Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
A6220
RENEWABLE OPERATING PERMIT
STAFF REPORT
ROP Number
MI-ROP-A6220-2015
INTERTAPE POLYMER GROUP
SRN: A6220
Located at
317 Kendall Avenue, Marysville, St. Clair, Michigan 48040
Permit Number:
MI-ROP-A6220-2015
Staff Report Date:
October 20, 2014
This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution
Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act
451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality (MDEQ),
Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions
of the Renewable Operating Permit (ROP).
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TABLE OF CONTENTS
October 20, 2014 STAFF REPORT
3
November 21, 2014 STAFF REPORT ADDENDUM
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10
Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
A6220
ROP Number
RENEWABLE OPERATING PERMIT
October 20, 2014 STAFF REPORT
MI-ROP-A6220-2015
Purpose
Major stationary sources of air pollutants, and some non-major sources, are required to obtain and
operate in compliance with a ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s
Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to
the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a
stationary source’s applicable requirements and compliance with them by consolidating all state and
federal air quality requirements into one document.
This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the
draft permit terms and conditions including citations of the underlying applicable requirements, an
explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any
determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the
stationary source.
General Information
Stationary Source Mailing Address:
Intertape Polymer Group
317 Kendall Avenue
Marysville, Michigan 48040
A6220
322221
Source Registration Number (SRN):
North American Industry Classification System
(NAICS) Code:
Number of Stationary Source Sections:
Is Application for a Renewal or Initial Issuance?
Application Number:
Responsible Official:
AQD Contact:
Date Permit Application Received:
Date Application Was Administratively Complete:
Is Application Shield In Effect?
Date Public Comment Begins:
Deadline for Public Comment:
1
Renewal
201400019
Eric Woolums
Operations Manager
810-941-9000
Sebastian G. Kallumkal
Senior Environmental Engineer
586-753-3738
February 3, 2014
February 7, 2014
Yes
October 20, 2014
November 19, 2014
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Source Description
Intertape Polymer Group (IPG) is located at 317 Kendall Avenue, Marysville, Michigan. The facility
produces pressure sensitive adhesive tape products. In general, the production of tape involves
preparation and application of an adhesive coating and a release coating to the paper or film backing of
the tape, and drying/curing the tape. The adhesive manufacturing steps are batch operations while the
coating application and drying operations are continuous. The facility consists of three primary web
coating lines controlled by a vapor-phase carbon adsorption solvent recovery system and a regenerative
thermal oxidizer; a pilot web coating line and R&D webcoating line controlled by the regenerative thermal
oxidizer; a dry stock mixing area controlled by two fabric filter collectors; a research and development
spray booth; cold cleaners; and affiliated process operations including dissolution of the adhesive
drystock (wet mix), whipping of adhesive, and storage (tote tanks) and delivery of adhesive to coaters
(whip room).
The following table lists stationary source emission information as reported to the Michigan Air Emissions
Reporting System in the 2013 submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant
Carbon Monoxide (CO)
Lead (Pb)
Nitrogen Oxides (NOx)
Particulate Matter (PM)
Sulfur Dioxide (SO2)
Volatile Organic Compounds (VOCs)
Individual Hazardous Air Pollutants (HAPs) **
Total Hazardous Air Pollutants (HAPs)
**As listed pursuant to Section 112(b) of the federal Clean Air Act.
Tons per Year
3.05
NA
3.63
0.45
0.04
407.70
NA
No Hazardous Air Pollutant (HAP) emissions were included in the Intertape Polymer Group 2013
MAERS emission inventory report (and none were required by the Air Quality Division to be reported).
Emission rate for Pb was not reported in the 2013 submittal.
In addition to the pollutants listed above that have been reported in MAERS, the potential to emit of
Greenhouse Gases in tons per year of CO2e is less than 100,000. CO2e is a calculation of the
combined global warming potentials of six Greenhouse Gases (carbon dioxide, methane, nitrous oxide,
hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride).
See Parts C and D in the draft ROP for summary tables of all processes at the stationary source that are
subject to process-specific emission limits or standards.
Regulatory Analysis
The following is a general description and history of the source. Any determinations of regulatory nonapplicability for this source are explained below in the Non-Applicable Requirement part of the Staff
Report and identified in Part E of the ROP.
The stationary source is located in St. Clair County, which is currently designated by the U.S.
Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants.
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The stationary source is subject to Title 40 of the Code of Federal Regulations (CFR), Part 70, because
the potential to emit Volatile Organic Compounds (VOC) exceeds 100 tons per year and the potential to
emit of any single HAP regulated by the federal Clean Air Act, Section 112, is equal to or more than 10
tons per year and/or the potential to emit of all HAPs combined is more than 25 tons per year.
No emissions units at the stationary source are currently subject to the Prevention of Significant
Deterioration (PSD) regulations of Part 18, Prevention of Significant Deterioration of Air Quality of Act
451 or 40 CFR, Part 52.21 because the process equipment was constructed/installed prior to June 19,
1978, the promulgation date of the PSD regulations. However, the stationary source is currently subject
to PSD regulations and any modifications of the process equipment at this stationary source will be
subject to the PSD requirements.
At this time, there are no GHG applicable requirements to include in the ROP. The mandatory
Greenhouse Gas Reporting Rule under 40 CFR Part 98 is not an ROP applicable requirement and is not
included in the ROP
EUCOATINGLINE1, EUCOATINGLINE3, EUCOATINGLINE4, EUPILOTLINE, and EUWETMIX&WHIPOP at the stationary source are not subject to the New Source Performance Standards (NSPS) for
Pressure Sensitive Tape and Label Surface Coating Operations promulgated in Title 40 of the Code of
Federal Regulations, Part 60, Subparts A and RR.
EUCOATINGLINE1, EUCOATINGLINE3, EUCOATINGLINE4, EUPILOTLINE, and EUWETMIX&WHIPOPERATIONS at the stationary source are subject to the Maximum Achievable Control Technology
Standards for Paper and other Web Coating (POWC) promulgated in Title 40 of the Code of Federal
Regulations (CFR), Part 63, Subparts A and JJJJ.
EUWETMIX&WHIP-OP is not subject to 40 CFR 63, Subpart HHHHH because the source is subject to
40 CFR 63, Subpart JJJJ, pursuant to 40 CFR 63.7985(a)(4).
EUSRBOILER, 30 MMBTU/hr, natural gas fired boiler for solvent recovery System (SRS) is subject to 40
CFR 63, Subpart DDDDD—National Emission Standards for Hazardous Air Pollutants for Major Sources:
Industrial, Commercial, and Institutional Boilers and Process Heaters.
EUGENERATOR, 200 KW, natural gas fired emergency generator, to power office building equipment, is
subject to 40 CFR 63, Subpart ZZZZ-National Emission Standards for Hazardous Air Pollutants for
Reciprocating internal Combustion Engines (RICE) located at a major source of HAP emissions. It is
considered as an existing source for Subpart ZZZZ.
The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all
applicable requirements and are consistent with the "Procedure for Evaluating Periodic Monitoring
Submittals."
The emission limitations for VOC and HAP from FGCOATINGPROCESS (EUCOATINGLINE1,
EUCOATINGLINE3, EUCOATINGLINE4, EUPILOTLINE, and EUWETMIX&WHIP-OP) at the stationary
source are exempt from the federal Compliance Assurance Monitoring (CAM) regulation under Title 40 of
the Code of Federal Regulations (CFR), Part 64, because VOC and HAP limitations are addressed by 40
CFR 63, Subpart JJJJ. Therefore, FGCOATINGPROCESS is exempt from CAM requirements for VOC
and HAP.
State of Michigan, Department of Environmental Quality (DEQ) Stipulation of Entry of Final Order by
Consent, AQD No. 28-2008 was finalized on December 2, 2008. DEQ and the Company entered into this
consent order because the company did not submit a timely administratively complete ROP renewal
application to AQD. This consent order allows the company to continue operation until the renewed ROP
is issued. This CO was not incorporated into the renewed ROP because the conditions of the CO are
not necessary to ensure or demonstrate compliance with another applicable requirement in the ROP.
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Please refer to Parts B, C and D in the draft ROP for detailed regulatory citations for the stationary
source. Part A contains regulatory citations for general conditions.
Process Description
FGCOATINGPROCESS (EUCOATINGLINE1, EUCOATINGLINE3, EUCOATINGLINE4, EUPILOTLINE, and EUWETMIX&WHIP-OP):
Prior to 1975, the three web coating lines EUCOATINGLINE1 (Line 1), EUCOATINGLINE3 (Line 3), and
Line 2 (since removed) operated at the facility. EUCOATINGLINE4 (Line 4) was originally permitted
under Permit to Install (PTI) No. 221-75 as a replacement for Line 2. Then, on July 30, 1980, IPG (then
Armak Company) was issued PTI No. 104-80, which later was re-issued as a Permit to Operate dated
January 13, 1989. The PTI No. 104-80 was obtained based on the source becoming subject to the new
Reasonably Available Control Technology (RACT) standard (Rule 610) effective January 18, 1980. Since
adhesive is coated onto a paper substrate, each coating line is subject to the emission limit requirements
of Rule 610. In response, IPG proposed installation of a vapor phase, carbon adsorption solvent
recovery system (SRS) to recover toluene solvent emitted by the primary coating lines. The SRS controls
portions of the three primary web coating lines as follows: EUCOATINGLINE1, B Unit Hood and B Unit
Ovens; EUCOATINGLINE3, A, B, C Unit Hoods and Dryers 2, 3, 4; and EUCOATINGLINE4, B Unit
Hood and B Unit Ovens. Each coating line consists of a basecoat applicator, a release coat applicator, a
top coat applicator and various drying (or curing) ovens. Emissions from the web coating lines are
primarily volatile organic compounds (VOCs), with the primary VOC being Toluene, which is a hazardous
air pollutant (HAP).
The pilot coating line EUPILOTLINE was originally permitted under PTI No. 423-78.
Since the tape manufacturing operations started at the Marysville facility in 1961, IPG has been
performing adhesives and coatings preparation operations. The application for PTI No. 104-80 included
the entire tape manufacturing process. EUWETMIX&WHIP-OP including these adhesive and coating
preparation operations include mixing and blending of coating ingredients prior to application, coating
mixing for viscosity adjustment, additive blending, cleaning of coating preparation equipment and coating
line parts, handling and storage and transfer of coatings and solvent. These adhesive and coating
preparation operations are included this flexible group because they are covered by the same permit PTI
No. 104-80, and because these are the affiliated operations covered by the POWC MACT standard.
On July 14, 1997, the MDEQ and IPG entered into the Consent Order No. 10-1997 to resolve Rule 901
compliance issues. IPG installed and began operating a Regenerative Thermal Oxidizer (RTO) on
portions of the three web coating lines as follows: EUCOATINGLINE1, A Oven, and C1 and C2 Ovens;
EUCOATINGLINE3, Dryer 5; and EUCOATINGLINE4, A Oven, and C1 and C2 Ovens. The VOC
emissions from the EUPILOTLINE are controlled only by the RTO. The RTO is required by the Consent
Order to be installed and operating properly at a minimum temperature of 1400 degrees F and minimum
retention time of 0.5 seconds. On February 27, 2002, IPG received written approval from the AQD
Southeast Michigan District Supervisor for an equivalent method of emissions control from the
EUCOATINGLINE1 and EUCOATINGLINE4, A Unit Ovens, depending on whether water-based or
solvent based coatings are used. Specifically, exhaust is required to be automatically routed to the RTO
when the lower explosive limit (LEL) in the A Unit oven is detected at 10% or greater. At a minimum,
proper operation of the LEL approach is to be demonstrated through IPG’s preventative maintenance
program and a monthly calibration schedule.
The Initial ROP (199700107a) was modified on August 15, 2006, to incorporate a request from the
company to change to the POWC MACT HAP emission calculation method specified in Equation 14 (40
CFR 63.3370(n)(1)(ii) and (o)(3)) and Equation 15 (40 CFR 63.3370(n)(3)(iii)(B) and (o)4). Since the
POWC MACT specifically requires use of these equations, AQD could not make this change without the
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approval of the USEPA. The company obtained approval from USEPA to modify the HAP emission
calculation method. Therefore, Appendix 10 was added to the ROP to incorporate the approved
alternative method.
Rule 2040 10(a) requires a 30-day rolling period summation to calculate the recovery efficiency of the
solvent recovery system to show compliance with Rule 610 emission limit. The POWC MACT standard
requires calendar month summation of solvent usage and solvent recovery to calculate recovery
efficiency.
The facility chose to use multiple capture and control devices (a solvent recovery device with liquid-liquid
material balance calculation and a regenerative thermal oxidizer with control efficiency tested during
initial performance test) to demonstrate compliance with the emission limitation (0.2 lb organic HAP per
lb of coating solids applied) specified in 40 CFR 63.3320(a)(3).
In accordance with company’s response to the letter of violation (LOV) for failure to conduct preventive
maintenance, the ROP requires the company to install a computerized maintenance monitoring system
(CMMS) and generate a manual “Must Do” checklist to list all the required maintenance items and track
the completion of such maintenance activities.
EUPAINTBOOTH
There is one small fabric filter spray booth (EUPAINTBOOTH) used for research and development of
new pressure sensitive adhesives. Because less than 200 gallons of coating are used in the research
and development spray booth, it is exempt from permitting under Rule 287(c). Also, since the company
is using coatings which are used on pressure sensitive tape, the coating would normally be subject to the
requirements contained in Rule 610. However, since the coating usage in this equipment is below 100
pounds per day and 2,000 pounds per month (as specified in Rule 610(7)), the equipment is exempt from
the requirements of Rule 610. The company will be limited to 100 pounds per day or 2,000 pounds per
month to insure that the requirements of Rule 610 will not become applicable.
EUCOMPOUNDING
The dry stock compounding process (EUCOMPOUNDING) permitted under PTI No. 885-93 is subject to
the requirements of Rule 331. The compounding process is the mixing of dry raw materials used in the
manufacturing of the adhesive and is controlled by two fabric filter collector baghouses.
FG-STORAGETANKS
There are two 20,000 gallon (75.7 cubic meters) underground storage tanks at the facility
(FGSTORAGETANKS) used to store solvent recovered from the solvent recovery system. The solvent
stored is primarily toluene. These tanks are exempt from new source review permitting because they are
below the 40,000 gallon capacity limit in Rule 284(i). However, because these tanks were installed in
1992 and are greater than 75 cubic meters, they are subject to NSPS Subpart Kb for the underground
storage of volatile organic liquids.
FG-COLDCLEANERS
The facility operates several cold cleaners (FGCOLDCLEANERS) that are subject to R 336.1707. These
cold cleaners are exempt from new source review permits to install pursuant to R 336.1281(h). In
addition, these units are not currently subject to the Halogenated Solvent Cleaning MACT Standard (40
CFR Part 63 Subpart T) because they do not use halogenated solvents.
EURDPILOT-LINE is used for research and development activities and includes adhesive preparation
(mixing/blending) and a small web coating machine. This will be used in the future for the R& D of nonPage: 7
solvent based adhesive technology. This coating line will not subject to 40 CFR 63, Subpart JJJJ
pursuant to 40 CFR 63.3300, as it is used for R&D only.
Source-wide Permit to Install (PTI)
Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established
pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a
footnote designation in the integrated ROP/PTI document.
The following table lists all individual PTIs that were incorporated into previous ROPs. PTIs issued after
the effective date of ROP No. MI-ROP-A6220-2009 are identified in Appendix 6 of the ROP.
104-80
185-99
PTI Number
423-78
885-93
221-75
Equivalent Requirements
The following table lists explanations of any equivalent requirements included in the draft permit pursuant
to Rule 213(2)(c). Equivalent requirements are enforceable applicable requirements which are
equivalent to the applicable requirements contained in the original PTI, a Consent Order/Judgment,
and/or the State Implementation Plan.
Emission Unit/Flexible Group ID
FG-COATINGPROCESS
Equivalent Requirement Discussion
The Air Use Permit for the coating process (No. 104-80) set the
VOC emission limit at 4.79 pounds per gallon of solids applied,
based on a 24-hour averaging period, in accordance with Rule
610. The permit also prescribed an equation for determining
compliance with that limit.
However Rule 1040 specifies methods for determining
compliance for coating lines that are subject to Rule 610 and that
have one or more add-on emissions control devices for which
emission limits are expressed in pounds of VOC per gallon of
coating solids, as applied. Therefore in order to be consistent
with the rules, the company will be required to calculate emissions
based on the equations found in Rule 1040(12)(d) rather than
those found in Air Use Permit No. 104-80.
Streamlined/Subsumed Requirements
This permit does not include any streamlined/subsumed requirements pursuant to Rules 213(2) and
213(6).
Non-applicable Requirements
Part E of the draft ROP lists requirements that are not applicable to this source as determined by the
AQD, if any were proposed in the application. These determinations are incorporated into the permit
shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to Rule
213(6)(a)(ii).
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Processes in Application Not Identified in Draft ROP
The following table lists processes that were included in the ROP application as exempt devices under
Rule 212(4). These processes are not subject to any process-specific emission limits or standards in
any applicable requirement.
Exempt
Emission Unit ID
EUOBOILER
EUBLDG41BOILER
EUTOTES
Description of
Exempt Emission Unit
812,000 BTU/hr Office Boiler.
Installed in 1954
125 HP (5.2 MMBTU/hr) Building 41
Boiler, Installed in 1954
Adhesive totes which store adhesive
work in process
Rule 212(4)
Exemption
R336.1214(b)
Rule 201
Exemption
R 336.1282(b)(i)
R336.1214(b)
R 336.1282(b)(i)
R336.1214(c)
R 336.1284(i)
Draft ROP Terms/Conditions Not Agreed to by Applicant
This permit does not contain any terms and/or conditions that the AQD and the applicant did not agree
upon pursuant to Rule 214(2).
Compliance Status
The AQD finds that the stationary source is expected to be in compliance with all applicable
requirements as of the effective date of this ROP.
Action taken by the DEQ
The AQD proposes to approve this permit. A final decision on the ROP will not be made until the public
and affected states have had an opportunity to comment on the AQD’s proposed action and draft permit.
In addition, the U.S. Environmental Protection Agency (USEPA) is allowed up to 45 days to review the
draft permit and related material. The AQD is not required to accept recommendations that are not
based on applicable requirements. The delegated decision maker for the AQD is Christopher Ethridge,
Southeast Michigan District Supervisor. The final determination for ROP approval/disapproval will be
based on the contents of the permit application, a judgment that the stationary source will be able to
comply with applicable emission limits and other terms and conditions, and resolution of any objections
by the USEPA.
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Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
RENEWABLE OPERATING PERMIT
ROP Number
A6220
November 21, 2014 STAFF REPORT ADDENDUM
MI-ROP-A6220-2015
Purpose
A Staff Report dated October 20, 2014, was developed in order to set forth the applicable requirements
and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by
R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments
received on the draft ROP during the 30-day public comment period as described in R 336.1214(3). In
addition, this addendum describes any changes to the draft ROP resulting from these pertinent
comments.
General Information
Responsible Official:
AQD Contact:
Eric Woolums, Operations Manager
810-941-9000
Sebastian Kallumkal, Senior Environmental Engineer
586-753-3738
Summary of Pertinent Comments
No pertinent comments were received during the 30-day public comment period.
Changes to the October 20, 2014 Draft ROP
No changes were made to the draft ROP.
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