Facility Name: Anheuser-Busch, LLC City: Cartersville County: Bartow AIRS #:

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1 Facility Name: Anheuser-Busch, LLC City: Cartersville County: Bartow AIRS #: Application #: TV Date Application Received: February 25, 2015 Permit No: V-04-0 Program Review Engineers Review Managers SSPP Hem R. Sharma Hamid Yavari ISMP Joshua Pittman David Sheffield SSCP Brian Koehler Jim Cooley-Mountain District, Cartersville Toxics N/A N/A Permitting Program Manager Eric Cornwell Introduction This narrative is being provided to assist the reader in understanding the content of the attached draft Part 70 operating permit. Complex issues and unusual items are explained here in simpler terms and/or greater detail than is sometimes possible in the actual permit. This permit is being issued pursuant to: (1) Georgia Air Quality Act, O.C.G.A , et seq. and (2) Georgia Rules for Air Quality Control, Chapter , and (3) Title V of the Clean Air Act. Section (10) of the Georgia Rules for Air Quality Control incorporates requirements of Part 70 of Title 40 of the Code of Federal Regulations promulgated pursuant to the Federal Clean Air Act. The primary purpose of this permit is to consolidate and identify existing state and federal air requirements applicable to Anheuser-Busch, LLC and to provide practical methods for determining compliance with these requirements. The following narrative is designed to accompany the draft permit and is presented in the same general order as the permit. It initially describes the facility receiving the permit, the applicable requirements and their significance, and the methods for determining compliance with those applicable requirements. This narrative is intended as an adjunct for the reviewer and to provide information only. It has no legal standing. Any revisions made to the permit in response to comments received during the public participation and EPA review process will be described in an addendum to this narrative. Printed: February 11, 2016 Page 1 of 19

2 I. Facility Description A. Facility Identification 1. Facility Name: Anheuser-Busch, LLC 2. Parent/Holding Company Name: Anheuser-Busch Companies, Inc. 3. Previous and/or Other Name(s): Anheuser-Busch Cartersville Brewery 4. Facility Location: 100 Busch Drive, Cartersville, GA Attainment, Non-attainment Area Location, or Contributing Area B. Site Determination The facility is in the Metro-Atlanta non-attainment area. The area has been designated as non-attainment for the 8-hour ozone national ambient air quality standards (NAAQS) and the fine particulate (PM 2.5 ) NAAQS. The site includes the brewhouse and a wastewater treatment plant which is located about a half mile away from the brew house, on the other side of an interstate highway. The wastewater plant is under common control with the brewery and supplies biogas for combustion in the brewery's steam boilers. It is therefore, connected by pipeline. However, since it was once operated by the City of Cartersville, which held an air quality permit for the facility, it has a separate AFS number. Both the brewery (AFS No ) and the wastewater treatment plant (AFS No ) are covered by the same Title V permit. There are no other facilities which could possibly be contiguous or adjacent and under common control. C. Existing Permits Table 1 below lists all current Title V permits, all amendments, 502(b)(10) changes, and offpermit changes, issued to the facility, based on a comparative review of form A.6, Current Permits, of the Title V application and the "Permit" file(s) on the facility found in the Air Branch office. Table 1: List of Current Permits, Amendments, and Off-Permit Changes Permit Number and/or Off- Permit Change Date of Issuance/ Effectiveness Purpose of Issuance V /24/2010 Tile V permit renewal V /9/ (b)(10) change for the use of new VOC containing flavors and storage for the flavors. Printed: February 11, 2016 Page 2 of 19

3 D. Process Description 1. SIC Codes(s): 2082 Malt Beverage Manufacturing The SIC Code(s) identified above were assigned by EPD's Air Protection Branch for purposes pursuant to the Georgia Air Quality Act and related administrative purposes only and are not intended to be used for any other purpose. Assignment of SIC Codes by EPD's Air Protection Branch for these purposes does not prohibit the facility from using these or different SIC Codes for other regulatory and non-regulatory purposes. Should the reference(s) to SIC Code(s) in any narratives or narrative addendum previously issued for the Title V permit for this facility conflict with the revised language herein, the language herein shall control; provided, however, language in previously issued narratives that does not expressly reference SIC Code(s) shall not be affected. 2. Description of Product(s) This facility is a complete beer brewery, and produces malt beverages. 3. Overall Facility Process Description This facility is a complete brewery, manufacturing beer and has overall capacity of 9.0 MMbbl/year. The malt beverage production process consists of fermentation, lagering, finishing and packaging. Raw ingredients such as barley malt, hops, and cereal grains are received, stored, conveyed and cooked. To produce products with new flavors, Anheuser- Busch Cartersville Brewery is injecting, [by VOC-Containing Flavor Application System (Emission Unit ID No. FL01)], certain new VOC-containing flavors into products at the existing Finishing Process (Emission Unit I.D. No. B003) via connecting the flavor containers to the existing flavor injection equipment. Steam for processing is provided by gas fired steam boilers. The finished products are canned or bottled on site. A wastewater treatment plant located nearby, supplies biogas for firing the process steam boilers. 4. Overall Process Flow Diagram E. Regulatory Status The facility provided a process flow diagram in their Title V permit application. 1. PSD/NSR This facility is major under PSD regulations and went through a PSD review in order to obtain their initial air quality permit. All the BACT limits from the PSD permit were incorporated in the facility s initial Title V permit and are carried over in the renewed permit. Printed: February 11, 2016 Page 3 of 19

4 The record indicates that the facility being a major source of NO x and VOC in the Atlanta Non-Attainment area, the facility is subject to NO x and VOC RACT under state rules (yy) and (tt) respectively. Anheuser Busch submitted NO x and VOC RACT plans to EPD in November 2000 and September 2000 respectively for review and approval. For VOC no additional control was proposed as the VOC RACT for the facility. On January 24, 2002 EPD informed the Permittee that no additional control was RACT for VOC. Also, for the NO x RACT, EPD made a determination that no additional add-on control equipment is needed under Rule (yy). The NO x RACT that was approved consisted of annual tune-ups for all four steam boilers at the facility. The NO x RACT also restricted the fuel use to natural gas in the steam boilers during the summer ozone season unless the facility was curtailed by the gas supplier. 2. Title V Major Source Status by Pollutant Table 2: Title V Major Source Status Pollutant PM PM 10 PM 2.5 Is the Pollutant Emitted? If emitted, what is the facility s Title V status for the pollutant? Major Source Status SO 2 VOC NO x CO Major Source Requesting SM Status Non-Major Source Status TRS H 2 S Individual HAP Total HAPs Total GHGs 3. MACT Standards This facility is not subject to any proposed or final MACT Standards. Note that since Anheuser-Busch has reclassified their all four steam boilers as gas-fired steam boilers per 40 CFR as of 12/31/2014, therefore, the facility is not subject to area sources steam boiler GACT; 40 CFR Part 63 Subpart JJJJJJ National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Steam boiler Area Sources. Printed: February 11, 2016 Page 4 of 19

5 4. Program Applicability (AIRS Program Codes) Program Code Program Code 6 - PSD Program Code 8 Part 61 NESHAP Program Code 9 - NSPS Program Code M Part 63 NESHAP Program Code V Title V Applicable (y/n) Yes No No No Yes Printed: February 11, 2016 Page 5 of 19

6 Regulatory Analysis II. Facility Wide Requirements A. Emission and Operating Caps: None applicable. B. Applicable Rules and Regulations None applicable. C. Compliance Status Review of forms of the permit application indicates that the facility does not have any Non- Compliant Emission Unit or Group. D. Operational Flexibility None applicable. E. Permit Conditions None applicable. Printed: February 11, 2016 Page 6 of 19

7 III. Regulated Equipment Requirements A. Brief Process Description Raw ingredients such as barley malt, hops, and cereal grains are received, stored, conveyed, milled and cooked. Yeast is added to the mash produced and the mixture is fermented in batches. Steam for cooking is provided by natural gas and No. 2 fuel oil fired steam boilers. The beer produced is packaged on site. To produce products with new flavors, brewery is injecting certain new VOC-containing flavors into products at the existing Finishing Process (Emission Unit I.D. No. B003) via connecting the flavor containers to the existing flavor injection equipment. The VOC compounds in the new flavors are primarily ethanol, which is emitted into the atmosphere during Packaging (Emission Unit ID No. B004). B. Equipment List for the Process ID No. SB01 Emission Units Specific Limitations/Requirements Air Pollution Control Devices Applicable Corresponding Permit Description ID No. Description Requirements/Standards Conditions Steam Boiler No. 1 (99 MMBtu/hr) 40 CFR 52.21, (2)(d), (2)(g), (2)(tt), (2)(yy) 3.3.1, 3.3.2, 3.3.3, 3.4.1, 3.4.2, 5.2.1, 5.2.2, 6.1.7, 6.2.1, 6.2.2, 6.2.3, None SB02 Steam Boiler No. 2 (99 MMBtu/hr) 40 CFR 52.21, (2)(d), (2)(g), (2)(tt), (2)(yy) 3.3.1, 3.3.2, 3.3.3, 3.4.1, 3.4.2, 5.2.1, 5.2.2, 6.1.7, 6.2.1, 6.2.2, 6.2.3, None SB03 Steam Boiler No. 3 (99 MMBtu/hr) 40 CFR 52.21, (2)(d), (2)(g), (2)(tt), (2)(yy) 3.3.1, 3.3.2, 3.3.3, 3.4.1, 3.4.2, 5.2.1, 5.2.2, 6.1.7, 6.2.1, 6.2.2, 6.2.3, None SB04 Steam Boiler No. 4 (99 MMBtu/hr) 40 CFR 52.21, (2)(d), (2)(g), (2)(tt), (2)(yy) 3.3.1, 3.3.2, 3.3.3, 3.4.1, 3.4.2, 5.2.1, 5.2.2, 6.1.7, 6.2.1, 6.2.2, 6.2.3, None B001 Fermentation (2)(b), (2)(tt) None B002 Lagering (Aging) (2)(b), (2)(tt) None B003 Finishing (2)(b), (2)(tt) None FL01 VOC-Containing Flavor Application System (2)(b), (2)(tt) 3.2.1, 6.2.4, 6.2.5, 6.2.6, None Printed: February 11, 2016 Page 7 of 19

8 ID No. B004 Emission Units Specific Limitations/Requirements Air Pollution Control Devices Applicable Corresponding Permit Description ID No. Description Requirements/Standards Conditions Packaging (2)(b), (2)(tt) None BERS SY01 Brewery wastewater pretreatment system Spent yeast handling (2)(b) (2)(b), (2)(tt) FL01, FL02, I None Flare No. 1 Flare No. 2 Bio filter No. 1 * Generally applicable requirements contained in this permit may also apply to emission units listed above. The lists of applicable requirements/standards and corresponding permit conditions are intended as a compliance tool and may not be definitive. C. Equipment & Rule Applicability The brewery is subject to Georgia Rule (tt), however the permit does not have any specific VOC RACT condition since the VOC RACT analysis submitted by the Permittee in September 2000 concluded that VOC control technologies are neither technically feasible nor cost effective. EPD agreed with those conclusions and communicated the same in a letter dated January 24, The four steam boilers are subject to NO x and VOC RACT requirements under Rule (yy) and (tt). Emission and Operating Caps: As indicated in the narrative for initial Title V Permit No V-01-0, Emissions from all the four steam boilers are limited for particulate matter, nitrogen oxides and opacity. Particulate matter emissions are limited to 0.10 lbs/mmbtu heat input and nitrogen oxide emissions are limited to 0.30 lbs/mmbtu heat input when firing natural gas and 0.40 lbs/mmbtu heat input when firing fuel oil. The opacity of emissions are restricted to 20 percent. Each of these restrictions is the result of a Best Available Control Technology (BACT) analysis, which was required for this facility since it is subject to PSD regulations. A limit of 0.70 percent sulfur in the fuel oil burned is also required due to BACT. As indicated in the narrative for Title V Permit Amendment No V-03-1, Permittee requested an annual emission cap of 34.0 tons for the VOC emissions (primarily ethanol) from this modification, i.e., VOC- Containing Flavor Application System FL01. This emission cap is equal to the potential VOC emissions from FL01. This process/source specific emission cap represents a reasonably available control technology (RACT) limit for VOC emission from FL01 under Georgia Rule (tt) and establishes the facility-wide ethanol emission level used in an ambient impact assessment conducted for this modification. The assessment/dispersion modeling demonstrates that after this modification the facility/brewery will be in compliance with EPD s policy regarding emissions of toxic air pollutants under Rule (2)(a)3(ii). Printed: February 11, 2016 Page 8 of 19

9 Rules and Regulations Assessment: As indicated in the narrative for initial Title V Permit No V-01-0, 40 CFR 52.21, the federal "Prevention of Significant Deterioration" regulations applied to the initial construction of this facility. The brewery has four steam boilers each rated at 99 million Btu per hour heat input, totaling 396 million Btu per hour. Facilities which have fossil fuel fired steam boilers totaling more than 250 million Btu per hour are major sources, by definition, under PSD regulations if they potentially emit more than 100 tons per year of a regulated pollutant. Once PSD regulations are triggered by any pollutant, other pollutants are considered to be emitted in significant quantities, if they are emitted above certain specified levels. The Best Available Control Technology (BACT) must be employed for each pollutant emitted in significant quantities. This usually includes the imposition of an emission limit in the permit for that pollutant. The original PSD permit issued to Anheuser-Busch included nitrogen oxide, particulate matter and opacity limits on the steam boiler emissions as well as the fuel oil sulfur limit. As indicated in the narrative for initial Title V Permit No V-02-0, The facility is now subject to the NOx and VOC RACT requirements under State Rules (yy) and (tt) respectively since it is located in a contributing area. The facility is located in an area that is designated as non-attainment for 8- hour ozone NAAQS and fine particulate PM 2.5 NAAQS. VOC RACT rules do not result in any new requirements or add on controls on the sources at the Cartersville brewery. The NOx RACT requirements consist of annual steam boiler tune- ups and the requirement to burn only natural gas in all the four steam boilers during the summer ozone months unless the gas supply to the steam boiler(s) is curtailed by the gas supplier. VOC RACT rules impose no new conditions on the steam boilers or the brewery sources at the facility (2)(tt) VOC Emissions from Major Sources As indicated in the narrative for Title V Permit Amendment No V-03-1, this rule requires reasonably available control technology (RACT) to control VOC emissions from any facility located in Bartow County that has potential VOC emissions greater than 100 tpy. In 2002 the Division made a determination on a RACT analysis conducted by the Permittee in 2000 that no add-on control was RACT for the VOC emissions from the existing facility/brewery under Rule (tt). The Permittee submitted a RACT analysis for the VOC emissions from FL01 with the application for the modification. The results of the RACT analysis indicated that implementations of add-on control for the VOC emissions from FL01 were not economically cost effective. The Division concurs with the conclusion of this RACT analysis. Therefore, no add-on control is considered as RACT for VOC emissions from FL (2)(yy) Emissions of Nitrogen Oxides from Major Sources This rule applies to sources in Bartow County (part of the 20-county ozone nonattainment area around Atlanta) with the potential to emit greater than 100 tpy NOx. NOx RACT plans were submitted to EPD in September 2000 for review and approval. The NOx RACT that was approved consists of annual tune-ups for all four (4) steam boilers at the facility, and restricts fuel use to natural gas in the steam boilers during the summer ozone season unless the facility is curtailed by the gas supplier. Printed: February 11, 2016 Page 9 of 19

10 (2)(d) Fuel Burning Equipment This rule limits particulate matter and opacity emissions from certain fuel-burning equipment. This rule is applicable to the four (4) steam boilers and the 18 building heaters. Particulate matter emissions for fuel burning equipment greater than 10 MMBtu/hr and less than 250 MMBtu/hr are limited by the equations specified in the rule. Particulate matter emissions for fuel burning equipment less than 10 MMBtu/hr are limited to 0.5 lb/mmbtu. The 18 building heaters have a maximum heat input of less than 1.0 MMBtu/hr each, therefore PM emissions are limited to 0.5 lb/mmbtu. The combustion of natural gas in these units ensures compliance with this rule. Opacity emissions are limited to 20%, with one 6-minute period of not more than 27%. The combustion of only natural gas, biogas, and No. 2 fuel oil ensures compliance with this rule. As indicated in the narrative for initial Title V Permit No V-01-0, Georgia Rule d), parts 2 and 3 apply to the steam boilers located at this facility. Part 1 of this Rule doesn't apply since this entire facility was constructed after January 1, Georgia Rule (d)2.(ii) limits particulate matter emissions from all four steam boilers at this facility according to the equation specified in this rule for steam boilers whose heat input is between 10 and 250 million Btu per hour. Based upon heat inputs of 99 MMBTU per hour, each of Anheuser-Busch's steam boilers would have a particulate matter limit of lbs per million Btu. However, a more restrictive limit of 0.10 lbs per million Btu required by condition 3.3.1a, due to the BACT requirements of PSD. Part 3 of Rule (d) includes a 20 percent opacity limit which applies to all fuel burning sources constructed after January 1, 1972, regardless of size. Part 4 of Rule (d) does not apply since all of the fuel burning equipment at this facility has heat inputs of less than 250 million Btu per hour (2)(g) Sulfur Dioxide This regulation limits the sulfur content of the fuels used in combustion to 2.5%. As indicated in the narrative for initial Title V Permit No V-01-0, Georgia Rule (g) Sulfur Dioxide applies to all fuel burning sources capable of burning fossil fuel. However, part 1 of the Rule is inapplicable since there are no fuel burning sources at this facility with heat inputs of greater than 250 million BTUS per hour. All four steam boilers at this facility are limited to burning fuel containing no more than 3 percent sulfur, by weight, although condition limits fuel oil sulfur content to only 0.70 percent. This is also due to BACT requirements. With regard to the 99 MMBtu/hr steam boilers, this regulation is subsumed by Permit Condition No , which limits the fuel fired in the four (4) steam boilers to natural gas, biogas, or No. 2 fuel oil (0.5% sulfur content). With regard to the building heaters, the combustion of natural gas ensures compliance with this rule. Note that Condition No is revised based on the comments received from the Mountain District Office-Cartersville. The comments regarding burning of No. 2 fuel oil are as under: Printed: February 11, 2016 Page 10 of 19

11 3.3.2 and others: This facility, like almost all facilities now, fires diesel fuel oil grade 2-D S15 (a.k.a. ultra-low sulfur diesel, not No. 2 fuel oil. diesel fuel oil grade 2-D S15 meets ASTM D975. No. 2 fuel oil meets ASTM 396. Please address this fuel in this permit and all future permits. In view of above Condition No is revised to address this issue and few other places this reference was added (2)(e) Particulate Emissions from Manufacturing Processes This regulation is applicable to emission units that have the potential to generate PM, except in cases where another rule or regulation might make a more stringent requirement. All process equipment other than the four (4) steam boilers and the building heaters are subject to this rule as these units are not subject to a more restrictive PM emissions limit. As indicated by the facility, these processes are in compliance with this rule (2)(b) Visible Emissions This rule limits opacity from emission points and structures to 40%, except in cases where another rule or regulation might make a more stringent requirement. All process equipment, other than the four (4) steam boilers which are subject to 20% opacity per Georgia Rule (d), are subject to this rule as these units are not subject to a more restrictive opacity limit. As indicated by the facility, all processes with the potential to emit particulate matter are in compliance with this rule. D. Compliance Status Review of application indicates that no noncompliance issue exists, therefore, no compliance plan noted on form F.2 of the permit application. E. Operational Flexibility None applicable. F. Permit Conditions Condition 3.2.1, which had been added by Permit Amendment No V-03-1, establishes the RACT emission limit under Rule (tt) for the VOC emissions from FL01. As indicated in the narrative for this amendment the emission cap in Condition also ensures that the ambient impact of the toxic air pollutants (presuming ethanol) emitted from the whole brewery after the start-up of FL01 be acceptable, as determined using the Division s Guideline for Ambient Impact Assessment of Toxic Air Pollutants developed per Georgia Rule (2)(a)3(ii). Thus Condition No is the same as in existing Condition Condition No limits particulate matter emissions to 0.10 lbs/mmbtu heat input, nitrogen oxide emissions to 0. lbs/mmbtu heat input when firing natural gas, 0.40 lbs/mmbtu heat input when firing oil and opacity emissions to 20 percent. These same limitations are contained in Printed: February 11, 2016 Page 11 of 19

12 existing permit, which were required by the PSD regulations, and were carried over without change into the existing renewal permit. This condition is the same as existing permit condition Condition No requires the Permittee to fire only gaseous fuel and No. 2 fuel oil (and/or ultra-low sulfur diesel oil) in all steam boilers. This condition is similar to the existing permit condition New Condition No requires the Permittee to fire only gaseous fuel and fuel oil in gas curtailment period. This is a new condition included in this Title V Renewal for the avoiding the applicability of Subpart JJJJJJ, as the facility has reclassified all steam boilers as gas fired steam boilers. Condition No requires the Permittee not to fire No. 2 fuel oil in all steam boilers during ozone season from May 1 to September 30 each year, per GA Rule (yy) and (rrr)5. This condition is the same as existing permit condition Condition No limits the opacity of emissions from steam boilers to twenty (20) percent. This condition is the same as existing permit condition Condition No limits the opacity of emissions from brewery sources to forty (40) percent. This condition is the same as existing permit condition Condition No requires routine maintenance on all air pollution control devices and is the same as existing permit condition Condition No requires spare bags for baghouses to be kept on hand and is the same as existing permit condition Printed: February 11, 2016 Page 12 of 19

13 IV. Testing Requirements (with Associated Record Keeping and Reporting) A. General Testing Requirements The permit includes a requirement that the Permittee conduct performance testing on any specified emission unit when directed by the Division. Additionally, a written notification of any performance test(s) is required 30 days (or sixty (60) days for tests required by 40 CFR Part 63) prior to the date of the test(s) and a test plan is required to be submitted with the test notification. Test methods and procedures for determining compliance with applicable emission limitations are listed and test results are required to be submitted to the Division within 60 days of completion of the testing. New Condition No is a Title V permit updated template condition, which is applicable to all facilities for submitting test data to US EPA. B. Specific Testing Requirements 1. Individual Equipment None applicable. 2. Equipment Groups (all subject to the same test requirements): None of the applicable regulations require specific performance testing; therefore testing was not required for any of the emissions units. However, the permit does contain a condition that the Division can require that a performance test be conducted to determine compliance with the emissions limits contained in Part 3.0 of the permit. Test methods for determining emissions are listed in Condition These conditions are same as in the existing permit. Printed: February 11, 2016 Page 13 of 19

14 V. Monitoring Requirements A. General Monitoring Requirements Condition requires that all continuous monitoring systems required by the Division be operated continuously except during monitoring system breakdowns and repairs. Monitoring system response during quality assurance activities is required to be measured and recorded. Maintenance or repair is required to be conducted in an expeditious manner. B. Specific Monitoring Requirements Most of the monitoring requirements specified in this renewal Permit No V-04-0, which are discussed either in the narrative for the initial Title V permit No V- 01-0, or in the narrative for the renewal Title V permits No V-02-0 and No V-03-0, are discussed below. Narrative for the initial Title V Permit No V-01-0 has provided the following discussions: The Steam boilers (Emission Units B001, B002, B003, and B004) burn natural gas as the primary fuel, with fuel oil (a blend of no. 2 & no. 6 fuel oil) as the backup fuel. [Note: Correct naming of steam boilers is SB01, SB02, SB03, and SB04]. The steam boilers are subject to Georgia Rule for Air Quality Control (2)(d) for opacity (visible emissions), Georgia Rule (2)(d) for particulate matter (PM) emissions and Rule (2)(g) for sulfur dioxide emissions. However, because of the Prevention of Significant Deterioration (PSD) regulations, emissions of particulate matter and sulfur dioxide are more strictly limited by this permit than would be required by the Georgia Air Quality Rules. Nitrogen oxide emissions are also limited by the permit due to PSD regulations. Low levels of excess air will result in nitrogen oxides emissions that are less than the permitted limitations; therefore an oxygen monitor is required to be installed on each steam boiler to measure flue gas oxygen concentration. Trigger levels of flue gas oxygen concentrations are specified to assure that the steam boilers are consistently operated with low excess air. Periodic checks of oxygen concentrations are required and any readings greater than the trigger levels are required to be reported. The steam boilers do not have pollution control equipment for particulate matter. Particulate matter emissions and opacity will be well below applicable limits when the steam boilers are fired with natural gas and for this reason, no monitoring is required. However, when fuel oil is burned, a minimum level of flue gas oxygen (3%) as measured by the oxygen monitors is used as a trigger to assure compliance with PM and opacity limitations. Periodic checks of oxygen concentrations are required and any readings less than the trigger level are required to be reported. The sulfur content of the fuel oil is limited to 0.70 percent sulfur by weight and fuel sulfur content is to be monitored through sampling and analysis. A sample of the fuel oil is required to Printed: February 11, 2016 Page 14 of 19

15 be taken each time a shipment of oil is transferred to the storage tank. The sample is required to be taken using the appropriate American Society for Testing and Materials (ASTM) sampling method and the ASTM Test Method for analyzing the sulfur content is specified. Condition No requires monitoring of the oxygen concentration in the exhaust gas and recording them every four hours during each day of operation of the steam boilers. This is same as existing permit Condition Condition No requires the Permittee to perform annual tune-ups of the four steam boilers (SB01-SB04) at this facility while burning No. 2 fuel oil, natural gas or biogas so as to be consistent with the terms of approval of NOx RACT plan for the steam boilers. Note that Part c of this condition had required the use of a conditional test method for determining NO x and oxygen concentrations. EPA has recommended the use of ASTM Method D-6522 and this condition was changed to require this method via Permit Amendment No V A search of EPA s website for CTM-30 will lead to a referral to Method D This condition also specifies that the oxygen levels limits in the steam boiler exhaust do not apply during the steam boiler tune-ups. Supplier s report of fuel sulfur content for each shipment of No. 2 fuel oil to the facility is adequate to ensure compliance with the fuel sulfur content limit (Condition 3.3.2). Note that the requirement to report the fuel sulfur content was moved to Section 6.2 (Condition ) in the previous renewal permit. This is same as existing permit Condition C. Compliance Assurance Monitoring (CAM) Federal Rule 40 CFR 64 Compliance Assurance Monitoring Applicability: 40 CFR 64, Compliance Assurance Monitoring (CAM) is applicable to an emissions unit at a major source required to obtain a Title V operating permit that is subject to an emissions standard, and uses an emission control device to achieve compliance with the standard. Specifically, for a source undergoing a Title V Renewal Process, the emission unit must have potential pre-control device emissions of the applicable regulated air pollutant equal to, or greater than, 100% of the amount required for a source to be classified as major. Narrative for Permit No V-02-0 had concluded that 40 CFR 64 (CAM) is not applicable to sources at the facility, since no control devices are used to control emissions from the steam boilers or other emission units at the facility. Hence CAM is not applicable to the emission units as per 40 CFR 64.2(a)(2). This conclusion remains valid because no modifications which could trigger the applicability of CAM requirements have been made to the facility since the issuance of the initial Title V permit. Printed: February 11, 2016 Page 15 of 19

16 VI. Record Keeping and Reporting Requirements A. General Record Keeping and Reporting Requirements The Permit contains general requirements for the maintenance of all records for a period of five years following the date of entry and requires the prompt reporting of all information related to deviations from the applicable requirements. Records, including identification of any excess emissions, exceedances, or excursions from the applicable monitoring triggers, the cause of such occurrence, and the corrective action taken, are required to be kept by the Permittee and reporting is required on a semiannual basis. Conditions No to are template conditions. Conditions and were updated in September 2011 to allow ~60 days to submit periodic reports. Alternative reporting deadlines are allowed per 40 CFR 70.6, 40 CFR 60.19(f) and 40 CFR 63.10(a). Condition defines all excess emission, exceedance and excursions to be reported as per Condition in the renewal permit. Firing of fuel oil that does not meet specifications of ASTM No. 2 in any steam boiler at the facility and the firing of No. 2 fuel in any steam boiler during the summer ozone season is reported as an exceedance in Condition b. Note that Condition b(ii) in Permit No V-02-0 were amended by issuance of Permit Amendment No V-02-1 for adding language that clarifies burning of fuel oil in the steam boilers at the facility during the summer ozone season is considered an exceedance only if there is no interruption in natural gas supply to the steam boilers. The same permit amendment also revised Condition 6.1.7c(i) and (ii) by defining a valid operating hour as a clock hour in which the steam boiler operates for at least 30 minutes and contains at least two data points of oxygen concentration with each point representing a 15 minute period. Rolling three hour average oxygen values for the steam boiler exhaust gas outside the indicated ranges for steam boilers while firing fuel oil and natural gas or biogas is reported as excursions in Condition c. Condition to establish a standard reporting requirement for major NO x and/or VOC emission sources located inside the Atlanta ozone non-attainment area. Condition of the existing amendment permit, which was added to establish a reporting requirement for exceedance of the annual VOC emission limit in Condition by Title V Permit Amendment No V-03-1, is incorporated in Condition No as 6.1.7b.iii, and hence this Condition is deleted. B. Specific Record Keeping and Reporting Requirements Record Keeping and Reporting Requirements specified in this permit renewal, which are discussed either in the narrative for the initial Title V Permit No V-01-0, or in the narrative for the renewal Title V Permit No V-02-0 and No V-02-0, are discuss below. Printed: February 11, 2016 Page 16 of 19

17 Conditions and require Permittee to maintain fuel oil receipts provided by the fuel supplier. Condition requires submission of a semi-annual report for the fuel oil fired in the steam boilers. The supplier sulfur content reports are required to be certified by the responsible official for the facility. This condition records all periods during which No. 2 fuel is fired in any steam boiler during the summer ozone season. These are the same conditions as existing permit conditions 6.2.1, and Conditions No through require the Permittee to keep record of product formulations used in flavoring; determine total monthly VOC emissions from the flavoring emission source FL01. These conditions have been carried over from Title V Permit Amendment No V These conditions were added to establish the record keeping, emission calculation/compliance determination and reporting requirements deemed necessary to make the 34.0 tpy VOC emission limit in Condition practically enforceable. These conditions are same as existing permit amendment Conditions 6.2.4, and Note that the existing Condition 6.2 7, which had been added to require the Permittee to notify the Division in writing of the startup of FL01, is not carried over in this renewal permit as it is no longer required, and conditions renumbered. New Condition requires the Permittee to keep records of all instances as and when fuel oil is fired in steam boilers. Printed: February 11, 2016 Page 17 of 19

18 VII. Specific Requirements A. Operational Flexibility The applicant did not include any alternative operating scenarios in their Title V Renewal Application. The facility s existing Title V Permit does not have any operational flexibility conditions and no new operational flexibility conditions are included in this Title V Renewal Permit. B. Alternative Requirements The facility has not requested any new alternative requirements under Rule (10)(d)8 to combine multiple overlapping of state and federal requirements. This permit does not contain any alternative requirement conditions. C. Insignificant Activities Refer to for the Online Title V Application. Refer to the following forms in the Title V permit application: Form D.1 (Insignificant Activities Checklist) Form D.2 (Generic Emissions Groups) Form D.3 (Generic Fuel Burning Equipment) Form D.6 (Insignificant Activities Based on Emission Levels of the Title V permit application) D. Temporary Sources None applicable. E. Short-Term Activities None applicable. F. Compliance Schedule/Progress Reports None applicable. G. Emissions Trading None applicable. H. Acid Rain Requirements None applicable. Printed: February 11, 2016 Page 18 of 19

19 I. Stratospheric Ozone Protection Requirements The facility has indicated that they are subject to Title VI. This facility has air conditioners or refrigeration equipment that uses CFC s, HFC s or other stratospheric ozone depleting substances as listed in 40 CFR Part 82, Subpart A, Appendices A and B. Therefore, the facility is subject to 40 CFR Part 82, Subpart A- Production and Consumption Control, Appendix A and B. The Title V permit application further indicates that the facility do have air conditioner or any piece of refrigeration equipment that contain refrigerant charge of greater than 50 lbs.; but the facility personnel do not maintain, service, repair or dispose of any motor vehicle air conditioners (MVAC s) or appliances. Therefore, the facility is not subject to 40 CFR 82, Subpart B- Servicing of Motor Vehicle Air Conditioners. J. Pollution Prevention None applicable. K. Specific Conditions None applicable. VIII. General Provisions Generic provisions have been included in this permit to address the requirements in 40 CFR Part 70 that apply to all Title V sources, and the requirements in Chapter of the Georgia Rules for Air Quality Control that apply to all stationary sources of air pollution. Template Condition was updated in September 2011 to change the default submittal deadline for Annual Compliance Certifications to February 28. Template Condition Section 8.27 was updated in August 2014 to include more detailed, clear requirements for emergency generator engines currently exempt from SIP permitting and considered insignificant sources in the Title V permit. Template Condition Section 8.28 was updated in August 2014 to more clearly define the applicability of the steam boiler MACT or GACT for major or minor sources of HAP. Printed: February 11, 2016 Page 19 of 19

20 Title V Application Review Addendum to Narrative The Division issued draft Title V Permit No V-04-0 for Anheuser-Busch Cartersville Brewery, located in Cartersville (Bartow County), Georgia on November 20, A public notice was placed in the The Daily Tribune News on December 10, The 30-day public review started on December 10, 2015 and ended on January 11, Comments were received by the Division from the facility by ; hard copy was received by mail on Jan 20, The comments are summarized below, followed by a discussion of the comments and any changes made to the permit as a result. Comment 1: Condition The Title V permit draft issued on November 20, 2015 exempts the facility from burning fuel oil except during periods of gas curtailment, gas supply emergencies or periods of testing on fuel oil. The facility would like to have the option to burn fuel oil in the future if it so chooses and be subject to the requirements of 40 CFR 63 Subpart JJJJJJ. We request the following modifications to this permit condition: Division Response: The Permittee shall only fire natural gas, biogas and fuel oil in the steam boilers (Emission Unit ID Nos: SB01, SB02, SB03 and SB04). In particular, fuel oil shall only be burned during periods of gas curtailment, gas supply emergencies, or periods of testing on fuel oil such that the boilers are not subject to the provisions of 40 CFR 63 Subpart JJJJJJ. Testing on fuel oil shall not exceed 48 hours per calendar year for each boiler. Should the facility choose to burn fuel oil such that a boiler no longer meets the definition of a gas-fired boiler that is not subject to 40 CFR 63 Subpart JJJJJJ, this condition no longer applies to that boiler and the Permittee shall comply with Conditions through of this permit as applicable. [Avoidance of 40 CFR 63 Subpart JJJJJJ] The Division agrees with the comment from the facility, and condition is revised as under The Permittee shall only fire natural gas, biogas and fuel oil in the steam boilers (Emission Unit ID Nos: SB01, SB02, SB03 and SB04). In particular, fuel oil shall only be burned during periods of gas curtailment, gas supply emergencies, or periods of testing on fuel oil such that the boilers are not subject to the provisions of 40 CFR 63 Subpart JJJJJJ. Testing on fuel oil shall not exceed 48 hours per calendar year for each boiler. Should the facility choose to burn fuel oil such that a boiler no longer meets the definition of a gas-fired boiler that is not subject to 40 CFR 63 Subpart JJJJJJ, this Printed: February 11, 2016 Addendum Page 1 of 6

21 Title V Application Review Comment 2: condition no longer applies to that boiler and the Permittee shall comply with Conditions through of this permit as applicable. [Avoidance of 40 CFR 63 Subpart JJJJJJ] The facility requested to have flexibility in using the fuel oil should the facility choose to burn fuel oil such that a boiler no longer meets the definition of a gas-fired boiler that is not subject to 40 CFR 63 Subpart JJJJJJ. The facility requested few conditions to be added to the permit, as listed in their comment letter. Division Response: The Division agrees with the comment from the facility and is allowing the facility to choose to burn fuel oil and then comply with 40 CFR 63 Subpart JJJJJJ. The following conditions have been included in the permit in Condition 7.3: Alternate Requirements of the permit. These conditions describes the requirements the facility has to follow should the facility choose to burn fuel oil such that a boiler no longer meets the definition of a gas-fired boiler; in such a case the facility is subject to 40 CFR 63 Subpart JJJJJJ Alternative Requirements 40 CFR 63 Subpart JJJJJJ If the Permittee elects to burn fuel oil in steam boilers (Emission Unit ID Nos: SB01, SB02, SB03 and SB04) such that a boiler is not exempt from 40 CFR 63 Subpart JJJJJJ, the Permittee shall comply with all applicable provisions of the National Emission Standards for Hazardous Air Pollutants (NESHAP) as found in 40 CFR 63, in Subpart A General Provisions, and Subpart JJJJJJ National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources for the operation of the boiler and shall comply with the provisions of Conditions through [40 CFR ] For 40 CFR 63 Subpart JJJJJJ, if the Permittee switches fuels or makes a physical change to a boiler and the fuel switch or change results in the applicability of a different subcategory within the subpart, in the boiler becoming subject to the subpart, or in the boiler switching out of the subpart due to a change to 100 percent natural gas, or the Permittee has taken a permit limit that resulted in a boiler subject to the subpart, the Permittee must provide notice of the date upon which the fuel switch occurred, the physical change was made, or a permit limit was taken within 30 days of the change. The notification must identify: [40 CFR (g)] a. The name of the owner or operator of the affected source, the location of the source, the boiler(s) that have switched fuels, were physically changed, or took a permit limit, and the date of the notice. b. The date upon which the fuel switch, physical change, or permit limit occurred. Printed: February 11, 2016 Addendum Page 2 of 6

22 Title V Application Review Within 180 days of the change described in Condition 7.3.2, the Permittee shall complete an energy assessment for the applicable boiler(s) as specified in Table 2 of 40 CFR 63 Subpart JJJJJJ. [40 CFR (b) and 40 CFR (h)] Within 180 days of the change described in Condition 7.3.2, the Permittee shall perform initial tune-up(s) for the applicable boiler(s) as defined in 40 CFR The Permittee shall conduct subsequent tune-ups on each applicable boiler biennially. Each biennial tune-up shall be conducted no more than 25 months after the previous tune-up. The tune-ups must be conducted while burning the type of fuel that provided the majority of the heat input to the boiler over the 12 months prior to the tune-up. All tuneups will be conducted using the following procedures: [40 CFR (b) and 40 CFR (h)] a. As applicable, inspect the burner, and clean or replace any components of the burner as necessary (the Permittee may delay the burner inspection until the next scheduled unit shutdown, not to exceed 36 months from the previous inspection). b. Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available. c. Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly (the Permittee may delay the inspection until the next scheduled unit shutdown, not to exceed 36 months from the previous inspection). d. Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any NO X requirement to which the unit is subject. e. Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer. f. Maintain on-site and submit, if requested by the Division, a report containing the following: i. The concentrations of CO in the effluent stream in parts per million, by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler. ii. A description of any corrective actions taken as a part of the tune-up of the boiler. Printed: February 11, 2016 Addendum Page 3 of 6

23 Title V Application Review iii. The type and amount of fuel used over the 12 months prior to the tune-up of the boiler, but only if the boiler was physically and legally capable of using more than one type of fuel during that period. Boilers sharing a fuel meter may estimate the fuel use by each boiler. g. If the boiler is not operating on the required date for a tune-up, the tune-up must be conducted within 30 days of startup Within 120 days of the change specified in Condition 7.3.2, the Permittee shall submit an Initial Notification for 40 CFR 63 Subpart JJJJJJ for the applicable boiler(s). [40 CFR (a)(2)] Within 120 days of the change specified in Condition 9.2, the Permittee shall submit the Notification of Compliance Status under 40 CFR 63 Subpart JJJJJJ for the applicable boiler(s). The Notification of Compliance Status shall be submitted according to 40 CFR (a)(4)(i) through (vi), as applicable, and shall be signed by a responsible official. [40 CFR (a)(4)] If the Permittee becomes subject to the provisions of Conditions through 7.3.9, the Permittee must prepare, by March 1 of each year, and submit to the Division, an annual compliance certification report for the previous calendar year containing the information specified below for each applicable boiler as subject to 40 CFR 63 Subpart JJJJJJ. The Permittee must submit the report by March 15 if the facility had any deviations. For units that are subject only to a requirement to conduct a biennial tune-up according to 40 CFR (a) and not subject to emission limits or operating limits, the Permittee may prepare only a biennial compliance report. [40 CFR (b)] a. Company name and address. b. Statement by a responsible official, with the official's name, title, phone number, address, and signature, certifying the truth, accuracy and completeness of the notification and a statement of whether the source has complied with all the relevant standards and other requirements of this subpart. This notification must include the following certification(s) of compliance and signed by a responsible official: i. This facility complies with the requirements in 40 CFR to conduct a biennial or 5-year tune-up, as applicable, of each boiler. ii. For units that do not qualify for a statutory exemption as provided in section 129(g)(1) of the Clean Air Act: No secondary materials that are solid waste were combusted in any affected unit. c. If the source experiences any deviations from the applicable requirements during the reporting period, include a description of deviations, the time periods during which the deviations occurred, and the corrective actions taken. Printed: February 11, 2016 Addendum Page 4 of 6