Air Individual Permit Part 70 Reissuance

Transcription

1 Air Individual Permit Part 70 Reissuance Permittee: Facility name: Rayven Inc Rayven Inc 431 Griggs Street N Saint Paul, MN Ramsey County Expiration date: December 5, 2023 * All Title I Conditions do not expire Part 70 Reissuance: December 5, 2018 Permit characteristics: Federal; Part 70/ Limits to avoid NSR; Limits to avoid NSR The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the submittals listed in the Permit Applications Table. This permit reissuance supersedes Air Emission Permit No and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in the permit. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR and as such are enforceable by EPA Administrator or citizens under the Clean Air Act. Signature: for Peggy Bartz This document has been electronically signed. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for the Minnesota Pollution Control Agency

2 Table of Contents 1. Permit applications table Where to send submittals Facility description Summary of subject items Limits and other requirements Submittal/action requirements Appendices Appendix A. Insignificant Activities and General Applicable Requirements Appendix B. Maximum Contents of Materials and Maximum Application Rates Page

3 Permit issued: December 5, Permit expires: December 5, 2023 Page 3 of Permit applications table Title description Application receipt date Action number Part 70 Reissuance 05/07/2018, resubmittal received /10/2018

4 Permit issued: December 5, Permit expires: December 5, 2023 Page 4 of Where to send submittals Send submittals that are required to be submitted to the U.S. EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by Minn. R to must be certified by a responsible official, defined in Minn. R , subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. Send submittals that are required by the Acid Rain Program to: U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C Send any application for a permit or permit amendment to: Fiscal Services 6 th Floor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term Unless another person is identified in the applicable Table, send all other submittals to: AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Or a signed and scanned PDF copy to: submitstacktest.pca@state.mn.us (for submittals related to stack testing) AQRoutineReport.PCA@state.mn.us (for other compliance submittals) (See complete instructions in Routine Air Report Instructions Letter at

5 Permit issued: December 5, Permit expires: December 5, 2023 Page 5 of Facility description The Rayven Inc (Facility) is located at 431 Griggs Street N in Saint Paul, Ramsey County, Minnesota. Rayven, Inc. operates a full-service imageable film products manufacturing facility. The Facility handles all aspects of the production processes including coating, printing, laminating, slitting and sheeting (converting), packaging and shipping. The Permittee's manufacturing processes include surface coating with pressure sensitive adhesives to produce tapes and labels. The main pollutants of concern are volatile organic compounds (VOC) and hazardous air pollutants (HAP). The Permittee has several activities that qualify as insignificant activities under Minnesota rules.

6 Permit issued: December 5, Permit expires: December 5, 2023 Page 6 of Summary of subject items SI ID: Description TFAC 1: Rayven Inc ACTV 3: All IAs COMG 2: Total Facility VOC Limits EQUI 11: Coating Line 1 (Blue Line) EQUI 11: Coating Line 1 (Blue Line) EQUI 12: Coating Line 3 (Silicone Line) EQUI 12: Coating Line 3 (Silicone Line) EQUI 12: Coating Line 3 (Silicone Line) EQUI 12: Coating Line 3 (Silicone Line) EQUI 13: Coating Line 5 (Black Line) EQUI 13: Coating Line 5 (Black Line) Relationshi p Type Related SI ID: Description has EQUI 11, EQUI members 12, EQUI 13 sends to STRU 15: Coater 1 Dryer (Blue Line) sends to STRU 20: Coater 1 (blue line) Corona Treater sends to STRU 17: Coater 3 Dryer (Silicone Line) sends to STRU 18: Coater 3 Dryer (Silicone Line) sends to STRU 22: Coater 3 (silicone line) Corona Treater #1 sends to STRU 23: Coater 3 (silicone line print press) Corona Treater #2 sends to STRU 13: Coater 5 (black line lamination) Corona Treater #2 sends to STRU 19: Coater 5 Dryer (Black Line) SI ID: Description EQUI 13: Coating Line 5 (Black Line) STRU 1: Warehouse STRU 2: Contains EU003 and EU 005 (black & silicone line) STRU 3: Converting STRU 4: Slitting STRU 5: Contains EU001, Blue Line STRU 6: Lab STRU 7: Office STRU 13: Coater 5 (black line lamination) Corona Treater #2 STRU 15: Coater 1 Dryer (Blue Line) STRU 17: Coater 3 Dryer (Silicone Line) STRU 18: Coater 3 Dryer (Silicone Line) STRU 19: Coater 5 Dryer (Black Line) STRU 20: Coater 1 (blue line) Corona Treater STRU 22: Coater 3 (silicone line) Corona Treater #1 STRU 23: Coater 3 (silicone line print press) Corona Treater #2 STRU 24: Coater 5 (black line coating head) Corona Treater Relationshi Related SI ID: p Type Description sends to STRU 24: Coater 5 (black line coating head) Corona Treater

7 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 7 of Limits and other requirements Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation TFAC Rayven Inc This permit establishes limits on the facility to keep it a minor source under New Source Review and NESHAPS. The Permittee cannot make any change at the source that would make the source a major source under New Source Review and NESHAPS until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Equipment Labeling: The Permittee shall permanently affix a unique number to each emissions unit for tracking purposes. The numbers shall correlate the unit to the appropriate Subject Item numbers used in this permit. The number can be affixed by placard, stencil, or other means. The number shall be maintained so that it is readable and visible at all times from a safe distance. If equipment is added, it shall be given a new unique number; numbers from replaced or removed equipment shall not be reused. [Minn. R , subp. 2] Equipment Inventory: The Permittee shall maintain a written list of all emissions units and control equipment on site. The Permittee shall update the list to include any replaced, modified, or new equipment prior to making the change. The list shall correlate the units to the Subject Item numbers used in this permit and shall include the data on GI-04, GI-05B, GI-05C, and GI-05F. The date of construction shall be the date the change was made for replaced, modified, or new equipment. [Minn. R , subp. 2] Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendices A and B. [Minn. R , subp. 2] PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of

8 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 8 of 20 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation permit issuance. [Minn. R (A)(2)] The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R to Compliance shall be demonstrated upon written request by the MPCA. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. [Minn. R ] Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R , subp. 16(J), Minn. R , subp. 2] Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. [Minn. R , subp. 14, Minn. R , subp. 16(J)] Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R , subp. 4] Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R [Minn. R ] Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R ] Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). [Minn. R , subp. 9(A)]

9 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 9 of 20 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. [Minn. R , subp. 16] Monitoring Equipment Calibration - The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. [Minn. R , subp. 4(D)] Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. [Minn. R , subp. 4(D)] Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). [Minn. R , subp. 5(C)] Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R , subp. 2), including records of the emissions resulting from those changes. [Minn. R , subp. 5(B)] If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. [Minn. R , subp. 4] Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator

10 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 10 of 20 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. [Minn. R , subp. 3] Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24- hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R , subp. 2] Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R , subp. 1] Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. [Minn. R , subp. 1] Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new or amended federal applicable requirement, and if there are 3 or more years remaining in the permit term, the Permittee shall file an application for an

11 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 11 of 20 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R , subp. 3. [Minn. R , subp. 3, Minn. R ] Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R , subp. 1(H). [Minn. R , subp. 1(H)] Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. Submit in a format specified by the Commissioner. [Minn. R ] Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R ] COMG 2 GP001 Total Facility VOC Limits The Permittee shall limit emissions of Volatile Organic Compounds <= 200 tons per year 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit as required by this permit at COMG 2. VOC contents for each VOC-containing material shall be determined as described under the Material Content requirement at COMG 2. All non-combustion VOC-emitting equipment at the Facility is subject to this limit except for insignificant activities listed in Appendix A of this permit. The calculation of VOCs used may take into account recovered/recycled VOCs as described under the Waste Credit requirement at COMG 2. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall limit HAPs - Total <= 24 tons per year 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period as required by this permit at COMG 2. HAP contents for each HAP-containing material (e.g., coatings, cleaners, etc.) shall be determined as described under the Material Content requirement at COMG 2. All non-combustion HAP-emitting equipment at the Facility is subject to this limit except for insignificant activities listed in Appendix A of this permit. [Title I Condition: Avoid major source under 40 CFR 63.2, Title I Condition: Avoid major source under 40 CFR (a)(2)] The Permittee shall limit HAPs - Single <= 9.0 tons per year 12- month rolling sum to be calculated by the 15th day of each month for the previous 12-month period as required by this permit at COMG 2. HAP contents for each HAP-containing material (e.g.,

12 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 12 of 20 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation coatings, cleaners, etc.) shall be determined as described under the Material Content requirement at COMG 2. All non-combustion HAPemitting equipment at the Facility is subject to this limit except for insignificant activities listed in Appendix A of this permit. [Title I Condition: Avoid major source under 40 CFR 63.2, Title I Condition: Avoid major source under 40 CFR (a)(2)] VOC and HAP PreCaps: If the Permittee replaces any existing non-combustion VOC and/or HAP-emitting equipment, adds new non-combustion VOC and/or HAP emitting equipment, or modifies the existing equipment listed in COMG 2, such equipment is subject to the above VOC and HAP permit limits as well as all of the requirements of COMG 2. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee is not required to repeat VOC calculations described in Minn. R , subp. 2. A permit amendment will still be needed regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to the limits or monitoring and recordkeeping in this permit. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2, Title I Condition: Avoid major source under 40 CFR (a)(2)] Volatile Organic Compounds: Monthly Calculation -- VOC Emissions. The Permittee shall calculate VOC emissions using the following equations: VOC (tons/month) = V - W V = Cleanup VOCs + (A1 x B1) + (A2 x B2) + (A3 x B3) +... W = (C1 x D1) + (C2 x D2) + (C3 x D3) +... where: V = total VOC used in tons/month; A# = amount of each VOC-containing coating applied at each Coating Line in the previous month, in tons/month; B# = weight percent VOC in A#, as a fraction; Cleanup VOCs = total amount of VOC used in cleanup materials at the Facility, in tons/month, calculated as specified earlier in this permit; W = the amount of VOC shipped in waste, in tons/month; C# = amount, in tons/month, of each VOC-containing waste material shipped. If the Permittee chooses to not take credit for waste shipments, this parameter would be zero; and D# = weight percent of VOC in C#, as a fraction. [Minn. R , subps. 4-5] Volatile Organic Compounds: Monthly Recordkeeping -- VOC in Cleanup Materials. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total quantity, in tons, of cleanup materials used at the

13 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 13 of 20 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Facility for the previous month using purchase records. 2) The total VOC used in cleanup materials, in tons/month, for the previous month using the following method: Cleanup VOCs = (A1 x B1) + (A2 x B2) + ( A3 x B3) +... where: A# = amount of each cleanup material used in the previous month, in tons/month; and B# = weight percent of VOC in A#, as a fraction. [Minn. R , subps. 4-5] Volatile Organic Compounds: Monthly Recordkeeping -- VOC Emissions. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total usage of VOC-containing cleanup materials for the previous calendar month using the methods and formulas specified at COMG 2. This record shall also include the VOC content of each material as determined by the Material Content requirement of this permit. 2) The total usage of VOC-containing coating materials for the previous calendar month using the daily and monthly usage records required at each Coating Line. This record shall also include the VOC content of each material as determined by the Material Content requirement of this permit. 3) The VOC emissions for the previous month by using the formulas specified at COMG 2. AND 4) The 12-month rolling sum VOC emissions for the previous 12- month period by summing the monthly VOC emissions data for the previous 12 months. [Minn. R , subps. 4-5] HAPs: Monthly Recordkeeping. By the 15th of the month, the Permittee shall calculate and record the following using the formulas specified in this permit: 1) The total of amount each HAP-containing cleanup and coating materials used in the previous calendar month using the daily and monthly usage records required at each Coating Line and at COMG 2 (monthly cleanup records). This record shall also include the individual and total HAP contents of each HAP-containing material used in the previous month, as determined by the Material Content requirement of this permit; 2) The total and individual HAP usage for the previous month using the formulas specified at COMG 2; and 3) The 12-month rolling sum total and individual HAP usage for the previous 12-month period by summing the monthly usage data for the previous 12 months. [Minn. R , subps. 4-5] HAPs: Monthly Calculation. The Permittee shall calculate each individual HAP and total HAP usage using the following equations: HAP (tons/month) = (A1 x B1) + (A2 x B2) + (A3 x B3) +... Where: HAP = the amount of each pollutant (either total HAP or each

14 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 14 of 20 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation individual HAP), used, in tons/month. A# = Amount of each HAP-containing material used in the previous month, in tons/month. B# = weight percent of each individual or total HAP in A#, as a fraction (e.g., 50% is 0.50). [40 CFR (d), Minn. R , subps. 4-5] Material Content. VOC and HAPs contents in coating and cleanup materials shall be determined by the Safety Data Sheet (SDS) or the Material Safety Data Sheet (MSDS) provided by the supplier for each material used. If a material content range is given on the SDS or the MSDS, the highest number in the range shall be used in all compliance calculations. If there is information provided in the Regulatory Section of the SDS, the highest number in the range of that section may be used. Other alternative methods approved by the MPCA may be used to determine the VOC and HAPs contents. The Commissioner reserves the right to require the Permittee to determine the VOC and HAP contents of any material, according to EPA or ASTM reference methods. If an EPA or ASTM reference method is used for material content determination, the data obtained shall supersede the SDS or the MSDS. [40 CFR (d), Minn. R , subps. 4-5] Waste Credit: If the Permittee elects to obtain credit for VOC shipped in waste materials, the Permittee shall either use item 1 or 2 to determine the VOC content for each credited shipment. 1) The Permittee shall analyze a composite sample of each waste shipment to determine the weight content of VOC, excluding water. 2) The Permittee may use supplier data for raw materials to determine the VOC content of each waste shipment, using the same content data used to determine the content of raw materials. If the waste contains several materials, the content of mixed waste shall be assumed to be the lowest VOC content of any of the materials. [Minn. R , subps. 4-5] Maximum Contents of Materials and Application Rates: The Permittee assumed certain worst-case contents of materials and application rates when determining the short term potential to emit of units in COMG 2. These assumptions are listed in Appendix B of this permit. Changing the maximum application rate or to a material that has a higher content of any of the given pollutants is considered a change in method of operation that must be evaluated under Minn. R , subp. 3 to determine if a permit amendment or notification is required under Minn. R [Minn. R , subp. 35a] EQUI 11 EU001 Coating Line 1 (Blue Line) This Coating Line is an affected facility (per 40 CFR Section ) which has taken limits to avoid the emissions limits in 40 CFR Section (a). If the VOC input exceeds the limit in any 12- month period, the coating line is then subject to additional requirements in 40 CFR pt. 60, subp. RR, and the Permittee must

15 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 15 of 20 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation obtain the appropriate permit amendment to add these requirements to the permit. [40 CFR (b), Minn. R ] The Permittee shall limit Volatile Organic Compounds <= 49.0 tons per year 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period as described later at EQUI 11. This limit is on all solvent applied in the coating. This means all organic solvent contained in the adhesive, release, and precoat formulations that are metered into the coating applicator from the formulation area. [40 CFR (b), Minn. R ] Daily Recordkeeping. On each day of operation, the Permittee shall record and maintain the quantity of each coating applied at Coating Line 1. This shall be based on usage logs or production records, which include batch quantities and formulation specifications. [Minn. R , subps. 4-5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2, Title I Condition: Avoid major source under 40 CFR (a)(2)] Monthly Recordkeeping: The Permittee shall maintain a calendar month record of all coatings used at Coating Line 1 and the results of the reference test methods specified in 40 CFR Section (a) or the manufacturer's formulation data used for determining the VOC content of those coatings. [40 CFR (a), Minn. R ] Monthly Recordkeeping -- VOC Applied in Coatings. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total tons of each coating used in the previous month using the records and formulation specifications required by this permit; 2) The VOC applied in coatings for the previous month using the formulas specified at EQUI 11; and 3) The 12-month rolling sum VOC applied in coatings for the previous 12-month period by summing the monthly VOC application data for the previous 12 months. [40 CFR (d), Minn. R , subps. 4-5, Minn. R ] Monthly Calculations -- VOC Applied in Coatings. The Permittee shall calculate the VOC applied in coatings, in tons/month, by the 15th of the month for the previous month using the following method: VOC = (W1 x M1) + (W2 x M2) + (W3 x M3) +... where: M# = the total mass, in tons, of each coating (#) applied during the calendar month; and W# = the weight fraction of volatile organics in coating M#. The value of W# shall be obtained from either a U.S. EPA Reference Method 24 test or manufacturer's formulation data. [40 CFR (a), (a), Minn. R , subps. 4-5, Minn. R ]

16 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 16 of 20 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Fuel Type: natural gas or propane, by design. [Minn. R , subp. 35a] The Permittee shall keep records of fuel purchases. [Minn. R , subp. 5] EQUI 12 EU003 Coating Line 3 (Silicone Line) This Coating Line is an affected facility (per 40 CFR Section ) which has taken limits to avoid the emissions limits in 40 CFR Section (a). If the VOC input exceeds the limit in any 12- month period, the coating line is then subject to additional requirements in 40 CFR pt. 60, subp. RR, and the Permittee must obtain the appropriate permit amendment to add these requirements to the permit. [40 CFR (b), Minn. R ] The Permittee shall limit Volatile Organic Compounds <= 49.0 tons per year 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period as described later at EQUI 12. This limit is on all solvent applied in the coating. This means all organic solvent contained in the adhesive, release, and precoat formulations that are metered into the coating applicator from the formulation area. [40 CFR (b), Minn. R ] Daily Recordkeeping. On each day of operation, the Permittee shall record and maintain the quantity of each coating applied at Coating Line 3. This shall be based on usage logs or production records, which include batch quantities and formulation specifications. [Minn. R , subps. 4-5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2, Title I Condition: Avoid major source under 40 CFR (a)(2)] Monthly Recordkeeping: The Permittee shall maintain a calendar month record of all coatings used at Coating Line 3 and the results of the reference test methods specified in 40 CFR Section (a) or the manufacturer's formulation data used for determining the VOC content of those coatings. [40 CFR (a), Minn. R ] Monthly Recordkeeping -- VOC Applied in Coatings. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total tons of each coating used in the previous month using the records and formulation specifications required by this permit; 2) The VOC applied in coatings for the previous month using the formulas specified at EQUI 12; and 3) The 12-month rolling sum VOC applied in coatings for the previous 12-month period by summing the monthly VOC application data for the previous 12 months. [40 CFR (d), Minn. R , subps. 4-5, Minn. R ] Monthly Calculations -- VOC Applied in Coatings. The Permittee shall calculate the VOC applied in coatings, in tons/month, by the 15th of the month for the previous month using the following

17 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 17 of 20 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation method: VOC = (W1 x M1) + (W2 x M2) + (W3 x M3) +... where: M# = the total mass, in tons, of each coating (#) applied during the calendar month; and W# = the weight fraction of volatile organics in coating M#. The value of W# shall be obtained from either a U.S. EPA Reference Method 24 test or manufacturer's formulation data. [40 CFR (a), (a), Minn. R , subps. 4-5, Minn. R ] Fuel Type: natural gas or propane, by design. [Minn. R , subp. 35a] The Permittee shall keep records of fuel purchases. [Minn. R , subp. 5] EQUI 13 EU005 Coating Line 5 (Black Line) This Coating Line is an affected facility (per 40 CFR Section ) which has taken limits to avoid the emissions limits in 40 CFR Section (a). If the VOC input exceeds the limit in any 12- month period, the coating line is then subject to additional requirements in 40 CFR pt. 60, subp. RR, and the Permittee must obtain the appropriate permit amendment to add these requirements to the permit. [40 CFR (b), Minn. R ] The Permittee shall limit Volatile Organic Compounds <= 49.0 tons per year 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period as described later at EQUI 13. This limit is on all solvent applied in the coating. This means all organic solvent contained in the adhesive, release, and precoat formulations that are metered into the coating applicator from the formulation area. [40 CFR (b), Minn. R ] Daily Recordkeeping. On each day of operation, the Permittee shall record and maintain the quantity of each coating applied at Coating Line 5. This shall be based on usage logs or production records, which include batch quantities and formulation specifications. [Minn. R , subps. 4-5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Monthly Recordkeeping: The Permittee shall maintain a calendar month record of all coatings used at Coating Line 5 and the results of the reference test methods specified in 40 CFR Section (a) or the manufacturer's formulation data used for determining the VOC content of those coatings. [40 CFR (a), Minn. R ] Monthly Recordkeeping -- VOC Applied in Coatings. By the 15th of the month, the Permittee shall calculate and record

18 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 18 of 20 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation the following: 1) The total tons of each coating used in the previous month using the records and formulation specifications required by this permit; 2) The VOC applied in coatings for the previous month using the formulas specified at EQUI 13; and 3) The 12-month rolling sum VOC applied in coatings for the previous 12-month period by summing the monthly VOC application data for the previous 12 months. [40 CFR (d), Minn. R , subps. 4-5, Minn. R ] Monthly Calculations -- VOC Applied in Coatings. The Permittee shall calculate the VOC applied in coatings, in tons/month, by the 15th of the month for the previous month using the following method: VOC = (W1 x M1) + (W2 x M2) + (W3 x M3) +... where: M# = the total mass, in tons, of each coating (#) applied during the calendar month; and W# = the weight fraction of volatile organics in coating M#. The value of W# shall be obtained from either a U.S. EPA Reference Method 24 test or manufacturer's formulation data. [40 CFR (a), (a), Minn. R , subps. 4-5, Minn. R ] Fuel Type: natural gas or propane, by design. [Minn. R , subp. 35a] The Permittee shall keep records of fuel purchases. [Minn. R , subp. 5]

19 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 19 of Submittal/action requirements This section lists most of the submittals required by this permit. Please note that some submittal requirements may appear in the Limits and Other Requirements section, or, if applicable, within a Compliance Schedule section. Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation TFAC Rayven Inc The Permittee shall submit an application for permit reissuance : Due 180 calendar days before Permit Expiration Date. [Minn. R , subp. 2] The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and July. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. Submit this on form DRF-2 (Deviation Reporting Form). If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R , subp. 6(A)(2)] The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the previous calendar year). Submit this on form CR-04 (Annual Compliance Certification Report). This report covers all deviations experienced during the calendar year. If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R , subp. 6(C)] The Permittee shall submit an annual report by the 31st of January. The report shall describe the changes made at the Facility during the previous calendar year using the latest MPCA application forms. The report shall include information for any new or replaced Subject Items. The report shall document the VOC and HAP 12-month rolling sum calculations for the previous calendar year. The report shall be submitted with the annual Compliance Certification required by this permit. As part of the Annual Report, the Permittee shall verify and certify that the Facility has maintained minor source status for New Source Review. [Minn. R , subp. 2]

20 Permit Issued: December 5, Permit Expires: December 5, 2023 Page 20 of Appendices Appendix A. Insignificant Activities and General Applicable Requirements The table below lists the insignificant activities that are currently at the Facility and their associated general applicable requirements. Minn. R. Rule description of the activity General applicable requirement Minn. R , subp. 3(B)(2) Indirect heating equipment with a capacity less than 420,000 Btu/hour, etc. Rayven Inc has one process boiler with a capacity of 0.3 MMBtu/hr. Minn. R , subp. 3(G) Emissions from a laboratory, as defined in Minn. R , subp. 3(G) Minn. R , subp. 3(H)(3) Minn. R , subp. 3(I) Brazing, soldering or welding equipment Rayven Inc has stated that they have brazing, soldering and welding equipment. Individual units with potential emissions less than 2000 lb/year of certain pollutants Rayven has 3 mixers and 3 degreasers that have VOC PTEs less than 2,000 lbs/year each. Rayven also has two 0.5 MMBtu/hr boilers that qualify under this item. Minn. R , subp. 3(K) Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source PM <= 0.4 lb/mmbtu Opacity <= 20% with exceptions (Minn. R ) PM, variable depending on airflow Opacity <= 20% (Minn. R ) PM, variable depending on airflow Opacity <= 20% (Minn. R ) Degreaser and mixers: PM, variable depending on airflow Opacity <= 20% (Minn. R ) and Boilers: PM <= 0.4 lb/mmbtu Opacity <= 20% with exceptions (Minn. R ) PM, variable depending on airflow Opacity <= 20% (Minn. R ) Appendix B. Maximum Contents of Materials and Maximum Application Rates All contents listed below are as applied. Coating Contents EQUI 11 EQUI 12 EQUI 13 Coating Line 1 [max. weight %] Coating Line 3 [max. weight %] Coating Line 5 [max. weight %] VOC Coating Lines Maximum Application Rates Emission Unit Web Speed (1000 ft 2 /hr) Coating Weight per Web Area (lb/1000 ft 2 ) EQUI EQUI EQUI

21 Technical Support Document for Air Emission Permit No This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR 70.7(a)(5) and Minn. R , subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit. 1. General information 1.1 Applicant and stationary source location Table 1. Applicant and source address Applicant/Address Rayven Inc 431 Griggs St N Saint Paul, Minnesota Contact: Chong Moua Phone: Stationary source/address (SIC Code: Unsupported Plastics Film and Sheet) Rayven Inc 431 Griggs St N Saint Paul, MN Facility description Rayven, Inc. operates a full-service imageable film products manufacturing facility. The Facility handles all aspects of the production processes including coating, printing, laminating, slitting and sheeting (converting), packaging and shipping. The Permittee's manufacturing processes include surface coating with pressure sensitive adhesives to produce tapes and labels. The main pollutants of concern are volatile organic compounds (VOC) and hazardous air pollutants (HAP). The Permittee has several activities that qualify as insignificant activities under Minnesota rules. 1.3 Description of the activities allowed by this permit action This permit action is Part 70 Reissuance. 1.4 Facility emissions Table 2. Total facility potential to emit summary PM tpy PM10 tpy PM2.5 tpy SO2 tpy NOx tpy CO tpy CO2e tpy VOC tpy Single HAP tpy Total facility limited potential emissions Total facility actual emissions (2017) * 60.5 * *Not reported in Minnesota emission inventory. All HAPs tpy Technical Support Document, Permit Number: Page 1 of 7

22 Table 3. Facility classification Classification Major Synthetic minor/area Minor/Area New Source Review X Part 70 X Part 63 X 1.5 Changes to permit The permit does not authorize any specific modifications, however, the MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R , the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action: The permit has been updated to reflect current MPCA templates, organization guidance, and standard citation formatting; The direct heating rule from Minn. R. ch was incorrectly listed as applying to the coating line ovens so it has been removed from the permit (the rule only applies if no other standard of performance applies and in this case 40 CFR pt. 60, subp. RR applies to the coating line ovens so the Minnesota standard does not apply); and Stacks that were removed or are no longer used for process venting have been deleted from the permit (STRU s 11, 12, 14, 16 and 21). COMG 1 is also no longer used for listing requirements so it has been removed from the permit (requirements moved to each EQUI). 2. Regulatory and/or statutory basis 2.1 New source review (NSR) The permit carries forward limits on the facility such that it is a minor source under New Source Review regulations. No changes are authorized by this permit. 2.2 Part 70 permit program The facility is a major source under the Part 70 permit program. 2.3 New source performance standards (NSPS) The coating lines are subject to the requirements of 40 CFR pt. 60, subp. RR. VOC emissions are limited to 49.0 tpy from each coating line to avoid emission limits in 40 CFR pt. 60, subp. RR. 2.4 National emission standards for hazardous air pollutants (NESHAP) The Permittee previously accepted limits on HAP emissions to avoid major source classification under 40 CFR pt. 63. However, the compliance date for 40 CFR pt. 63, subp. KK, May 30, 1996, had passed prior to issuance of the permit with the HAP limits; therefore, the Facility has two coating lines (EQUI 11 and EQUI 12) subject to the requirements of 40 CFR pt. 63, subp. KK. To avoid major source classification, single and total HAP emissions are limited to 9.0 and 24.0 tpy from the coating lines. Paper and Other Web Coating NESHAP, 40 CFR pt. 63, subp. JJJJ, does not apply because subp. KK does apply as stated in 40 CFR (a). 2.5 Compliance assurance monitoring (CAM) There are no controls for emission units at this Facility. Therefore, 40 CFR pt. 64 (CAM) does not apply. Technical Support Document, Permit Number: Page 2 of 7

23 2.6 Regulatory Overview Table 4. Regulatory overview of facility Subject item* Applicable regulations Rationale COMG 2 Total Facility VOC Limits EQUI 11, EQUI 12, and EQUI 13 - Spray Booth/Coating Lines Title I Condition: Avoid major source under 40 CFR 63.2, Title I Condition: Avoid major source under 40 CFR (a)(2) Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R , National Emission Standards for Hazardous Air Pollutants (NESHAP). Limit set on individual and total HAPs emissions from coating operations to avoid major source classification for NESHAPs. The limits are written to apply to all existing, new, or modified noncombustion HAP-emitting units other than the activities listed in the permit appendix related to insignificant activities. Second citation is for 40 CFR pt. 63, subp. KK. Prevention of Significant Deterioration (PSD). Title 1 limits set for VOC emissions to avoid major source classification under PSD for all noncombustion VOC emissions other than the activities listed in the permit appendix related to insignificant activities. This is a rolling limit to account for substantial and unpredictable variations in operation. The PTE from the three coating lines, given the NSPS limits listed at each coating EQUI, appears to be less than the NSR major source level; however, the Permittee can choose to exceed the NSPS usage limits so long as they comply with the appropriate NSPS limits. For this reason, the total facility VOC limit must be separately enforceable in order to avoid being a major source under NSR. 40 CFR pt. 60, subp. RR NSPS for Pressure Sensitive Tape and Label Surface Coating Operations. Limits to keep VOC usage less than threshold in the rule so that no NSPS emissions limits apply. Minn. R , subp. 35a Fuel type limited to natural gas or propane. *Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.). 3. Technical information 3.1 Calculations of potential to emit (PTE) Attachment 1 to this TSD contains detailed spreadsheets and supporting information prepared by the MPCA based on information submitted by the Permittee. Under federal standards, each coating line is regulated as one emission unit. For example, from 40 CFR pt. 60, subp RR: Coating line means any number or combination of adhesive, release, or precoat coating applicators, flashoff areas, and ovens which coat a continuous web, located between a web unwind station and a web rewind station, to produce pressure sensitive tape and label materials. For this reason, each coating line is listed as one EQUI in the permitting database. However, different elements of each line has differing emissions. These are all calculated in Attachment 1 and the totals provided for each line. Technical Support Document, Permit Number: Page 3 of 7