MEMORANDUM January 27, Phillip Fielder, P.E., Permits and Engineering Group Manager

Transcription

1 OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION DRAFT/PROPOSED MEMORANDUM January 27, 2015 TO: THROUGH: THROUGH: THROUGH: FROM: SUBJECT: Phillip Fielder, P.E., Permits and Engineering Group Manager Rick Groshong, Environmental Programs Manager, Enforcement Section Phil Martin, P.E., Engineering Manager, Existing Source Section Peer Review Eric L. Milligan, P.E., Engineering Section Evaluation of Permit Application No TVR2 (M-3) Jindal Films Americas, L.L.C. Films Shawnee L.L.C. (SIC 2671) Facility ID: Wolverine Road Shawnee, Pottawatomie County Located 3 miles north of I-40 on SH 18 and ½ mile west on Wolverine Road. Latitude: ; Longitude: SECTION I. INTRODUCTION Jindal Films Americas, L.L.C. has applied for a significant modification of their current permit to remove the requirements for control of VOC emissions from Line 112, with a thermal oxidizer, from their current permit. The facility is currently operating as authorized by Permit No TVR2 (M-2). The thermal oxidizer was originally installed at the facility in 1992 as authorized by Permit No C, issued September 17, 1992, as part of installation of a new coating line (Line 112). The original permit did not list any underlying applicable requirements for installation of the thermal oxidizer to control VOC emissions from the new Line 112. It was later noted, that the total potential emissions permitted for the facility were in excess of the PSD major source thresholds (250 TPY See Applicability Determination No AD, issued September 29, 1998) at the time Line 112 was installed and that operation of Line 112 with the thermal oxidizer ensured that VOC emissions were below the PSD significance level (40 TPY). Permit No C, documented that the thermal oxidizer was not considered BACT for toxic emissions because the cost per ton was too high. In order to justify removal of the thermal oxidizer, which is used to control emissions of VOC from Line 112, all regulatory requirements have to be evaluated to ensure that removal of the control device would not have caused uncontrolled emissions from Line 112 to trigger an applicable requirement or to establish limits on uncontrolled emissions from Line 112 to prevent a potential violation of an applicable requirement.

2 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 2 There were three BACT requirements in effect at the time of installation of Line 112: the BACT requirements for Prevention of Significant Deterioration (PSD), the BACT requirements for any major source (>100 TPY), and the BACT requirements for emissions of Toxic Air Contaminates (TAC) greater than the de minimis levels. Since the facility has taken an emission limit below the PSD major source thresholds and will maintain that limit after removal of the thermal oxidizer, removal of the thermal oxidizer should not trigger PSD requirements retroactively. As previously indicated, the cost of the control device at the time of installation ($/ton) was not considered BACT. The last applicable requirement would be the BACT requirements for any major source (>100 TPY) or modification of any major source (>100 TPY). A limit of less than 100 TPY on the emissions from Line 112 will ensure that this BACT requirement would not have been violated. Therefore, the permit will establish a VOC emission limit for Line 112 to ensure that installation of Line 112 would not retroactively trigger applicable BACT requirements. SECTION II. PROCESS DESCRIPTION Plastic resin pellets are the raw material used to make film in this plant. It is received at the plant in rail and truck shipments. New and reclaimed pellets are pneumatically conveyed to storage and then to the orientation lines. At the conveying discharge point, the spent conveyance air is discharged through bag filters after the material has been conveyed to its discharge point. The resin is extruded in molten form through a flat die using an extruder. The molten polymer comes out of the flat die in the form of a 36-inch wide flat base sheet and is quenched using a cast roller. The base sheet is then stretched in the machine direction (MD) using differential speeds of oil heated rollers. Both edges of the MD stretched sheet are then secured into clips running on two endless conveying chains diverging into an air heated oven that causes the sheet to stretch into the transverse direction (TD). At the oven exit, the 240-inch wide film is trimmed, split into two 120-inch wide webs and the surface is modified using a corona treatment process. Corona treatment is the imparting of a static electrical charge to the plastic resin sheet in order to improve the adhesion properties of the surface prior to coating. The webs are then wound into mill rolls which will be subsequently slit or coated then slit. The mill rolls are warehoused until needed for shipment or further processing. A significant portion of the facility's production is coated in order to enhance physical and chemical properties of the film. Coating operations can typically include the following steps: The mill roll is received from the orientation line or roll storage, unwound and treated on one or both sides with a Corona process, The precoat is then applied on both sides simultaneously or sequentially, The film is then dried in vertical or horizontal ovens, The topcoat is then applied on one side at a time, Next, the film is dried one final time, and Finally, the film is cooled down on a chill roll and wound into a coated mill roll.

3 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 3 Scrap material generated during orientation is returned to the reclaim area, for repelletization prior to reuse or resale. Uncoated and coated film generated during manufacturing is either sold, recycled, or disposed. Recycling consists of grinding the film into fluff that is subsequently extruded and pelletized. The recycled pellets are blended with virgin resin prior to being used in the orientation lines. Essential film properties are determined by the nature of the resin, including the average molecular weight. Additional factors include the type and quantity of additives, the orientation and quenching temperatures, and the stretch ratios. Film flatness is the result of a delicate combination of proper process conditions along the orientation line with proper die adjustment controlled by computerized scanning equipment. Film properties are also obtained by controlling the accurate make-up of the coating batches, by uniformly and precisely applying the correct amount of coating, and drying the precoat and topcoat. During the slitting process, a slitter unwinds the film from the mill roll at high speed. Properly spaced blades in the film path slit the web into multiple narrower webs that are rewound by contact pallets that will be stored in a finished goods warehouse prior to being shipped to customers. SECTION III. EQUIPMENT The facility is organized into one emission unit group (EUG) that incorporates the orientation lines, the coating lines, and the emergency fire pump engine. The orientation lines consist of the equipment used to store and transfer materials, extrude and stretch the plastic resin into a film, and any associated recycling of the material. The coating lines include all of the equipment associated with blending, applying, drying, and emission controls associated with the coating lines. The facility uses an 85-bhp diesel fire pump engine as a backup power source for the fire suppression system. Facility Wide Emission Unit Group Orientation Lines Lines 100, 101, 102, 103, 104, 105, 106 Coating Lines Lines 110, 111, STENG01 Emergency Fire Pump Diesel Engine SECTION IV. EMISSIONS The types of emissions from the facility are: combustion emissions, VOC emissions, PM 10 emissions, and ozone emissions resulting from use of coatings and from the plastic resin extrusion process. Emissions from the combustion of natural gas were estimated from AP-42 (7/98), Section 1.4. VOC emissions from the coating process are calculated using mass balance based on the coating formulation. VOC and PM 10 emissions resulting from the orientation lines have been estimated using a calculation method developed by Mobil Chemical s Research and Development group. This calculation method was derived from targeted stack testing designed

4 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 4 to develop a single emission factor that would represent the range of all variables and operations. A statistical characterization was developed from the emission data collected. A 95% statistical confidence level of the mean s upper confidence limit was used to establish the emission factor. HAP emissions are also speciated using these calculation methods. Ozone emissions are generated by the corona treaters used on the orientation lines to prepare the film surface for coating. Ozone emissions from the corona treaters are based on stack tests conducted at a similar facility and a formula derived from those stack tests and the actual rating of the corona treaters. Emissions from the Emergency Fire Pump Engine were based on AP-42 (10/96), Section 3.3. Total Facility Emissions NO X CO VOC SO 2 PM 10 O 3 EUG TPY TPY TPY TPY TPY TPY 1 - Orientation Lines Coating Lines Emergency Fire Pump Eng Totals Coatings and raw materials used contain ammonia and HAP. The coatings chemical composition and safety data are available on Material Safety Data Sheets (MSDS) which are kept at the facility. The table below lists facility-wide estimates of the HAP and ammonia emissions from the coating and orientation operations. Estimated Ammonia & HAP Emissions HAP CAS # TPY 1,1,1-Trichloroethane Acetaldehyde Acetophenone Acrolein <0.01 Carbon Disulfide Formaldehyde Hexyl Cellosolve Methanol Methyl Methacrylate Propionaldehyde Toluene Vinyldiene Chloride Xylene Total HAP Ammonia

5 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 5 SECTION V. INSIGNIFICANT ACTIVITIES The insignificant activities identified and justified in the application are duplicated below. Appropriate recordkeeping of activities indicated below with * is specified in the Specific Conditions. 1. Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 MMBTUH heat input (commercial natural gas). The facility uses space heaters to heat the buildings. All are rated less than 1 MMBTUH. 2. * Emissions from fuel storage/dispensing equipment operated solely for facility owned vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day period. The facility has a 250-gallon gasoline tank and a 250-gallon diesel tank. Throughput of the tanks is approximately 1,500 gallons of unleaded gasoline and 4,000 gallons of diesel per year. Loading of gasoline at area sources of HAP is regulated by NESHAP Subpart CCCCCC. However, this facility is a major source of HAP and is not subject. Therefore, the gasoline loading is still considered an insignificant activity. 3. * Emissions from storage tanks constructed with a capacity less than 39,894 gallons which store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. None identified but may be used in the future. 4. Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including hazardous waste satellite (accumulation) areas. The facility has chemical, paint, and/or solvent storage rooms or cabinets, including hazardous waste satellite (accumulation) areas all which have emissions below 5 TPY. 5. * Activities that have the potential to emit no more than 5 TPY (actual) of any criteria pollutant. The cooling towers have actual emissions of less than 5 TPY. SECTION VI. OKLAHOMA AIR POLLUTION CONTROL RULES OAC 252:100-1 (General Provisions) Subchapter 1 includes definitions but there are no regulatory requirements. [Applicable] OAC 252:100-2 (Incorporation by Reference) [Applicable] This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal Regulations. These requirements are addressed in the Federal Regulations section. OAC 252:100-3 (Air Quality Standards and Increments) [Applicable] Primary Standards are in Appendix E and Secondary Standards are in Appendix F of the Air Pollution Control Rules. At this time, all of Oklahoma is in attainment of these standards.

6 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 6 OAC 252:100-5 (Registration, Emission Inventory, and Annual Operating Fees) [Applicable] Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission inventories annually, and pay annual operating fees based upon total annual emissions of regulated pollutants. Emission inventories have been submitted and fees paid for the past years. OAC 252:100-8 (Permits for Part 70 Sources) [Applicable] Part 5 includes the general administrative requirements for Part 70 permits. Any planned changes in the operation of the facility which result in emissions not authorized in the permit and which exceed the Insignificant Activities or Trivial Activities thresholds require prior notification to AQD and may require a permit modification. Insignificant activities mean individual emission units that either are on the list in Appendix I (OAC 252:100) or whose actual calendar year emissions do not exceed the following limits: 5 TPY of any one criteria pollutant 2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any threshold less than 10 TPY for single HAP that the EPA may establish by rule A facility-wide emission cap for all criteria pollutants and HAP has been established based on information in the previous permit (Permit TVR2 (M-2)) and information in the permit application. OAC 252:100-9 (Excess Emission Reporting Requirements) [Applicable] Except as provided in OAC 252: (a)(1), the owner or operator of a source of excess emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following working day of the first occurrence of excess emissions in each excess emission event. No later than thirty (30) calendar days after the start of any excess emission event, the owner or operator of an air contaminant source from which excess emissions have occurred shall submit a report for each excess emission event describing the extent of the event and the actions taken by the owner or operator of the facility in response to this event. Request for affirmative defense, as described in OAC 252: , shall be included in the excess emission event report. Additional reporting may be required in the case of ongoing emission events and in the case of excess emissions reporting required by 40 CFR Parts 60, 61, or 63. OAC 252: (Open Burning) [Applicable] Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in this subchapter. OAC 252: (Particulate Matter) [Applicable] This subchapter specifies a particulate matter (PM) emissions limitation of 0.6 lb/mmbtu from new fuel-burning equipment with a rated heat input of 10 MMBTUH or less and a formula for calculating the allowable emissions for heat inputs greater than 10 MMBTUH. AP-42, Table (7/98), lists the total PM emissions for natural gas to be 7.6 lb/mmft 3 or about lb/mmbtu. The table below lists the fuel-burning equipment with heat inputs greater than 10 MMBTUH and the allowable PM emission limitations. The permit requires the use of

7 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 7 commercial-grade natural gas for all fuel-burning equipment to ensure compliance with Subchapter 19. Fuel-Burning Equipment Heat Input (MMBTUH) PM Emissions (lb/mmbtu) Allowable PM Emissions (lb/mmbtu) Line 110 Topcoat Oven # Line 110 Topcoat Oven # Line 103 Oven Line 104 Oven Line 105 Oven Line 106 Oven This subchapter also limits emissions of particulate matter from direct-fired fuel-burning equipment and industrial processes based upon their process weight rates. The emission rate in pounds per hour (E) is not to exceed the rate calculated using the process weight rate in tons per hour (P), for process rates up to 60,000 lb/hr the formula in appendix G is (E = 4.10*P (0.67) ). The table on the following page lists the process weight rates and the allowable emissions for each process. Max Process Weight Rate (lb/hr) PM Emissions (lb/hr) PM Allowable (lb/hr) Material Handling* 30, Orientation Lines* 41, Coating Lines 15, * Material handling is part of the orientation lines, but is separated here due to different process weight rates. All conveying is done pneumatically and the exhaust from the conveying system is processed by either baghouses or fabric filters. With the baghouses and filters in place the facility will not exceed the allowable limits. The permit will require proper operation and maintenance of the baghouses and filters. OAC 252: (Visible Emissions and Particulate Matter) [Applicable] No discharge of greater than 20% opacity is allowed except for short-term occurrences, which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case, shall the average of any six-minute period exceed 60% opacity. When using natural gas as a fuel for the heaters there is very little possibility of exceeding the opacity standards. Particulate emissions from the material handling systems throughout the plant are controlled by use of baghouses or fabric filters. The permit will require proper operation and maintenance of the baghouses and filters.

8 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 8 OAC 252: (Fugitive Dust) [Applicable] No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. Under normal operating conditions, this facility will not cause a problem in this area, therefore it is not necessary to require specific precautions to be taken. OAC 252: (Sulfur Compounds) [Applicable] Part 5 limits sulfur dioxide emissions from new equipment (constructed after July 1, 1972). For gaseous fuels the limit is 0.2 lb/million BTU heat input. This is equivalent to approximately 0.2 weight percent sulfur in the fuel gas which is equivalent to 2,000 ppm sulfur. AP-42, Table (7/98), lists the total SO 2 emissions for natural gas to be 0.6 lb/mmft 3 or about lb/mmbtu which is in compliance with Subchapter 31. The permit will require the use of commercial natural gas for all fuel-burning equipment to ensure compliance with Subchapter 31. OAC 252: (Volatile Organic Compounds) [Applicable] Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with an organic vapor recovery system. All storage tanks that store a VOC with a vapor pressure greater than 1.5 psia are less than 400 gallons. Part 5 limits the VOC content of coatings used in coating lines or operations. The VOC content of the coatings is limited to the following: Coating VOC Limit (lb/gallon) Alkyd Primer 4.8 Vinyls 6.0 NC Laquers 6.4 Acrylics 6.0 Epoxies 4.8 Maintenance Finishes 4.8 Custom Product Finishes 6.5 The facility uses primarily water-based coatings. All coatings have VOC contents less than 4.8 lb/gallon, which complies with the lowest VOC limitation above taking into account all coating formulations. Part 5 requires all emissions of VOC from the cleanup of any article, machine, or equipment used in applying coatings to be included when determining compliance with the above stated solvent limitations and emission limits. All solvent usage not incorporated into the coatings as they are applied has been averaged over coating usage and all coatings still comply with the VOC limitations. Part 7 requires fuel-burning and refuse-burning equipment to be operated and maintained so as to minimize VOC emissions. Temperature and available air must be sufficient to provide essentially complete combustion.

9 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 9 OAC 252: (Toxic Air Contaminants (TAC)) [Applicable] This subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in areas of concern (AOC). Any work practice, material substitution, or control equipment required by the Department prior to June 11, 2004, to control a TAC, shall be retained, unless a modification is approved by the Director. Since no AOC has been designated there are no specific requirements for this facility at this time. OAC 252: (Testing, Monitoring, and Recordkeeping) [Applicable] This subchapter provides general requirements for testing, monitoring and recordkeeping and applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To determine compliance with emissions limitations or standards, the Air Quality Director may require the owner or operator of any source in the state of Oklahoma to install, maintain and operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All required testing must be conducted by methods approved by the Air Quality Director and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests. Emissions and other data required to demonstrate compliance with any federal or state emission limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any required testing or monitoring not conducted in accordance with the provisions of this subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. The following Oklahoma Air Pollution Control Rules are not applicable to this facility: OAC 252: Alternative Emissions Reduction not requested OAC 252: Mobile Sources not in source category OAC 252: Incinerators not type of emission unit OAC 252: Cotton Gins not type of emission unit OAC 252: Grain Elevators not in source category OAC 252: Nitrogen Oxides not in source category OAC Carbon Monoxide not type of emission unit OAC 252: Nonattainment Areas not in area category OAC 252: Municipal Solid Waste Landfills not in source category SECTION VII. FEDERAL REGULATIONS PSD, 40 CFR Part 52 [Not Applicable] Total emissions are less than the major source threshold of 250 TPY of any single regulated pollutant and the facility is not one of the 26 specific industries with a threshold of 100 TPY.

10 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 10 NSPS, 40 CFR Part 60 [Not Applicable] Subpart K, Ka, Kb, VOL Storage Vessels. All tanks at the facility are not subject because they are below the de minimis size (19,813 gallons). Subpart EE, Surface Coating of Metal Furniture. This facility does not paint furniture. Subpart MM, Automobiles and Light-Duty Trucks Surface Coating. No automobiles or light-duty trucks are coated at this facility. Subpart TT, Metal Coil Surface Coating. No metal coils are coated at this facility. Subpart QQ, Graphic Arts: Rotogravure Printing. This facility does not use rotogravure printing. Subpart RR, Pressure Sensitive Tape and Label Surface Coating. No pressure sensitive tape or labels are coated at this facility. Subpart SS, Surface Coating of Large Appliances. No large appliances are coated at this facility. Subpart WW, Beverage Can Surface Coating. No beverage cans are coated at this facility. Subpart FFF, Flexible Vinyl and Urethane Coating and Printing. This facility does not coat or print on flexible vinyl or urethane. Subpart IIII, Stationary Compression Ignition (CI) Internal Combustion Engines (ICE). This subpart affects CI ICE manufactured after There is a diesel engine on-site but it was manufactured prior to NESHAP, 40 CFR Part 61 [Not Applicable] There are no emissions of any of the regulated pollutants: arsenic, asbestos, beryllium, benzene, coke oven emissions, mercury, radionuclides or vinyl chloride. NESHAP, 40 CFR Part 63 [Subparts JJJJ and ZZZZ are Applicable] Subpart JJJJ, Paper and Other Web Coating. This subpart applies to paper and other web coating operations located at a major source of HAP. This facility has web coating operations and the facility is a major source of HAP. Therefore, this facility is subject to the requirements of this subpart. Existing affected sources must limit organic HAP emissions to the atmosphere to no more than one of the following: 5% of the total organic HAP applied, 4% of the total mass of the coatings applied, or organic HAP do not exceed 20% of the mass of solids applied. This facility is an existing source and compliance with the standard was required on December 4, Since this facility does not use a control device to comply with these emission limits, this facility has two options to show compliance with these standards: the as purchased or the as applied compliant coating materials compliance options. Compliance with the as purchased compliant coating option must be demonstrated monthly and the coatings must contain no more than 4% by mass organic HAP or the organic HAP cannot exceed 20% of the mass of solids. Compliance with the as applied option must also be demonstrated monthly but can be based on each coating or on an average of all coatings used during the month. Compliance with the HAP limitations can also be shown using the VOC content of the materials. The permit will require compliance with all applicable requirements. Subpart EEEE, Organic Liquids Distribution (Non-Gasoline). This subpart establishes emission limitations, operating limits, and work practice standards for organic hazardous air pollutants (HAP) emitted from organic liquids distribution (OLD) (non-gasoline) operations at major sources of HAP emissions. The affected source is the collection of activities and equipment used

11 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 11 to distribute organic liquids into, out of, or within a facility that is a major source of HAP. The affected source is composed of: (1) All storage tanks (This only affects storage tanks with a capacity of 5,000 gallons or more.) storing organic liquids (organic liquids are liquids or liquid mixtures that contain 5 percent by weight or greater of an organic HAP listed in Table 1 of this subpart). (2) All transfer racks at which organic liquids are loaded into or unloaded out of transport vehicles and/or containers (This only affects existing transfer racks with throughputs greater than 800,000 gallons.); (3) All equipment leak components in organic liquid service that are associated with affected storage tanks or transfer racks, pipelines between two affected storage tanks or two affected transfer racks. (4) All transport vehicles while they are loading or unloading organic liquids at transfer racks subject to this subpart. (5) All containers while they are loading or unloading organic liquids at transfer racks subject to this subpart. This facility does not have any storage vessels greater than or equal to 5,000 gallons that store liquids that contain greater than 5% of a listed HAP. The facility also does not have any of the other listed affected equipment. Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart affects any existing, new, or reconstructed stationary RICE located at a major or area source of HAP emissions. Owners and operators of the following new or reconstructed RICE must meet the requirements of Subpart ZZZZ by complying with either 40 CFR Part 60 Subpart IIII (for CI engines) or 40 CFR Part 60 Subpart JJJJ (for SI engines): 1) Stationary RICE located at an area source; 2) The following Stationary RICE located at a major source of HAP emissions: i) 2SLB and 4SRB stationary RICE with a site rating of 500 brake HP; ii) 4SLB stationary RICE with a site rating of < 250 brake HP; iii) Stationary RICE with a site rating of 500 brake HP which combust landfill or digester gas equivalent to 10% or more of the gross heat input on an annual basis; iv) Emergency or limited use stationary RICE with a site rating of 500 brake HP; and v) CI stationary RICE with a site rating of 500 brake HP. No further requirements apply for engines subject to NSPS under this part. Engines < 500-hp at major sources are considered existing if they commenced construction or reconstruction after June 12, This facility is a major source of HAP and the following existing engines are subject to this subpart. Existing CI RICE 85-hp Emergency Fire Pump Facilities with existing stationary CI RICE located at a major source of HAP emissions must comply with the applicable emission limitations and operating limitations no later than May 3, Existing emergency stationary CI RICE at major sources must comply with the following management practices:

12 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 12 Change oil and filter every 500 hours of operation or annually, whichever comes first; Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first; Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary; and Minimize the engine's time spent at idle and minimize the engine's startup time at startup to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the non-startup emission limitations apply. Sources have the option to utilize an oil analysis program as described in (i) in order to extend the specified oil change requirement. Additionally, there are limitations on the hours that an emergency engine may operate. Total operating hours are limited to 100 hours/year for maintenance and readiness checks unless Federal, State, or local standards require maintenance and testing beyond 100 hours per year. The 100 hours/year includes up to 50 hours of nonemergency operations. The 50 hours cannot include peak shaving or other income generating power production. The 50 hours includes up to 15 hours of power generation as part of a demand response program in the event of a potential electrical blackout situation. All applicable requirements have been incorporated into the permit. Subpart DDDDD, Industrial, Commercial and Institutional Boilers and Process Heaters. This subpart establishes emission limitations and work practice standards for industrial, commercial, and institutional boilers and process heaters located at major sources of HAP. Boiler means an enclosed device using controlled flame combustion and having the primary purpose of recovering thermal energy in the form of steam or hot water. Process heater means an enclosed device using controlled flame, and the unit's primary purpose is to transfer heat indirectly to a process material (liquid, gas, or solid) or to a heat transfer material (e.g., glycol or a mixture of glycol and water) for use in a process unit, instead of generating steam. Process heaters are devices in which the combustion gases do not come into direct contact with process materials. Process heaters do not include units used for comfort heat or space heat, food preparation for on-site consumption, or autoclaves. Per (d) hot water heaters are not subject to this subpart. Hot water heater means a closed vessel with a capacity of no more than 120 gallons in which water is heated and withdrawn for use external to the vessel. Hot water boilers with a heat input capacity of less than 1.6 MMBTUH are included in this definition. Jindal Films has stated that they do not have any process heaters or boilers other than hot water heaters and are not subject to this subpart. The facility does have dryers which do not meet the definition of boiler or process heaters. Subpart CCCCCC, Gasoline Dispensing Facilities. This subpart establishes emission limitations and management practices for HAP emitted from the loading of gasoline storage tanks at gasoline dispensing facilities (GDF) located at an area source. This facility is a major source and is not subject to this subpart.

13 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 13 CAM, 40 CFR Part 64 [Not Applicable] Compliance Assurance Monitoring (CAM), as published in the Federal Register on October 22, 1997, applies to any pollutant specific emission unit at a major source, that is required to obtain a Title V permit, if it meets all of the following criteria: It is subject to an emission limit or standard for an applicable regulated air pollutant It uses a control device to achieve compliance with the applicable emission limit or standard It has potential emissions, prior to the control device, of the applicable regulated air pollutant to be classified as a major source. This facility does not use a control device to meet the HAP and VOC emission limits and is not subject to this regulation for these pollutants. Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable] This facility does not store any regulated substance above the applicable threshold limits. More information on this federal program is available at the web site: Stratospheric Ozone Protection, 40 CFR Part 82 [Subparts A and F are Applicable] These standards require phase out of Class I & II substances, reductions of emissions of Class I & II substances to the lowest achievable level in all use sectors, and banning use of nonessential products containing ozone-depleting substances (Subparts A & C); control servicing of motor vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations which meet phase out requirements and which maximize the substitution of safe alternatives to Class I and Class II substances (Subpart D); require warning labels on products made with or containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons (Subpart H). Subpart A identifies ozone-depleting substances and divides them into two classes. Class I controlled substances are divided into seven groups; the chemicals typically used by the manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform (Class I, Group V). A complete phase-out of production of Class I substances is required by January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs. Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances, scheduled in phases starting by 2002, is required by January 1, Subpart F requires that any persons servicing, maintaining, or repairing appliances except for motor vehicle air conditioners; persons disposing of appliances, including motor vehicle air conditioners; refrigerant reclaimers, appliance owners, and manufacturers of appliances and recycling and recovery equipment comply with the standards for recycling and emissions reduction.

14 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 14 The standard conditions of the permit address the requirements specified at for persons opening appliances for maintenance, service, repair, or disposal; for equipment used during the maintenance, service, repair, or disposal of appliances; for certification by an approved technician certification program of persons performing maintenance, service, repair, or disposal of appliances; for recordkeeping; for leak repair requirements; and for refrigerant purchase records for appliances normally containing 50 or more pounds of refrigerant. SECTION VIII. COMPLIANCE Inspection An operating inspection was conducted on October 19, Diane Kaczmarcik of Air Quality who was accompanied by Mr. Homer Dingman, SSHE Manager, for ExxonMobil Chemical Company, conducted the inspection. No compliance issues were noted during the inspection. Tier Classification This application has been determined to be Tier II based on the request for a significant modification of a Part 70 operating permit. Information on all permit actions is available for review by the public on the Air Quality section of DEQ web page at: The permittee has submitted an affidavit that they are not seeking a permit for land use or for any operation upon land owned by others without their knowledge. The affidavit certifies that the applicant owns the land. Public Review The applicant will publish the Notice of Filing a Tier II Application, in The Shawnee News- Star a daily newspaper in Pottawatomie County. The notice will state that the application is available for review at the Shawnee Public Library located at 101 North Philadelphia Street in Shawnee or at the AQD main office. The applicant will publish the Notice of Draft Permit in a newspaper of general circulation in Pottawatomie County. The notice will state that the draft permit is available for public review at the Shawnee Public Library located at 101 North Philadelphia Street in Shawnee or at the AQD main office. The draft permit will also be made available for public review on the Air Quality section of the DEQ web page at State Review This facility is not located within 50 miles of the border of Oklahoma and any other state. EPA Review This permit has been approved for concurrent public and EPA review. The draft/proposed permit will be forwarded to EPA for a 45-day review period. If no comments are received from the public, the draft/proposed permit will be deemed the proposed permit.

15 PERMIT MEMORANDUM NO TVR2 (M-3) DRAFT/PROPOSED Page 15 Fees Paid The fee for a significant modification of a Part 70 operating permit ($6,000) was submitted. SECTION IX. SUMMARY The facility is operating as described in the permit application. Ambient air quality standards are not threatened at this site. There are no active Air Quality compliance or enforcement issues concerning this facility. Issuance of the amended operating permit is recommended, contingent on public and EPA review.

16 PERMIT TO OPERATE AIR POLLUTION CONTROL FACILITY SPECIFIC CONDITIONS DRAFT/PROPOSED Jindal Films Americas, L.L.C. Permit No TVR2 (M-3) Films Shawnee L.L.C. Facility ID 1008 The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on May 28, 2006, June 13, 2006, February 4, 2008, May 27, 2011, and all supplemental information. The Evaluation Memorandum dated January 27, 2015, explains the derivation of applicable permit requirements and estimates of emissions; however, it does not contain operating limitations or permit requirements. Continuing operation under this permit constitutes acceptance of, and consent to, the conditions contained herein: 1. Emission Unit Groups and limitations for each: [OAC 252: (a)(1)] Emissions: VOC emissions are based on material usage and compliance with the VOC annual emission limitation shall be based on material usage. SO 2 emissions are considered insignificant. a. Emissions shall not exceed the following limits based on a twelve-month rolling total. Pollutant TPY 1 NO X CO VOC PM O Ammonia TPY limits are based on twelve-month rolling totals. b. Each month the permittee shall calculate emissions from the facility and the total emissions from the facility emitted over the previous twelve months. (1) For the combustion of natural gas, all emissions shall be calculated using the most recent version of AP-42. (2) All emissions from coatings shall be based on the total amount of VOC and HAP in the coating and the amount of the coating used unless specified otherwise. (3) Emissions of ozone shall be calculated using stack test data. c. VOC emissions from Line 112 shall not exceed 100 TPY based on a 12-month rolling total. d. Each month the permittee shall calculate emissions from the facility and the total emissions from the facility emitted over the previous twelve months. (1) The material usage for Line 112 shall be recorded monthly. (2) All emissions from coatings shall be based on the total amount of VOC and HAP in the coating and the amount of the coating used unless specified otherwise.

17 SPECIFIC CONDITIONS NO TVR2 (M-3) DRAFT/PROPOSED Page 2 2. The owner/operator shall comply with all applicable requirements of the NESHAP: Paper and Other Web Coating, Subpart JJJJ, for each affected facility (web coating line) located at the facility including but not limited to: [40 CFR to ] Emission Standards and Compliance Dates a. The owner/operator shall comply with the requirements for existing sources on and after the compliance date specified in [ (a)] (1) The owner/operator shall comply with the provisions of 40 CFR Part 63, Subpart JJJJ by December 5, [ (a)] b. The owner/operator shall limit organic HAP emissions to the level specified in (b)(2) or (3). [ (b)] (1) The owner/operator shall limit organic HAP emissions to no more than 4 percent of the mass of coating materials applied for each month; or [ (b)(2)] (2) The owner/operator shall limit organic HAP emissions to no more than 20 percent of the mass of coating solids applied for each month. [ (b)(3)] c. The owner/operator shall demonstrate compliance with 40 CFR Part 63, Subpart JJJJ by the procedures in [ (c)] General Requirements for Compliance with the Emission Standards and For Monitoring and Performance Tests d. The owner/operator shall comply with the provisions of 40 CFR Part 63, Subpart A as specified in Table 2 of 40 CFR Part 63, Subpart JJJJ. [ (a)] e. The owner/operator shall determine the organic HAP or volatile matter and coating solids content of coating materials according to procedures in (c) and (d). If applicable, determine the mass of volatile matter retained in the coated web or otherwise not emitted to the atmosphere according to (g). [ (a)(1)] (1) Organic HAP content. If you determine compliance with the emission standards in by means other than determining the overall organic HAP control efficiency of a control device, you must determine the organic HAP mass fraction of each coating material as-purchased by following one of the procedures in (c)(1) through (3), and determine the organic HAP mass fraction of each coating material as-applied by following the procedures in (c)(4). [ (c)] (2) Volatile organic and coating solids content. If you determine compliance with the emission standards in by means other than determining the overall organic HAP control efficiency of a control device and you choose to use the volatile organic content as a surrogate for the organic HAP content of coatings, you must determine the as-purchased volatile organic content and coating solids content of each coating material applied by following the procedures in (d)(1) or (2), and the as-applied volatile organic content and coating solids content of each coating material by following the procedures in (d)(3). [ (d)]

18 SPECIFIC CONDITIONS NO TVR2 (M-3) DRAFT/PROPOSED Page 3 Requirements for Showing Compliance f. As-purchased compliant coating materials. If you comply by using coating materials that individually meet the emission standards in (b)(2) or (3), you must demonstrate that each coating material applied during the month at an existing affected source contains no more than 0.04 mass fraction organic HAP or 0.2 kg organic HAP per kg coating solids on an as-purchased basis as determined in accordance with (c). [ (b)(1)] (1) You are in compliance with emission standards in (b)(2) and (3) if each coating material applied at an existing affected source is applied aspurchased and contains no more than 0.04 kg organic HAP per kg coating material or 0.2 kg organic HAP per kg coating solids [ (b)(2)] g. As-applied compliant coating materials. If the owner/operator complies by using coating materials that meet the emission standards in (b)(2) or (3) as applied, the owner/operator shall demonstrate compliance by following one of the procedures in (c)(1) through (4). Compliance shall be determined in accordance with (c)(5). [ (c)] (1) Each coating material as-applied meets the mass fraction of coating material standard ( (b)(2)). You must demonstrate that each coating material applied at an existing affected source during the month contains no more than 0.04 kg organic HAP per kg coating material applied as determined in accordance with (c)(1)(i) and (ii). You must calculate the as-applied organic HAP content of as-purchased coating materials which are reduced, thinned, or diluted prior to application. [ (c)(1)] i) Determine the organic HAP content or volatile organic content of each coating material applied on an as-purchased basis in accordance with ii) (c). [ (c)(1)(i)] Calculate the as-applied organic HAP content of each coating material using Equation 1a of or calculate the as-applied volatile organic content of each coating material using Equation 1b of [ (c)(1)(ii)] (2) Each coating material as-applied meets the mass fraction of coating solids standard ( (b)(3)). You must demonstrate that each coating material applied at an existing affected source contains no more than 0.20 kg of organic HAP per kg of coating solids applied. You must demonstrate compliance in accordance with (c)(2)(i) and (ii). [ (c)(2)] i) Determine the as-applied coating solids content of each coating material following the procedure in (d). You must calculate the asapplied coating solids content of coating materials which are reduced, thinned, or diluted prior to application, using Equation 2 of [ (c)(2)(i)] ii) Calculate the as-applied organic HAP to coating solids ratio using Equation 3 of [ (c)(2)(ii)]

19 SPECIFIC CONDITIONS NO TVR2 (M-3) DRAFT/PROPOSED Page 4 (3) Monthly average organic HAP content of all coating materials as-applied is less than the mass percent limit ( (b)(2)). Demonstrate that the monthly average as-applied organic HAP content of all coating materials applied at an existing affected source is less than 0.04 kg organic HAP per kg of coating material applied as determined by Equation 4 of [ (c)(3)] (4) Monthly average organic HAP content of all coating materials as-applied is less than the mass fraction of coating solids limit ( (b)(3)). Demonstrate that the monthly average as-applied organic HAP content on the basis of coating solids applied of all coating materials applied at an existing affected source is less than 0.20 kg organic HAP per kg coating solids applied as determined by Equation 5 of [ (c)(4)] (5) The affected source is in compliance with emission standards in (b)(2) or (3) if: [ (c)(5)] i) The organic HAP content of each coating material as-applied at an existing affected source is no more than 0.04 kg organic HAP per kg coating material or 0.2 kg organic HAP per kg coating solids; or [ (c)(5)(i)] ii) The monthly average organic HAP content of all as-applied coating materials at an existing affected source are no more than 0.04 kg organic HAP per kg coating material or 0.2 kg organic HAP per kg coating solids. [ (c)(5)(ii)] h. Monthly allowable organic HAP applied. Demonstrate that the total monthly organic HAP applied as determined by Equation 6 of this section is less than the calculated equivalent allowable organic HAP as determined by Equation 13a or b in (l). [ (d)] Notifications, Reports, and Records i. Each owner or operator of an affected source subject to 40 CFR Part 63, Subpart JJJJ must submit the reports specified in (b), (c), and (e) to the Administrator. [ (a)] (1) You must submit a semiannual compliance report according to (c)(1) and (2). [ (c)] i) Compliance report dates. For each affected source that is subject to permitting regulations pursuant to 40 CFR part 70 or 40 CFR part 71, and the permitting authority has established dates for submitting semiannual reports pursuant to 70.6(a)(3)(iii)(A) or 71.6(a)(3)(iii)(A), you may submit the first and subsequent compliance reports according to the dates the permitting authority has established instead of according to the dates in (c)(1)(i) through (iv). [ (c)(1)(v)] ii) The compliance report must contain the information in (c)(2)(i) through (v). [ (c)(2)] (2) You must submit a Notification of Compliance Status as specified in 63.9(h). [ (e)]