
Permit Number:  98-A-378-S9

Plant Number:  52-01-003

Company:  IAC Iowa City LLC

Contact Person:
Responsible Party:
Trisha Semelroth
Brian Pedrick
Human Resources Manager
Plant Manager


319-688-6323

tsemelroth@iacgroup.com



2500 Highway 6 East
2500 Highway 6 East
Iowa City, IA 52240
Iowa City, IA 52240


                              Permitted Equipment

Emission Point ID:  S099

Emission Unit(s) and Control Equipment:

                                     EU ID
                                  Description
                            Maximum Rated Capacity
                     Control Equipment Description and ID
                                     PB20
                          Adhesive Application Booth
                          4 guns at 11.5 oz/min each
                          Dry Filters (CE FILTER-44)

Equipment Location:  2500 Highway 6 East
                        Iowa City, IA 52240


Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, and federal law.

                                Project Number
                              Project Description
                                 Stack Testing
                                 Issuance Date
                                    18-142
            Update VOC and HAP Limits, Update NESHAP Applicability
                                      No
                                  06/05/2018

                                                                               
                                                                               
                                     Under the Direction of the Director of the
                                                Department of Natural Resources

                                       
                               PERMIT CONDITIONS


1.  Emission Limits

The owner or operator is required to report all emissions as required by law, regardless of whether a specific emission limit has been established in this permit.  The following emission limits shall not be exceeded:

                                   Pollutant
                                 lb/hr[(1][)]
                                tons/yr[(2][)]
                                 Other Limits
                                Reference/Basis
Particulate Matter (PM)  -  State
                                      NA
                                      NA
                               0.1 gr/dscf[(1)]
                            567 IAC 23.3(2)"a"
PM10
                                  0.86[(3][)]
                                      NA
                                      NA
                                     NAAQS
Opacity
                                      NA
                                      NA
                              40%[(4][)] [(5][)]
                            567 IAC 23.3(2)"d"
Volatile Organic Compounds (VOC)
                                      NA
                                   95.0[(6)]
                                      NA
                       Title V & PSD Synthetic Minor
(Single HAP) 
                                      NA
                                   9.0[(7)]
                                      NA
                              HAP Synthetic Minor
(Total HAP)
                                      NA
                                  24.0[(8][)]
                                      NA
                              HAP Synthetic Minor

 The emission limit is expressed as the average of three (3) runs.
 The emission limit is based on a twelve (12) month rolling total.
 Previous PSD Synthetic minor limit of 0.86 pounds per hour and 3.75 tons per year of PM10.  This limit was removed when the plant became a minor source for PSD.
 The emission limit is based on a six (6) minute average.
 An exceedance of the indicator opacity of 10% will require the owner or operator to promptly investigate the emission unit and make corrections to operations or equipment associated with the exceedance.  If exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., stack testing).
 Facility-wide emission limit of 95.0 tons VOC per rolling 12-month period. This limit was established in Project 18-142 to restrict potential emissions of the facility below "major source" threshold for the purposes of Title V and Prevention of Significant Deterioration (PSD).  The limit is for all non-combustion VOC emissions at the facility.
 Facility-wide emission limits of 9.0 tons of any single HAP per rolling 12-month period. This limit was established in Project 18-142 to restrict potential emissions of the facility below "major source" threshold for the purposes of NESHAP applicability as defined in 40 CFR § 63.2.
 Facility-wide emission limits of 24.0 tons of total HAP per rolling 12-month period. This limit was established in Project 18-142 to restrict potential emissions of the facility below "major source" threshold for the purposes of NESHAP applicability as defined in 40 CFR § 63.2.



2.  Compliance Demonstration(s)
                                       
                        Compliance Demonstration Table

                                   Pollutant
                            Compliance Methodology
                                   Frequency
                                 Test Run Time
                                  Test Method
PM  -  State 
                                     None
                                      NA
                                    1 hour
40 CFR 60, Appendix A, Method 5 
40 CFR 51 Appendix M Method 202
PM10
                                     None
                                      NA
                                    1 hour
40 CFR 51, Appendix M, 201A with 202
Opacity
                                     None
                                      NA
                                    1 hour
40 CFR 60, Appendix A, Method 9
VOC
                                Record Keeping
                              Daily/Monthly[(1)]
                                    1 hour
40 CFR 63, Appendix A, Method 320 or
40 CFR 60, Appendix A, Method 18
HAP
                                Record Keeping
                              Daily/Monthly[(1)]
                                    1 hour
40 CFR 63, Appendix A, Method 320 or
40 CFR 60, Appendix A, Method 18

 See Condition 5 of this permit for specific requirements and frequency of VOC and HAP recordkeeping for the VOC and HAP emission limit caps in Condition 1.


2.  Compliance Demonstration(s) (Continued)

If an initial stack test is specified in the "Compliance Demonstration Table," the owner or the owner's authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 within the applicable time period specified below:

 Within sixty (60) days after achieving the maximum production rate and no later than one hundred eighty (180) days after the initial startup date of the proposed equipment for the addition of new equipment or the physical modification of existing equipment or control equipment.
 Within ninety (90) days of the issuance of this permit if there is no physical modification to any emission units or control equipment.

If any additional stack testing beyond an initial test (i.e. quarterly, semi-annual, annual, etc.) is required in "Compliance Demonstration Table," the owner or the owner's authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 as specified in the "Compliance Demonstration Table."  See Conditions 12.A.(4) and 12.B.(5) for notification and reporting requirements.

If stack testing is required, the owner or the owner's authorized agent shall use the test method and run time listed in the "Compliance Demonstration Table" unless another testing methodology is approved by the Department prior to testing. 

Each emissions compliance test must be approved by the Department.  Unless otherwise specified by the Department, each test shall consist of three (3) separate runs.  The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by the Department.  

Per 567 IAC 25.1(7)"a", at the Department's request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration.  A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration.  Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any.  It shall be the responsibility of the owner to coordinate and schedule the pretest meeting.  A representative of the Department shall be allowed to witness the test(s).  The Department shall reserve the right to impose additional, different, or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports.  The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.


3.  Emission Point Characteristics

This emission point shall conform to the specifications listed below:

                                   Parameter
                                     Value
Stack Height (feet from the ground)
44 feet
Discharge Style
Vertical Unobstructed
Stack Outlet Dimensions (inches)
25 inches
Exhaust Temperature ([o]F)
70
Exhaust Flowrate (scfm)
10,000 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted emission point.  The Department recognizes that the temperature and flow rate may vary with changes in the process and ambient conditions.  If it is determined that any of the emission point characteristics above are different than the values stated, the owner or operator shall submit a request either by electronic mail or written correspondence to the Department within thirty (30) days of the discovery to determine if a permit amendment is required, or submit a permit application requesting to amend the permit.


4.  Federal Standards

 New Source Performance Standards (NSPS):

This emission unit is not subject to any NSPS subparts at this time as there are no applicable subparts for its source category.

      NOTE:  The absence of the inclusion of any NSPS requirements as part of this permit does not relieve the owner or operator from any obligation to comply with all applicable NSPS conditions.

 National Emission Standards for Hazardous Air Pollutants (NESHAP):
      This facility is of the source category for Subpart PPPP  -  Surface Coating of Plastic Parts and Products (40 CFR §63.4480- 40 CFR §63.4581) of the National Emission Standards for Hazardous Air Pollutants (NESHAP).  However, this emission unit is not subject because the facility is an area source of HAP at this time and Subpart PPPP is only applicable to major sources of HAP.

This facility is of the source category for Subpart HHHHHH (National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources; 40 CFR §63.11169  -  §63.11180). However, this facility does not perform any paint stripping using methylene chloride or perform any spray application of coatings that contain target HAP, as defined in §63.11180 (coating containing compounds of chromium (Cr), lead (Pb), manganese (Mn), Nickel (Ni) or cadmium (Cd)), and therefore, per 40 CFR §63.11170, is not subject to the Subpart. 

      NOTE:  Failure to include any NESHAP requirements as a part of this permit does not relieve the owner or operator from the obligation to comply with all applicable NESHAP conditions.
      
      

5.  Operating Requirements with Associated Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department.  Records shall be legible and maintained in an orderly manner.  The operating requirements and associated recordkeeping for this permit shall be:


       A maximum of one spray gun shall be operated in the adhesive application booth at any time.

       For the purpose of calculating emissions, the permittee shall assume 100% of the VOC and HAP in all materials used in non-combustion sources at this facility is emitted.

       The permittee shall maintain the following daily records:
          The identification, the VOC content, the HAP content, and the amount (gallons) of each VOC-containing material and/or HAP-containing material used in the non-combustion sources at this facility. For the purpose of calculating emissions, all VOC and HAP-containing materials may be considered emitted on the day they are delivered to the plant or the production line.  
         
       The permittee shall maintain the following monthly records:
          The identification, the VOC content, the HAP content, and the amount (gallons) of each VOC-containing material and/or HAP-containing material used in the non-combustion sources at this facility.
          The monthly VOC emission rate (tons) from the non-combustion sources at this facility.
          The rolling, 12-month total of the VOC emission rate from the non-combustion sources at this facility.
          The monthly emission rate (tons) of each individual HAP from the non-combustion sources at this facility.
          The rolling, 12-month total of each individual HAP emitted from non-combustion sources at this facility.
          The monthly emission rate (tons) of total HAPs from the non-combustion sources at this facility.
          The rolling, 12-month total of total HAPs emitted from the non-combustion sources at this facility.
         

5.  Operating Requirements with Associated Monitoring and Recordkeeping (continued)

       If the rolling, 12-month total of the VOC emissions from all non-combustion sources at this facility exceeds 75.0 tons per 12-month rolling period, the permittee shall maintain the following daily records:
          The total emissions of  VOC (tons) from all non-combustion sources at this facility; and
          The rolling 365-day total amount of VOC emissions from all non-combustion sources at this facility.
     
      Daily recordkeeping/calculations for VOC emissions shall continue until the rolling 12-month total amount of VOC emissions drops below 75.0 tons on the last day of a month. Monthly calculation of VOC emissions will then begin in the following month.
      
       If the rolling, 12-month total of any individual HAP emitted from the non-combustion sources at this facility exceeds 6.5 tons per 12-month rolling period, the permittee shall maintain the following daily records:
          The total emissions of individual HAPs (tons) from the non-combustion sources at this facility; and
          The rolling 365-day total amount of individual HAP emissions from the non-combustion sources at this facility.
      
      Daily recordkeeping/calculations for individual HAP emissions shall continue until the rolling 12-month total amount of individual HAP emissions drops below 6.5 tons on the last day of a month. Monthly calculation of individual HAP emissions will then begin in the following month.
       If the rolling, 12-month total of cumulative HAP emitted from the non-combustion sources at this facility exceeds 18.0 tons per 12-month rolling period, the permittee shall maintain the following daily records:
          The total emissions of cumulative HAPs (tons) from the non-combustion sources at this facility; and
          The rolling 365-day total amount of cumulative HAP emissions from the non-combustion sources at this facility.
         
      Daily recordkeeping/calculations for cumulative HAP emissions shall continue until the rolling 12-month total amount of cumulative HAP emissions drops below 18.0 tons on the last day of a month. Monthly calculation of cumulative HAP emissions will then begin in the following month.   

       The permittee may take credit for any waste VOC shipped off-site. The permittee shall record the amount of the waste shipped off-site each day, and analyze the VOC content of the waste once every calendar quarter.  The sample analyzed shall be taken as a representative sample (as defined in 40 CFR §260.10) of the waste sent off-site for that quarter and shall be used as representative until the subsequent quarter's analysis is received.  The credit (calculated from the most current analysis and the amount shipped off-site) may be subtracted from the VOC rolling totals as of the date the waste is shipped off-site.

       The owner or operator shall maintain the Dry Filters according to the manufacturer's specifications and maintenance schedule.
          The owner or operator shall maintain a copy of the manufacture's specifications and instructions.
          The owner or operator shall maintain a log of all maintenance and inspection activities performed on the Dry Filters. This log shall include, but is not necessarily limited to:
             The date and time any inspection and/or maintenance was performed on the Dry Filters;
             Any issues identified during the inspection and the date each issue was resolved;
             Any issues addressed during the maintenance activities and the date each issue was resolved; and 
             Identification of the staff member performing the maintenance or inspection. 



6.  Continuous Emission Monitoring Systems (CEMS)

Continuous emission monitoring is not required by this permit at this time.



7.  Department Review

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3.  The proposed equipment has been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20  -  35; and 40 Code of Federal Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.  This permit is issued based on information submitted by the applicant.  Any misinformation, false statements or misrepresentations by the applicant or by the applicant's representative(s) shall cause this permit to be void.  

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the potential of that equipment for reducing air contaminant emissions.  The Department assumes no liability, directly or indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, installation, maintenance or operation of the proposed equipment.


8.  Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as described in this permit and in the application for this permit.  The permit holder, owner, and operator of the facility shall assure that the installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capacity, etc.).  No person shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the provisions of this permit and all other applicable requirements  and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created.


9.  Transferability

Unless the equipment is portable, this permit is not transferable from one location to another or from one piece of equipment to another.  See Condition 12.A.(2) for notification requirements for relocating portable equipment (567 IAC 22.3(3)"f").  


10.  Construction

 General Requirements:
      It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as submitted.  
      
      In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment.  If a proposed project is not timely completed, the owner or operator shall seek a permit amendment in order to revert back to the most recent previous version of the permit.  The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable.
      
      This permit or amendment shall become void if any one of the following conditions occurs:
 The construction or implementation of the proposed project, as it affects the emission point permitted herein, is not initiated within eighteen (18) months after the permit issuance date; or
 The construction or implementation of the proposed project, as it affects the emission point permitted herein, is not completed within thirty-six (36) months after the permit issuance date; or
 The construction or implementation of the proposed project, as it affects the emission point permitted herein, is not completed within a time period specified elsewhere in this permit.

 Changes to Plans and Specifications:
The owner or operator shall amend this permit or amendment prior to startup of the equipment if:
 Any changes are made to the final plans and specifications submitted for the proposed project; or
 This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted equipment and control equipment and the specified operation thereof.

10.  Construction (continued)

 Amended Permits:
The owner or operator may continue to act under the provisions of the previous permit for the affected emission unit(s) and emission point, together with any previous amendment to the permit, until one of the following conditions occurs:
          The proposed project authorized by this amendment is completed as it affects the emission unit(s) and emission point permitted herein; or
          This current amendment becomes void.


11.  Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise.  Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period.  

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A.  If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified in 567 IAC 24.1.  

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident [See Permit Condition 12.B.(1)]. A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports within seven (7) days of the onset of the upset condition [See Permit Condition 12.B.(2)].


12.  Notification, Reporting, and Recordkeeping

 The owner or operator shall furnish the Department the following written notifications:
          Per 567 IAC 22.3(3)"b":
             The date construction, installation, or alteration is initiated postmarked within thirty (30) days following initiation of construction, installation, or alteration.
             The actual date of startup, postmarked within fifteen (15) days following the start of operation.
          Per 567 IAC 22.3(3)"f," when portable equipment for which a permit has been issued is to be transferred from one location to another, the Department shall be notified:
          At least fourteen (14) days before equipment relocation if the equipment will be located in a nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance area for the NAAQS.
          At least seven (7) days before equipment relocation.
          Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership within thirty (30) days of the occurrence.  The notification shall include the following information:
             The date of ownership change; the name, address, and telephone number of the responsible official, the contact person, and the owner of the equipment both before and after the ownership change; and the construction permit number(s) of the equipment changing ownership.
          Unless specified per a federal regulation, the owner or the owner's authorized agent shall notify the Department in writing not less than thirty (30) days before a required test or performance evaluation of a continuous emission monitor [567 IAC 25.1(7)].  The notification shall include:
             The time; the place; the name of the person who will conduct the tests; and other information as required by the Department.
         If the owner or operator does not provide timely notice to the Department, the Department shall not consider the test results or performance evaluation results to be a valid demonstration of compliance with the applicable rules or permit conditions.  Upon written request, the Department may allow a notification period of less than thirty (30) days.
      

12.  Notification, Reporting, and Recordkeeping (continued)

 The owner or operator shall furnish the Department with the following reports:
 Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported within eight (8) hours or at the start of the first working day following the onset of the incident.  The report may be made by electronic mail, in person or by telephone.
 Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2 shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days of the onset of the upset condition.
 Operation of this emission unit(s) or control equipment outside of those operating parameters specified in Permit Condition 5 in accordance to the schedule set forth in 567 IAC 24.1.
 Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days following the end of the calendar quarter, on forms provided by the Director.
 Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, whether successful or not, postmarked no later than six (6) weeks after the completion of the test period unless other regulations provide for other notification requirements.  In that case, the more stringent reporting requirement shall be met.

 All data, records, reports, documentation, construction plans, and calculations required under this permit shall be available at the plant during normal business hours for inspection and copying by federal, state, or local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

 Information regarding this permit should be sent to the attention of the following individuals based on the type of information being submitted:  change in ownership (Air Quality Bureau Records Center), permit correspondence (Construction Permit Supervisor), stack testing correspondence (Stack Test Coordinator), and reports and notifications (Compliance Unit Supervisor and DNR Field Office).  The addresses are:

Air Quality Bureau
Iowa Department of Natural Resources
502 E. 9th St.
Des Moines, IA  50319
Telephone:  (515) 725-8200
Fax:  (515) 725-9501
Field Office 6 
1023 West Madison 
Washington, IA 52353 
Telephone: (319) 653-2135 
Fax: (319) 653-2856 



13.  Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7.  Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7.  In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment.  The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable.



14.  Permit History

                                  Permit No.
                                  Project No.
                                  Description
                                     Date
                                 Stack Testing
                                   98-A-378
                                    98-209
                                Original Permit
                                  02/18/1998
                                      No
                                  98-A-378-S1
                                    98-377
                             Restrict Paint Usage
                                  08/20/1998
                                      Yes
                                  98-A-378-S2
                                    01-298
                              Change Paint Limits
                                  07/09/2001
                                      No
                                  98-A-378-S3
                                    01-578
                              Change Paint Limits
                                  10/12/2001
                                      No
                                  98-A-378-S4
                                    03-753
        Replacement of Painting Equipment with Electrostatic Equipment
                                  01/15/2004
                                      No
                                  98-A-378-S5
                                    04-584
                        Establish Plant-Wide VOC Limit
                                  12/29/2004
                                      No
                                  98-A-378-S6
                                    05-077
                       Change Recordkeeping Requirements
                                  03/17/2005
                                      No
                                  98-A-378-S7
                                    09-443
       Modify Emission Limits, Operating Limits, Add NESHAP requirements
                                  01/20/2010
                                      No
                                  98-A-378-S8
                                    12-415
                  Convert Booth to Adhesive Application Booth
                                  11/13/2012
                                      No
                                       
                                       
                                       
                                       
                                       


                                       
                                 END OF PERMIT
