April 30, 2020 Jeremiah Bryant Plant Engineer Manchester Packaging Company 2000 East James Blvd St. James, Missouri 65559 RE: New Source Review Permit - Project Number: 2020-01-022 Dear Jeremiah Bryant: Enclosed with this letter is your permit to construct. Please study it carefully and refer to Appendix A for a list of common abbreviations and acronyms used in the permit. Also, note the special conditions, if any, on the accompanying pages. The document entitled, "Review of Application for Authority to Construct," is part of the permit and should be kept with this permit in your files. Operation in accordance with these conditions, your new source review permit application and with your amended operating permit is necessary for continued compliance. The reverse side of your permit certificate has important information concerning standard permit conditions and your rights and obligations under the laws and regulations of the State of Missouri. This permit may include requirements with which you may not be familiar. If you would like the department to meet with you to discuss how to understand and satisfy the requirements contained in this permit, an appointment referred to as a Compliance Assistance Visit (CAV) can be set up with you. To request a CAV, please contact your local regional office or fill out an online request. The regional office contact information can be found at the following website: http://dnr.mo.gov/regions/. The online CAV request can be found at http://dnr.mo.gov/cav/compliance.htm. If you were adversely affected by this permit decision, you may be entitled to pursue an appeal before the administrative hearing commission pursuant to Sections 621.250 and 643.075.6 RSMo. To appeal, you must file a petition with the administrative hearing commission within thirty days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed; if it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the administrative hearing commission, whose contact information is: Administrative Hearing Commission, United States Post Office Building, 131 West High Street, Third Floor, P.O. Box 1557, Jefferson City, Missouri 65102, phone: 573-751-2422, fax: 573-751-5018, website: www.oa.mo.gov/ahc.

Jeremiah Bryant Page Two

If you have any questions regarding this permit, please do not hesitate to contact Russell Osborne, at the Department of Natural Resources’ Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102 or at (573) 751-4817. Thank you for your attention to this matter. Sincerely, AIR POLLUTION CONTROL PROGRAM Susan Heckenkamp New Source Review Unit Chief SH:roa Enclosures c: Southeast Regional Office PAMS File: 2020-01-022 Permit Number: 042020-012

MISSOURI AIR CONSERVATION COMMISSION

PERMIT TO CONSTRUCT Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to construct the air contaminant source(s) described below, in accordance with the laws, rules and conditions as set forth herein.

Permit Number: 042020-012 Project Number: 2020-01-022 Installation Number: 161-0039

Parent Company: Manchester Packaging Company

Parent Company Address: 2000 East James Blvd, St. James, Missouri 65559

Installation Name: Manchester Packaging Company

Installation Address: 2000 East James Blvd, St. James, Missouri 65559

Location Information: Phelps County, S16, T38N, R6W

Application for Authority to Construct was made for: Installation of a new Soma Optima 2 flexographic printing press equipped with an overhead dryer (EP-18) and a deck dryer (EP-19). This review was conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6.060, Construction Permits Required.

Standard Conditions (on reverse) are applicable to this permit.

Standard Conditions (on reverse) and Special Conditions are applicable to this permit.

Director or Designee Department of Natural Resources

April 30, 2020 Effective Date

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STANDARD CONDITIONS: Permission to construct may be revoked if you fail to begin construction or modification within two years from the effective date of this permit. Permittee should notify the Enforcement and Compliance Section of the Air Pollution Control Program if construction or modification is not started within two years after the effective date of this permit, or if construction or modification is suspended for one year or more. You will be in violation of 10 CSR 10-6.060 if you fail to adhere to the specifications and conditions listed in your application, this permit and the project review. In the event that there is a discrepancy between the permit application and this permit, the conditions of this permit shall take precedence. Specifically, all air contaminant control devices shall be operated and maintained as specified in the application, associated plans and specifications. You must notify the Enforcement and Compliance Section of the Department’s Air Pollution Control Program of the anticipated date of start up of this (these) air contaminant source(s). The information must be made available within 30 days of actual startup. Also, you must notify the Department’s regional office responsible for the area within which you are located within 15 days after the actual start up of this (these) air contaminant source(s). A copy of the permit application and this permit and permit review shall be kept at the installation address and shall be made available to Department’s personnel upon request. You may appeal this permit or any of the listed special conditions to the Administrative Hearing Commission (AHC), P.O. Box 1557, Jefferson City, MO 65102, as provided in RSMo 643.075.6 and 621.250.3. If you choose to appeal, you must file a petition with the AHC within 30 days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed. If it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the AHC. If you choose not to appeal, this certificate, the project review and your application and associated correspondence constitutes your permit to construct. The permit allows you to construct and operate your air contaminant source(s), but in no way relieves you of your obligation to comply with all applicable provisions of the Missouri Air Conservation Law, regulations of the Missouri Department of Natural Resources and other applicable federal, state and local laws and ordinances. The Air Pollution Control Program invites your questions regarding this air pollution permit. Please contact the Construction Permit Unit using the contact information below.

Contact Information: Missouri Department of Natural Resources

Air Pollution Control Program P.O. Box 176

Jefferson City, MO 65102-0176 (573) 751-4817

The regional office information can be found at the following website:

http://dnr.mo.gov/regions/

Project No. 2020-01-022 Permit No. 042020-012

SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

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The special conditions listed in this permit were included based on the authority granted to the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643.075) and by the Missouri Rules listed in Title 10, Division 10 of the Code of State Regulations (specifically 10 CSR 10-6.060). For specific details regarding conditions, see 10 CSR 10-6.060 paragraph (3)(E). “Conditions required by permitting authority.” Manchester Packaging Company Phelps County, S16, T38N, R6W 1. Superseding Condition

The conditions of this permit supersede all Special Conditions found in the previously issued construction permit, Permit No. 052014-007, issued by the Air Pollution Control Program.

2. VOC Emission Limitations

A. Manchester Packaging Company shall emit less than 250.0 tons of VOCs in any consecutive 12-month period from the entire installation. See all applicable emission points listed below in Table 1. Manchester Packaging Company shall include all actual emissions, including all SSM emissions, in the compliance demonstration calculations for these emission units.

Table 1: Manchester Packaging Company VOC Emissions Points Emission Points Description

EP-01 L-1 Extruder Inline Flexographic Press - Ink L-1 Extruder Inline Flexographic Press – Solvent

EP-02 Portable Inline Flexographic Press – Ink Portable Inline Flexographic Press – Solvent

EP-03 P-3 Flexographic Printing Press – Ink P-3 Flexographic Printing Press – Solvent

EP-04 P-4 Flexographic Printing Press – Ink P-4 Flexographic Printing Press – Solvent

EP-05 Overhead Press Dryer P-5 Flexographic Printing Press – Ink P-5 Flexographic Printing Press – Solvent

EP-06 Deck Press Dryer P-5 Flexographic Printing Press – Ink P-5 Flexographic Printing Press – Solvent

EP-08 Space Heating EP-09 Space Heating EP-12 Space Heating EP-15 Extruders

EP-16 Overhead Press Dryer P-6 Flexographic Printing Press – Ink

EP-16 P-6 Flexographic Printing Press – Solvent EP-17 Deck Press Dryer

Project No. 2020-01-022 Permit No. 042020-012

SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

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Emission Points Description P-6 Flexographic Printing Press – Ink P-6 Flexographic Printing Press – Solvent

EP-18 Overhead Press Dryer P-7 Flexographic Printing Press - Ink P-7 Flexographic Printing Press - Solvent

EP-19 Deck Press Dryer P-7 Flexographic Printing Press - Ink P-7 Flexographic Printing Press - Solvent

B. Attachment A or equivalent forms, such as electronic forms, approved by

the Air Pollution Control Program shall be used to demonstrate compliance with Special Conditions 2.A.

3. Operational Requirement - Solvent/Ink/Cloths

Manchester Packaging Company shall keep the ink solvents and cleaning solutions in sealed containers whenever the materials are not in use. Manchester Packaging Company shall provide and maintain suitable, easily read, permanent markings on all inks, solvents, and cleaning solution containers used with this equipment.

4. Alternative Materials

A. Manchester Packaging Company is allowed to use alternative materials for the emission units listed in Table 1 that are different from the materials listed in the Application for Authority to Construct.

B. The limits established by Special Condition 1 shall include emissions from

the use of any alternative materials. Their emissions shall be accounted for in the recordkeeping associated with these limits.

C. Manchester Packaging Company shall maintain a list of any alternative materials used and the date they are either first purchased or used.

D. Manchester Packaging Company shall maintain a copy of the alternative material’s information and other documentation (such as SDS) used to estimate the emissions.

E. Manchester Packaging Company shall not use any alternative materials

containing HAPs in the P-7 printing press. F. Manchester Packaging Company shall use the highest VOC

concentrations listed on the material’s SDS to calculate and track emissions from the alternative materials.

G. Attachment B or equivalent forms, such as electronic forms, preapproved

Project No. 2020-01-022 Permit No. 042020-012

SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

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by the Air Pollution Control Program shall be used to show compliance with Special Condition 4.B.

5. Record Keeping and Reporting Requirements B. Manchester Packaging Company shall maintain all records required by

this permit for not less than five years and shall make them available to any Missouri Department of Natural Resources’ personnel upon request. These records shall include SDS for all materials used.

C. Manchester Packaging Company shall report to the Air Pollution Control

Program’s Compliance/Enforcement Section, by mail at P.O. Box 176, Jefferson City, MO 65102 or by email at AirComplianceReporting@dnr.mo.gov, no later than 10 days after the end of the month during which any record required by this permit shows an exceedance of a limitation imposed by this permit.

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REVIEW OF APPLICATION FOR AUTHORITY TO CONSTRUCT AND OPERATE SECTION (5) REVIEW

Project Number: 2020-01-022 Installation ID Number: 161-0039 Permit Number: _ 042020-012______________

Installation Address: Parent Company: Manchester Packaging Company Manchester Packaging Company 2000 East James Blvd 2000 East James Blvd St. James, Missouri 65559 St. James, Missouri 65559

Phelps County, S16, T38N, R6W

REVIEW SUMMARY • Manchester Packaging Company has applied for authority to install a new Soma

Optima 2 flexographic printing press, equipped with two natural gas fired dryers. The new flexographic printer will be label as P-7

• The application was deemed complete on January 21, 2020.

• The Soma Optima 2 flexographic printer has and MHDR for ink, solvent, and natural

gas combustion of 11.3 lbs, 29.3 lbs, and 0.7 MMBtu, respectively. • HAP emissions are expected from the combustion of natural gas in the overhead

and deck dryer (EP-18 and EP-19). Per material SDS, no HAP emissions are expected form the use of inks and solvents.

• None of the New Source Performance Standards (NSPS) apply to the installation.

Subpart DDD, VOC Emissions from the Polymer Manufacturing Industry, does not apply to the installation as the installation does not manufacture polyethylene. The installation receives pellets of polyethylene by rail.

• None of the NESHAPs apply to this installation.

• None of the currently promulgated MACT regulations apply to the proposed

equipment. 40 CFR Subpart 63 National Emission Standards for Hazardous Air Pollutants for Source Categories, Subpart KK, National Emissions Standards for Printing and Publishing Industry does not apply to this facility as it is an area source of HAPs.

• No air pollution control equipment is being used in association with the new

equipment. • This review was conducted in accordance with Section (5) of Missouri State Rule

10 CSR 10-6.060, Construction Permits Required. Potential emissions of VOCs are

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conditioned below NSR major source levels of 250 tons per year. • This installation is located in Phelps County, an attainment/unclassifiable area for all

criteria pollutants. • This installation is not on the List of Named Installations found in 10 CSR 10-

6.020(3)(B), Table 2. The installation's major source level is 250 tons per year and fugitive emissions are not counted toward major source applicability.

• Ambient air quality modeling was not performed for this review. No model is

currently available which can accurately predict ambient ozone concentrations caused by this installation's VOC emissions.

• Emissions testing is not required for the equipment as a part of this permit. Testing

may be required as part of other state, federal or applicable rules. • An application to amend the Part 70 Operating Permit application is required for this

installation within 1 year of equipment startup. • Approval of this permit is recommended with special conditions.

INSTALLATION DESCRIPTION Manchester Packaging Company is an existing facility specializing in polyethylene film products in St. James, Missouri. The polyethylene film products produced by the installation are printed and unprinted polyethylene film and printed and unprinted polyethylene bags. The installation receives polyethylene resin by rail. The polyethylene resin is unloaded from the railcar by the Railcar Unloader Transfer System (EP-10) and transferred to a resin storage silo. The stored polyethylene resin is transferred to the master blenders by Vacuum Loader 2 (EP-14) and then transferred to the auxiliary blenders by Vacuum Loader 1 (EP-13). After blending, the polyethylene resin is transferred to the Extruder (EP-14) by Hopper Loader Transfer System (EP-11) to produce unprinted polyethylene film. The unprinted polyethylene film is either sold as is or it can be printed and/or formed into bags. The installation operates five flexographic presses (EP-01, EP-02, EP-03, EP-04, EP-05, and EP-06) to print onto the polyethylene film and bags, based upon customer specifications. The installation currently operates under the Part 70 Operating Permit OP2015-002, which expires April 3, 2020. However, a Part 70 Operating Permit renewal application has been received and is currently being reviewed under Project No. 2020-02-013

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Currently, Manchester Packaging Company is a minor source for NSR permitting; accepting a voluntary limit on VOCs of 250 tons per year. The following New Source Review permits have been issued to Manchester Packaging Company from the Air Pollution Control Program. Table 2: Permit History

Permit Number Description 0198-03 3 Flexographic Printing Presses

112012-014 Add Extruders 052014-007 New Flexographic Printing Press

PROJECT DESCRIPTION

Manchester Packaging Company has applied for the Authority to Construct a new Soma Optima 2 flexographic printing press. The printing press will be identified as P-7 (EP-18 and EP-19). The printer will be utilized to print onto the polyethylene film extruded on site. The printing press is equipped with two in-process dryers to dry inks and solvents. One dryer will be the overhead dryer (EP-18). The other is a deck dryer (EP-19) located between the printing decks. The amount of polyethylene film available for print will not be increased as a result of this project; therefore, the only emissions increase as a result of this project will be from the new equipment being installed. No controls are being used to control the emissions from the new P-7 printing press. The expected pollutants from the new P-7 printing press are volatile organic compounds (VOC) and particulates (PM, PM10, PM2.5) from the inks and solvents and combustion emission from the overhead and deck dryers. The inks or solvents being used by MPC do not contain any HAPs. The Soma Optima 2 flexographic printer has a MHDR for ink, solvent, and natural gas combustion of 11.3 lbs, 29.3 lbs, and 0.7 MMBtu, respectively. The solvent and ink will be mixed by the P-7 printing press. The usage rates and emissions for the inks and solvents were split, equally, among the overhead dryer (EP-18) and the deck dryer (EP-19). Thus, EP-18 and EP-19 will have identical MHDRs for inks, solvents, and natural gas combustion at values of 5.65 lbs, 14.65 lbs, 0.35 MMBtu, respectively. Upon the installation of the new P-7 printing press, Manchester Packaging Company will remove the P-3 printing press (EP-03) and the P-5 printing press (EP-05 & EP-06). The removal of the equipment will be made federally enforceable upon the completion of the new Operating Permit, Project No. 2020-02-013.

EMISSIONS/CONTROLS EVALUATION The potential emissions from the new P-7 printing press were calculated using the product Material Safety Data Sheets and a mass balance calculation. All VOCs within the ink and solvents were assumed to be emitted with a 2% ink solvent retention. This value was obtained from AP42 4.9.1-1 "Typical parameters for computing solvent parameters from printing lines". The inks or solvents being used by Manchester Packaging Company do not contain any HAPs; therefore, no HAP emissions are expected, aside from combustion HAPs generated in the dryers of the press. Since no

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HAP emissions are expected from the proposed process material, Manchester Packaging Company is prohibited from using HAP containing alternative materials. The mass balance calculations are based upon the P-7 printing press maximum possible flow of solvent and the maximum flow of ink for 8760 hours per year. Table 3 lists the inks and solvents used by the P-7 printing press. Table 3: Ink and Solvent Used in P-7 Flexographic Press

Material Name Density (lb/gal)

VOC Content (%)

Solvent Blend 6.8 100 Extender Varnish 7.4 63.4

Thermoplastic Proc Magenta LF 8.0 71.2 Surface HI STR Diarylide Yellow 7.7 60.6

Acrosolve PNP 7.4 100 1-1-1 Solvent Blend 6.6 100

Surface HR Line Black 7.8 55.7 Weathermaster XT Black L/F 7.9 60.3

Weathermaster XT Carbazole Violet L/F 7.5 68.2 Weathermaster XT GS Yellow L/F 7.8 58.6

Silver 7.8 61.6 Weathermaster XT Cyan Green L/F 8.0 60.6

HI STR Carbazole Violet 7.7 60.3 Weathermaster XT BS Quinn Red L/F 7.7 63.8

Process Yellow LF SD 8.0 58.9 EHS 65 Cyan Blue 7.9 60.2

Surface HS Cyan Green 65% 8.0 61.6 HO Surface White 12.0 28.1 Stretchwrap Primer 6.0 94.2

Black Conc. 8.0 42.1 Imprint White 10.1 38.6

Surface Process Black SD 8.2 59.7 Surface YS Naphthol Warm Red 7.7 60.0

HI STR Methyl Violet 7.9 54.2 Thermoplast Proc Extender Surface 7.7 75.8

Soil Black HI STR LO Slip 7.5 54.4 Soil White LO Slip 9.0 44.2

Unibase CN Wax Compound 7.5 60.1 Weathermaster XT 877 Silver 8.6 39.3

Surface White 11.3 34.1 Weathermaster XT Wax Compound 7.4 56.0 Weathermaster Process Yellow LF 7.8 61.6

Weathermaster Process Magenta LF 8.0 60.6 Weathermaster Process Cyan Blue 7.5 60.6

Weathermaster Process Black 8.2 60.6 Weathermaster XT Orange L/F 8.0 61.6

Weathermaster XT Med Red L/F 7.8 62.0 Weathermaster Mix Varnish 7.4 48.2

Weathermaster XT Extender Varnish 7.3 75.3 HI STR 034 Orange 7.5 63.5

Surface HI STR Rubine Red 7.8 61.6 Surface HI STR YS Rhodamine Red 7.9 58.6 Weathermaster XT 021 Orange LF 7.7 72.8

Process Yellow LF SD 8.0 58.9

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The emission factors used for the combustion of natural gas in the overhead and deck dryers were obtained from the EPA document AP-42, Compilation of Air Pollutant Emission Factors, Fifth Edition, Section 1.4 Natural Gas Combustion (July 1998). The following table provides an emissions summary for this project. Existing potential emissions were taken from Operating Permit OP2015-002. Existing actual emissions were taken from the installation’s 2018 EIQ. Potential emissions of the application represent the potential of the new equipment, assuming continuous operation (8760 hours per year). Table 4: Emissions Summary (tpy)

Pollutant Regulatory De Minimis

Levels

Existing Potential

Emissions

Existing Actual

Emissions (2018 EIQ)

Potential Emissions of

the Project

New Installation Conditioned

Potential PM 25.0 3.54 0.003 0.03 3.60

PM10 15.0 3.54 0.003 0.02 3.59 PM2.5 10.0 3.54 0.003 0.02 3.59 SOx 40.0 0.01 0.0002 0.00 0.01 NOx 40.0 1.24 0.050 0.30 1.49 VOC 40.0 < 250.0 45.69 160.32 < 250.0 CO 100.0 1.04 0.04 0.25 1.13

GHG (CO2e) N/A 1499.09 N/R 360.72 N/A GHG (mass) N/A 1490.29 N/R 362.85 N/A

HAPs 10.0/25.0 0.036 0.00 0.006 0.041 N/A = Not Applicable; N/R = Not Reported

PERMIT RULE APPLICABILITY This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6.060, Construction Permits Required. Potential emissions of VOCs are conditioned below NSR major source thresholds.

APPLICABLE REQUIREMENTS

Manchester Packaging Company shall comply with the following applicable requirements. The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping, monitoring, and reporting requirements. Compliance with these emission standards, based on information submitted in the application, has been verified at the time this application was approved. For a complete list of applicable requirements for your installation, please consult your operating permit.

GENERAL REQUIREMENTS

• Operating Permits, 10 CSR 10-6.065

• Start-Up, Shutdown, and Malfunction Conditions, 10 CSR 10-6.050

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• Submission of Emission Data, Emission Fees and Process Information, 10 CSR 10-6.110

o Per 10 CSR 10-6.110(4)(B)2.B(II) and (4)(B)2.C(II) a full EIQ is required for the first full calendar year the equipment (or modifications) approved by this permit are in operation.

• Restriction of Particulate Matter to the Ambient Air Beyond the Premises of

Origin, 10 CSR 10-6.170

• Restriction of Emission of Odors, 10 CSR 10-6.165

SPECIFIC REQUIREMENTS

• Restriction of Particulate Matter Emissions from Fuel Burning Equipment Used for Indirect Heating, 10 CSR 10-6.405 applies to the new equipment. Compliance is met with the rule as Manchester Packaging stated, in the Application for Authority to Construct, to combust exclusively pipeline grade natural gas in the new equipment.

• Control of Sulfur Dioxide Emissions, 10 CSR 10-6.261 applies to the new equipment. However, there is an exception for natural gas exclusive units, per 10 CSR 10-6.261(1)(A). Compliance with this rule is demonstrated by the reporting and record keeping requirements outlined in 10 CSR 10-6.261(4)

STAFF RECOMMENDATION

On the basis of this review conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6.060, Construction Permits Required, it is recommended that this permit be granted with special conditions.

PERMIT DOCUMENTS The following documents are incorporated by reference into this permit: • The Application for Authority to Construct form, dated January 14, 2020, received

January 21, 2020, designating Manchester Packaging Company as the owner and operator of the installation

Attachment A –VOC Compliance Worksheet

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Manchester Packaging Company Phelps County, S16, T38N, R6W Installation ID Number: 161-0039 Permit Number: 042020-012 This sheet covers (Copy this sheet as needed.) (month, year)

(a) (b) (c) (d) (e)

Ink, Solvent or Additive (Name, Product #)

Amount of Ink, Solvent or Additive

Used (gallon) Density (lb/gal) VOC Content

(Weight %)

VOC Emissions

(Tons) Example:

Weathermaster XT 021 Orange LF

10 7.7 72.80% 0.02803

Extruders (EP-15) (f) Amount of Polyethylene Film Produced

(tons) (g) Emission

Factor (lb/ton) (h)

0.0398

Total Natural Gas Combustion (i) Amount of Natural Gas Used (MMcf) (j) Emission

Factor (lb/MMcf) (k)

5.5

(l) Total VOC Emissions Calculated for this Month in Tons

(m) 12-Month VOC Emissions Total (o) from Previous Month’s Worksheet in Tons (n) Monthly VOC Emissions Total (l) from Previous Year’s Worksheet in Tons (o) Current 12-month Total of VOC Emissions in Tons: (o) = [(l) + (m) - (n)]

(a) Record the name of all inks, solvents and additives used this month. (b) Record the respective gallons of inks, solvents and additives used this month. (c) Record the respective density of inks, solvents and additives from the MSDS. (d) Record the respective VOC content of inks, solvents and additives. Obtain VOC content of other inks, solvents and additives from

their respective MSDS. If a range is given for the VOC content, use the highest value in the range. (e) Calculate VOC emissions from inks, solvents and additives: (e) = [(b) x (c) x (d)] * 0.98 / 2000. The 0.98 accounts for the 2% ink

solvent retention factor. (f) Record the tons of Polyethylene Film produced by the extruders. Emission factor provided by Journal of the Air & Waste Management Association (Volume 46 June 1996) paper “Development of Emission Factors for Polyethylene Processing (g) VOC emission factor for the extruder process (h) Calculate VOC emissions from the extruders: (h) = [(f) x (g)] / 2000 (i) Record the MMcf of natural gas used by the Manchester Packaging (j) VOC emission factor for natural gas combustion. Emission factor obtained from EPA document AP-42 Table 1.4-2 (k) Calculate VOC emissions from natural gas combustion: (k) = [(j) x (k)] / 2000 (l) Sum each individual VOC emissions for this month: (l) = [sum of all VOC emissions in (e)] + (h) + (k) (m) Record the 12-month total VOC emissions (o) from last month’s Attachment A. (n) Record the monthly VOC emissions total (l) from previous year’s Attachment A. (o) Calculate the current 12-month total VOC emissions. A value less than 250.0 tons of VOC indicates compliance.

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Attachment B – Alternative Material VOC Worksheet

Manchester Packaging Company Phelps County, S16, T38N, R6W Project Number: 2020-01-022 Installation ID Number: 161-0039 Permit Number: 042020-012 This sheet covers the period from to . (Copy this sheet as needed) (month, year) (month, year) This sheet covers the proposed change to material: __________________ Table 1: Mass Balance Worksheet

A B C D VOC Name and CAS #1

VOC Content (Weight %)2

Press or Adhesives MHDR (lbs/hr)

Potential VOC Emissions (lb/hr)3

E. Total Potential VOC Emissions from Proposed Materials: Lb/hr4

1 Record the name of each material used that contains a VOC as defined in 10 CSR 10-6.020. 2 If VOC content has a range, then use the highest value. 3 Calculate the potential VOC emissions in lb/hr: [(Column B) ∗ (Column C)] ∗ 0.98 = Column D The 0.98 factor accounts for the 2% ink solvent retention factor. 4 Sum the values in Column D. If the sum is greater than 3.94 lbs VOC/hr for ink or 14.36 lbs VOC/hr for solvents, then Manchester Packaging Company shall seek approval from the Air Pollution Control Program New Source Review Unit before use of the alternative material.

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APPENDIX A Abbreviations and Acronyms

% .............. percent ºF .............. degrees Fahrenheit acfm ......... actual cubic feet per minute BACT ....... Best Available Control Technology BMPs ....... Best Management Practices Btu............ British thermal unit CAM ........ Compliance Assurance Monitoring CAS .......... Chemical Abstracts Service CEMS ...... Continuous Emission Monitor System CFR .......... Code of Federal Regulations CO ............ carbon monoxide CO2........... carbon dioxide CO2e ......... carbon dioxide equivalent COMS ...... Continuous Opacity Monitoring System CSR .......... Code of State Regulations dscf ........... dry standard cubic feet EIQ .......... Emission Inventory Questionnaire EP ............. Emission Point EPA .......... Environmental Protection Agency EU ............ Emission Unit fps ............. feet per second ft ............... feet GACT ...... Generally Available Control Technology GHG ........ Greenhouse Gas gpm .......... gallons per minute gr .............. grains GWP ........ Global Warming Potential HAP ......... Hazardous Air Pollutant hr .............. hour hp ............. horsepower lb .............. pound lbs/hr ........ pounds per hour MACT ...... Maximum Achievable Control Technology µg/m3 ........ micrograms per cubic meter m/s ............ meters per second

Mgal ......... 1,000 gallons MW .......... megawatt MHDR ..... maximum hourly design rate MMBtu .... Million British thermal units MMCF ..... million cubic feet MSDS ....... Material Safety Data Sheet NAAQS .... National Ambient Air Quality Standards NESHAPs National Emissions Standards for Hazardous Air Pollutants NOx ........... nitrogen oxides NSPS ........ New Source Performance Standards NSR .......... New Source Review PM ............ particulate matter PM2.5......... particulate matter less than 2.5 microns in aerodynamic diameter PM10 ......... particulate matter less than 10 microns in aerodynamic diameter ppm .......... parts per million PSD .......... Prevention of Significant Deterioration PTE .......... potential to emit RACT ....... Reasonable Available Control Technology RAL .......... Risk Assessment Level SCC .......... Source Classification Code scfm .......... standard cubic feet per minute SDS ........... Safety Data Sheet SIC ........... Standard Industrial Classification SIP ............ State Implementation Plan SMAL....... Screening Model Action Levels SOx ........... sulfur oxides SO2 ........... sulfur dioxide SSM .......... Startup, Shutdown & Malfunction tph ............ tons per hour tpy ............ tons per year VMT ......... vehicle miles traveled VOC ......... Volatile Organic Compound