Certified Mail Facility ID: 1677000105 Michelle Poole .
Certified Mail9/12/2011Facility ID: 1677000105Permit Number: P0106317County: SummitMichelle PooleBemis Company, Inc.1972 AKRON PENINSULA RD.Akron, OH 44313RE:DRAFT AIR POLLUTION TITLE V PERMITPermit Type: Significant Permit Modification, Off-Permit ChangeDear Permit Holder:A draft of the OAC Chapter 3745-77 Title V permit for the referenced facility has been issued. The purpose ofthis draft is to solicit public comments. A public notice will appear in the Ohio EPA Weekly Review and thelocal newspaper, Akron Beacon Journal. A copy of the public notice, the Statement of Basis, and the draftpermit are enclosed. This permit can be accessed electronically on the Division of Air Pollution Control (DAPC) Webpage, www.epa.ohio.gov/dapc by clicking the "Issued Air Pollution Control Permits" link. Comments will be accepted as amarked-up copy of the draft permit or in narrative format. Any comments must be sent to the following:Andrew HallPermit Review/Development SectionOhio EPA, DAPC50 West Town Street, Suite 700P.O. Box 1049Columbus, Ohio 43216-1049andAkron Regional Air Quality Management District146 South High Street, Room 904Akron, OH 44308Comments and/or a request for a public hearing will be accepted within 30 days of the date the notice is published in thenewspaper. You will be notified in writing if a public hearing is scheduled. A decision on processing the Title V permitwill be made after consideration of comments received and oral testimony if a public hearing is conducted.You will then be provided with a Preliminary Proposed Title V permit and another opportunity to commentpriorto the 45-day Proposed Title V permit submittal to U.S. EPA Region 5. The permit will be issued final afterU.S. EPA review is completed and no objections to the final issuance have been received. If you have anyquestions, please contact Akron Regional Air Quality Management District at (330)375-2480.Sincerely,Michael W. Ahern, ManagerPermit Issuance and Data Management Section, DAPCCc:U.S. EPA Region 5 - Via E-Mail NotificationARAQMD; Pennsylvania; West Virginia
Summit CountyPUBLIC NOTICEIssuance of Draft Air Pollution Title V PermitBemis Company, Inc.Issue Date:Permit Number:Permit Type:Permit Description:Facility ID:Facility Location:Facility Description:9/12/2011P0106317Significant Permit Modification, Off-Permit ChangeSignificant Title V Permit Modification to add the new flexographic printing press (K021)and the new plating making process (P010) and to update the terms and conditions tomake them consistent with the modified Permits to Install. This facility consists of sixflexographic printing lines (K003, K008, K010, K016, K020, and K021), a plate makingprocess (P010), and several insignificant emissions units.1677000105Bemis Company, Inc.1972 AKRON PENINSULA RD.,AKRON, OH 44313Plastics Packaging Film and Sheet (including Laminated) ManufacturingThe Director of the Ohio Environmental Protection Agency, 50 West Town Street, Columbus Ohio, has issueda draft action of an air pollution control Title V operating permit for the facility at the location identified above onthe date indicated. Comments concerning this draft action, or a request for a public meeting, must be sent inwriting no later than thirty (30) days from the date this notice is published. All comments, questions, requestsfor permit applications or other pertinent documentation, and correspondence concerning this action must bedirected to Laura Miracle at Akron Regional Air Quality Management District, 146 South High Street, Room904, Akron, OH 44308 or (330)375-2480. The permit, which includes a detailed description of the operations,and associated statement of basis for the permit requirements, can be downloaded from the Web page:www.epa.ohio.gov/dapc
Statement of BasisBemis Company, Inc.Permit Number: P0106317Facility ID: 1677000105Statement of Basis For Air Pollution Title V PermitFacility ID:Facility Name:1677000105Bemis Company, Inc.Facility Description:Paper coating & laminated, packaging.Facility Address:1972 AKRON PENINSULA RD., AKRON, OH 44313Permit #:P0106317, Significant Permit ModificationThis facility is subject to Title V because it is major for:LeadSulfur DioxideCarbon MonoxideVolatile Organic CompoundsNitrogen OxidesParticulate Matter 10 micronsSingle Hazardous Air PollutantCombined Hazardous Air PollutantsMaximum Available Control Technology Standard(s)A. Standard Terms and ConditionsHas each insignificant emissions unit been reviewed toYesconfirm it meets the definition in OAC rule 3745-77-01(U)?Were there any Acommon control@ issues associatedwith this facility? If yes, provide a summary of thoseissues and explain how the DAPC decided to resolvethem.Please identify the affected unit(s) and associated PTI,if applicable, along with a brief description of anychanges to the permit document that qualify as a minorpermit modification per OAC rule 3745-77-08(C)(1)Please identify the affected unit(s) and associated PTI,if applicable, along with a brief description of anychanges to the permit document that qualify as asignificant permit modification per OAC rule 3745-7708(C)(3)NON/APermit to Install (PTI) P0106570 for emissions unit P010, PTI P0106672 for emissions unit K021,and PTI P0108338 for emissions units K008, K010, K016, and K020 are administrativemodifications that changed the record keeping and monitoring requirements for the facility-wideemission limitations and the control equipment monitoring as requested by the facility.Additionally, PTI P0108655 for emissions unit K021 is an administrative modification that changesthe testing requirements for the capture system. PTI 16-02495 was for the installation of K021(flexographic printing line) and PTI 16-2489 was for the installation of P010 (Plate Making). PTI16-02495 was a synthetic minor to avoid PSD applicability.
Statement of BasisBemis Company, Inc.Permit Number: P0106317Facility ID: 1677000105Please identify the affected unit(s)and associated PTI,if applicable, along with a brief description of anychanges to the permit document that qualify as areopening per OAC rule 3745-77-08(D)Please identify the affected unit(s) and associated PTI,if applicable, along with a brief description of anychanges to the permit document resulting from arenewal per OAC rule 3745-77-08(E)Permit to Install (PTI) P0106570 for emissions unit P010 and PTI P0106672 are administrativemodification to incorporate Best Available Technology (BAT) under OAC rule 3745-31-05(A)(3).N/AB. Facility-Wide Terms and ConditionsTerm and Condition (paragraph)BasisSIP(3745- )CommentsOther2NY3NY45NNYY6.a)YYReporting for the catalytic oxidizer. Other - 3745-31-05(A)(3).YTesting for the catalytic oxidizer. Other - 3745-31-05(A)(3).72109(B)(3)(l)&(n), 7707(C)(1), 40CFR Part 642109(B)(3)(m),77-07(C)(1),40 CFR Part6477-07(C)(1)and 40 CFRPart 6477-07(A)(13)Facility-wide VOC, individual HAP, and combined HAPs emission limitations to avoid PSDpermitting and 40 CFR Part 63, subpart KK MACT standard. Other - OAC rule 3745-31-05(D).Record keeping for the emissions units K003, K006, K008, K010, K013, K016, K018, K020,T001, T002, and T003. Other - OAC rule 3745-31-05(D)Quarterly deviation reporting for emission limitations. Other - OAC rule 3745-31-05(D)Explanation of how compliance with the HAP and VOC emission limitations are determined.Other - OAC rule 3745-31-05(D)Monitoring and record keeping for the catalytic oxidizer. Other - 3745-31-05(A)(3).N877-01(H)NList of insignificant emissions units that are subject to an emission limitation in a Permit toInstall.List of “de minimis” emissions units.6.b)6.c)
Statement of BasisBemis Company, Inc.Permit Number: P0106317Facility ID: 1677000105C. Emissions Unit Terms and ConditionsKey:EU emissions unit IDND negative declaration (i.e., term that indicates that a particular rule(s) is (are) notapplicable to a specific emissions unit)OR operational restrictionM monitoring requirementsSt streamlining term used to replace a PTI monitoring, record keeping, or reportingrequirement with an equivalent or more stringent requirementEU(s)K003K003LimitationBasisSIP(3745- )Other65% by weightcaptureefficiency and90% by weightcontrolefficiency2109(Y)(1)(b)N65% by weightoverall ENFNNNNENF did noncompliance issues drive the monitoring requirements?R record keeping requirementsRp reporting requirementsET emission testing requirements (not including compliance method terms)Misc miscellaneous requirementsRYYStRpNYNYStNNETMiscYNYNCommentsOR - VOC shall be vented to the catalyticoxidizer.The following operational restrictions weremoved to monitoring: the averagetemperature of the exhaust gasesimmediately before the catalyst bed, theVOC conversion efficiency of the catalyst,operating emissions unit with an interlocksystem, having the components comprisingof the capture system in good operatingcondition to ensure all emissions capturedare vent to the oxidizer, and the averagetotal exhaust flow rate from this emissionsunit. CAM is applicable.OR - VOC shall be vented to the catalyticoxidizer.The following operational restrictions weremoved to monitoring: the averagetemperature of the exhaust gasesimmediately before the catalyst bed, theVOC conversion efficiency of the catalyst,operating emissions unit with an interlocksystem, having the components comprisingof the capture system in good operatingcondition to ensure all emissions captured
Statement of BasisBemis Company, Inc.Permit Number: P0106317Facility ID: 1677000105K00885.0 lbs ofVOC/hrNYNNNNNNNNNNNK008,K010,K016,andK020109 tpy VOCNYNNYNNYNYNNNK008,K010,andK01678% by weightcaptureefficiency and90% by weightcontrolefficiencyNYNYYNNYYYYYNK010220.0 lbs ofVOC/hourNYNNNNNNNNNNNare vent to the oxidizer, and the averagetotal exhaust flow rate from this emissionsunit. CAM is applicable.M, R, Rp, and ET -The emission limitationis based on the maximum capacity of thepress and a worst-case coating formulationand the allowable capture and controlefficiencies. The control efficiency istested periodically and if necessary thecapture efficiency is tested.Other - OAC rule 3745-31-05(A)(3).ET - Emission testing is done for thecontrol efficiency and if required for thecapture efficiency. Using these resultsalong with the monitoring and recordkeeping, the annual emissions for VOC aredetermined.Other - OAC rule 3745-31-05(A)(3).OR - VOC shall be vented to the catalyticoxidizer, complying coating employed onthe in-line lamination station for K010 canbe vented to atmosphere, the averagetemperature of the exhaust gasesimmediately before the catalyst bed, theVOC conversion efficiency of the catalyst,operating emissions unit with an interlocksystem, having the components comprisingof the capture system in good operatingcondition to ensure all emissions capturedare vent to the oxidizer, and the averagetotal exhaust flow rate from this emissionsunit. CAM is applicable.Other - OAC rule 3745-31-05(A)(3).M, R, Rp, and ET -The emission limitationis based on the maximum capacity of thepress and a worst-case coating formulationand the allowable capture and control
Statement of BasisBemis Company, Inc.Permit Number: P0106317Facility ID: 1677000105efficiencies. The control efficiency istested periodically and if necessary thecapture efficiency is tested.K010,K020,andK021K010,K020,andK021K01640% VOC byvolume ofcoating or ink,excluding waterand exemptsolvents or 25%VOC by volumeof volatilematter in thecoating or inkThe VOCcontent of thecoatings andinks employedshall notexceed 0.8pound of VOCper pound ofsolids appliedor 0.16 poundof VOC perpound ofcoating or inkapplied34.0 lbs ofVOC/hrNYNNYNNYNYNNNOther - OAC rule 3745-31-05(A)(3).ET - Compliance with the emissionlimitation is determined using USEPAMethods 24 or 24A which is usually doneby the coating supplier.Other - OAC rule 3745-31-05(A)(3).2109(Y)(4)(a)(ii)NNNYNNYNYNNNET - Compliance with the emissionlimitation is determined using USEPAMethods 24 or 24A which is usually doneby the coating supplier.NYNNNNNNNNNNNM, R, Rp, and ET -The emission limitationis based on the maximum capacity of thepress and a worst-case coating formulationand the allowable capture and controlefficiencies. The control efficiency istested periodically and if necessary thecapture efficiency is tested.Other - OAC rule 3745-31-05(A)(3).
Statement of BasisBemis Company, Inc.Permit Number: P0106317Facility ID: 1677000105K01675% by weightoverall 20124.0 lbs ofVOC/hrNYNNNNNNNNNNNK02090% by weightcaptureefficiency and90% by weightcontrolefficiencyNYNYYNNYYYYYNOR - VOC shall be vented to the catalyticoxidizer.The following operational restrictions weremoved to monitoring: the averagetemperature of the exhaust gasesimmediately before the catalyst bed, theVOC conversion efficiency of the catalyst,operating emissions unit with an interlocksystem, having the components comprisingof the capture system in good operatingcondition to ensure all emissions capturedare vent to the oxidizer, and the averagetotal exhaust flow rate from this emissionsunit. CAM is applicable.M, R, Rp, and ET -The emission limitationis based on the maximum capacity of thepress and a worst-case coating formulationand the allowable capture and controlefficiencies. The control efficiency istested periodically and if necessary thecapture efficiency is tested.Other - OAC rule 3745-31-05(A)(3).OR - VOC shall be vented to the catalyticoxidizer except for complying coatingsemployed on the laminator, the averagetemperature of the exhaust gasesimmediately before the catalyst bed, theVOC conversion efficiency of the catalyst,operating emissions unit with an interlocksystem, having the components comprisingof the capture system in good operatingcondition to ensure all emissions capturedare vent to the oxidizer, and the averagetotal exhaust flow rate from this emissionsunit. CAM is currently not applicable.Other OAC rule 3745-31-05(A)(3).
Statement of BasisBemis Company, Inc.Permit Number: P0106317Facility ID: 1677000105K02116.22 lbs ofVOC per hourNYNNNNNNNNNNNK02190% by weightcaptureefficiency and95% by weightcontrolefficiencyNYNYYNNYNYNYNK02122.0 tpy VOC,as a rolling, 12monthsummationNYNNYNNYNYNNNK021The emissionsfrom the naturalgas fired dryerovens shall notexceed thefollowing:NYNNNNNNNNNNNM, R, Rp, and ET -The emission limitationis based on the maximum capacity of thepress and a worst-case coating formulationand the allowable capture and controlefficiencies. The control efficiency istested periodically and if necessary thecapture efficiency is tested.Other - OAC rule 3745-31-05(A)(3).OR - VOC shall be vented to the catalyticoxidizer, complying coating employed onthe adhesive station can be vented toatmosphere, the average temperature ofthe exhaust gases immediately before thecatalyst bed, the VOC conversionefficiency of the catalyst, operatingemissions unit with an interlock system,having the components comprising of thecapture system in good operating conditionto ensure all emissions captured are ventto the oxidizer, and the average totalexhaust flow rate from this emissions unit.CAM is applicable.Other - OAC rule 3745-31-05(A)(3).ET - Emission testing is done for thecontrol efficiency and if required for thecapture efficiency. Using these resultsalong with the monitoring and recordkeeping, the rolling 12-month VOCemissions are determined.Other - OAC rule 3745-31-05(D).M, R, Rp, and ET -The emission limitationsare based on the maximum heat input ofthe ovens and the AP-42 emission factors.Other - OAC rule 3745-31-05(A)(3).
Statement of BasisBemis Company, Inc.Permit Number: P0106317Facility ID: 16770001050.28 pound ofNOx per hourand 1.20 tonsof NOx peryear.0.23 pound ofCO per hourand 1.01 tonsof CO per year.0.02 pound ofPE per hourand 0.09 ton ofPE per year.P0100.002 pound ofSO2 per hourand 0.01 ton ofSO2 per year.9.9 tpy VOC, asa rolling, 12monthsummationNYNNYNNYNYNNNET - Emission testing is done for thecontrol efficiency and if required for thecapture efficiency. Using these resultsalong with the monitoring and recordkeeping, the rolling 12-month VOCemissions are determined.Other - OAC rule 3745-31-05(A)(3).P01085% reduction,by weight, inthe overall VOCemissions and90% by weightcontrolefficiency2107(G)(2), 2107(G)(6), and2107(M)(4)NNYYNNYNYNYNCAM is not applicable.OR - VOC shall be vented to the catalyticoxidizer and cannot employphotochemically reactive cleanup material.The following operational restrictions weremoved to monitoring: the averagetemperature of the exhaust gasesimmediately before the catalyst bed, theVOC conversion efficiency of the catalyst,operating emissions unit with an interlock
Statement of BasisBemis Company, Inc.Permit Number: P0106317Facility ID: 1677000105system, having the components comprisingof the capture system in good operatingcondition to ensure all emissions capturedare vent to the oxidizer, and the averagetotal exhaust flow rate from this emissionsunit. CAM is not applicable.
DRAFTDivision of Air Pollution ControlTitle V PermitforBemis Company, Inc.Facility ID:Permit Number:Permit 7Significant Permit Modification, Off-Permit Change9/12/2011To be entered upon final issuanceTo be entered upon final issuance
Division of Air Pollution ControlTitle V PermitforBemis Company, Inc.Table of ContentsAuthorization . 1A. Standard Terms and Conditions . 21. Federally Enforceable Standard Terms and Conditions . 32. Monitoring and Related Record Keeping and Reporting Requirements. 33. Scheduled Maintenance. 64. Risk Management Plans . 65. Title IV Provisions . 76. Severability Clause . 77. General Requirements . 78. Fees. 89. Marketable Permit Programs. 810. Reasonably Anticipated Operating Scenarios . 811. Reopening for Cause . 912. Federal and State Enforceability . 913. Compliance Requirements. 914. Permit Shield . 1115. Operational Flexibility. 1116. Emergencies. 1117. Off-Permit Changes . 1118. Compliance Method Requirements . 1219. Insignificant Activities or Emissions Levels. 1220. Permit to Install Requirement . 1221. Air Pollution Nuisance . 1222. Permanent Shutdown of an Emissions Unit . 1323. Title VI Provisions . 1324. Reporting Requirements Related to Monitoring and Record Keeping Requirements Under State LawOnly . 1325. Records Retention Requirements Under State Law Only. 1426. Inspections and Information Requests . 1427. Scheduled Maintenance/Malfunction Reporting . 1428. Permit Transfers . 15
29. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable EmissionLimitations, Operational Restrictions, or Control Device Operating Parameter Limitations . 15B. Facility-Wide Terms and Conditions. 16C. Emissions Unit Terms and Conditions . 271. K021, Vision 2. 282. P010, BASF2 . 423. Emissions Unit Group -Group 1: K003,K008,K016, . 464. Emissions Unit Group -Group 2: K010,K020, . 57
Draft Title V PermitBemis Company, Inc.Permit Number: P0106317Facility ID: 1677000105Effective Date:To be entered upon final issuanceAuthorizationFacility ID:1677000105Facility Description: Paper coating & laminated, packaging.Application Number(s): A0039454, A0039580Permit Number:P0106317Permit Description: Significant Title V Permit Modification to add the new flexographic printing press (K021)and the new plating making process (P010) and to update the terms and conditions tomake them consistent with the modified Permits to Install. This facility consists of sixflexographic printing lines (K003, K008, K010, K016, K020, and K021), a plate makingprocess (P010), and several insignificant emissions units.Permit Type:Significant Permit Modification, Off-Permit ChangeIssue Date:9/12/2011Effective Date:To be entered upon final issuanceExpiration Date:To be entered upon final issuanceSuperseded Permit Number: P0106172This document constitutes issuance of an OAC Chapter 3745-77 Title V permit to:Bemis Company, Inc.1972 AKRON PENINSULA RD.AKRON, OH 44313Ohio EPA District Office or local air agency responsible for processing and administering your permit:Akron Regional Air Quality Management District146 South High Street, Room 904Akron, OH 44308(330)375-2480The above named entity is hereby granted a Title V permit pursuant to Chapter 3745-77 of the OhioAdministrative Code. This permit and the authorization to operate the air contaminant sources (emissionsunits) at this facility shall expire at midnight on the expiration date shown above. You will be sent a noticeapproximately 18 months prior to the expiration date regarding the renewal of this permit. If you do not receivea notice, please contact the Akron Regional Air Quality Management District. If a renewal permit is not issuedprior to the expiration date, the permittee may continue to operate pursuant to OAC rule 3745-77-08(E) and inaccordance with the terms of this permit beyond the expiration date, if a timely renewal application issubmitted. A renewal application will be considered timely if it is submitted no earlier than 18 months (540days) and no later than 6 months (180 days) prior to the expiration date.This permit is granted subject to the conditions attached hereto.Ohio Environmental Protection AgencyScott J. NallyDirectorPage 1 of 69
Draft Title V PermitBemis Company, Inc.Permit Number: P0106317Facility ID: 1677000105Effective Date:To be entered upon final issuanceA. Standard Terms and ConditionsPage 2 of 69
Draft Title V PermitBemis Company, Inc.Permit Number: P0106317Facility ID: 1677000105Effective Date:To be entered upon final issuance1.Federally Enforceable Standard Terms and Conditionsa)All Standard Terms and Conditions are federally enforceable, with the exception of those listedbelow which are enforceable under State law only:(1)Standard Term and Condition A. 24., Reporting Requirements Related to Monitoring andRecord Keeping Requirements of State-Only Enforceable Permit Terms and Conditions(2)Standard Term and Condition A. 25., Records Retention Requirements for State-OnlyEnforceable Permit Terms and Conditions(3)Standard Term and Condition A. 27., Scheduled Maintenance/Malfunction Reporting(4)Standard Term and Condition A. 29., Additional Reporting Requirements When ThereAre No Deviations of Federally Enforceable Emission Limitations, OperationalRestrictions, or Control Device Operating Parameter Limitations(Authority for term: ORC 3704.036(A))2.Monitoring and Related Record Keeping and Reporting Requirementsa)Except as may otherwise be provided in the terms and conditions for a specific emissions unit(i.e., in section C. Emissions Unit Terms and Conditions of this Title V permit), the permitteeshall maintain records that include the following, where applicable, for any required monitoringunder this permit:(1)The date, place (as defined in the permit), and time of sampling or measurements.(2)The date(s) analyses were performed.(3)The company or entity that performed the analyses.(4)The analytical techniques or methods used.(5)The results of such analyses.(6)The operating conditions existing at the time of sampling or measurement.(Authority for term: OAC rule 3745-77-07(A)(3)(b)(i))b)Each record of any monitoring data, testing data, and support information required pursuant tothis permit shall be retained for a period of five years from the date the record was created.Support information shall include all calibration and maintenance records and all original stripchart recordings for continuous monitoring instrumentation, and copies of all reports required bythis permit. Such records may be maintained in computerized form.(Authority for term: OAC rule 3745-77-07(A)(3)(b)(ii))Page 3 of 69
Draft Title V PermitBemis Company, Inc.Permit Number: P0106317Facility ID: 1677000105Effective Date:To be entered upon final issuancec)The permittee shall submit required reports in the following manner:(1)All reporting required in accordance with OAC rule 3745-77-07(A)(3)(c) for deviationscaused by malfunctions shall be submitted in the following manner:Any malfunction, as defined in OAC rule 3745-15-06(B)(1), shall be promptly reported tothe Ohio EPA in accordance with OAC rule 3745-15-06. In addition, to fulfill the OACrule 3745-77-07(A)(3)(c) deviation reporting requirements for malfunctions, writtenreports that identify each malfunction that occurred during each calendar quarter(including each malfunction reported only verbally in accordance with OAC rule 3745-1506) shall be submitted (i.e., postmarked) by January 31, April 30, July 31, and October31 of each year in accordance with Standard Term and Condition A.2.c)(2) below; andeach report shall cover the previous calendar quarter. An exceedance of the visibleemission limitations specified in OAC rule 3745-17-07(A)(1) that is caused by amalfunction is not a violation and does not need to be reported as a deviation if theowner or operator of the affected air contaminant source or air pollution controlequipment complies with the requirements of OAC rule 3745-17-07(A)(3)(c).In accordance with OAC rule 3745-15-06, a malfunction reportable under OAC rule3745-15-06(B) is a deviation of the federally enforceable permit requirements. Eventhough verbal notifications and written reports are required for malfunctions pursuant toOAC rule 3745-15-06, the written reports required pursuant to this term must besubmitted quarterly to satisfy the prompt reporting provision of OAC rule 3745-7707(A)(3)(c).In identifying each deviation caused by a malfunction, the permittee shall specify theemission limitation(s) (or control requirement(s)) for which the deviation occurred,describe each deviation, and provide the magnitude and duration of each deviation. Fora specific malfunction, if this information has been provided in a written report that wassubmitted in accordance with OAC rule 3745-15-06, the permittee may simply referencethat
1972 AKRON PENINSULA RD. Akron, OH 44313 RE: DRAFT AIR POLLUTION TITLE V PERMIT Permit Type: Significant Permit Modification, Off-Permit Change Dear Permit Holder: A draft of the OAC Chapter 3745-77 Title V permit for the referenced facility has been issued.
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