commission pursuant to §§621.250 and 643.075.6 RSMo. To appeal, you must file a petition with the administrative hearing commission within 30 days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed; if it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the administrative hearing commission, whose contact information is: Administrative Hearing Commission, United States Post Office Building, 131 West High Street, Third Floor, P.O. Box 1557, Jefferson City, Missouri 65102, phone: 573-751-2422, fax: 573-751-5018, website: www.oa.mo.gov/ahc.

() Recycled paper

Ms. Cheryl Rogers Page Two

If you have any questions regarding this permit, please do not hesitate to contact Alana Hess, at the Department of Natural Resources' Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102 or at (573) 751-4817. Thank you for your attention to this matter.

Sincerely,

AIR POLLUTION CONTROL PROGRAM

Susan Heckenka p New Source Review Unit Chief

SH:ahj

Enclosures

c: St. Louis Regional Office PAMS File: 2016-02-047

Permit Number: 1 '2 2 0 1 6 - 0 0 7