Facility Name: KIMOTO TECH, Inc. City: Cedartown County: Polk AIRS #:

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1 Facility Name: KIMOTO TECH, Inc. City: Cedartown County: Polk AIRS #: Application #: TV Date Application Received: September 28, 2015 Permit No: V-04-0 Program Review Engineers Review Managers SSPP Steve Neadow Manny Patel ISMP Anna Gray Dan McCain SSCP Afunya Addo-Osafo James Eason Toxics N/a N/a Permitting Program Manager Eric Cornwell Introduction This narrative is being provided to assist the reader in understanding the content of the attached draft Part 70 operating permit. Complex issues and unusual items are explained here in simpler terms and/or greater detail than is sometimes possible in the actual permit. This permit is being issued pursuant to: (1) Georgia Air Quality Act, O.C.G.A , et seq. and (2) Georgia Rules for Air Quality Control, Chapter , and (3) Title V of the Clean Air Act. Section (10) of the Georgia Rules for Air Quality Control incorporates requirements of Part 70 of Title 40 of the Code of Federal Regulations promulgated pursuant to the Federal Clean Air Act. The primary purpose of this permit is to consolidate and identify existing state and federal air requirements applicable to KIMOTO TECH, Inc. and to provide practical methods for determining compliance with these requirements. The following narrative is designed to accompany the draft permit and is presented in the same general order as the permit. It initially describes the facility receiving the permit, the applicable requirements and their significance, and the methods for determining compliance with those applicable requirements. This narrative is intended as an adjunct for the reviewer and to provide information only. It has no legal standing. Any revisions made to the permit in response to comments received during the public participation and EPA review process will be described in an addendum to this narrative. Printed: April 12, 2016 Page 1 of 14

2 I. Facility A. Facility Identification 1. Facility Name: KIMOTO TECH, Inc. 2. Parent/Holding Company Name: KIMOTO TECH, Inc. 3. Previous and/or Other Name(s): None. 4. Facility Location: 601 Canal Street, Cedartown, Georgia Attainment, Non-attainment Area Location, or Contributing Area B. Site Determination The facility is located in Polk County, which is considered an attainment area for all criteria pollutants. There are no other facilities which could possibly be contiguous or adjacent and under common control. C. Existing Permits Table 1: List of Current Permits, Amendments, and Off-Permit Changes Permit Number and/or Off- Permit Change Date of Issuance/ Effectiveness Purpose of Issuance V-03-0 March 24, 2011 Title V Renewal D. Process 1. SIC Codes(s) The SIC Code(s) identified above were assigned by EPD's Air Protection Branch for purposes pursuant to the Georgia Air Quality Act and related administrative purposes only and are not intended to be used for any other purpose. Assignment of SIC Codes by EPD's Air Protection Branch for these purposes does not prohibit the facility from using these or different SIC Codes for other regulatory and non-regulatory purposes. Should the reference(s) to SIC Code(s) in any narratives or narrative addendum previously issued for the Title V permit for this facility conflict with the revised language herein, the language herein shall control; provided, however, language in previously issued narratives that does not expressly reference SIC Code(s) shall not be affected. Printed: April 12, 2016 Page 2 of 14

3 2. of Product(s) Coated plastic (polyester) films and strips used as masking films, ink and laser jet printer films and audiocassette leader taps. 3. Overall Facility Process Kimoto Tech, Inc. coats base film made from different substrates, e.g., polycarbonate, polyester, etc. Dryers remove coated solvents. The remaining dried, coated film becomes an article of manufacturer that Kimoto Tech, Inc. markets as either a final product or a product intermediate that other manufacturers use in their products. Applications for coated films include printing plates for offset printing and media used for digital printing. Specialty coating for third parties include pressure sensitive adhesives, barrier films, electrostatic films for printing and films for photoelectric applications. Kimoto Tech, Inc. has two production lines for specialty coating. Each line has sequential coaters and dryers for multi-station film coating. Substrate film is purchased from vendors in rolls. The film is threaded from an unwinding unit to a precision coating machine, then to a dryer and eventually it goes to a winding unit. The dried film is stored, inspected and converted to sheets or short rolls, according to customer requirements. Other activities that support film coating include batching or mixing coating solutions and boilers for generating steam for in line dryers. Coating mixing occurs in two separate chemical building in bulk capacity process tanks and in smaller capacity containers. Pot container capacities are usually 55gallons; totes are up to 250 gallons. Three small package boilers (<10,000,000 BTU per hour heat input capacity) provide utility steam for indirect heating of process tanks and dryers. Coaters and dryers exhausts are captured and routed to thermal oxidizers for destruction of VOC's and HAP's before release to the atmosphere. Production support activities include material handling and storage, work area clean-up, a QA/QC laboratory, a R&D facility, and a maintenance shop. 4. Overall Process Flow Diagram E. Regulatory Status The facility provided a process flow diagram in their Title V permit application. 1. PSD/NSR This facility is potentially a major source under PSD regulations, but has taken VOC emission limit of 249 tons per year to remain a non-major source under PSD/NSR regulations. Printed: April 12, 2016 Page 3 of 14

4 2. Title V Major Source Status by Pollutant Table 2: Title V Major Source Status Pollutant Is the Pollutant Emitted? If emitted, what is the facility s Title V status for the pollutant? Major Source Major Source Status Requesting SM Status PM Yes Non-Major Source Status PM 10 Yes PM 2.5 Yes SO 2 Yes VOC Yes NO x Yes CO Yes TRS H 2 S Individual HAP Yes Total HAPs Yes Total GHGs Yes 3. MACT Standards The facility is subject to the following subparts of 40 CFR Part 63, Subpart JJJJ, National Emission Standards for Hazardous Air Pollutants: Paper and Other Web Coating. 4. Program Applicability (AIRS Program Codes) Program Code Program Code 6 - PSD Program Code 8 Part 61 NESHAP Program Code 9 - NSPS Program Code M Part 63 NESHAP Program Code V Title V Applicable (y/n) No No No Yes Yes Printed: April 12, 2016 Page 4 of 14

5 Regulatory Analysis II. Facility Wide Requirements A. Emission and Operating Caps: The facility has a previously accepted 249 tpy VOC emissions limit to remain a minor source under PSD/NSR regulations. B. Applicable Rules and Regulations The facility is subject to the requirements of 40 CFR 63 Subparts A, General Provisions" and JJJJJ, National Emission Standards for Hazardous Air Pollutants: Paper and Other Web Coating. C. Compliance Status Title V application submitted was late and thus Consent Order No. EPD-AQC-6818 was issued. D. Operational Flexibility None applicable. E. Permit Conditions Renewal Condition Notes This condition limits the plant-wide VOC emissions to 249 tpy. The Permittee uses VOC control systems consisting of thermal oxidizers and emission capture systems to comply with this condition. Conditions and identifies this facility is subject to the applicable requirements under 40 CFR Part 63, Subpart A and 40 CFR Part 63, Subpart JJJJJ. Both conditions emphasize that actual text as specified in 40 CFR Part 63, Subpart A or 40 CFR Part 63, Subpart JJJJJ shall govern when there are discrepancies between the requirements in the conditions of this permit and 40 CFR Part 63, Subpart A or Subpart JJJJ. III. Regulated Equipment Requirements A. Brief Process This facility produces various coated plastic (polyester) films and strips. Some of the products are masking films used in the graphic arts industry. The others are used as ink and laser jet printer films or as audiocassette leader tapes. The coating operation is carried out on two similar multi-station web-coating lines which can perform either roller or knife coating. First, a specific clear polyester film from offsite suppliers is loaded onto a spindle in roll form and fed to coater rooms in sequence. Depending on the product specification, the film is treated with various solvents, colored by various tints, coated with specific coatings, then oven dried. The dried film Printed: April 12, 2016 Page 5 of 14

6 is rolled and stored for shipment. Thermal oxidizers are used to decrease VOC/HAP emissions from the web film coating processes. B. Equipment List for the Process Emission Units Specific Limitations/Requirements ID No. Applicable Requirements/Standards Line 1 D1L1 Dryer #1 on Line # (2)(b) D2L1 Dryer #2 on Line # (2)(e) C1L1 #1 Coating Head Application Line # (2)(w) C2L1 #2 Coating Head Application Line #1 40 CFR 63 Subpart JJJJ Line 2 D1L2 D2L2 D3L2 C1L2 Dryer #1 on Line #2 Dryer #2 on Line #2 Dryer #3 on Line #2 #1 Coating Head Application Line # (2)(b) (2)(e) (2)(w) 40 CFR 63 Subpart JJJJ C2L2 #2 Coating Head Application Line #2 C3L2 #3 Coating Head Application Line #2 Corresponding Permit Conditions through 3.2.4, 3.3.1, through 3.4.3, 4.2.1, 4.2.2, 5.21 through 5.2.6, 5.2.7, 6.1.7, through 3.2.4, 3.3.1, through 3.4.3, 4.2.1, 4.2.2, 5.21 through 5.2.6, 5.2.8, 6.1.7, 6.2 Air Pollution Control Devices ID No. OTL2 O3L2 Thermal Oxidizer Regenerative Thermal Oxidizer Moved to Insignificant Activities Based on Emission Levels Emission Units Specific Limitations/Requirements Air Pollution Control Devices ID No. Corresponding Applicable ID Permit Requirements/Standards No. Conditions T001 Toluene Storage Tank T002 MEK Storage Tank T003 Butyl Acetate Storage Tank T004 Wet Solvent Storage Tank T005 No. 2 Fuel Oil Storage Tank T006 EVA II Dope Storage Tank T007 P Tank T008 E Tank TPR1 Propane Tank TK04 Mixing Tank #4 TK06 Mixing Tank #6 TK10 Mixing Tank #10 TK11 Mixing Tank #11 T101 Mixing Tank #101 T109 Mixing Tank #109 T111 Mixing Tank #111 TK07 Storage Tank #7 TK05 Storage Tank #5 T107 Storage Tank #107 T108 Storage Tank #108 T110 Storage Tank #110 Equipment No Longer in use. Emission Units Specific Limitations/Requirements Air Pollution Control Devices ID No. Corresponding Applicable ID Permit Requirements/Standards No. Conditions TK01 Storage Tank #1 N/A N/A TK02 Mixing Tank #2 N/A N/A TK03 Storage Tank #3 N/A N/A Printed: April 12, 2016 Page 6 of 14

7 Emission Units Specific Limitations/Requirements Air Pollution Control Devices ID No. Corresponding Applicable ID Permit Requirements/Standards No. Conditions TK08 Mixing Tank #8 N/A N/A TK09 Storage Tank #9 N/A N/A TK12 Mixing Tank #12 N/A N/A T102 Mixing Tank #102 N/A N/A T103 Mixing Tank #103A N/A N/A T104 Mixing Tank #103B N/A N/A CR01 Nol Tee Rubber Crusher (2)(b) (2)(e) 3.4.2, NDF1/ NDF2 Dust Collector C. Equipment & Rule Applicability Emission and Operating Caps: KIMOTO TECH uses thermal oxidizers to reduce the VOC and HAP emissions from the web film coating lines and thus to comply with the VOC and HAP emission limitations in this permit. Therefore, the operating parameters of the oxidizers and associated emission capture systems established during performance tests become the operating limits/standards for the coating operations. The values of these parameters were established during the most recent performance tests. Rules and Regulations Assessment: Georgia Rule (2)(b) - Visible Emissions applies to all the process units at this facility which do not have a more stringent limit. Visible emissions are limited by this Rule to less than 40% opacity. The visible emissions from this facility are substantially below 40% opacity due to the nature of the production processes involved. Georgia Rule (2)(e) - Particulate Emission from Manufacturing Processes applies to all process units at this facility that are not covered by a more specific rule or regulation. This Rule establishes particulate matter (PM) emission limits for the process units based on their process weight input rates. PM emissions from this facility are substantially below the applicable Georgia Rule (e) limits due to the natural of the production processes involved. Georgia Rule (2)(d) - Fuel Burning Equipment applies to all indirectheating fuel burning units such as boilers and water heaters at this facility. The rule limits both the PM and visible emissions from these fuel burning sources, which are anticipated to be substantially below the applicable Georgia Rule (d) limits due to the nature of the equipment and the fuels involved. Georgia Rule (2)(g) Sulfur Dioxide limits the sulfur content(s) of the fuel(s) used by the this facility to no more than 2.5% by weight. Kimoto only uses natural gas as regular process fuel and fuel oil as backup. Since the sulfur contents in natural gas are well below the Georgia Rule (g) limit, it is not necessary to keep sulfur Printed: April 12, 2016 Page 7 of 14

8 content records for natural gas. The Permittee is required to keep fuel sulfur content records when burning fuel oil(s). Georgia Rule (2)(w) - Paper Coating applies to the film coating operations at this facility because the operations have potential to emit 100 tpy or more of VOC in total. Georgia Rule (w) limits the VOC emissions from the film coating operations at this facility to no more than 2.9 pounds per gallon of each coating, excluding water, delivered to the coating applicator from a coating line. If such coating contains more than 2.9 pounds VOC per gallon, the solids equivalent limit shall be 4.79 pounds VOC per gallon of coating solids (24-hour composite average) delivered to the coating applicator. If used, the VOC control system shall have a Division-approved VOC capture system, destroy or recovery at least 90% of the nonmethane VOC entering, and achieve an overall VOC emissions rate less than the solids equivalent limit. Currently the facility depends on the use of VOC control systems to comply with Georgia Rule (w). The use of the VOC control system is optional when the facility only uses compliant coatings. The facility is an existing major source under NESHAP rules because the potential HAP emissions from the film coating processes exceed 10/25 tpy. Because they are utilized for film web coating, both Coating Lines No. 1 and 2 are subject to the MACT standard under 40 CFR Part 63, Subpart JJJJ, National Emissions Standards for Hazardous Air Pollutants: Paper and Other Web Coating. The facility shall comply with the applicable emission limitation(s) and/or work practice standard(s) of this MACT standard by the existing source compliance date of December 5, The Permittee plans to use only thermal oxidation to comply with the standard. D. Compliance Status Title V application submitted was late and thus Consent Order No. EPD-AQC-6818 was issued. E. Operational Flexibility None applicable. F. Permit Conditions Renewal Condition Notes Emission requirements / operating caps associated with the MACT standard, 40 CFR Part 63, Subpart JJJJ attributed to Thermal Oxidizer (OTL2). Emission requirements / operating caps associated with the MACT standard, 40 CFR Part 63, Subpart JJJJ attributed to Thermal Oxidizer (OTL2) and Regenerative Thermal Oxidizer O3L2. Limiting organic hazardous air pollutant (HAP) emissions from each web coating operation/web coating lines at this facility to no more than 5% of the organic HAP applied for each month (95% reduction). Limiting emissions from any paper coating operations as performed on Coating Lines No. 1 or No. 2, volatile organic compounds (VOC) in amounts exceeding 2.9 pounds per gallon of coating, excluding water, delivered to the coating applicator from a paper coating line. Printed: April 12, 2016 Page 8 of 14

9 Renewal Condition Notes GA Rule (e) Emission limit based on process rate GA Rule (b) 40% Opacity limit The facility must maintain an inventory of critical spare parts for all control equipment for such parts that are most probable to fail under normal operating conditions. IV. Testing Requirements (with Associated Record Keeping and Reporting) A. General Testing Requirements The permit includes a requirement that the Permittee conduct performance testing on any specified emission unit when directed by the Division. Additionally, a written notification of any performance test(s) is required 30 days (or sixty (60) days for tests required by 40 CFR Part 63) prior to the date of the test(s) and a test plan is required to be submitted with the test notification. Test methods and procedures for determining compliance with applicable emission limitations are listed and test results are required to be submitted to the Division within 60 days of completion of the testing. B. Specific Testing Requirements Renewal Condition Notes Standard testing conditions listed in all Title V Permits including specific tests associated with this facility s process. This condition is added updating template addressing the US EPA's Central Data Exchange (CDX) using the Compliance and Emissions Data Reporting Interface (CEDRI) in accordance with any applicable NSPS or NESHAP standards (40 CFR 60 or 40 CFR 63) that contain Electronic Data Reporting Requirements. Requires the facility to test the oxidizers once every five years to ensure optimum operating conditions are being met. Last performance test; June 13, Requires that all continuous monitoring system(s) shall be installed, calibrated and operating in accordance with the applicable manufacturer specifications when any performance test(s) is conducted. If the production rate(s) increases above the rate(s) at which the acceptable performance test(s) was made, the Division may require additional testing for compliance at the higher production rate. V. Monitoring Requirements A. General Monitoring Requirements Condition requires that all continuous monitoring systems required by the Division be operated continuously except during monitoring system breakdowns and repairs. Monitoring system response during quality assurance activities is required to be measured and recorded. Maintenance or repair is required to be conducted in an expeditious manner. Printed: April 12, 2016 Page 9 of 14

10 B. Specific Monitoring Requirements Renewal Condition Notes Requires that all continuous monitoring systems required by the Division be operated continuously except during monitoring system breakdowns and repairs. Monitoring system response during quality assurance activities is required to be measured and recorded. Maintenance or repair is required to be conducted in an expeditious manner. Specific monitoring requirements associated with the MACT standard, 40 CFR Part 63, Subpart JJJJ attributed to Thermal Oxidizer (OTL2) and Regenerative Thermal Oxidizer O3L2. The facility must implement and maintain a program for leak detection and correction for the hoses and ductworks serving the VOC emission capture systems and VOC control devices. Conditions 5.2.6, and establish CAM conditions for the VOC emissions from Coating Lines No. 1 and/or No. 2 respectively. These conditions are based on the CAM Plan provided with the permit renewal application No and the HAP emission monitoring plans to be submitted by KIMOTO for the emission capture systems serving both of the oxidizers. C. Compliance Assurance Monitoring (CAM) The CAM plan has been updated in this renewal permit. Indicator No. 2 is the static pressure difference. This indicator will ensure the capture system is operating properly. Condition No contains the CAM requirements for Line 1. Under Indicator No. 1 - Temperature, the general criteria list two temperatures for the combustion chamber. These temperatures represent the minimum combustion temperature necessary depending on whether the VOC load is low or high. VI. Record Keeping and Reporting Requirements A. General Record Keeping and Reporting Requirements The Permit contains general requirements for the maintenance of all records for a period of five years following the date of entry and requires the prompt reporting of all information related to deviations from the applicable requirements. Records, including identification of any excess emissions, exceedances, or excursions from the applicable monitoring triggers, the cause of such occurrence, and the corrective action taken, are required to be kept by the Permittee and reporting is required on a semiannual basis. Template Conditions and were updated in September 2011 to allow ~60 days to submit periodic reports. Alternative reporting deadlines are allowed per 40 CFR 70.6, 40 CFR 60.19(f) and 40 CFR 63.10(a). Printed: April 12, 2016 Page 10 of 14

11 B. Specific Record Keeping and Reporting Requirements Renewal Condition(s) Notes Standard record keeping and reporting requirements. Updated and slightly modified Excess Emissions: None. Exceedances: VOC emissions from the entire plant in amounts exceeding 249 tons during any consecutive 12-month period. VOC emissions from either Coating Line No. 1 or No. 2 that exceed the applicable limit(s) in Condition HAP emissions from any work/coating station(s) on the Coating Line No. 1 or No. 2 that is not operated as an always-controlled working station. Excursions: Any 3-hour period during which the average combustion temperature of the thermal oxidizers (Air Pollution Control Device ID Nos. OTL2 and O3L2) is below the value established by the most recent performance test. Any 3-hour period during which the average pressure drop is less than water column for the capture system associated with the thermal oxidizers (Air Pollution Control Device ID Nos. OTL2 and O3L2) Additional Requirements Any calendar month in which the facility-wide VOC emissions exceed tons. Conditions require KIMOTO maintain, record, and calculate the consecutive 12-month rolling total of VOC emissions from the entire facility for each calendar month in the reporting period. KIMOTO must notify the Division in writing if the 12-month rolling total of VOC emissions from the entire facility exceeds 249 tons. For each of the paper coating lines subject to Rule (2)(w), KIMOTO must keep separate material usage and/or production records which allow the determination that each of the coating lines is in compliance with Condition Condition establishes the applicable recordkeeping requirements under 40 CFR part 63, Subpart JJJJ and requires KIMOTO to maintain all the records required by the applicable provisions of 40 CFR (a) for each of the web coating lines in accordance with 40 CFR 63.10(b)(1) and (b)(2). Condition requires KIMOTO to use the records in Condition to prepare and submit semiannual compliance reports according to 40 CFR (c). Condition requires KIMOTO develop and implement a Startup, Shutdown, and Malfunction Plan (SSMP) for the web film coating lines using control devices to comply with the HAP emission limit as directed in 40 CFR Part 63, Subpart JJJJ. Condition requires KIMOTO submit a Startup, Shutdown, and Malfunction Plan (SSMP) for the web film coating lines using control devices to comply with the HAP emission limit as directed in 40 CFR Part 63, Subpart JJJJ. VII. Specific Requirements A. Operational Flexibility Not applicable. Printed: April 12, 2016 Page 11 of 14

12 B. Alternative Requirements Not applicable. C. Insignificant Activities Refer to for the Online Title V Application. Refer to the following forms in the Title V permit application: Form D.1 (Insignificant Activities Checklist) Form D.2 (Generic Emissions Groups) Form D.3 (Generic Fuel Burning Equipment) Form D.6 (Insignificant Activities Based on Emission Levels of the Title V permit application) D. Temporary Sources Not applicable. E. Short-Term Activities Not applicable. F. Compliance Schedule/Progress Reports The facility is compliant with all applicable rules and regulations listed in previous sections of this narrative. G. Emissions Trading Not applicable. H. Acid Rain Requirements Not applicable. I. Stratospheric Ozone Protection Requirements Not applicable. J. Pollution Prevention Not applicable. Printed: April 12, 2016 Page 12 of 14

13 K. Specific Conditions Not applicable. Printed: April 12, 2016 Page 13 of 14

14 VIII. General Provisions Generic provisions have been included in this permit to address the requirements in 40 CFR Part 70 that apply to all Title V sources, and the requirements in Chapter of the Georgia Rules for Air Quality Control that apply to all stationary sources of air pollution. Template Condition was updated in September 2011 to change the default submittal deadline for Annual Compliance Certifications to February 28. Template Condition Section 8.27 was updated in August 2014 to include more detailed, clear requirements for emergency generator engines currently exempt from SIP permitting and considered insignificant sources in the Title V permit. Template Condition Section 8.28 was updated in August 2014 to more clearly define the applicability of the Boiler MACT or GACT for major or minor sources of HAP. Printed: April 12, 2016 Page 14 of 14

15 Title V Application Review KIMOTO TECH, Inc., TV Addendum to Narrative The 30-day public review started on February 24, 2016 and ended on March 25, The Division received no comments from the public, U.S. EPA, or company. Printed: April 12, 2016 Addendum Page 1 of 1