DAQ-2024-007430

DAQE-AN114910013-24

{{$d1 }}

Rich Garber
Packaging Corporation of America
4654 West 1525 South
Salt Lake City, UT 84104-5332
[e-mail]

Dear Mr. Garber:

Re: Approval Order: Minor Modification to Approval Order DAQE-AN114910008-20 to add Sheet
Plant
Project Number: N114910013

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on August
25, 2023. Packaging Corporation of America must comply with the requirements of this AO, all
applicable state requirements (R307), and Federal Standards.

The project engineer for this action is Dylan Frederick, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as
the DAQE number shown on the upper right-hand corner of this letter. No public comments were
received on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:DF:jg

cc: Salt Lake County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

March 20, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN114910013-24
Minor Modification to Approval Order DAQE-AN114910008-20
to add Sheet Plant

Prepared By
Dylan Frederick, Engineer
[phone]
[e-mail]

Issued to
Packaging Corporation of America - Corrugated Products Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

March 20, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 10

DAQE-AN114910013-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Packaging Corporation of America Packaging Corporation of America - Corrugated
Products Facility

Mailing Address Physical Address
4654 West 1525 South 4654 West 1525 South
Salt Lake City, UT 84104-5332 Salt Lake City, UT 84104-5332

Source Contact UTM Coordinates
Name: Rich Garber 415,382 m Easting
Phone: [phone],510,300 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 2653 (Corrugated & Solid Fiber Boxes)

SOURCE INFORMATION
General Description
Packaging Corporation of America (PCA) owns a printing and manufacturing facility in Salt Lake
County. The facility consists of a full-line plant and a specialty sheet plant. The facility converts brown
paper into corrugated boxes for displays and packaging. Sheets of paper are combined with adhesive,
formed into shapes, and heated using steam produced by an onsite boiler. The corrugated board is then
cut to size based on customer specifications before being sent through a flexographic printing process that
applies ink. The printed product is then folded and glued, and it is then ready for shipping off-site.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units
DAQE-AN114910013-24
Page 4

Project Description
PCA has requested to add a sheet plant to the facility. The sheet plant was previously registered as a
small source exemption at a different location, under site ID 11940. Because it has been moved to the
same property as the full-line plant, it has been added to the approval order. The sheet plant will include
the following equipment:

Various HVAC and space heating units
A scrap collection system with cyclones and baghouses
Printing equipment, including various die cutters, gluers, and flexographic printing and converting
equipment, and conveying equipment.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 6378 19242.00
Carbon Monoxide 4.44 9.04
Nitrogen Oxides 5.29 13.36
Particulate Matter - PM10 0.41 2.01
Particulate Matter - PM2.5 0.41 0.99
Sulfur Oxides 0.03 0.36
Volatile Organic Compounds 1.89 9.81

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethylene Glycol (CAS #107211) 0 578
Glycol Ethers (CAS #EDF109) 0 4162
Change (TPY) Total (TPY)
Total HAPs 0.28 2.37

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

DAQE-AN114910013-24
Page 5

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All
maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Corrugated Container Manufacturing Facility
Full-Line Plant, Sheet Plant

II.A.2 Two (2) Boilers
Cleaver Brooks
Rating: 16.5 MMBtu/hr
Fuel: Natural Gas

Hurst
Rating: 25.2 MMBtu/hr
Fuel: Natural Gas

II.A.3 One (1) Storage Silo
Controls: fabric filter dust collector

DAQE-AN114910013-24
Page 6

II.A.4 Three (3) Cyclonic Separators
Cyclone 1
Controls: trimmings and scrap from plant operation

Cyclone 2
Controls: Printing Operation - Mitsubishi EVOL 4FGR

(NEW) Cyclone 3 - Sheet Plant
Controls: trimmings and scrap from plant converting operations

II.A.5 Two (2) Pneumatic Conveyor Systems
Location: One (1) at full line plant, One (1) at sheet plant

II.A.6 Two (2) Flexographic Printing Operations
Full Line Plant
Controls: Use of low VOC content, water-based inks, and cyclone

Sheet Plant
Controls: Use of low VOC content, water-based inks

II.A.7 Six (6) HVAC units
Rating: 5.184 MMBtu/hr each

II.A.8 Various Boilers/Comfort Heating Devices
Rating: less than 5 MMBtu/hr each
*listed for informational purposes only

II.A.9 Various Mobile Equipment Items
*listed for informational purposes only

II.A.10 One (1) Scrap Handling System
Controls: Cyclone and Baghouse

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Corrugated Container Manufacturing Facility

II.B.1.a The owner/operator shall not allow visible emissions from any source on site to exceed 10%
opacity. [R307-401-8]

II.B.1.b Opacity observations of emissions from stationary sources shall be conducted in accordance with
40 CFR 60, Appendix A, Method 9. [R307-201-3]

II.B.2 Fuel
II.B.2.a The owner/operator shall use natural gas as fuel for the boilers and various comfort heaters.
[R307-401-8]

DAQE-AN114910013-24
Page 7

II.B.3 VOC & HAP Requirements
II.B.3.a The owner/operator shall not emit more than the following from evaporative sources (painting,
printing, coating, and/or cleaning) on site:

9.52 tons per rolling 12-month period of VOCs
2.37 tons per rolling 12-month period of all HAPs combined.

[R307-401-8]

II.B.3.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method to
calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:

VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]

HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed].

[R307-401-8]

II.B.3.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs
reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the
quantities calculated above to provide the monthly total emissions of VOCs and HAPs.
[R307-401-8]

II.B.3.a.3 The owner/operator shall keep records each month of the following:

A. The name (as per SDS) of the VOC- and HAP-emitting material.

B. The maximum percent by weight of VOCs and each HAP in each material used.

C. The density of each material used.

D. The volume of each VOC- and HAP-emitting material used.

E. The amount of VOCs and the amount of each HAP emitted from each material.

F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled
from each material.

G. The total amount of VOCs, the total amount of each HAP, and the total amount
of all HAPs combined emitted from all materials (in tons).

[R307-401-8]

II.B.4 Boiler Requirements
II.B.4.a The boilers listed in condition II.A.2 shall not exceed 8,760 hours of operation combined per
rolling 12-month period. [R307-401-8]

DAQE-AN114910013-24
Page 8

II.B.4.a.1 The owner/operator shall:

A. Determine hours of operation through supervisor monitoring and maintaining an
operations log.

B. Record hours of operation each day for each boiler.

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th
day of each month using data from the previous 12 months.

D. Keep hours of operation records for all periods the plant is in operation.

[R307-401-8]

II.B.5 Sheet Plant Requirements
II.B.5.a The owner/operator shall not consume more than 105.7 MMscf of natural gas at the sheet plant
per rolling 12-month period. [R307-401-8]

II.B.5.a.1 The owner/operator shall:

A. Calculate a new 12-month total by the 20th day of each month using data from
the previous 12 months.

B. Determine consumption from vendor records.

C. Record consumption on a monthly basis.

D. Keep consumption records for all periods the plant is in operation.

[R307-401-8]

II.B.5.b The owner/operator shall install a cyclone and baghouse system to control emissions from the
scrap collection system. All emissions from the scrap collection system shall be routed through
the cyclone and baghouse before being vented to the atmosphere. [R307-401-8]

II.B.5.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure drop across the scrap collection system baghouse. [R307-401-8]

II.B.5.c.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

II.B.5.c.2 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less.
[R307-401-8]

II.B.5.d During operation of the cyclone/baghouse, the owner/operator shall maintain the static pressure
drop across the baghouse according to manufacturer recommendations. [R307-401-8]

II.B.5.d.1 The owner/operator shall record the static pressure differential at least once per operating day
while the specialty sheet plant baghouse is operating. [R307-401-8]

DAQE-AN114910013-24
Page 9

II.B.5.d.2 The owner/operator shall maintain the following records of the static pressure differential:

A. Manufacturer recommended a static pressure differential for the unit;

B. Daily static pressure differential readings;

C. Date of reading.

[R307-401-8]

II.B.5.e The owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's
instructions or replace the gauges at least once every year. [R307-401-8]

II.B.5.e.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]

II.B.5.f The owner/operator shall use inks, glues, and adhesives that comply with all applicable limits in
R307-351, "Graphic Arts." [R307-351]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN114910008-20 dated February 26, 2020
Is Derived From NOI dated August 25, 2023
Incorporates Additional Information dated December 1, 2023
Incorporates Additional Information dated January 5, 2024
Incorporates Additional Information dated January 9, 2024
Incorporates Additional Information dated January 31, 2024

DAQE-AN114910013-24
Page 10

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-IN114910013-24

February 8, 2024

Rich Garber
Packaging Corporation of America
4654 West 1525 South
Salt Lake City, UT 84104-5332
[e-mail]

Dear Mr. Garber:

Re: Intent to Approve: Minor Modification to Approval Order DAQE-AN114910008-20 to add
Sheet Plant
Project Number: N114910013

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Dylan Frederick, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Dylan Frederick, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:DF:jg

cc: Salt Lake County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN114910013-24
Minor Modification to Approval Order
DAQE-AN114910008-20 to add Sheet Plant

Prepared By
Dylan Frederick, Engineer
[phone]
[e-mail]

Issued to
Packaging Corporation of America - Corrugated Products Facility

Issued On
February 8, 2024

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 10

DAQE-IN114910013-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Packaging Corporation of America Packaging Corporation of America - Corrugated
Products Facility

Mailing Address Physical Address
4654 West 1525 South 4654 West 1525 South
Salt Lake City, UT 84104-5332 Salt Lake City, UT 84104-5332

Source Contact UTM Coordinates
Name: Rich Garber 415,382 m Easting
Phone: [phone],510,300 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 2653 (Corrugated & Solid Fiber Boxes)

SOURCE INFORMATION
General Description
Packaging Corporation of America (PCA) owns a printing and manufacturing facility in Salt Lake
County. The facility consists of a full-line plant and a specialty sheet plant. The facility converts brown
paper into corrugated boxes for displays and packaging. Sheets of paper are combined with adhesive,
formed to shape, and heated using steam produced by an onsite boiler. The corrugated board is then cut
to size based on customer specifications before being sent through a flexographic printing process that
applies inks. The printed product is then folded and glued and is then ready for shipping off site.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units
DAQE-IN114910013-24
Page 4

Project Description
PCA has requested to add a sheet plant to the facility. The sheet plant previously was registered as a
small source exemption at a different location, under site ID 11940. Because it has been moved to the
same property as the full line plant, it has been added to the approval order. The sheet plant will include
the following equipment:

- Various HVAC and space heating units
- A scrap collection system with cyclone and baghouse
- Printing equipment, including various die cutters, gluers, and flexographic printing and converting
equipment and conveying equipment.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 6378 19242.00
Carbon Monoxide 4.44 9.04
Nitrogen Oxides 5.29 13.36
Particulate Matter - PM10 0.41 2.01
Particulate Matter - PM2.5 0.41 0.99
Sulfur Oxides 0.03 0.36
Volatile Organic Compounds 1.89 9.81

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethylene Glycol (CAS #107211) 0 578
Glycol Ethers (CAS #EDF109) 0 4162
Change (TPY) Total (TPY)
Total HAPs 0.28 2.37

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Salt Lake Tribune and Deseret News on February 11, 2024.
During the public comment period the proposal and the evaluation of its impact on air quality will be
available for the public to review and provide comment. If anyone so requests a public hearing within 15
days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as
close as practicable to the location of the source. Any comments received during the public comment
period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result
of the comments received.

DAQE-IN114910013-24
Page 5

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All
maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

DAQE-IN114910013-24
Page 6

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

II.A THE APPROVED EQUIPMENT

II.A.1 Corrugated Container Manufacturing Facility
Full-Line Plant, Sheet Plant

II.A.2 Two (2) Boilers
Cleaver Brooks
Rating: 16.5 MMBtu/hr
Fuel: Natural Gas

Hurst
Rating: 25.2 MMBtu/hr
Fuel: Natural Gas

II.A.3 One (1) Storage Silo
Controls: fabric filter dust collector

II.A.4 Three (3) Cyclonic Separators
Cyclone 1
Controls: trimmings and scrap from plant operation

Cyclone 2
Controls: Printing Operation - Mitsubishi EVOL 4FGR

(NEW) Cyclone 3 - Sheet Plant
Controls: trimmings and scrap from plant converting operations

II.A.5 Two (2) Pneumatic Conveyor Systems
Location: One (1) at full line plant, One (1) at sheet plant

II.A.6 Two (2) Flexographic Printing Operations
Full Line Plant
Controls: Use of low VOC content, water-based inks, and cyclone

Sheet Plant
Controls: Use of low VOC content, water-based inks

II.A.7 Six (6) HVAC units
Rating: 5.184 MMBtu/hr each

II.A.8 Various Boilers/Comfort Heating Devices
Rating: less than 5 MMBtu/hr each
*listed for informational purposes only

II.A.9 Various Mobile Equipment Items
*listed for informational purposes only

II.A.10 One (1) Scrap Handling System
Controls: Cyclone and Baghouse

DAQE-IN114910013-24
Page 7

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Corrugated Container Manufacturing Facility

II.B.1.a The owner/operator shall not allow visible emissions from any source on site to exceed 10%
opacity. [R307-401-8]

II.B.1.b Opacity observations of emissions from stationary sources shall be conducted in accordance with
40 CFR 60, Appendix A, Method 9. [R307-201-3]

II.B.2 Fuel

II.B.2.a The owner/operator shall use natural gas as fuel for the boilers and various comfort heaters.
[R307-401-8]

II.B.3 VOC & HAP Requirements
II.B.3.a The owner/operator shall not emit more than the following from evaporative sources (painting,
printing, coating, and/or cleaning) on site:

9.52 tons per rolling 12-month period of VOCs

2.37 tons per rolling 12-month period of all HAPs combined.

[R307-401-8]

II.B.3.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method to
calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:

VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]

HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]

[R307-401-8]

II.B.3.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs
reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the
quantities calculated above to provide the monthly total emissions of VOCs and HAPs.
[R307-401-8]

DAQE-IN114910013-24
Page 8

II.B.3.a.3 The owner/operator shall keep records each month of the following:

A. The name (as per SDS) of the VOC- and HAP-emitting material

B. The maximum percent by weight of VOCs and each HAP in each material used

C. The density of each material used

D. The volume of each VOC- and HAP-emitting material used

E. The amount of VOCs and the amount of each HAP emitted from each material

F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled
from each material

G. The total amount of VOCs, the total amount of each HAP, and the total amount
of all HAPs combined emitted from all materials (in tons).

[R307-401-8]

II.B.4 Boiler Requirements

II.B.4.a The boilers listed in condition II.A.2 shall not exceed 8,760 hours of operation combined per
rolling 12-month period. [R307-401-8]

II.B.4.a.1 The owner/operator shall:

A. Determine hours of operation through supervisor monitoring and maintaining an
operations log

B. Record hours of operation each day for each boiler

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th
day of each month using data from the previous 12 months

D. Keep hours of operation records for all periods the plant is in operation.

[R307-401-8]

II.B.5 Sheet Plant Requirements
II.B.5.a The owner/operator shall not consume more than 105.7 MMscf of natural gas at the sheet plant
per rolling 12-month period. [R307-401-8]

II.B.5.a.1 The owner/operator shall:

A. Calculate a new 12-month total by the 20th day of each month using data from
the previous 12 months

B. Determine consumption from vendor records

C. Record consumption on a monthly basis

D. Keep consumption records for all periods the plant is in operation.

[R307-401-8]

DAQE-IN114910013-24
Page 9

II.B.5.b The owner/operator shall install a cyclone and baghouse system to control emissions from the
scrap collection system. All emissions from the scrap collection system shall be routed through
the cyclone and baghouse before being vented to the atmosphere. [R307-401-8]

II.B.5.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure drop across the scrap collection system baghouse. [R307-401-8]

II.B.5.c.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

II.B.5.c.2 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less.
[R307-401-8]

II.B.5.d During operation of the cyclone/baghouse, the owner/operator shall maintain the static pressure
drop across the baghouse according to manufacturer recommendations. [R307-401-8]

II.B.5.d.1 The owner/operator shall record the static pressure differential at least once per operating day
while the specialty sheet plant baghouse is operating. [R307-401-8]

II.B.5.d.2 The owner/operator shall maintain the following records of the static pressure differential:

A. Manufacturer recommended static pressure differential for the unit;

B. Daily static pressure differential readings;

C. Date of reading.

[R307-401-8]

II.B.5.e The owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's
instructions or replace the gauges at least once every year. [R307-401-8]

II.B.5.e.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]

II.B.5.f The owner/operator shall use inks, glues, and adhesives that comply with all applicable limits in
R307-351 "Graphic Arts". [R307-351]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN114910008-20 dated February 26, 2020
Is Derived From NOI dated August 25, 2023
Incorporates Additional Information dated December 1, 2023
Incorporates Additional Information dated January 5, 2024
Incorporates Additional Information dated January 9, 2024
Incorporates Additional Information dated January 31, 2024

DAQE-IN114910013-24
Page 10

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

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DAQE-NN114910013-24
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801-536-4000
[e-mail]
UTAH DIVISION OF AIR QUALITY
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DAQE-NN114910013-24

February 8, 2024

Salt Lake Tribune and Deseret News
Legal Advertising Dept.
P.O. Box 704055
West Valley City, UT 84170
Acct #9001399880

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Salt Lake Tribune and
Deseret News on February 11, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Salt Lake County
cc: Wasatch Front Regional Council

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN114910013-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Packaging Corporation of America
Location: Packaging Corporation of America - Corrugated Products Facility – 4654 West
1525 South, Salt Lake City, UT
Project Description: Packaging Corporation of America has requested to add a sheet plant to their
existing approval order. The sheet plant will convert corrugated sheets into
finished boxes for customers. The new plant will add 6 HVAC units rated 5.184
MMBtu/hr, a scrap collection system with a cyclone and baghouse, and various
printing equipment to the facility.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before March 12, 2024 will be considered in making
the final decision on the approval/disapproval of the proposed project. Email comments will also be
accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with
R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: February 11, 2024

{{#s=Sig_es_:signer1:signature}}

DAQE-

RN114910013
February 2, 2024

Rich Garber
Packaging Corporation of America
4654 West 1525 South
Salt Lake City, UT 84104
[e-mail]

Dear Rich Garber,

Re: Engineer Review:
Minor Modification to Approval Order DAQE-AN114910008-20 to add Sheet Plant
Project Number: N114910013

The DAQ requests a company representative review and sign the attached Engineer Review (ER). This
ER identifies all applicable elements of the New Source Review permitting program. Packaging
Corporation of America should complete this review within 10 business days of receipt.

Packaging Corporation of America should contact Dylan Frederick at [phone] if there are
questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns,
please email Dylan Frederick at [e-mail] the signed cover letter. Upon receipt of the
signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion
of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO)
for signature by the DAQ Director.

If Packaging Corporation of America does not respond to this letter within 10 business days, the project
will move forward without source concurrence. If Packaging Corporation of America has concerns that
cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting
construction.

Approval Signature _____________________________________________________________
(Signature & Date)

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of
Environmental Quality

Kimberly D. Shelley Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird Director

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Engineer Review N114910013: Packaging Corporation of America- Corrugated Products Facility
February 2, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N114910013
Owner Name Packaging Corporation of America
Mailing Address 4654 West 1525 South
Salt Lake City, UT, 84104

Source Name Packaging Corporation of America- Corrugated Products Facility
Source Location 4654 West 1525 South
Salt Lake City, UT 84104-5332

UTM Projection 415,382 m Easting, 4,510,300 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 2653 (Corrugated & Solid Fiber Boxes)

Source Contact Rich Garber
Phone Number [phone]
Email [e-mail]

Billing Contact Rich Garber
Phone Number [phone]
Email [e-mail]

Project Engineer Dylan Frederick, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted August 25, 2023
Date of Accepted Application December 12, 2023

Engineer Review N114910013: Packaging Corporation of America- Corrugated Products Facility
February 2, 2024
Page 2
SOURCE DESCRIPTION

General Description
Packaging Corporation of America (PCA) owns a printing and manufacturing facility in Salt
Lake County. The facility consists of a full-line plant and a specialty sheet plant. The facility
converts brown paper into corrugated boxes for displays and packaging. Sheets of paper are
combined with adhesive, formed to shape, and heated using steam produced by an onsite boiler.
The corrugated board is then cut to size based on customer specifications before being sent
through a flexographic printing process that applies inks. The printed product is then folded and
glued and is then ready for shipping off site.

NSR Classification:
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County
SO2 NAA,
Salt Lake County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units

Project Proposal
Minor Modification to Approval Order DAQE-AN114910008-20 to add Sheet Plant

Project Description
PCA has requested to add a sheet plant to the facility. The sheet plant previously was registered
as a small source exemption at a different location, under site ID 11940. Because it has been
moved to the same property as the full line plant, it has been added to the approval order. The
sheet plant will include the following equipment:

Various HVAC and space heating units
A scrap collection system with cyclone and baghouse
Printing equipment, including various die cutters, gluers, and flexographic printing and
converting equipment and conveying equipment.

EMISSION IMPACT ANALYSIS
All criteria pollutants are below the modeling thresholds contained in R307-410-4. All HAP emissions are
below their respective emission threshold values in R307-410-5. Therefore, no modeling is required for this
modification. [Last updated December 21, 2023]

Engineer Review N114910013: Packaging Corporation of America- Corrugated Products Facility
February 2, 2024
Page 3
SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 6378 19242.00
Carbon Monoxide 4.44 9.04
Nitrogen Oxides 5.29 13.36
Particulate Matter - PM10 0.41 2.01
Particulate Matter - PM2.5 0.41 0.99
Sulfur Oxides 0.03 0.36
Volatile Organic Compounds 1.89 9.81

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethylene Glycol (CAS #107211) 578
Glycol Ethers (CAS #EDF109) 4162
Change (TPY) Total (TPY)
Total HAPs 0.28 2.37

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N114910013: Packaging Corporation of America- Corrugated Products Facility
February 2, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding Sheet Plant Flexographic Printing Operations
PCA has requested to add a sheet plant with flexographic printing operations and a scrap collection
system. This installation will result in increases of VOCs and HAPs from printing operations, and
PM10 and PM2.5 from the scrap collection system.

To control PM10/PM2.5 emissions from the printing operation, PCA has proposed to install a
cyclone/baghouse system to the scrap collection system. This system would filter air through the
cyclone system before sending remaining emissions through a fabric filter baghouse. The System
utilizes a MERV filter with a 99.995% removal efficiency. This is the most stringent control
available for control of particulate emissions, and is accepted as BACT.

To Control VOC/HAP emissions from the proposed printing operations, PCA has proposed the use
of water based, low-VOC content inks and adhesives. Additional controls could be applied to
further capture VOC emissions, but would require add-on control systems, including a VOC
capture device and a control device such as a thermal oxidizer to destroy VOC emissions. The
estimated annual emissions for VOCs are estimated at 1.6 tons per year. PCA provided a cost
estimate for a thermal oxidizer, giving a capital estimate of 1.5 million plus 0.5 million for gas
connections and controls in order to fit the baghouse/cyclone exhaust system. Due to the low
amount of VOCs produced annually and the high capital cost over the lifetime of the equipment,
an add-on VOC control system would be economically infeasible to implement for control of
printing emissions from the sheet printing line. Use of water based, low-VOC content inks and
adhesives and compliance with other measures in R307-351 "Graphic Arts" are accepted as BACT.

BACT for control of the sheet plant operations will be the installation of a scrap collection system
with a cyclone and baghouse to meet a 10% opacity limit, installation of fabric filters certified by
the manufacturer to meet a 99.995% removal efficiency, and the use of water based, low VOC
content inks and adhesives compliant with R307-351 "Graphic Arts". [Last updated February 2,
2024]

2. BACT review regarding HVAC units
The new sheet plant will come with six 5.184 MMBtu/hr HVAC units installed for space heating.
These will be active during winter months to provide heating and will combust natural gas, causing
emissions of NOx, CO, VOCs, PM10, PM2.5, and SO2.

The units are individually equipped with a high thermal efficiency design, offering a 92% thermal
efficiency, maximizing heat generated from natural gas combustion. PCA has estimated a
maximum annual usage of 105.7 MMScf of natural gas annually from these units. Each HVAC
unit will emit 0.88 tons per year of NOx, 0.74 tons per year of CO, and trace amounts of other
pollutants. PCA found no add-on controls that are used in the industry for control of HVAC
equipment. Due to the low amount of emissions from these units, add on technologies to control
emissions would not be economically feasible to implement. The high thermal efficiency design
combined with a clean burning fuel such as natural gas is BACT for this equipment.

BACT for control of each 5.184 MMBtu/hr HVAC unit will be the use of natural gas and a 10%
opacity limit. [Last updated February 2, 2024]

Engineer Review N114910013: Packaging Corporation of America- Corrugated Products Facility
February 2, 2024
Page 5
SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded. [R307-
401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-
150]

I.8 The owner/operator shall submit documentation of the status of construction or modification
to the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director,
send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

Engineer Review N114910013: Packaging Corporation of America- Corrugated Products Facility
February 2, 2024
Page 6

II.A THE APPROVED EQUIPMENT

II.A.1 Corrugated Container Manufacturing Facility
Full-Line Plant, Sheet Plant

II.A.2 Two (2) Boilers
Cleaver Brooks
Rating: 16.5 MMBtu/hr
Fuel: Natural Gas

Hurst
Rating: 25.2 MMBtu/hr
Fuel: Natural Gas

II.A.3 One (1) Storage Silo
Controls: fabric filter dust collector

II.A.4 Three (3) Cyclonic Separators
Cyclone 1
Controls: trimmings and scrap from plant operation

Cyclone 2
Controls: Printing Operation - Mitsubishi EVOL 4FGR

(NEW) Cyclone 3 - Sheet Plant
Controls: trimmings and scrap from plant converting operations

II.A.5 Two (2) Pneumatic Conveyor Systems
Location: One (1) at full line plant, One (1) at sheet plant

II.A.6 Two (2) Flexographic Printing Operations
Full Line Plant
Controls: Use of low VOC content, water-based inks, and cyclone

Sheet Plant
Controls: Use of low VOC content, water-based inks

II.A.7
NEW
Six (6) HVAC units
Rating: 5.184 MMBtu/hr each

II.A.8 Various Boilers/Comfort Heating Devices
Rating: less than 5 MMBtu/hr each
*listed for informational purposes only

II.A.9 Various Mobile Equipment Items
*listed for informational purposes only

II.A.10
NEW
One (1) Scrap Handling System
Controls: Cyclone and Baghouse

Engineer Review N114910013: Packaging Corporation of America- Corrugated Products Facility
February 2, 2024
Page 7

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Corrugated Container Manufacturing Facility

II.B.1.a The owner/operator shall not allow visible emissions from any source on site to exceed 10%
opacity. [R307-401-8]

II.B.1.b Opacity observations of emissions from stationary sources shall be conducted in accordance
with 40 CFR 60, Appendix A, Method 9. [R307-201-3]

II.B.2 Fuel

II.B.2.a The owner/operator shall use natural gas as fuel for the boilers and various comfort heaters.
[R307-401-8]

II.B.3 VOC & HAP Requirements
II.B.3.a
NEW
The owner/operator shall not emit more than the following from evaporative sources
(painting, printing, coating, and/or cleaning) on site:

9.52 tons per rolling 12-month period of VOCs
2.37 tons per rolling 12-month period of all HAPs combined. [R307-401-8]

II.B.3.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method to
calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:

VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]

HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8]

II.B.3.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and
HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed
from the quantities calculated above to provide the monthly total emissions of VOCs and
HAPs. [R307-401-8]

Engineer Review N114910013: Packaging Corporation of America- Corrugated Products Facility
February 2, 2024
Page 8
II.B.3.a.3 The owner/operator shall keep records each month of the following:

A. The name (as per SDS) of the VOC- and HAP-emitting material

B. The maximum percent by weight of VOCs and each HAP in each material used

C. The density of each material used

D. The volume of each VOC- and HAP-emitting material used

E. The amount of VOCs and the amount of each HAP emitted from each material

F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from
each material

G. The total amount of VOCs, the total amount of each HAP, and the total amount of all
HAPs combined emitted from all materials (in tons). [R307-401-8]

II.B.4 Boiler Requirements

II.B.4.a
NEW
The boilers listed in condition II.A.2 shall not exceed 8,760 hours of operation combined per
rolling 12-month period. [R307-401-8]

II.B.4.a.1
NEW
The owner/operator shall:

A. Determine hours of operation through supervisor monitoring and maintaining an
operations log

B. Record hours of operation each day for each boiler

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months

D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8]

II.B.5
NEW
Sheet Plant Requirements
II.B.5.a
NEW
The owner/operator shall not consume more than 105.7 MMscf of natural gas at the sheet
plant per rolling 12-month period. [R307-401-8]

II.B.5.a.1
NEW
The owner/operator shall:

A. Calculate a new 12-month total by the 20th day of each month using data from the
previous 12 months

B. Determine consumption from vendor records

C. Record consumption on a monthly basis

D. Keep consumption records for all periods the plant is in operation. [R307-401-8]

Engineer Review N114910013: Packaging Corporation of America- Corrugated Products Facility
February 2, 2024
Page 9
II.B.5.b
NEW
The owner/operator shall install a cyclone and baghouse system to control emissions from the
scrap collection system. All emissions from the scrap collection system shall be routed
through the cyclone and baghouse before being vented to the atmosphere. [R307-401-8]

II.B.5.c
NEW
The owner/operator shall install a manometer or magnehelic pressure gauge to measure the
static pressure drop across the scrap collection system baghouse. [R307-401-8]

II.B.5.c.1
NEW
The pressure gauge shall be located such that an inspector/operator can safely read the
indicator at any time. [R307-401-8]

II.B.5.c.2
NEW
The pressure gauge shall measure the pressure drop in 1-inch water column increments or less.
[R307-401-8]

II.B.5.d
NEW
During operation of the cyclone/baghouse, the owner/operator shall maintain the static
pressure drop across the baghouse according to manufacturer recommendations. [R307-401-8]

II.B.5.d.1
NEW
The owner/operator shall record the static pressure differential at least once per operating day
while the specialty sheet plant baghouse is operating. [R307-401-8]

II.B.5.d.2
NEW
The owner/operator shall maintain the following records of the static pressure differential:

A. Manufacturer recommended static pressure differential for the unit;

B. Daily static pressure differential readings;

C. Date of reading. [R307-401-8]

II.B.5.e
NEW
The owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's
instructions or replace the gauges at least once every year. [R307-401-8]

II.B.5.e.1
NEW
The owner/operator shall maintain records of the pressure gauge calibrations and
replacements. [R307-401-8]

II.B.5.f
NEW
The owner/operator shall use inks, glues, and adhesives that comply with all applicable limits
in R307-351 "Graphic Arts". [R307-351]

Engineer Review N114910013: Packaging Corporation of America- Corrugated Products Facility
February 2, 2024
Page 10
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes AO DAQE-AN114910008-20 dated February 26, 2020
Is Derived From NOI dated August 25, 2023
Incorporates Additional Information dated December 1, 2023
Incorporates Additional Information dated January 5, 2024
Incorporates Additional Information dated January 9, 2024
Incorporates Additional Information dated January 31, 2024

REVIEWER COMMENTS

1. Comment regarding Emission Estimates:
Emission estimates were calculated using the following methods:

Sheet Plant - Potential emissions were calculated based on a maximum production capacity of
842,400 MSF/yr of printed materials. A mass balance was done to determine VOC and HAP
emissions for the printing operations. An emission factor of 0.0032 lb VOC/MSF was used with a
20% safety factor. An emission factor of 0.00056 lb HAP/MSF with a safety factor of 20% was
used. When multiplied by the maximum annual printing capacity, an annual VOC total of 1.60 TPY
and 0.283 TPY of HAPs were determined. Emission factors were based off of plant emissions data.

HVAC and Space Heating emissions - Only space heating is expected to produce emissions through
natural gas consumption. Six (6) HVAC Units each rated 5.184 MMBtu/hr are assumed to operate
up to 2920 hours per year. This gives a natural gas consumption annually of 105.7 MMCF. This
natural gas total is multiplied by AP-42 Chapter 1.4, table 1.4-1 and table 1.4-2 emission factors.

Scrap System - A maximum of 270 operating days per year was assumed, along with a 0.00005
gr/dscf loading rate from a manufacturer guarantee, and maximum flow rate of 111,000 dscf/min.

Information received 1-5-24 was incorporated into the emission total for the permit. The emissions
calculated in that addendum replace the emission totals for the HVAC units in the NOI, which is
why the most recent emission summary table received prior to this information does not match the
current permit. [Last updated January 10, 2024]

2. Comment regarding NSPS and MACT Applicability:
40 CFR 60 (NSPS) Subpart Dc applies to steam heating units with a maximum design capacity
between 10 and 100 MMBtu/hr. The boilers on site are 16.8 and 25.2 MMBtu/hr and have a
manufacturer date that meets the applicability in NSPS subpart Dc. Therefore, NSPS Subpart Dc
applies to the site. Because the boilers are natural gas, there are no emission limitations, only
recordkeeping requirements.

40 CRR 63 (MACT) Subpart KK applies to each new and existing major source of HAPs at which
publication rotogravure, product and packaging rotogravure, or wide-web flexographic printing
presses are operated. The flexographic printing operation is not a wide-web flexographic printing
press. This source is not a major source of HAPs. Therefore, this subpart does not apply to this
facility. [Last updated January 31, 2024]

Engineer Review N114910013: Packaging Corporation of America- Corrugated Products Facility
February 2, 2024
Page 11
3. Comment regarding Title V applicability:
Title V of the 1990 Clean Air Act (Title V) applies to the following:

1. Any major source
2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationary Sources;
3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants.
4. Any Title IV affected source.

This facility is not a major source and is not a Title IV source. The facility is subject to 40 CFR 60
(NSPS) regulations. It is not subject to 40 CFR 61 (NESHAP) and 40 CFR 63 (MACT) regulations.
The facility is subject to 40 CFR 60 NSPS Subpart Dc. NSPS Subpart Dc is not exempt from Title V
requirements, but it does not have a limitation or emission standard required by this subpart. The
only applicable requirements are recordkeeping requirements. Because there is no limitation or
emission standard applicable in NSPS Subpart Dc, Title V does not apply to this facility. [Last
updated January 31, 2024]

4. Comment regarding Sheet plant emission limitations:
PCA's calculations noted that space heating calculations only occurred for part of the year. To
account for these emission assumptions, a natural gas limit was placed on the sheet plant to enforce
the emission estimations included in the NOI. An annual consumption limit of 105.7 MMscf/year
was added to the permit as a result. [Last updated January 31, 2024]

5. Comment regarding HAP calculations:
The previous approval order did not specify what HAPs were emitted at the facility. A figure of 2.09
tons per year of "generic HAPs" were previously listed on the permit. PCA provided an emission
inventory for HAPs for the existing facility, and determined that the primary two HAPs were glycol
ether and ethylene glycol. The inventory showed that recent year actual emissions from the facility
were 90 lbs of HAPs, in a ratio of 79/90 for glycol ethers and 11/90 for ethylene glycol. These ratios
were applied to the existing and new emissions estimates at the facility, giving a total of 2.081 tons
per year of glycol ethers and 0.289 tons per year of ethylene glycol. Future speciated HAP emissions
may differ from this estimate due to differences in ink product formulations, but will remain below
the 2.37 tons per year HAP limit established in this approval order. Future modifications should
evaluate these estimates if there is any change. [Last updated February 2, 2024]

Engineer Review N114910013: Packaging Corporation of America- Corrugated Products Facility
February 2, 2024
Page 12
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

1/10/24, 12:05 PM State of Utah Mail - PCA Specialty Sheet Plant Information Request 12-21-23
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1787281609005316549&simpl=msg-f:1787281609005316549 1/2
Dylan Frederick <[e-mail]>
PCA Specialty Sheet Plant Information Request 12-21-23
Garber, Rich D <[e-mail]>
To: Dylan Frederick <[e-mail]>
Cc: "Campbell, Cody" <[e-mail]>
Dylan – I think I have addressed all of your questions and provided the requested information below and in the attachments.

HVAC and GHG Calculations:

Updated information (see calculations below) includes 6 mass air unit HVAC space heaters just slightly above the 5 MMBTU/hr threshold. The overall gas usage is slightly greater than the Au
previously). I determined that we would need to heat the building and offices all 7 day of the week during the winter months. I was informed that the HVAC vendor and engineers determined
due to structural and earthquake load issues. We would prefer that the gas usage be used as part of the calculation of overall plant emissions (for information only) and not be considered an
with space-heating HVAC emission limits, per se with other permits. With that said, however, if an individual limit for space-heating gas usage must be set in the permit, we believe this update
sufficient for winter heating of the offices and warehouse. Actual usage of the space heating equipment is expected to be below maximum design except during extreme weather conditions.

GHG Emissions: CO2e calculations have been added, as requested, using the 5th GHG Protocol (see attached), including use of global warming potential for methane and N2O. Total PTE

HVAC BACT: The HVAC contractor indicated that the natural gas heating unit efficiencies are 92% which is state-of-the-art and among the best for commercial warehouse operations. Use o
efficiency design would be considered BACT for these units. There are no add-on NOx controls for units of this size that are used in the industry or that would be cost-effective as add-on tech

HAP Emissions from HVAC: AP-42 Table 1.4-3 was reviewed for HAP emissions from natural gas combustion. Factors for individual HAPs, are very low and emissions are negligible to de
3).

Emisson Sources - VOC and HAP Emission Factors:

We used 2021 complete production and VOC/HAP data from our vendor reports to estimate future maximum VOC and HAP emissions at the maximum possible production rate (projected fro
throughput). The ratio of 842,000 MSF/219,451 MSF is 3.84x. The table below provides a summary of that data and the projected (PTE) emissions in units of lbs/yr and tons/yr.

1/10/24, 12:05 PM State of Utah Mail - PCA Specialty Sheet Plant Information Request 12-21-23
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1787281609005316549&simpl=msg-f:1787281609005316549 2/2

PM Emissions Calculations and Vendor Information on the Scrap System Baghouse:

Information was provided by Air System Design Engineers (see attached). The scrap system is comprised of a cyclone separator followed by a best in industry Camfil God Series X-FLO bagh
series air filtration system. The first filter media in the baghouse is the HemiPleat eXtreme Technology Green with MERV 15 filter with efficiency rating of 99.995% on particles 0.5 microns an
MERV 14 with efficiency rating of 95% for particles 1 micron and larger. Vendor filter and equipment documents are attached to this email.

Permit Organization:
We’re ok with the filter plant having its own VOC tracking requirement. We’d like to take a quick review with you when the draft is available at your earliest convenience.

I hope this provides adequate response to your questions and information needs. Please let me know if have questions or you’d like to further discuss or need additional information.

Thanks,
[Quoted text hidden]
3 attachments
Global-Warming-Potential-Values - 5th (Feb 16 2016)_1.pdf
79K
AP-42 Natural Gas Combustion Emissions Factors.pdf
187K
PCA SLC Baghouse and Filter Performance Specs.pdf
1479K
12/21/23, 3:05 PM State of Utah Mail - Packaging Corporation of America South Plant Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1784125979199119627&simpl=msg-f:1784125979199119627 1/4
Dylan Frederick <[e-mail]>
Packaging Corporation of America South Plant Information Request
Garber, Rich D <[e-mail]>Fri, Dec 1, 2023 at 4:58 PM
To: Dylan Frederick <[e-mail]>
Cc: "Campbell, Cody" <[e-mail]>, "Wilson, Lyle" <[e-mail]>
Dylan – With regard to the mailing address and physical address for the co-located plants, here is the current mailing address and
physical address for the Full Line Corrugated Plant at Salt Lake South from the Air Permit:

Mailing Address Physical Address
4654 West 1525 South 4654 West 1525 South
Salt Lake City, UT 84104 Salt Lake City, UT 84104-5332

The addition of the Salt Lake Sheet Plant at the site will be denoted with “Suite A” at the above address. The Full Line
Plant (existing) will be denoted with “Suite B” at the above address.

As far as the permit nomenclature and naming conventions, we thought “Sheet Plant” and “Full Line Plant” would be good
names to use to differentiate the operations.

In response to your initial email and questions, we would respectfully suggest the following edits for your consideration
(please let me know if you want us to do a redline from a Word document and we will be happy to mark it up that way). If
you had something different in mind, we are open to other suggestions:

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT
Hurst
Rating: 25.2 MMBtu/hr Fuel: Natural Gas

II.A.3 One (1) Storage Silo
Controls: fabric filter dust collector
12/21/23, 3:05 PM State of Utah Mail - Packaging Corporation of America South Plant Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1784125979199119627&simpl=msg-f:1784125979199119627 2/4
II.A.4 Two (2) Cyclonic Separators – Full Line Plant
Cyclone 1
Controls: trimmings and scrap from plant corrugating and converting
operations
Cyclone 2
Controls: Printing Operation - Mitsubishi EVOL 4FGR
*New
One (1) Cyclonic Separator – Sheet Plant
Controls: trimmings and scrap from plant converting operations

II.A.5 One (1) Pneumatic Conveying System – Full Line Plant
One (1) Pneumatic Conveying System – Sheet Plant
II.A.6 One (1) Flexographic Printing Operation – Full Line Plant
Controls: Use of low VOC content, water-based inks, and cyclone
One (1) Flexographich Printing Operation – Sheet Plant
Controls: Use of low-VOC content, water based inks,
DAQE-AN114910008-20
Page 6

II.A.7 Various Boilers/Comfort Heating Devices – Full Line and Sheet
Plant
Rating: less than 5 MMBtu/hr each
*listed for informational purposes only
II.A.8 Various Mobile Equipment Items
*listed for informational purposes only

SECTION II: SPECIAL PROVISIONS
12/21/23, 3:05 PM State of Utah Mail - Packaging Corporation of America South Plant Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1784125979199119627&simpl=msg-f:1784125979199119627 3/4
Comment: we assume these will be updated with new site total.
II.B REQUIREMENTS AND LIMITATIONS
[R307-401-8]

BACT – Estimated Cost of Add-On VOC Control

Add-on (large) Thermal Oxidizer for 110,000 CFM Maximum (after Baghouse): $1.5 MM
Gas Connections and Controls: $0.5 MM
Total Estimated Capital: $2.0 MM
Annual Operating Cost (System Maintenance, Gas): $100,000
Collateral dis-benefits: GHG emissions from operation of the thermal oxidizer

Maximum Estimated VOC Control: 1.8 Tons/Yr.

Evaluating this over a 10 year period yields a per ton estimated cost of more than $150,000 per ton of VOC controlled
[2.0MM + (100k/yr*10 yrs)]/(1.8 tons/yr * 10 yrs) = $167k/ton

Conclusions:
Control of VOC from water-based flexographic printing is not cost-effective or economically feasible for the plant.
Control of VOC from water-based flexographic printing in not routine within the industry.

I will propose a time for Tuesday next week for Cody and I to talk with you via Teams. Please let me know if that will not
suit your schedule. We are happy to review a draft permit with you as soon as possible. Our project schedule is of critical
importance to the company and your help as always is greatly appreciated.
12/21/23, 3:05 PM State of Utah Mail - Packaging Corporation of America South Plant Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1784125979199119627&simpl=msg-f:1784125979199119627 4/4

Please let me know if you have any questions.

Best Regards,
[Quoted text hidden]