DAQ-2024-008228

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DAQC-517-24
Site ID 11767 (B1)
MEMORANDUM

TO: FILE – GENPAK

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joseph Randolph, Environmental Scientist III

DATE: May 28, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Iron County,
FRS ID# UT0000004902100036

INSPECTION DATE: May 15, 2024

SOURCE LOCATION: 2791 West Highway 56, Cedar City, UT

SOURCE CONTACTS: Jeff Veater, Maintenance Manager: 435-865-7025, ext. 108
Richard Dawson, Plant Manager: 435-865-7025, ext. 211
Toni Cornforth, EHS Manager: 435-865-7025, ext. 111

Mailing address:
Genpak Corporation
2791 West Highway 56
Cedar City, UT 84720

OPERATING STATUS: Operating

PROCESS DESCRIPTION:

Plastic Molding. Isopentane and butane are received by rail cars and tank truck. The fumes from
unloading are recycled back into the rail cars and tank trucks. Virgin polystyrene pellets are brought in
by rail or truck and offloaded pneumatically into storage silos. Polystyrene from the process is reclaimed
and then reformed in to pellets and pneumatically loaded into one of twelve storage silos. The virgin and
recycled pellets are gravity fed through ducts to one of six extrusion lines. At the line, the pellets are fed
to a heat unit that creates a liquid, and then to a mixing area where isopentane and/or butane is added as a
blowing agent. Different blowing agents are used based on final use of the containers. This mix then
goes through a forced air unit and over a pre-sized die which determines thickness of the styrofoam. As
the stream blows over the die, it cools, thickens, and solidifies. The solid material runs over a cutter
which cuts the roll and forms it flat over several sets of rollers. The rolls are taken off the rollers and
stored for aging for three to seven days. The aged rolls are then placed on feed rollers on the
molding/forming lines. There are 6 molding lines. The styrofoam is rolled out over dies and cut into
strips. The strips go into a molding oven which heats and then presses the material to the correct shape
and size. The finished strips are then sent over a drop area where the scrap is blown off and falls into a
shredder and duct collector. The finished products are then dropped into a pile and hand packed in boxes.
The boxes are placed on a conveyor and sent to a warehouse for storage and delivery by truck as needed.
The scrap material is ducted to silos, and then to the repelletizer. The silos are each equipped with a top
side, pulse jet baghouse. Emissions from the repelletizers are ducted to a natural gas fired thermal
oxidizer unit for VOC destruction.

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East Building. Plastic is brought in by truck and offloaded pneumatically to one of two silos. Scrap from
the silos and material from the polyethylene terephthalate (PET) silos is pneumatically sent to a
crystallizer and scrap dyer natural gas heater to melt the product. The exhaust from the dryer and
crystallizer go to a common vent and outside stack. The melted product is sent to a thermoformer with
trim grinders where it is heated and formed into products and then trimmed. The exhaust and scrap from
the hermoformer/trimmers go to one of four inside scrap bins. The four internal and two external fluff
(scrap) silos have baghouse controls. This building has ceased operations and is planned for sale
July 2024.

APPLICABLE REGULATIONS: Title V permit No. 2100036004, dated February 12, 2020

SOURCE INSPECTION
EVALUATION:

SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements." (R307-415-6b)

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status: In Compliance. The permittee appeared to be operating in compliance with this permit. See
status of each condition below for details.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that
the Director may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this
permit. Upon request, the permittee shall also furnish to the Director copies of records
required to be kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))
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I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause.
The filing of a request by the permittee for a permit modification, revocation and
reissuance, or termination, or of a notification of planned changes or anticipated
noncompliance shall not stay any permit condition, except as provided under
R307-415-7f(1) for minor permit modifications. (R307-415-6a(6)(c))

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late
application. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: In Compliance. This permit expires on February 12, 2025. Renewal Application is due on
August 12, 2024.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the Director
takes final action on the permit renewal application. In such case, the terms and conditions
of this permit shall remain in force until permit renewal or denial. This protection shall
cease to apply if, subsequent to the completeness determination required pursuant to
R307-415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the
deadline specified in writing by the Director any additional information identified as being
needed to process the application. (R307-415-7b(2))

Status: In Compliance. This permit expires on February 12, 2025. Renewal Application is due on
August 12, 2024.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: Not Evaluated. This is a statement of fact and not an inspection item.

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I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: In Compliance. The DAQ mail log shows the annual inventory emission fee was received
September 19, 2023.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-415-6a(8))

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related
activity is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements.
(R307-415-6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: In Compliance. This inspection was completed during business hours. All requested records
were provided.

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I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible
official as defined in R307-415-3. This certification shall state that, based on information
and belief formed after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307-415-5d)

Status: In Compliance. All records were certified and signed by the designated official during this
inspection cycle.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

I.L.1.b The identification of the methods or other means used by the permittee for determining the
compliance status with each term and condition during the certification period. Such
methods and other means shall include, at a minimum, the monitoring and related
recordkeeping and reporting requirements in this permit. If necessary, the permittee also
shall identify any other material information that must be included in the certification to
comply with section 113(c)(2) of the Act, which prohibits knowingly making a false
certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period covered
by the certification, including whether compliance during the period was continuous or
intermittent. The certification shall be based on the method or means designated in
Provision I.L.1.b. The certification shall identify each deviation and take it into account in
the compliance certification. The certification shall also identify as possible exceptions to
compliance any periods during which compliance is required and in which an excursion or
exceedance as defined under 40 CFR Part 64 occurred; and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director:
(R307-415-6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In Compliance. The annual certification was last submitted April 10, 2024,
(due April 15, 2024) and is reviewed under a separate cover.
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I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this permit, or
(R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed in this
permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-112, and
the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110 prior to
or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA Section
408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the Director to obtain information from the source under Utah Code Ann.
Section 19-2-120, and the ability of the EPA to obtain information from the source under
the CAA Section 114. (R307-415-6f(3)(d))

Status: In Compliance. No permit shields are in force at this time (see III.A below).

I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
the extent caused by improperly designed equipment, lack of preventive maintenance,
careless or improper operation, or operator error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to minimize
levels of emissions that exceeded the emission standards, or other requirements in this
permit. (R307-415-6g(3)(c))
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I.N.2.d The permittee submitted notice of the emergency to the Director within two working days
of the time when emission limitations were exceeded due to the emergency. This notice
must contain a description of the emergency, any steps taken to mitigate emissions, and
corrective actions taken. This notice fulfills the requirement of Provision I.S.2.c below.
(R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (R307-415-6g(4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (R307-415-6g(5))

Status: In Compliance. No emergencies have been reported during the previous 12 months. Genpak
is aware of breakdown requirements.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be retained by the
permittee for a period of at least five years from the date of the monitoring sample,
measurement, report, or application. Support information includes all calibration and
maintenance records, all original strip-charts or

appropriate recordings for continuous monitoring instrumentation, and copies of all reports
required by this permit. (R307-415-6a(3)(b)(ii))

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I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the source shall
record the following information, where applicable: (R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more frequently
if specified in Section II. All instances of deviation from permit requirements shall be
clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a responsible official
in accordance with Provision I.K of this permit. (R307-415-6a(3)(c)(i)

I.S.2.c The Director shall be notified promptly of any deviations from permit requirements
including those attributable to upset conditions as defined in this permit, the probable cause
of such deviations, and any corrective actions or preventative measures taken. Prompt, as
used in this condition, shall be defined as written notification within the number of days
shown under "Enforceable Dates and Timelines" at the front of this permit. Deviations
from permit requirements due to breakdowns shall be reported in accordance with the
provisions of R307-107. (R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be submitted to the
Director are to be sent to the following address or to such other address as may be required
by the Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b All reports, notifications or other submissions required by this permit to be submitted to the
EPA should be sent to one of the following addresses or to such other address as may be
required by the Director:

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For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Office of Partnerships and Regulatory Assistance Air and Radiation Program
(mail code 8P-AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In Compliance. Records are retained for at least 5 years. Monitoring reports are submitted
every six months. No deviation reports have been received in the past year. Six-month
reports were submitted and reviewed by DAQ under separate cover.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a remaining
permit term of three or more years. No such reopening is required if the effective date of
the requirement is later than the date on which this permit is due to expire, unless the terms
and conditions of this permit have been extended pursuant to R307-415-7c(3), application
shield. (R307-415-7g(1)(a))

I.T.1.b The Director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other terms or
conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to assure
compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date of this
permit and are in conflict with existing permit conditions. (R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit.
(R307-415-7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: Not Evaluated. This is a statement of fact and not an inspection item.

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I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

Status: In Compliance. Review of SLEIS shows inventories have been submitted as required.

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both
provisions shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: Not Evaluated. This is a statement of fact and not an inspection item.

SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2 GPW Building - Polystyrene Foam Extruder Lines
Six (6) extrusion lines, two extruders on each line. Designated as emission unit S-1a and b, S-2a
and b, and S-3a and b. Powered by Electricity. No unit specific applicable requirements.

II.A.3 GPW Building – Fifteen (15) Storage Silos
Twelve (12) "fluff" storage silos with baghouses/bin vents (recycled polystyrene pellets and
recycled scrap) and three (3) storage silos with bin vents (virgin polystyrene pellets). Designated
as emission units S-5a thru S-5p.

II.A.4 GPW Building - Isopentane Storage Tank
Approximately 30,000 gallon storage tank for Isopentane which is used as a blowing agent.
Designated as emission unit S-9. No unit specific applicable requirements.

II.A.5 GPW Building - Thermal Oxidizer
This is a 2-canister regenerative thermal oxidizer. It controls process streams from the two (2)
repelletizers (S-7a and b) and the two (2) white fluff silos (S-5o and S-5p). Designated as unit S-8.
Minimum 5000 SCFM, natural gas fired only.

II.A.6 GPW Building - Butane Storage Tank
Approximately 7,125 gallon storage tank for Butane which is used as a blowing agent. Designated
as emission unit S-10. No unit specific applicable requirements.

II.A.7 GPW Building - Isopentane and Butane Vapor Recovery System
During transfer to storage tanks, vapors are passed back to the rail tank to prevent gaseous
emissions to the atmosphere. Designated as emission unit S-8. No unit specific applicable
requirements.

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II.A.8 GPW Building – Two (2) 6" Scrap Repellitizer Units
Scrap material is melted and repelletized for use as recycled material. Designated as emission unit
S-10. No unit specific applicable requirements.

II.A.9 GPW Building - Comfort heaters
Various heaters each with rated capacity less than 5 MMbtu/hr. The total maximum capacity from
all heaters is less than 9 MMBtu/hour. Equipped to burn natural gas only. Designated as emission
unit heaters. No unit specific applicable requirements.

II.A.10 GPW Building - Cup Plant - Small Heating Units
Two (2) Direct fired make-up air/heating units with a max rating of 1.0 MMBtu/hr each. Seven (7)
Direct fired make-up air/heating units with a max rating of 15,000 Btu/hr each. Two (2) HVAC
units with a max rating of 360,000 Btu/hr each, designated as units Htr #1 & Htr #2. Five (5) Rim
roasters with a max rating of 16,200 Btu/hr each, designated as units RR #1 thru RR #5. Three (3)
Cup pre-treatment heating units with a max rating of 3,240 Btu/hr each, designated PT #1 thru PT
#3. Natural gas fired only. No unit specific applicable requirements.

II.A.11

GPW Building - Cup Plant - Pellet Silos
Two (2) Exterior virgin silos with polypropylene pellets. One (1) Exterior virgin silo with
polystyrene pellets. One (1) Interior virgin silo with polystyrene/calcium carbonate hybrid pellets.
Three (3) Interior scrap fluff silos with baghouses which vent indoors. None of these silos exhaust
to the atmosphere. No unit specific applicable requirements.

II.A.12 GPW Building - Cup Plant - Extruders
Three (3) cup manufacturing extruders. Designated as unit D100, D140, and E100. Powered by
electricity. No unit specific applicable requirements.

II.A.13 GPW Building - Cup Plant - Thermoformers
Two (2) cup manufacturing thermoformers. Powered by electricity. Designated as units F86 &
F87. No unit specific applicable requirements.

II.A.14 GPW Building - Cup Plant - Printers
Five (5) Ink Printers. No unit specific applicable requirements.

II.A.15 GPW Building - Electric Thermoformers
No unit specific applicable requirements.

II.A.16 GPW Building - Grinders
Seventeen (17) grinders. Eleven rated at 750 lbs/hr and six rated at 1500 lbs/hr. Grinders are
exhausted to either interior or exterior silos controlled via baghouse.

II.A.17 GPE Building - Extruders
Five (5) extrusion lines. Each extrusion line has co-extruders. All are powered by electricity. The
extruders are exhausted to the scrap silos. No unit specific applicable requirements.

II.A.18 GPE Building - Grinder
Ten (10) grinders. One rated at a maximum of 1,000 lbs/hr, eight rated at a maximum of 2,000
lbs/hr, and one rated at a maximum of 5,000 lbs/hr. Exhausted to interior/exterior silos controlled
via baghouses.

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II.A.19 GPE Building - Scrap Silos
Five (5) internal scrap fluff silos with baghouses.

II.A.20 GPE Building - Fluff Silos
Four (4) exterior fluff silos with baghouses.

II.A.21 GPE Building - PET Silos
Four (4) exterior plastic pellet virgin silos (no exhaust point). No unit specific applicable
requirements.

II.A.22 GPE Building - PET Dryer
Two (2) natural gas fired PET hopper dryers. One (1) with a maximum rating of 154,000 Btu/hr,
one (1) with a maximum rating of 597,000 Btu/hr.

II.A.23 GPE Building - Natural Gas Heaters
Twenty Six (26) natural gas fired heaters each with a maximum rating of 175,000 Btu/hr.
Designated as emission units AH1 thru AH26.

II.A.24 GPE Building - Thermoformers
Nine (9) electric thermoformers with trim grinders which vent to interior silos. No unit specific
applicable requirements.

II.A.25 GPE Building - Crystallizer
Two (2) enclosed crystallizers and mixing chambers. One (1) with a maximum rating of 150,000
Btu/hr and one (1) with a maximum rating of 373,000 Btu/hr. No unit specific applicable
requirements.

II.A.26 GPE Building - Scrap Dryer
One (1) scrap dryer with maximum rating of 1540,000 BTU/hr. Designated as unit SD-1,
exhausted to a common stack EF-2. Natural gas fired.

Status: In Compliance. No excess equipment noted.
II.A.10-14 – Cup plant is mostly removed and area is used for storage.
II.A.17-26 – The East building has ceased operation and all equipment removed and building is
being sold off as of July 1, 2024.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted
facility as indicated:

II.B.1 Conditions on permitted source (Source-wide).

II.B.1.a Condition:

A Risk Management Plan (RMP) developed in accordance with 40 CFR Part 68 shall be submitted
to the United States Environmental Protection Agency not later than the applicable date in
40 CFR 68.10(a). [Authority granted under 40 CFR 68; condition originated in 40 CFR Part 68]

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II.B.1.a.1 Monitoring:

A copy of the Risk Management Plan shall be available upon request along with a copy of the
transmittal letter to EPA.

II.B.1.a.2 Recordkeeping:

A copy of the Risk Management Plan shall be available to the Director upon request along with a
copy of the transmittal letter to EPA.

II.B.1.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. The most recent RMP revision was in September 2020. Genpak certifies compliance
with this condition.

II.B.1.b Condition:

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the
extent practicable, maintain and operate any permitted plant equipment, 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. [Authority granted under R307-401-8(2);
condition originated in DAQE-AN117670014-18]

II.B.1.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.b.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. The plant appeared to be well maintained. A work order system is in place to track
maintenance. The plant is utilizing an electronic database system.

14
II.B.1.c Condition:

Emissions of the blowing agent (Non-HAP VOC's) shall not exceed 191.92 tons per rolling 12-
month period. This includes the VOC emissions resulting from up to 10 days of maintenance and
repair time during which the thermal oxidizer may be inoperable. The blowing agents are
isopentane and butane. [Authority granted under R307-401-8; condition originated in
DAQE-AN117670014-18]

II.B.1.c.1 Monitoring:

The amount of blowing agent (Non-HAP VOC) emitted shall be calculated as 37.4% of total
blowing agent consumed. Consumption records shall be maintained for all periods of operation.
By the twentieth day of each month, a new 12-month total shall be calculated using data from the
previous 12 months. Calculation of emissions from the thermal oxidizer shall include 80% of
emissions from the two repelletizer lines, S-7a and S-7b, and the vents from two white fluff silos,
S-5o and S-5p, using a destruction efficiency of 98.5%.

II.B.1.c.2 Recordkeeping:

Results of monitoring shall be maintained as described in Provision I.S.1 of this permit.

II.B.1.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. For the 12-month rolling period ending April 30, 2024, for tons of blowing agent
(Non-HAP VOC) was 58.92 tons. Records confirm compliance.

II.B.1.d Condition:

Visible emissions shall be no greater than 20 percent opacity unless otherwise specified in this
permit. [Authority granted under R307-401-8; condition originated in DAQE-AN117670014-18]

II.B.1.d.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director. If visible emissions other than
condensed water vapor are observed from an emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial survey. The
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for point sources, and in
accordance 58 FR 61640 Method 203A, or other EPA-approved testing method, as acceptable to
the Director, for fugitive sources.

II.B.1.d.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of this
permit. If an opacity determination is indicated, a notation of the determination will be made in the
log. All data required by 40 CFR 60, Appendix A, Method 9 or 58 FR 61640 Method 203A, or
15
other EPA-approved testing method, as acceptable to the Director, shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.1.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. No visible emissions were observed during this inspection. Records confirm that
monthly opacity surveys are completed. Review of records show proper methods used and forms
show all required items.

II.B.1.e Condition:

The permittee shall comply with the applicable requirements for recycling and emission reduction
for class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions
Reduction. [Authority granted under 40 CFR 82.150(b); condition originated in 40 CFR Part 82
Subpart F]

II.B.1.e.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart F.

II.B.1.e.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.e.3 Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In Compliance. The annual certification certifies compliance with this condition. All work is done
by third party.

II.B.1.f Condition:

The permittee shall comply with the applicable requirements for servicing of motor vehicle air
conditioners pursuant to 40 CFR 82, Subpart B - Servicing of Motor Vehicle Air Conditioners.
[Authority granted under 40 CFR 82.30(b); condition originated in 40 CFR 82]

II.B.1.f.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this permit,
its compliance status with the requirements of 40 CFR 82, Subpart B.

16
II.B.1.f.2 Recordkeeping:

All records required in 40 CFR 82, Subpart B shall be maintained consistent with the requirements
of Provision S.1 in Section I of this permit.

II.B.1.f.3 Reporting:

All reports required in 40 CFR 82, Subpart B shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In Compliance. The annual certification certifies compliance with this condition. All work is done
by third party.

II.B.1.g Condition:

Visible emissions shall be no greater than 10 percent opacity from each natural gas fuel
combustion exhaust point. [Authority granted under R307-401-8; condition originated in
DAQE-AN117670014-18]

II.B.1.g.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.g.2 Recordkeeping:

In lieu of visible emissions observations, records of fuel usage shall be maintained consistent with
the requirements of Provision I.S.1 of this permit to demonstrate that only natural gas is being
burned.

II.B.1.g.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. The company certifies only natural gas use in the annual certification and no
connections other than natural gas were observed.

II.B.2 Conditions on GPW Building – Fifteen (15) Storage Silos.

II.B.2.a Condition:

Visible emissions shall be no greater than 10 percent opacity from each baghouse. [Authority granted
under R307-401-8; condition originated in DAQE-AN117670014-18]

II.B.2.a.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly basis by
an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9, or
other EPA-approved testing method, as acceptable to the Director. If visible emissions other than
condensed water vapor are observed from an emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial survey. The
17
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for point sources, and in
accordance 58 FR 61640 Method 203A, or other EPA-approved testing method, as acceptable to
the Director, for fugitive sources.

II.B.2.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 or 58 FR 61640 Method
203A, or other EPA-approved testing method, as acceptable to the Director, shall be maintained
in accordance with Provision I.S.1 of this permit.

II.B.2.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. No visible emissions were observed from GPW during this inspection. Records
confirm that monthly opacity surveys were completed in the past year.

II.B.3 Conditions on GPW Building - Thermal Oxidizer.

II.B.3.a Condition:

Operating temperature shall be no less than 1,360 degrees F. [Authority granted under R307-401-
8; condition originated in DAQE-AN117670014-18]

II.B.3.a.1 Monitoring:

The operating temperature shall be continuously monitored and recorded. The monitoring
equipment shall be located such that an inspector can at any time safely read the output. All
instruments shall be calibrated against a certified primary standard at least once a year.

II.B.3.a.2 Recordkeeping:

Records of monitoring and calibration shall be maintained as described in provision I.S.1 of this
permit.

II.B.3.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. The Thermal Oxidizer temperature is continuously recorded by way of a chart
recorder, a digital recorder, and a SCADA recorder. The temperature output was located such that
it could be safely read. The thermocouple is calibrated by a third party annually. Last calibrations
were done during Thanksgiving week shutdown. The temperature of the Thermal Oxidizer at the
time of this inspection was 1,450 degrees F average.

18
II.B.3.b Condition:

Emissions of VOC shall be not greater than 1.05 lb/hr. [Authority granted under R307-401-8;
condition originated in DAQE-AN117670014-18]

II.B.3.b.1 Monitoring:

(a) Stack testing to show compliance with the VOC emission limitations shall be performed as
specified below:

(1) Testing and Frequency. Emissions shall be tested every five years based on the date of
the last stack test. The source may also be tested at any time if directed by the Director.

(2) Notification. The Director shall be notified at least 30 days prior to conducting any
required emission testing. A source test protocol shall be submitted to DAQ when the
testing notification is submitted to the Director. The source test protocol shall be
approved by the Director prior to performing the test(s). The source test protocol shall
outline the proposed test methodologies, stack to be tested, and procedures to be used. A
pretest conference shall be held, if directed by the Director, between the owner/operator,
the tester, and the Director.

(3) Methods.

(A) Sample Location - the emission point shall conform to the requirements of 40 CFR
60, Appendix A, Method 1, and Occupational Safety and Health Administration
(OSHA) approved access shall be provided to the test location.

(B) 40 CFR 60, Appendix A, Method 25 or 25A, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine volatile organic
compounds emission rate.

(C) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.

(4) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration
as determined by the appropriate methods above shall be multiplied by the volumetric
flow rate and any necessary conversion factors determined by the Director to give the
results in the specified units of the emission limitation.

(5) Production Rate During Testing. The production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three (3) years.

(b) The permittee shall monitor the thermal oxidizer temperature and work practice standards as
indicators to provide reasonable assurance of compliance with the VOC emission limitation.

(1) Measurement Approach:

(A) Primary Indicator: The permittee shall continuously measure the thermal oxidizer
chamber temperature by a thermocouple.

19
(B) Secondary Indicator: The permittee shall follow good work practices, including
daily inspections of the chart recorded, weekly inspections of the thermal oxidizer,
and annual inspections of the thermal oxidizer.

(2) Indicator Range:

(A) Primary Indicator: An excursion is defined as a temperature less than 1,410 degrees
F that is outside the range as approved by the Director. Excursions trigger an
inspection, corrective action to return the operating temperature to 1,410 degrees F
or more, and a reporting requirement.

(B) Secondary Indicator: An excursion is defined as an omission to perform the daily
inspection of the chart recorder, weekly inspection of the thermal oxidizer and
replacement of the circular chart, and annual inspections of the thermal oxidizer.
Excursions trigger an inspection, corrective action, and a reporting requirement.

(3) Performance Criteria:

(A) Data Representativeness:

i. Primary Indicator: The thermal oxidizer temperature shall be measured using a
thermocouple located in the oxidizer chamber. The minimum tolerance of the
thermocouple is ± 10.5º F or ± 0.75%. The minimum chart recorder sensitivity
(minor division) is 20º F or as approved by the Director.

ii. Secondary Indicator: Not applicable.

(B) QA/QC Practices and Criteria: The accuracy of the thermocouple shall be verified
annually by a third party supplier with the calibration performed according to the
manufacturer's recommendation. The data acquisition system shall be operated and
maintained according to the manufacturer's recommendations.

(C) Monitoring Frequency:

i. Primary Indicator: The thermal oxidizer temperature shall be measured
continuously.

ii. Secondary Indicator: Daily inspection of the temperature chart recorder. Weekly
inspection of the thermal oxidizer. Annual inspection of the thermal oxidizer.

(D) Data Collection Procedure:

i. Primary Indicator: Record continuously on a circular chart recorder.

ii. Secondary Indicator: Record results of daily and weekly inspections; Record
results of annual inspection by third party supplier. Preventive maintenance
records by the maintenance department on the thermal oxidizer log book.

(E) Averaging Period:

i. Primary Indicator: 1 hour block average.
ii. Secondary Indicator: Not Applicable

(c) Once every five years, during the stack test required in (a) above, the permittee shall acquire
new test data to evaluate or update the indicator range and excursion level for the indicators.
20
Any resultant changes to the monitoring shall be addressed in accordance with 40 CFR
64.7(e).

II.B.3.b.2 Recordkeeping:

In addition to the recordkeeping requirement described in Provision I.S.1 of this permit,

(a) The permittee shall maintain a file of all stack testing and all other information required by
permit provision I.S.1.

(b) The permittee shall maintain a file of continuous monitor measurements, including
performance testing measurements, all performance evaluations, all calibration checks, all
adjustments, and maintenance.

(c) The permittee shall maintain a file of the occurrence and duration of any excursion, corrective
actions taken, and any other supporting information required to be maintained under 40 CFR
64 (such as data used to document the adequacy of monitoring, or records of monitoring
maintenance or corrective actions). Instead of paper records, the permittee may maintain
records on alternative media, such as microfilm, computer files, magnetic tape disks, or
microfiche, provided that the use of such alternative media allows for expeditious inspection
and review, and does not conflict with other applicable recordkeeping requirements. (40 CFR
64.9(b))
II.B.3.b.3 Reporting:

(a) The monitoring report required in Provision I.S.2 of this permit shall include, at a minimum,
the following information, as applicable:

(1) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions
taken;(40 CFR 64.9(a)(2)(i))

(2) Summary information on the number, duration and cause (including unknown cause, if
applicable) for monitor downtime incidents (other than downtime associated with zero
and span or other daily calibration checks, if applicable). (40 CFR 64.9(a)(2)(ii))

(b) The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status.

Status: In Compliance. Stack testing was last conducted on November 17-18, 2021. Testing was reviewed in
DAQC-357-23, with results of 1.01 lb/hr VOC. Test results were submitted late to DAQ (see memo
for details). Genpak meets Compliance Assurance Monitoring by continuously monitoring the
Thermal Oxidizer temperature. The accuracy of the thermocouple is verified annually by a third-
party calibration. A circular chart recorder is used as the primary indicator to continuously
measure the Thermal Oxidizer temperature. Good work practices are followed as the secondary
indicator. The chart recorder appears to meet the data representativeness requirements. Daily,
weekly, and annual inspections of the thermal oxidizer are used for the secondary indicator.
Required records are kept to verify compliance. No excursions (except TO temp) have been
reported in the past year. Next testing is due in 2026.

21
II.B.3.c Condition:

Visible emission shall be no greater than 10 percent opacity. [Authority granted under R307-401-8;
condition originated in DAQE-AN117670014-18]

II.B.3.c.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly basis by
an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9, or
other EPA-approved testing method, as acceptable to the Director. If visible emissions other than
condensed water vapor are observed from an emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial survey. The
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for point sources, and in
accordance 58 FR 61640 Method 203A, or other EPA-approved testing method, as acceptable to
the Director, for fugitive sources.

II.B.3.c.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 or 58 FR 61640 Method
203A, or other EPA-approved testing method, as acceptable to the Director, shall be maintained
in accordance with the requirements of Provision I.S.1 of this permit.

II.B.3.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. The Thermal Oxidizer was operating at 0% opacity at the time of this inspection.
Records confirm compliance with the monthly observation requirement.

II.B.4 Condition on GPE Building – Grinder.

II.B.4.a Condition:

Visible emission shall be no greater than 10 percent opacity from exterior baghouses. [Authority
granted under R307-401-8; condition originated in DAQE-AN117670014-18]

II.B.4.a.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly basis by
an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9, or
other EPA-approved testing method, as acceptable to the Director. If visible emissions other than
condensed water vapor are observed from an emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial survey. The
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for point sources, and in
accordance 58 FR 61640 Method 203A, or other EPA-approved testing method, as acceptable to
the Director, for fugitive sources.
22
II.B.4.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 or 58 FR 61640 Method
203A, or other EPA-approved testing method, as acceptable to the Director, shall be maintained
in accordance with the requirements of Provision I.S.1 of this permit.

II.B.4.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. All the GPW Grinders vent to fluff silo ducting.

II.B.5 Conditions on GPE Building - Scrap Silos.

II.B.5.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under
R307-401-8; condition originated in DAQE-AN117670014-18]

II.B.5.a.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly basis by
an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9, or
other EPA-approved testing method, as acceptable to the Director. If visible emissions other than
condensed water vapor are observed from an emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial survey. The
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for point sources, and in
accordance 58 FR 61640 Method 203A, or other EPA-approved testing method, as acceptable to
the Director, for fugitive sources.

II.B.5.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 or 58 FR 61640 Method
203A, or other EPA-approved testing method, as acceptable to the Director, shall be maintained
in accordance with Provision I.S.1 of this permit.

II.B.5.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: GPE (East Building) building operations have ceased. All equipment has been removed or will be
removed by July 2024, as building is being sold.

23
II.B.6 Conditions on GPE Building - Fluff Silos.

II.B.6.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under
R307-401-8; condition originated in DAQE-AN117670014-18]

II.B.6.a.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly basis by
an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9, or
other EPA-approved testing method, as acceptable to the Director. If visible emissions other than
condensed water vapor are observed from an emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial survey. The
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9,
or other EPA-approved testing method, as acceptable to the Director, for point sources, and in
accordance 58 FR 61640 Method 203A, or other EPA-approved testing method, as acceptable to
the Director, for fugitive sources.

II.B.6.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 or 58 FR 61640 Method
203A, or other EPA-approved testing method, as acceptable to the Director, shall be maintained
in accordance with Provision I.S.1 of this permit.

II.B.6.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: GPE (East Building) building operations have ceased. All equipment has been removed or will be
removed by July 2024, as building is being sold.

II.C Emissions Trading
(R307-415-6a(10)

Per Title V permit - Not applicable to this source.

II.D Alternative Operating Scenarios.
(R307-415-6a(9)

Per Title V permit - Not applicable to this source.

II.E Source-specific Definitions.

Per Title V permit - Not applicable to this source.

24
SECTION III: PERMIT SHIELD

III.A Per Title V permit language - A permit shield was not granted for any specific requirements.

SECTION IV: ACID RAIN PROVISIONS

III.A Note: The Condition Number III.A is incorrect. It should be Section IV. Per Title V permit
language - This source is not subject to Title IV. This section is not applicable.

EMISSION INVENTORY: 2023 Emission Inventory Report

2023 Emissions Inventory Report
Genpak Corporation: Polystyrene Foam Production Facility (11767)
Emissions Summary

Pollutant Code/CAS # Pollutant Name Emissions (tons,
excluding tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary(Filt + Cond) 1.06531 <.00001 1.06531
PM10-FIL PM10 Filterable 0.92214 <.00001 0.92214
PM25-PRI PM2.5 Primary(Filt + Cond) 1.04155 <.00001 1.04155
PM25-FIL PM2.5 Filterable 0.92214 <.00001 0.92214
PM-CON PM Condensible 0.11942 <.00001 0.11942
SO2 Sulfur Dioxide 0.01257 <.00001 0.01257
NOX Nitrogen Oxides 1.9693 <.00001 1.9693
VOC Volatile Organic Compounds 71.13358 <.00001 71.13358
CO Carbon Monoxide 0.838 <.00001 0.838
7439921 Lead 0.00001 <.00001 0.00001
NH3 Ammonia 0.31925 <.00001 0.31925

Pollutant Code/CAS # Pollutant Name Is VOC/PM? Total Emissions
(tons)*
7440382 Arsenic (HAP) PM <.00001
71432 Benzene (HAP) VOC 0.00003
7440417 Beryllium (HAP) PM <.00001
7440439 Cadmium (HAP) PM 0.00002
7440473 Chromium (HAP) PM 0.00002
7440484 Cobalt (HAP) PM <.00001
50000 Formaldehyde (HAP) VOC 0.00108
110543 Hexane (HAP) VOC 0.02601
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
25
Pollutant Code/CAS # Pollutant Name Is VOC/PM? Total Emissions
(tons)*
7439965 Manganese (HAP) PM 0.00001
7439976 Mercury (HAP) - <.00001
91203 Naphthalene (HAP) VOC 0.00001
7440020 Nickel (HAP) PM 0.00003
7782492 Selenium (HAP) PM <.00001
108883 Toluene (HAP) VOC 0.00005
91576 2-Methylnaphthalene (HAP) PM <.00001

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions in the past 5 years. Genpak was sent a
request for information for missed Title V certification (2022),
missed semiannual reports (2022, 2023), and missed deviation
reports. The company submitted missing reports and these are
reported separately. No further action was taken.

COMPLIANCE
ASSISTANCE: Additional assistance was provided on requirements of Title V
certification report formats and NOI for removed equipment or
operations.

COMPLIANCE STATUS &
RECOMMENDATIONS: Genpak should be found in compliance with the Conditions of
its Title V Operating Permit at the time of this inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual.

ATTACHMENT: VEO form.