CPFP|7001048|090214|14097|00A1086S3

PZ

Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Union Tank Car Company-Muscatine Repair Shop

Contact: Responsible Party:

David Herrin Troy McKim

Manger-Environmental Compliance Plant Manager

(312)431-3111 Ext. 3168

175 West Jackson Blvd., Suite 2100 2603 Dick Drake Way

Chicago, Illinois 60604 Muscatine, Iowa 52761

Permitted Equipment

Emission Unit(s): Inline Tank Car Qualification Process (Repair Area)

Welding & Metal Arc Cutting (EU 8)

Maximum Capacity: 30 Railcars per day

Control Equipment: Mini-pleat Filters (CEM1)

Emission Point: EPM1

Equipment Location: 2603 Dick Drake Way

Muscatine, Iowa 52761

Plant Number: 70-01-048

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with 

applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, 

and federal law.

Permit No. Project No. Description Date Stack 

Testing

00-A-1086-S3 14-097 Modify Stack Configuration & Control Install 

Date

09/02/14 No

____________________________________

Under the Direction of the Director of

the Department of Natural Resources
Union Tank Car Company Inline Tank Car Qualification Process (EP M1) Page 2 of 10

Muscatine, Iowa 00-A-1086-S3

PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or 

misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In 

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has 

been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal 

Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the 

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or 

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, 

installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point 

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the 

facility shall assure that the installation of the equipment listed in this permit conforms to the design in the 

application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this 

emission unit(s), control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person 

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring 

that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the 

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and 

control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by 

paragraph 567 IAC 24.2(1) "Maintenance and Repair”.

3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one location to another or from one piece of 

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been 

issued is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) 

days prior to transferring to the new location unless the equipment will be located in an area which is classified as 

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notification shall be given fourteen (14) days prior to the relocation of equipment1(See Permit 

Condition 8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if 

the relocation will cause a violation of the (NAAQS). In such case, a supplemental permit shall be required prior to 

the initiation of construction of additional control equipment or modifications to equipment needed to meet the 

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as 

submitted, and that adequate operation and maintenance is provided to ensure that no condition of air 

pollution is created. 
Union Tank Car Company Inline Tank Car Qualification Process (EP M1) Page 3 of 10

Muscatine, Iowa 00-A-1086-S3

4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or 

operator shall seek a permit amendment in order to revert back to the most recent previous version of the 

permit. The previous, unchanged permit provisions are included in the amendment for your convenience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted 

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected 

emission unit(s) and emission point, together with any previous amendment to the permit, until one of the 

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and 

emission point permitted herein; or

(2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.11(g), where applicable, any credible evidence may be used 

for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this 

permit or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are 

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good 

practice for minimizing emissions except when another regulation applicable to the unit or process provides 

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be 

limited to one (1) six-minute period per one (1) hour period. 

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties 

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the 

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within 

a reasonable period of time, as specified in 567 IAC 24.1. 

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See 

Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all 

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
Union Tank Car Company Inline Tank Car Qualification Process (EP M1) Page 4 of 10

Muscatine, Iowa 00-A-1086-S3

7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two 

(2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days 

following initiation of construction, installation, or alteration;

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be 

transferred from one location to another, the Department shall be notified:

(a) at least fourteen (14) days before equipment relocation if the equipment will be located in a 

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance 

area for the NAAQS; 

(b) at least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership

within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the 

owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of each compliance test required by Permit 

Condition 12 shall be done not less than thirty (30) days before the required test or performance 

evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time, 

 the place, 

 the name of the person who will conduct the tests, 

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not 

consider the test results or performance evaluation results to be a valid demonstration of compliance 

with the applicable rules or permit conditions. Upon written request, the Department may allow a 

notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported

within eight (8) hours or at the start of the first working day following the onset of the incident. The 

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2

shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days 

of the onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified 

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring 

system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days 

following the end of the calendar quarter, on forms provided by the Director.
Union Tank Car Company Inline Tank Car Qualification Process (EP M1) Page 5 of 10

Muscatine, Iowa 00-A-1086-S3

8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, 

whether successful or not, postmarked not later than six (6) weeks after the completion of the test 

period unless other regulations provide for other notification requirements. In that case, the more 

stringent reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit 

shall be available at the plant during normal business hours for inspection and copying by federal, state, or 

local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years 

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9549

Fax: (515) 725-9501

E. The owner or operator shall send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9545

Fax: (515) 725-9502

F. The owner or operator shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9550

Fax: (515) 725-9502

DNR Field Office 6

1023 West Madison

Washington, IA 52353

Telephone: (319) 653-2135

Fax: (319) 653-2856

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless 

they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in 

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of 

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the 

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319

Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319
Union Tank Car Company Inline Tank Car Qualification Process (EP M1) Page 6 of 10

Muscatine, Iowa 00-A-1086-S3

10. Emission Limits

The following emission limits shall not be exceeded: 

Pollutant lb/hr1tons/yr2 Additional 

Limits

Reference

(567 IAC)

Particulate Matter (PM) – Federal NA NA NA NA

Particulate Matter (PM) – State 1.8 NA 0.1 gr/scf 23.3(2)”a”

PM10 0.873 NA NA NAAQS

PM2.5 0.0334 NA NA NAAQS

Opacity NA NA 40%5,623.3(2)”d”

Sulfur Dioxide (SO2) NA NA NA NA

Nitrogen Oxides (NOx) NA NA NA NA

Volatile Organic Compounds (VOC) NA NA NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA NA NA

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a 12-month rolling total.

3 The limit established as part of Project 08-621 that demonstrated predicted compliance with PM10 NAAQS.

4 The limit for PM2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; 

Call for Iowa SIP Revision” for PM2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

5 The emission limit is a six (6) minute average.

6 An exceedance of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly 

investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If 

exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., 

stack testing).

11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 27 Feet

Discharge Style Horizontal Discharge

Stack Opening (inches) 72 inches by 96 inches

Exhaust Temperature (F) Ambient

Exhaust Flowrate (scfm) 25,000 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted 

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process 

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values 

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to 

determine if a permit amendment is required or submit a permit application requesting to amend the permit.
Union Tank Car Company Inline Tank Car Qualification Process (EP M1) Page 7 of 10

Muscatine, Iowa 00-A-1086-S3

12. Compliance Demonstration(s) 

Pollutant Compliance 

Demonstration

Compliance Methodology Frequency

PM – Federal No Performance Testing NA

PM – State No Performance Testing NA

PM10 No Performance Testing NA

PM2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO2 No NA NA

NOx No NA NA

VOC No NA NA

CO No NA NA

Pb No NA NA

HAP No NA NA

If an initial compliance demonstration specified above is testing, the owner or the owner’s authorized agent shall 

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days after 

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of 

the proposed equipment. 

If subsequent testing is specified above, the owner or the owner’s authorized agent shall verify compliance with 

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the 

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 1 hour 40 CFR 60, Appendix A, Method 5 

40 CFR 51 Appendix M Method 202

PM10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM2.5 15 hours 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO2 1 hour 40 CFR 60, Appendix A, Method 6C

NOx 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the 

Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs 

shall apply for compliance, unless otherwise indicated by the Department. 
Union Tank Car Company Inline Tank Car Qualification Process (EP M1) Page 8 of 10

Muscatine, Iowa 00-A-1086-S3

12. Compliance Demonstration(s) (Continued)

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days 

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the 

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. 

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It 

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the 

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, 

different, or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be 

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate 

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where 

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is 

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this 

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the

Department to determine whether this unit(s) is in compliance.

13. New Source Performance Standards (NSPS) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart MMMMNational Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and 

Products as specified in 40 CFR Part 63 §63.3881. Union Tank Car Company shall comply with all reporting, 

notification, and recordkeeping requirements as specified 40 CFR Part 63 Subpart MMMM, specifically §63.3910, 

§63.3920, §63.3930, and §63.3931.

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart A-General 

Provisions as specified in 40 CFR Part 63 §63.3901. Union Tank Car Company (Plant No. 70-01-048) shall comply 

with all reporting, notification, and recordkeeping requirements as specified 40 CFR Part 60 Subpart A, §63.3901

(Table 2).

14. Operating Limits

Operating limits for this emission unit shall be:

A. Mini-pleat Filters (CEM1) shall be installed and operational by September 2, 2014.

B. Mini-pleat Filters (CEM1) shall have a MERV rating of no less than 13.

C. Mini-pleat Filters (CEM1) shall be maintained and replaced per manufacturer’s instructions and 

specifications.

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of 

two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an 

orderly manner. These records shall show the following:

A. Maintain a record of the installation and operation date of Mini-pleat Filters (CEM1).

B. Maintain record of MERV Rating of Mini-pleat filters (CEM1).

C. The owner or operator shall maintain a record for all maintenance and replacement of the Mini-pleat Filters

(CEM1).
Union Tank Car Company Inline Tank Car Qualification Process (EP M1) Page 9 of 10

Muscatine, Iowa 00-A-1086-S3

16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.

17. Permit History

Permit No. Project No. Description Date Stack 

Testing

00-A-1086 00-144 Original Permit 12/21/00 No

00-A-1086-S1 08-621 Amend Operating Limits 10/29/09 No

00-A-1086-S2 12-409 Add Particulate Filter, Establish PM2.5 

Limits, Add Fan to Increase Flow

04/08/13 No
Union Tank Car Company Inline Tank Car Qualification Process (EP M1) Page 10 of 10

Muscatine, Iowa 00-A-1086-S3

18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be 

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form 

particulate matter immediately after discharge from the stack

Department Iowa Department of Natural Resources

dia. Diameter

F Degrees Fahrenheit

ft Foot

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM – Federal Particulate Matter that does not include the condensable PM

PM – State Particulate Matter that includes condensable PM

ppm parts per million

ppmv parts per million by volume

ppmw parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year

END OF PERMIT
CPFP|7001048|090214|14097|00A1087S3

PZ

Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Union Tank Car Company-Muscatine Repair Shop

Contact: Responsible Party:

David Herrin Troy McKim

Manger-Environmental Compliance Plant Manager

(312)431-3111 Ext. 3168

175 West Jackson Blvd., Suite 2100 2603 Dick Drake Way

Chicago, Illinois 60604 Muscatine, Iowa 52761

Permitted Equipment

Emission Unit(s): Inline Tank Car Qualification Process

Welding & Metal Arc Cutting (EU 8)

Maximum Capacity: 30 Railcars per day

Control Equipment: Mini-pleat Filters (CEM2)

Emission Point: EPM2

Equipment Location: 2603 Dick Drake Way

Muscatine, Iowa 52761

Plant Number: 70-01-048

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with 

applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, 

and federal law.

Permit No. Project No. Description Date Stack 

Testing

00-A-1087-S3 14-097 Modify Stack Configuration & Control Install 

Date

09/02/14 No

____________________________________

Under the Direction of the Director of

the Department of Natural Resources
Union Tank Car Company Inline Tank Car Qualification Process (EP M2) Page 2 of 10

Muscatine, Iowa 00-A-1087-S3

PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or 

misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In 

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has 

been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal 

Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the 

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or 

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, 

installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point 

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the 

facility shall assure that the installation of the equipment listed in this permit conforms to the design in the 

application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this 

emission unit(s), control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person 

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring 

that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the 

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and 

control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by 

paragraph 567 IAC 24.2(1) "Maintenance and Repair”.

3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one location to another or from one piece of 

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been 

issued is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) 

days prior to transferring to the new location unless the equipment will be located in an area which is classified as 

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notification shall be given fourteen (14) days prior to the relocation of equipment1(See Permit 

Condition 8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if 

the relocation will cause a violation of the (NAAQS). In such case, a supplemental permit shall be required prior to 

the initiation of construction of additional control equipment or modifications to equipment needed to meet the 

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as 

submitted, and that adequate operation and maintenance is provided to ensure that no condition of air 

pollution is created. 
Union Tank Car Company Inline Tank Car Qualification Process (EP M2) Page 3 of 10

Muscatine, Iowa 00-A-1087-S3

4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or 

operator shall seek a permit amendment in order to revert back to the most recent previous version of the 

permit. The previous, unchanged permit provisions are included in the amendment for your convenience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted 

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected 

emission unit(s) and emission point, together with any previous amendment to the permit, until one of the 

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and 

emission point permitted herein; or

(2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.11(g), where applicable, any credible evidence may be used 

for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this 

permit or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are 

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good 

practice for minimizing emissions except when another regulation applicable to the unit or process provides 

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be 

limited to one (1) six-minute period per one (1) hour period. 

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties 

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the 

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within 

a reasonable period of time, as specified in 567 IAC 24.1. 

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See 

Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all 

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
Union Tank Car Company Inline Tank Car Qualification Process (EP M2) Page 4 of 10

Muscatine, Iowa 00-A-1087-S3

7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two 

(2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days 

following initiation of construction, installation, or alteration;

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be 

transferred from one location to another, the Department shall be notified:

(a) at least fourteen (14) days before equipment relocation if the equipment will be located in a 

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance 

area for the NAAQS; 

(b) at least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership

within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the 

owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of each compliance test required by Permit 

Condition 12 shall be done not less than thirty (30) days before the required test or performance 

evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time, 

 the place, 

 the name of the person who will conduct the tests, 

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not 

consider the test results or performance evaluation results to be a valid demonstration of compliance 

with the applicable rules or permit conditions. Upon written request, the Department may allow a 

notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported 

within eight (8) hours or at the start of the first working day following the onset of the incident. The 

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2

shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days 

of the onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified 

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring 

system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days 

following the end of the calendar quarter, on forms provided by the Director.
Union Tank Car Company Inline Tank Car Qualification Process (EP M2) Page 5 of 10

Muscatine, Iowa 00-A-1087-S3

8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, 

whether successful or not, postmarked not later than six (6) weeks after the completion of the test 

period unless other regulations provide for other notification requirements. In that case, the more 

stringent reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit 

shall be available at the plant during normal business hours for inspection and copying by federal, state, or 

local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years 

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9549

Fax: (515) 725-9501

E. The owner or operator shall send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9545

Fax: (515) 725-9502

F. The owner or operator shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9550

Fax: (515) 725-9502

DNR Field Office 6

1023 West Madison

Washington, IA 52353

Telephone: (319) 653-2135

Fax: (319) 653-2856

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless 

they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in 

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of 

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the 

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319

Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319
Union Tank Car Company Inline Tank Car Qualification Process (EP M2) Page 6 of 10

Muscatine, Iowa 00-A-1087-S3

10. Emission Limits

The following emission limits shall not be exceeded: 

Pollutant lb/hr1tons/yr2 Additional 

Limits

Reference

(567 IAC)

Particulate Matter (PM) – Federal NA NA NA NA

Particulate Matter (PM) – State 1.8 NA 0.1 gr/scf 23.3(2)”a”

PM10 0.873 NA NA NAAQS

PM2.5 0.0334 NA NA NAAQS

Opacity NA NA 40%5,623.3(2)”d”

Sulfur Dioxide (SO2) NA NA NA NA

Nitrogen Oxides (NOx) NA NA NA NA

Volatile Organic Compounds (VOC) NA NA NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA NA NA

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a 12-month rolling total.

3 The limit established as part of Project 08-621 that demonstrated predicted compliance with PM10 NAAQS.

4 The limit for PM2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; 

Call for Iowa SIP Revision” for PM2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

5 The emission limit is a six (6) minute average.

6 An exceedance of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly 

investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If 

exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., 

stack testing).

11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 27 Feet

Discharge Style Horizontal Discharge

Stack Opening (inches) 72 inches by 96 inches

Exhaust Temperature (F) Ambient

Exhaust Flowrate (scfm) 25,000 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted 

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process 

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values 

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to 

determine if a permit amendment is required or submit a permit application requesting to amend the permit.
Union Tank Car Company Inline Tank Car Qualification Process (EP M2) Page 7 of 10

Muscatine, Iowa 00-A-1087-S3

12. Compliance Demonstration(s) 

Pollutant Compliance 

Demonstration

Compliance Methodology Frequency

PM – Federal No Performance Testing NA

PM – State No Performance Testing NA

PM10 No Performance Testing NA

PM2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO2 No NA NA

NOx No NA NA

VOC No NA NA

CO No NA NA

Pb No NA NA

HAP No NA NA

If an initial compliance demonstration specified above is testing, the owner or the owner’s authorized agent shall 

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days after 

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of 

the proposed equipment.

If subsequent testing is specified above, the owner or the owner’s authorized agent shall verify compliance with 

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the 

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 1 hour 40 CFR 60, Appendix A, Method 5 

40 CFR 51 Appendix M Method 202

PM10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM2.5 15 hours 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO2 1 hour 40 CFR 60, Appendix A, Method 6C

NOx 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the 

Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs 

shall apply for compliance, unless otherwise indicated by the Department. 
Union Tank Car Company Inline Tank Car Qualification Process (EP M2) Page 8 of 10

Muscatine, Iowa 00-A-1087-S3

12. Compliance Demonstration(s) (Continued)

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days 

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the 

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. 

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It 

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the 

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, 

different, or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be 

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate 

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where 

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is 

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this 

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the

Department to determine whether this unit(s) is in compliance.

13. New Source Performance Standards (NSPS) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart MMMMNational Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and 

Products as specified in 40 CFR Part 63 §63.3881. Union Tank Car Company shall comply with all reporting, 

notification, and recordkeeping requirements as specified 40 CFR Part 63 Subpart MMMM, specifically §63.3910, 

§63.3920, §63.3930, and §63.3931.

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart A-General 

Provisions as specified in 40 CFR Part 63 §63.3901. Union Tank Car Company (Plant No. 70-01-048) shall comply 

with all reporting, notification, and recordkeeping requirements as specified 40 CFR Part 60 Subpart A, §63.3901

(Table 2).

14. Operating Limits

Operating limits for this emission unit shall be:

A. Mini-pleat Filters (CEM2) shall be installed and operational by September 2, 2014.

B. Mini-pleat Filters (CEM2) shall have a MERV rating of no less than 13.

C. Mini-pleat Filters (CEM2) shall be maintained and replaced per manufacturer’s instructions and 

specifications.

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of 

two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an 

orderly manner. These records shall show the following:

A. Maintain a record of the installation and operation date of Mini-pleat Filters (CEM2).

B. Maintain record of MERV Rating of Mini-pleat filters (CEM2).

C. The owner or operator shall maintain a record for all maintenance and replacement of the Mini-pleat Filters

(CEM2).
Union Tank Car Company Inline Tank Car Qualification Process (EP M2) Page 9 of 10

Muscatine, Iowa 00-A-1087-S3

16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.

17. Permit History

Permit No. Project No. Description Date Stack 

Testing

00-A-1087 00-144 Original Permit 12/21/00 No

00-A-1087-S1 08-621 Amend Operating Limits 10/29/09 No

00-A-1087-S2 12-409 Add Particulate Filter, Establish PM2.5 

Limits, Add Fan to Increase Flow

04/08/13 No
Union Tank Car Company Inline Tank Car Qualification Process (EP M2) Page 10 of 10

Muscatine, Iowa 00-A-1087-S3

18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be 

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form 

particulate matter immediately after discharge from the stack

Department Iowa Department of Natural Resources

dia. Diameter

F Degrees Fahrenheit

ft Foot

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM – Federal Particulate Matter that does not include the condensable PM

PM – State Particulate Matter that includes condensable PM

ppm parts per million

ppmv parts per million by volume

ppmw parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year

END OF PERMIT
CPFP|7001048|090214|14097|00A1088S3

PZ

Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Union Tank Car Company-Muscatine Repair Shop

Contact: Responsible Party:

David Herrin Troy McKim

Manger-Environmental Compliance Plant Manager

(312)431-3111 Ext. 3168

175 West Jackson Blvd., Suite 2100 2603 Dick Drake Way

Chicago, Illinois 60604 Muscatine, Iowa 52761

Permitted Equipment

Emission Unit(s): Inline Tank Car Qualification Process

Welding & Metal Arc Cutting (EU 8)

Maximum Capacity: 30 Railcars per day

Control Equipment: Mini-pleat Filters (CEM3)

Emission Point: EPM3

Equipment Location: 2603 Dick Drake Way

Muscatine, Iowa 52761

Plant Number: 70-01-048

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with 

applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, 

and federal law.

Permit No. Project No. Description Date Stack 

Testing

00-A-1088-S3 14-097 Modify Stack Configuration & Control Install 

Date

09/02/14 No

____________________________________

Under the Direction of the Director of

the Department of Natural Resources
Union Tank Car Company Inline Tank Car Qualification Process (EP M3) Page 2 of 10

Muscatine, Iowa 00-A-1088-S3

PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or 

misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In 

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has 

been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal 

Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the 

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or 

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, 

installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point 

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the 

facility shall assure that the installation of the equipment listed in this permit conforms to the design in the 

application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this 

emission unit(s), control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person 

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring 

that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the 

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and 

control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by 

paragraph 567 IAC 24.2(1) "Maintenance and Repair”.

3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one location to another or from one piece of 

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been 

issued is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) 

days prior to transferring to the new location unless the equipment will be located in an area which is classified as 

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notification shall be given fourteen (14) days prior to the relocation of equipment1(See Permit 

Condition 8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if 

the relocation will cause a violation of the (NAAQS). In such case, a supplemental permit shall be required prior to 

the initiation of construction of additional control equipment or modifications to equipment needed to meet the 

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as 

submitted, and that adequate operation and maintenance is provided to ensure that no condition of air 

pollution is created. 
Union Tank Car Company Inline Tank Car Qualification Process (EP M3) Page 3 of 10

Muscatine, Iowa 00-A-1088-S3

4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or 

operator shall seek a permit amendment in order to revert back to the most recent previous version of the 

permit. The previous, unchanged permit provisions are included in the amendment for your convenience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted 

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected 

emission unit(s) and emission point, together with any previous amendment to the permit, until one of the 

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and 

emission point permitted herein; or

(2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.11(g), where applicable, any credible evidence may be used 

for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this 

permit or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are 

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good 

practice for minimizing emissions except when another regulation applicable to the unit or process provides 

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be 

limited to one (1) six-minute period per one (1) hour period. 

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties 

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the 

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within 

a reasonable period of time, as specified in 567 IAC 24.1. 

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See 

Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all 

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
Union Tank Car Company Inline Tank Car Qualification Process (EP M3) Page 4 of 10

Muscatine, Iowa 00-A-1088-S3

7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two 

(2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days 

following initiation of construction, installation, or alteration;

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be 

transferred from one location to another, the Department shall be notified:

(a) at least fourteen (14) days before equipment relocation if the equipment will be located in a 

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance 

area for the NAAQS; 

(b) at least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership

within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the 

owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of each compliance test required by Permit 

Condition 12 shall be done not less than thirty (30) days before the required test or performance 

evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time, 

 the place, 

 the name of the person who will conduct the tests, 

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not 

consider the test results or performance evaluation results to be a valid demonstration of compliance 

with the applicable rules or permit conditions. Upon written request, the Department may allow a 

notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported

within eight (8) hours or at the start of the first working day following the onset of the incident. The 

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2

shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days 

of the onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified 

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring 

system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days 

following the end of the calendar quarter, on forms provided by the Director.
Union Tank Car Company Inline Tank Car Qualification Process (EP M3) Page 5 of 10

Muscatine, Iowa 00-A-1088-S3

8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, 

whether successful or not, postmarked not later than six (6) weeks after the completion of the test 

period unless other regulations provide for other notification requirements. In that case, the more 

stringent reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit 

shall be available at the plant during normal business hours for inspection and copying by federal, state, or 

local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years 

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9549

Fax: (515) 725-9501

E. The owner or operator shall send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9545

Fax: (515) 725-9502

F. The owner or operator shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9550

Fax: (515) 725-9502

DNR Field Office 6

1023 West Madison

Washington, IA 52353

Telephone: (319) 653-2135

Fax: (319) 653-2856

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless 

they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in 

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of 

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the 

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319

Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319
Union Tank Car Company Inline Tank Car Qualification Process (EP M3) Page 6 of 10

Muscatine, Iowa 00-A-1088-S3

10. Emission Limits

The following emission limits shall not be exceeded: 

Pollutant lb/hr1tons/yr2 Additional 

Limits

Reference

(567 IAC)

Particulate Matter (PM) – Federal NA NA NA NA

Particulate Matter (PM) – State 1.8 NA 0.1 gr/scf 23.3(2)”a”

PM10 0.873 NA NA NAAQS

PM2.5 0.0334 NA NA NAAQS

Opacity NA NA 40%5,623.3(2)”d”

Sulfur Dioxide (SO2) NA NA NA NA

Nitrogen Oxides (NOx) NA NA NA NA

Volatile Organic Compounds (VOC) NA NA NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA NA NA

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a 12-month rolling total.

3 The limit established as part of Project 08-621 that demonstrated predicted compliance with PM10 NAAQS.

4 The limit for PM2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; 

Call for Iowa SIP Revision” for PM2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

5 The emission limit is a six (6) minute average.

6 An exceedance of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly 

investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If 

exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., 

stack testing).

11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 27 Feet

Discharge Style Horizontal Discharge

Stack Opening (inches) 72 inches by 96 inches

Exhaust Temperature (F) Ambient

Exhaust Flowrate (scfm) 25,000 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted 

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process 

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values 

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to 

determine if a permit amendment is required or submit a permit application requesting to amend the permit.
Union Tank Car Company Inline Tank Car Qualification Process (EP M3) Page 7 of 10

Muscatine, Iowa 00-A-1088-S3

12. Compliance Demonstration(s) 

Pollutant Compliance 

Demonstration

Compliance Methodology Frequency

PM – Federal No Performance Testing NA

PM – State No Performance Testing NA

PM10 No Performance Testing NA

PM2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO2 No NA NA

NOx No NA NA

VOC No NA NA

CO No NA NA

Pb No NA NA

HAP No NA NA

If an initial compliance demonstration specified above is testing, the owner or the owner’s authorized agent shall 

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days after 

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of 

the proposed equipment. 

If subsequent testing is specified above, the owner or the owner’s authorized agent shall verify compliance with 

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the 

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 1 hour 40 CFR 60, Appendix A, Method 5 

40 CFR 51 Appendix M Method 202

PM10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM2.5 15 hours 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO2 1 hour 40 CFR 60, Appendix A, Method 6C

NOx 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the 

Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs 

shall apply for compliance, unless otherwise indicated by the Department. 
Union Tank Car Company Inline Tank Car Qualification Process (EP M3) Page 8 of 10

Muscatine, Iowa 00-A-1088-S3

12. Compliance Demonstration(s) (Continued)

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days 

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the 

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. 

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It 

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the 

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, 

different, or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be 

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate 

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where 

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is 

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this 

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the

Department to determine whether this unit(s) is in compliance.

13. New Source Performance Standards (NSPS) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart MMMMNational Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and 

Products as specified in 40 CFR Part 63 §63.3881. Union Tank Car Company shall comply with all reporting, 

notification, and recordkeeping requirements as specified 40 CFR Part 63 Subpart MMMM, specifically §63.3910, 

§63.3920, §63.3930, and §63.3931.

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart A-General 

Provisions as specified in 40 CFR Part 63 §63.3901. Union Tank Car Company (Plant No. 70-01-048) shall comply 

with all reporting, notification, and recordkeeping requirements as specified 40 CFR Part 60 Subpart A, §63.3901

(Table 2).

14. Operating Limits

Operating limits for this emission unit shall be:

A. Mini-pleat Filters (CEM3) shall be installed and operational by September 2, 2014.

B. Mini-pleat Filters (CEM3) shall have a MERV rating of no less than 13.

C. Mini-pleat Filters (CEM3) shall be maintained and replaced per manufacturer’s instructions and 

specifications.

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of 

two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an 

orderly manner. These records shall show the following:

A. Maintain a record of the installation and operation date of Mini-pleat Filters (CEM3).

B. Maintain record of MERV Rating of Mini-pleat filters (CEM3).

C. The owner or operator shall maintain a record for all maintenance and replacement of the Mini-pleat Filters

(CEM3).
Union Tank Car Company Inline Tank Car Qualification Process (EP M3) Page 9 of 10

Muscatine, Iowa 00-A-1088-S3

16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.

17. Permit History

Permit No. Project No. Description Date Stack 

Testing

00-A-1088 00-144 Original Permit 12/21/00 No

00-A-1088-S1 08-621 Amend Operating Limits 10/29/09 No

00-A-1088-S2 12-409 Add Particulate Filter, Establish PM2.5 

Limits, Add Fan to Increase Flow

04/08/13 No
Union Tank Car Company Inline Tank Car Qualification Process (EP M3) Page 10 of 10

Muscatine, Iowa 00-A-1088-S3

18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be 

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form 

particulate matter immediately after discharge from the stack

Department Iowa Department of Natural Resources

dia. Diameter

F Degrees Fahrenheit

ft Foot

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM – Federal Particulate Matter that does not include the condensable PM

PM – State Particulate Matter that includes condensable PM

ppm parts per million

ppmv parts per million by volume

ppmw parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year

END OF PERMIT
CPFP|7001048|090214|14097|96A636S4

PZ

Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Union Tank Car Company-Muscatine Repair Shop

Contact: Responsible Party:

David Herrin Troy McKim

Manger-Environmental Compliance Plant Manager

(312)431-3111 Ext. 3168

175 West Jackson Blvd., Suite 2100 2603 Dick Drake Way

Chicago, Illinois 60604 Muscatine, Iowa 52761

Permitted Equipment

Emission Unit(s): Railcar Interior Painting/Stencil & Touchup Painting (EU6)

Heaters for Tank Cars (13 @ 2.5 MMBtu/hr each) (EU12)

Heaters for Hopper Cars (4 @ 4 MMBtu/hr each) (EU13)

Maximum Capacity: 400 gallons of coating per day

Control Equipment: Mini-pleat Filters (CE6A)

Emission Point: EP6A

Equipment Location: 2603 Dick Drake Way

Muscatine, Iowa 52761

Plant Number: 70-01-048

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with 

applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, 

and federal law.

Permit No. Project No. Description Date Stack 

Testing

96-A-636-S4 14-097 Modify Stack Configuration & Control Install 

Date

09/02/14 No

____________________________________

Under the Direction of the Director of

the Department of Natural Resources
Union Tank Car Company Railcar Interior Lining Shop (EP6A) Page 2 of 10

Muscatine, Iowa 96-A-636-S4

PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or 

misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In 

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has 

been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal 

Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the 

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or 

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, 

installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point 

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the 

facility shall assure that the installation of the equipment listed in this permit conforms to the design in the 

application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this 

emission unit(s), control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person 

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring 

that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the 

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and 

control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by 

paragraph 567 IAC 24.2(1) "Maintenance and Repair”.

3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one location to another or from one piece of 

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been 

issued is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) 

days prior to transferring to the new location unless the equipment will be located in an area which is classified as 

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notification shall be given fourteen (14) days prior to the relocation of equipment1(See Permit 

Condition 8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if 

the relocation will cause a violation of the (NAAQS). In such case, a supplemental permit shall be required prior to 

the initiation of construction of additional control equipment or modifications to equipment needed to meet the 

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as 

submitted, and that adequate operation and maintenance is provided to ensure that no condition of air 

pollution is created. 
Union Tank Car Company Railcar Interior Lining Shop (EP6A) Page 3 of 10

Muscatine, Iowa 96-A-636-S4

4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or 

operator shall seek a permit amendment in order to revert back to the most recent previous version of the 

permit. The previous, unchanged permit provisions are included in the amendment for your convenience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted 

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected 

emission unit(s) and emission point, together with any previous amendment to the permit, until one of the 

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and 

emission point permitted herein; or

(2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.11(g), where applicable, any credible evidence may be used 

for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this 

permit or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are 

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good 

practice for minimizing emissions except when another regulation applicable to the unit or process provides 

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be 

limited to one (1) six-minute period per one (1) hour period. 

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties 

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the 

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within 

a reasonable period of time, as specified in 567 IAC 24.1. 

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See 

Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all 

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
Union Tank Car Company Railcar Interior Lining Shop (EP6A) Page 4 of 10

Muscatine, Iowa 96-A-636-S4

7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two 

(2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days 

following initiation of construction, installation, or alteration;

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be 

transferred from one location to another, the Department shall be notified:

(a) at least fourteen (14) days before equipment relocation if the equipment will be located in a 

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance 

area for the NAAQS; 

(b) at least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership

within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the 

owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of each compliance test required by Permit 

Condition 12 shall be done not less than thirty (30) days before the required test or performance 

evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time, 

 the place, 

 the name of the person who will conduct the tests, 

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not 

consider the test results or performance evaluation results to be a valid demonstration of compliance 

with the applicable rules or permit conditions. Upon written request, the Department may allow a 

notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported

within eight (8) hours or at the start of the first working day following the onset of the incident. The 

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2

shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days 

of the onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified 

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring 

system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days 

following the end of the calendar quarter, on forms provided by the Director.
Union Tank Car Company Railcar Interior Lining Shop (EP6A) Page 5 of 10

Muscatine, Iowa 96-A-636-S4

8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, 

whether successful or not, postmarked not later than six (6) weeks after the completion of the test 

period unless other regulations provide for other notification requirements. In that case, the more 

stringent reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit 

shall be available at the plant during normal business hours for inspection and copying by federal, state, or 

local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years 

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9549

Fax: (515) 725-9501

E. The owner or operator shall send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9545

Fax: (515) 725-9502

F. The owner or operator shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9550

Fax: (515) 725-9502

DNR Field Office 6

1023 West Madison

Washington, IA 52353

Telephone: (319) 653-2135

Fax: (319) 653-2856

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless 

they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in 

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of 

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the 

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319

Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319
Union Tank Car Company Railcar Interior Lining Shop (EP6A) Page 6 of 10

Muscatine, Iowa 96-A-636-S4

10. Emission Limits

The following emission limits shall not be exceeded: 

Pollutant lb/hr1tons/yr2 Additional 

Limits

Reference

(567 IAC)

Particulate Matter (PM) – Federal NA NA NA NA

Particulate Matter (PM) – State 1.2 NA 0.01 gr/dscf 23.4(13)

PM10 0.63 NA NA NAAQS

PM2.5 0.0214 NA NA NAAQS

Opacity NA NA 40%5, 623.3(2)”d”

Sulfur Dioxide (SO2) NA NA NA NA

Nitrogen Oxides (NOx) NA NA NA NA

Volatile Organic Compounds (VOC) NA 2007 NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA 923.1(4)”cm”8

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a 365-day rolling total.

3 The limit established as part of Project 08-621 that demonstrated predicted compliance with PM10 NAAQS.

4 The limit for PM2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; 

Call for Iowa SIP Revision” for PM2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

5 The emission limit is a six (6) minute average.

6 An exceedance of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly 

investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If 

exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., 

stack testing).

7 Total VOC emissions from coating operations (EU 5, 6, 7, 12, and 13) shall not exceed 200 tons per 365-day rolling 

period. (Note: The VOC PTE of the 17 natural gas heaters is 0.89 tons per year and counts against the 200 ton/yr bubble 

limit).

8

Iowa adoption of NESHAP Subpart MMMM: National Emission Standards for Hazardous Air Pollutants: Surface 

Coating of Miscellaneous Metal Parts and Products

9 Union Tank Car Company (Plant No. 70-01-048) complies with facility-specific emission limit as specified in 40 CFR 

Part63 §63.3890(c)(2). The facility-specific limit is calculated monthly based on 12-month compliance period. 

11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 29 Feet

Discharge Style Horizontal Discharge

Stack Opening (inches) 72 inches by 96 inches

Exhaust Temperature (F) 87 oF

Exhaust Flowrate (scfm) 24,200 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted 

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process 

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values 

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to 

determine if a permit amendment is required or submit a permit application requesting to amend the permit.
Union Tank Car Company Railcar Interior Lining Shop (EP6A) Page 7 of 10

Muscatine, Iowa 96-A-636-S4

12. Compliance Demonstration(s) 

Pollutant Compliance 

Demonstration

Compliance Methodology Frequency

PM – Federal No Performance Testing NA

PM – State No Performance Testing NA

PM10 No Performance Testing NA

PM2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO2 No NA NA

NOx No NA NA

VOC Yes Material Usage Tracking Daily &365-day Rolling 

Calculation

CO No NA NA

Pb No NA NA

HAP Yes NESHAP Subpart MMMM Monthly

If an initial compliance demonstration specified above is testing, the owner or the owner’s authorized agent shall 

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days after 

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of 

the proposed equipment. 

If subsequent testing is specified above, the owner or the owner’s authorized agent shall verify compliance with 

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the 

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 1 hour 40 CFR 60, Appendix A, Method 5 

40 CFR 51 Appendix M Method 202

PM10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM2.5 23 hours 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO2 1 hour 40 CFR 60, Appendix A, Method 6C

NOx 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the 

Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs 

shall apply for compliance, unless otherwise indicated by the Department. 
Union Tank Car Company Railcar Interior Lining Shop (EP6A) Page 8 of 10

Muscatine, Iowa 96-A-636-S4

12. Compliance Demonstration(s) (Continued)

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days 

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the 

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. 

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It 

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the 

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, 

different, or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be 

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate 

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where 

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is 

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this 

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the

Department to determine whether this unit(s) is in compliance.

13. New Source Performance Standards (NSPS) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart MMMMNational Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and 

Products as specified in 40 CFR Part 63 §63.3881. Union Tank Car Company shall comply with all reporting, 

notification, and recordkeeping requirements as specified 40 CFR Part 63 Subpart MMMM, specifically §63.3910, 

§63.3920, §63.3930, and §63.3931.

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart A-General 

Provisions as specified in 40 CFR Part 63 §63.3901. Union Tank Car Company (Plant No. 70-01-048) shall comply 

with all reporting, notification, and recordkeeping requirements as specified 40 CFR Part 60 Subpart A, §63.3901

(Table 2).

14. Operating Limits

Operating limits for this emission unit shall be:

A. Total VOC emissions from coating operations (EU 5, 6, 7, 12, and 13) shall not exceed 200 tons per 365-

day rolling period. (Note: coating operations include Railcar Exterior Painting (EU-5), Railcar Interior 

Painting/Touchup Painting (EU 6, 12, and 13), and Rubber Lining of Tank Cars (EU-7).

B. Railcar Interior Painting/Stencil & Touchup Painting (EU6) shall not exceed 20 hours of operation per day.

C. Mini-pleat Filters (CE6A) shall be installed and operational by September 2, 2014.

D. Mini-pleat Filters (CE6A) shall have a MERV rating of no less than 13.

E. Mini-pleat Filters (CE6A) shall be maintained and replaced per manufacturer’s instructions and 

specifications.
Union Tank Car Company Railcar Interior Lining Shop (EP6A) Page 9 of 10

Muscatine, Iowa 96-A-636-S4

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of 

two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an 

orderly manner. These records shall show the following:

A. For all coating operations (EU 5, 6, 7, 12, and 13) record the amount of coating or solvent used (in gallons) 

and the VOC content of all coatings or solvents used (in lbs/gallon) each day.

B. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons each day.

C. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons per 365-day 

rolling period.

D. For each day record the number of hours Railcar Interior Painting/Stencil & Touchup Painting (EU6) is 

operated.

E. Maintain a record of the installation and operation date of Mini-pleat Filters (CE6A).

F. Maintain record of MERV Rating of Mini-pleat filters (CE6A).

G. The owner or operator shall maintain a record for all maintenance and replacement of Mini-pleat Filters 

(CE6A).

16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.

17. Permit History

Permit No. Project No. Description Date Stack 

Testing

96-A-636 96-200 Original Permit 06/11/96 Yes

96-A-636-S1 00-142 Revise Paint Use Limit 03/26/00 No

96-A-636-S2 08-621 Amend Operating Limits 10/29/09 No

96-A-363-S3 12-409 Add Particulate Filter, Establish PM2.5 

Limits

04/08/13 No
Union Tank Car Company Railcar Interior Lining Shop (EP6A) Page 10 of 10

Muscatine, Iowa 96-A-636-S4

18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be 

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form 

particulate matter immediately after discharge from the stack

Department Iowa Department of Natural Resources

dia. Diameter

F Degrees Fahrenheit

ft Foot

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM – Federal Particulate Matter that does not include the condensable PM

PM – State Particulate Matter that includes condensable PM

ppm parts per million

ppmv parts per million by volume

ppmw parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year

END OF PERMIT
CPFP|7001048|090214|14097|00A531S3

PZ

Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Union Tank Car Company-Muscatine Repair Shop

Contact: Responsible Party:

David Herrin Troy McKim

Manger-Environmental Compliance Plant Manager

(312)431-3111 Ext. 3168

175 West Jackson Blvd., Suite 2100 2603 Dick Drake Way

Chicago, Illinois 60604 Muscatine, Iowa 52761

Permitted Equipment

Emission Unit(s): Railcar Interior Painting/Stencil & Touchup Painting (EU6)

Heaters for Tank Cars (13 @ 2.5 MMBtu/hr each) (EU12)

Heaters for Hopper Cars (4 @ 4 MMBtu/hr each) (EU13)

Maximum Capacity: 400 gallons of coating per day

Control Equipment: Mini-pleat Filters (CE6D)

Emission Point: EP6D

Equipment Location: 2603 Dick Drake Way

Muscatine, Iowa 52761

Plant Number: 70-01-048

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with 

applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, 

and federal law.

Permit No. Project No. Description Date Stack 

Testing

00-A-531-S3 14-097 Modify Stack Configuration & Control Install 

Date

09/02/14 No

____________________________________

Under the Direction of the Director of

the Department of Natural Resources
Union Tank Car Company Railcar Interior Lining Shop (EP6D) Page 2 of 10

Muscatine, Iowa 00-A-531-S3

PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or 

misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In 

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has 

been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal 

Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the 

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or 

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, 

installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point 

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the 

facility shall assure that the installation of the equipment listed in this permit conforms to the design in the 

application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this 

emission unit(s), control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person 

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring 

that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the 

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and 

control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by 

paragraph 567 IAC 24.2(1) "Maintenance and Repair”.

3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one location to another or from one piece of 

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been 

issued is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) 

days prior to transferring to the new location unless the equipment will be located in an area which is classified as 

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notification shall be given fourteen (14) days prior to the relocation of equipment1(See Permit 

Condition 8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if 

the relocation will cause a violation of the (NAAQS). In such case, a supplemental permit shall be required prior to 

the initiation of construction of additional control equipment or modifications to equipment needed to meet the 

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as 

submitted, and that adequate operation and maintenance is provided to ensure that no condition of air 

pollution is created. 
Union Tank Car Company Railcar Interior Lining Shop (EP6D) Page 3 of 10

Muscatine, Iowa 00-A-531-S3

4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or 

operator shall seek a permit amendment in order to revert back to the most recent previous version of the 

permit. The previous, unchanged permit provisions are included in the amendment for your convenience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted 

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected 

emission unit(s) and emission point, together with any previous amendment to the permit, until one of the 

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and 

emission point permitted herein; or

(2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.11(g), where applicable, any credible evidence may be used 

for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this 

permit or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are 

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good 

practice for minimizing emissions except when another regulation applicable to the unit or process provides 

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be 

limited to one (1) six-minute period per one (1) hour period. 

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties 

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the 

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within 

a reasonable period of time, as specified in 567 IAC 24.1. 

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See 

Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all 

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
Union Tank Car Company Railcar Interior Lining Shop (EP6D) Page 4 of 10

Muscatine, Iowa 00-A-531-S3

7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two 

(2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days 

following initiation of construction, installation, or alteration;

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be 

transferred from one location to another, the Department shall be notified:

(a) at least fourteen (14) days before equipment relocation if the equipment will be located in a 

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance 

area for the NAAQS; 

(b) at least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership

within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the 

owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of each compliance test required by Permit 

Condition 12 shall be done not less than thirty (30) days before the required test or performance 

evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time, 

 the place, 

 the name of the person who will conduct the tests, 

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not 

consider the test results or performance evaluation results to be a valid demonstration of compliance 

with the applicable rules or permit conditions. Upon written request, the Department may allow a 

notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported 

within eight (8) hours or at the start of the first working day following the onset of the incident. The 

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2

shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days 

of the onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified 

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring 

system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days 

following the end of the calendar quarter, on forms provided by the Director.
Union Tank Car Company Railcar Interior Lining Shop (EP6D) Page 5 of 10

Muscatine, Iowa 00-A-531-S3

8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, 

whether successful or not, postmarked not later than six (6) weeks after the completion of the test 

period unless other regulations provide for other notification requirements. In that case, the more

stringent reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit 

shall be available at the plant during normal business hours for inspection and copying by federal, state, or 

local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years 

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9549

Fax: (515) 725-9501

E. The owner or operator shall send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9545

Fax: (515) 725-9502

F. The owner or operator shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9550

Fax: (515) 725-9502

DNR Field Office 6

1023 West Madison

Washington, IA 52353

Telephone: (319) 653-2135

Fax: (319) 653-2856

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless 

they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in 

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of 

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the 

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319

Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319
Union Tank Car Company Railcar Interior Lining Shop (EP6D) Page 6 of 10

Muscatine, Iowa 00-A-531-S3

10. Emission Limits

The following emission limits shall not be exceeded: 

Pollutant lb/hr1tons/yr2 Additional 

Limits

Reference

(567 IAC)

Particulate Matter (PM) – Federal NA NA NA NA

Particulate Matter (PM) – State 1.2 NA 0.01 gr/dscf 23.4(13)

PM10 0.63 NA NA NAAQS

PM2.5 0.0214 NA NA NAAQS

Opacity NA NA 40%5, 6 23.3(2)”d”

Sulfur Dioxide (SO2) NA NA NA NA

Nitrogen Oxides (NOx) NA NA NA NA

Volatile Organic Compounds (VOC) NA 2007 NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA 923.1(4)”cm”8

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a 365-day rolling total.

3 The limit established as part of Project 08-621 that demonstrated predicted compliance with PM10 NAAQS.

4 The limit for PM2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; 

Call for Iowa SIP Revision” for PM2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

5 The emission limit is a six (6) minute average.

6 An exceedance of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly 

investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If 

exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., 

stack testing).

7 Total VOC emissions from coating operations (EU 5, 6, 7, 12, and 13) shall not exceed 200 tons per 365-day rolling 

period. (Note: The VOC PTE of the 17 natural gas heaters is 0.89 tons per year and counts against the 200 ton/yr bubble 

limit).

8

Iowa adoption of NESHAP Subpart MMMM: National Emission Standards for Hazardous Air Pollutants: Surface 

Coating of Miscellaneous Metal Parts and Products

9 Union Tank Car Company (Plant No. 70-01-048) complies with facility-specific emission limit as specified in 40 CFR 

Part63 §63.3890(c)(2). The facility-specific limit is calculated monthly based on 12-month compliance period. 

11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 29 Feet

Discharge Style Horizontal Discharge

Stack Opening (inches) 72 inches by 96 inches

Exhaust Temperature (F) 87 oF

Exhaust Flowrate (scfm) 24,200 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted 

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process 

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values 

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to 

determine if a permit amendment is required or submit a permit application requesting to amend the permit.
Union Tank Car Company Railcar Interior Lining Shop (EP6D) Page 7 of 10

Muscatine, Iowa 00-A-531-S3

12. Compliance Demonstration(s) 

Pollutant Compliance 

Demonstration

Compliance Methodology Frequency

PM – Federal No Performance Testing NA

PM – State No Performance Testing NA

PM10 No Performance Testing NA

PM2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO2 No NA NA

NOx No NA NA

VOC Yes Material Usage Tracking Daily &365-day Rolling 

Calculation

CO No NA NA

Pb No NA NA

HAP Yes NESHAP Subpart MMMM Monthly

If an initial compliance demonstration specified above is testing, the owner or the owner’s authorized agent shall 

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days after 

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of 

the proposed equipment. 

If subsequent testing is specified above, the owner or the owner’s authorized agent shall verify compliance with 

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the 

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 1 hour 40 CFR 60, Appendix A, Method 5 

40 CFR 51 Appendix M Method 202

PM10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM2.5 23 hours 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO2 1 hour 40 CFR 60, Appendix A, Method 6C

NOx 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the 

Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs 

shall apply for compliance, unless otherwise indicated by the Department. 
Union Tank Car Company Railcar Interior Lining Shop (EP6D) Page 8 of 10

Muscatine, Iowa 00-A-531-S3

12. Compliance Demonstration(s) (Continued)

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days 

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the 

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. 

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It 

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the 

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, 

different, or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be 

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate 

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where 

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is 

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this 

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the 

Department to determine whether this unit(s) is in compliance.

13. New Source Performance Standards (NSPS) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart MMMMNational Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and 

Products as specified in 40 CFR Part 63 §63.3881. Union Tank Car Company shall comply with all reporting, 

notification, and recordkeeping requirements as specified 40 CFR Part 63 Subpart MMMM, specifically §63.3910, 

§63.3920, §63.3930, and §63.3931.

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart A-General 

Provisions as specified in 40 CFR Part 63 §63.3901. Union Tank Car Company (Plant No. 70-01-048) shall comply 

with all reporting, notification, and recordkeeping requirements as specified 40 CFR Part 60 Subpart A, §63.3901

(Table 2).

14. Operating Limits

Operating limits for this emission unit shall be:

A. Total VOC emissions from coating operations (EU 5, 6, 7, 12, and 13) shall not exceed 200 tons per 365-

day rolling period. (Note: coating operations include Railcar Exterior Painting (EU-5), Railcar Interior 

Painting/Touchup Painting (EU 6, 12, and 13), and Rubber Lining of Tank Cars (EU-7).

B. Railcar Interior Painting/Stencil & Touchup Painting (EU6) shall not exceed 20 hours of operation per day.

C. Mini-pleat Filters (CE6D) shall be installed and operational by September 2, 2014.

D. Railcar Interior Painting/Stencil & Touchup Painting (EU6) shall not exceed 20 hours of operation per day.

E. Mini-pleat Filters (CE6D) shall have a MERV rating of no less than 13.

F. Mini-pleat Filters (CE6D) shall be maintained and replaced per manufacturer’s instructions and 

specifications.
Union Tank Car Company Railcar Interior Lining Shop (EP6D) Page 9 of 10

Muscatine, Iowa 00-A-531-S3

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of 

two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an 

orderly manner. These records shall show the following:

A. For all coating operations (EU 5, 6, 7, 12, and 13) record the amount of coating or solvent used (in gallons) 

and the VOC content of all coatings or solvents used (in lbs/gallon) each day.

B. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons each day.

C. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons per 365-day 

rolling period.

D. For each day record the number of hours Railcar Interior Painting/Stencil & Touchup Painting (EU6) is 

operated.

E. Maintain a record of the installation and operation date of Mini-pleat Filters (CE6D).

F. Maintain record of MERV Rating of Mini-pleat filters (CE6D).

G. The owner or operator shall maintain a record for all maintenance and replacement of the Mini-pleat Filters

(CE6D).

16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.

17. Permit History

Permit No. Project No. Description Date Stack 

Testing

00-A-531 00-142 Original Permit 03/26/00 No

00-A-531-S1 08-621 Amend Operating Limits 10/29/09 No

00-A-531-S2 12-409 Add Particulate Filter, Establish PM2.5 

Limits

04/08/13 No
Union Tank Car Company Railcar Interior Lining Shop (EP6D) Page 10 of 10

Muscatine, Iowa 00-A-531-S3

18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be 

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form 

particulate matter immediately after discharge from the stack

Department Iowa Department of Natural Resources

dia. Diameter

F Degrees Fahrenheit

ft Foot

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM – Federal Particulate Matter that does not include the condensable PM

PM – State Particulate Matter that includes condensable PM

ppm parts per million

ppmv parts per million by volume

ppmw parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year

END OF PERMIT
CPFP|7001048|090214|14097|00A533S3

PZ

Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Union Tank Car Company-Muscatine Repair Shop

Contact: Responsible Party:

David Herrin Troy McKim

Manger-Environmental Compliance Plant Manager

(312)431-3111 Ext. 3168

175 West Jackson Blvd., Suite 2100 2603 Dick Drake Way

Chicago, Illinois 60604 Muscatine, Iowa 52761

Permitted Equipment

Emission Unit(s): Railcar Interior Painting/Stencil & Touchup Painting (EU6)

Heaters for Tank Cars (13 @ 2.5 MMBtu/hr each) (EU12)

Heaters for Hopper Cars (4 @ 4 MMBtu/hr each) (EU13)

Maximum Capacity: 400 gallons of coating per day

Control Equipment: Mini-pleat Filters (CE6F)

Emission Point: EP6F

Equipment Location: 2603 Dick Drake Way

Muscatine, Iowa 52761

Plant Number: 70-01-048

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with 

applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, 

and federal law.

Permit No. Project No. Description Date Stack 

Testing

00-A-533-S3 14-097 Modify Stack Configuration & Control Install 

Date

09/02/14 No

____________________________________

Under the Direction of the Director of

the Department of Natural Resources
Union Tank Car Company Railcar Interior Lining Shop (EP6F) Page 2 of 10

Muscatine, Iowa 00-A-533-S3

PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or 

misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In 

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has 

been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal 

Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the 

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or 

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, 

installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point 

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the 

facility shall assure that the installation of the equipment listed in this permit conforms to the design in the 

application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this 

emission unit(s), control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person 

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring 

that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the 

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and 

control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by 

paragraph 567 IAC 24.2(1) "Maintenance and Repair”.

3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one location to another or from one piece of 

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been 

issued is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) 

days prior to transferring to the new location unless the equipment will be located in an area which is classified as 

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notification shall be given fourteen (14) days prior to the relocation of equipment1(See Permit 

Condition 8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if 

the relocation will cause a violation of the (NAAQS). In such case, a supplemental permit shall be required prior to 

the initiation of construction of additional control equipment or modifications to equipment needed to meet the 

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as 

submitted, and that adequate operation and maintenance is provided to ensure that no condition of air 

pollution is created. 
Union Tank Car Company Railcar Interior Lining Shop (EP6F) Page 3 of 10

Muscatine, Iowa 00-A-533-S3

4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or 

operator shall seek a permit amendment in order to revert back to the most recent previous version of the 

permit. The previous, unchanged permit provisions are included in the amendment for your convenience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted 

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected 

emission unit(s) and emission point, together with any previous amendment to the permit, until one of the 

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and 

emission point permitted herein; or

(2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.11(g), where applicable, any credible evidence may be used 

for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this 

permit or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are 

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good 

practice for minimizing emissions except when another regulation applicable to the unit or process provides 

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be 

limited to one (1) six-minute period per one (1) hour period. 

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties 

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the 

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within 

a reasonable period of time, as specified in 567 IAC 24.1. 

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See 

Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all 

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
Union Tank Car Company Railcar Interior Lining Shop (EP6F) Page 4 of 10

Muscatine, Iowa 00-A-533-S3

7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two 

(2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days 

following initiation of construction, installation, or alteration;

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be 

transferred from one location to another, the Department shall be notified:

(a) at least fourteen (14) days before equipment relocation if the equipment will be located in a 

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance 

area for the NAAQS; 

(b) at least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership

within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the 

owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of each compliance test required by Permit 

Condition 12 shall be done not less than thirty (30) days before the required test or performance 

evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time, 

 the place, 

 the name of the person who will conduct the tests, 

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not 

consider the test results or performance evaluation results to be a valid demonstration of compliance 

with the applicable rules or permit conditions. Upon written request, the Department may allow a 

notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported

within eight (8) hours or at the start of the first working day following the onset of the incident. The 

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2

shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days 

of the onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified 

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring 

system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days 

following the end of the calendar quarter, on forms provided by the Director.
Union Tank Car Company Railcar Interior Lining Shop (EP6F) Page 5 of 10

Muscatine, Iowa 00-A-533-S3

8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, 

whether successful or not, postmarked not later than six (6) weeks after the completion of the test 

period unless other regulations provide for other notification requirements. In that case, the more 

stringent reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit 

shall be available at the plant during normal business hours for inspection and copying by federal, state, or 

local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years 

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9549

Fax: (515) 725-9501

E. The owner or operator shall send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9545

Fax: (515) 725-9502

F. The owner or operator shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9550

Fax: (515) 725-9502

DNR Field Office 6

1023 West Madison

Washington, IA 52353

Telephone: (319) 653-2135

Fax: (319) 653-2856

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless 

they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in 

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of 

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the 

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319

Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319
Union Tank Car Company Railcar Interior Lining Shop (EP6F) Page 6 of 10

Muscatine, Iowa 00-A-533-S3

10. Emission Limits

The following emission limits shall not be exceeded: 

Pollutant lb/hr1tons/yr2 Additional 

Limits

Reference

(567 IAC)

Particulate Matter (PM) – Federal NA NA NA NA

Particulate Matter (PM) – State 1.2 NA 0.01 gr/dscf 23.4(13)

PM10 0.63 NA NA NAAQS

PM2.5 0.0214 NA NA NAAQS

Opacity NA NA 40%5, 6 23.3(2)”d”

Sulfur Dioxide (SO2) NA NA NA NA

Nitrogen Oxides (NOx) NA NA NA NA

Volatile Organic Compounds (VOC) NA 2007 NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA 923.1(4)”cm”8

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a 365-day rolling total.

3 The limit established as part of Project 08-621 that demonstrated predicted compliance with PM10 NAAQS.

4 The limit for PM2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; 

Call for Iowa SIP Revision” for PM2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

5 The emission limit is a six (6) minute average.

6 An exceedance of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly 

investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If 

exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., 

stack testing).

7 Total VOC emissions from coating operations (EU 5, 6, 7, 12, and 13) shall not exceed 200 tons per 365-day rolling 

period. (Note: The VOC PTE of the 17 natural gas heaters is 0.89 tons per year and counts against the 200 ton/yr bubble 

limit).

8

Iowa adoption of NESHAP Subpart MMMM: National Emission Standards for Hazardous Air Pollutants: Surface 

Coating of Miscellaneous Metal Parts and Products

9 Union Tank Car Company (Plant No. 70-01-048) complies with facility-specific emission limit as specified in 40 CFR 

Part63 §63.3890(c)(2). The facility-specific limit is calculated monthly based on 12-month compliance period. 

11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 29 Feet

Discharge Style Horizontal Discharge

Stack Opening (inches) 72 inches by 96 inches

Exhaust Temperature (F) 87 oF

Exhaust Flowrate (scfm) 24,200 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted 

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process 

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values 

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to 

determine if a permit amendment is required or submit a permit application requesting to amend the permit.
Union Tank Car Company Railcar Interior Lining Shop (EP6F) Page 7 of 10

Muscatine, Iowa 00-A-533-S3

12. Compliance Demonstration(s) 

Pollutant Compliance 

Demonstration

Compliance Methodology Frequency

PM – Federal No Performance Testing NA

PM – State No Performance Testing NA

PM10 No Performance Testing NA

PM2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO2 No NA NA

NOx No NA NA

VOC Yes Material Usage Tracking Daily &365-day Rolling 

Calculation

CO No NA NA

Pb No NA NA

HAP Yes NESHAP Subpart MMMM Monthly

If an initial compliance demonstration specified above is testing, the owner or the owner’s authorized agent shall 

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days after 

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of 

the proposed equipment. 

If subsequent testing is specified above, the owner or the owner’s authorized agent shall verify compliance with 

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the 

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 1 hour 40 CFR 60, Appendix A, Method 5 

40 CFR 51 Appendix M Method 202

PM10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM2.5 23 hours 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO2 1 hour 40 CFR 60, Appendix A, Method 6C

NOx 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

CO2 1 hour 40 CFR 60, Appendix A, Method 3

CH4 1 hour 40 CFR 60, Appendix A, Method 18

N2O 1 hour 40 CFR 60, Appendix A, Method 320

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the 

Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs 

shall apply for compliance, unless otherwise indicated by the Department. 
Union Tank Car Company Railcar Interior Lining Shop (EP6F) Page 8 of 10

Muscatine, Iowa 00-A-533-S3

12. Compliance Demonstration(s) (Continued)

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days 

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the 

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. 

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It 

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the 

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, 

different, or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be 

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate 

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where 

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is 

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this 

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the 

Department to determine whether this unit(s) is in compliance.

13. New Source Performance Standards (NSPS) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart MMMMNational Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and 

Products as specified in 40 CFR Part 63 §63.3881. Union Tank Car Company shall comply with all reporting, 

notification, and recordkeeping requirements as specified 40 CFR Part 63 Subpart MMMM, specifically §63.3910, 

§63.3920, §63.3930, and §63.3931.

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart A-General 

Provisions as specified in 40 CFR Part 63 §63.3901. Union Tank Car Company (Plant No. 70-01-048) shall comply 

with all reporting, notification, and recordkeeping requirements as specified 40 CFR Part 60 Subpart A, §63.3901

(Table 2).

14. Operating Limits

Operating limits for this emission unit shall be:

A. Total VOC emissions from coating operations (EU 5, 6, 7, 12, and 13) shall not exceed 200 tons per 365-

day rolling period. (Note: coating operations include Railcar Exterior Painting (EU-5), Railcar Interior 

Painting/Touchup Painting (EU 6, 12, and 13), and Rubber Lining of Tank Cars (EU-7).

B. Railcar Interior Painting/Stencil & Touchup Painting (EU6) shall not exceed 20 hours of operation per day.

C. Mini-pleat Filters (CE6F) shall be installed and operational by September 2, 2014.

D. Railcar Interior Painting/Stencil & Touchup Painting (EU6) shall not exceed 20 hours of operation per day.

E. Mini-pleat Filters (CE6F) shall have a MERV rating of no less than 13.

F. Mini-pleat Filters (CE6F) shall be maintained and replaced per manufacturer’s instructions and 

specifications.
Union Tank Car Company Railcar Interior Lining Shop (EP6F) Page 9 of 10

Muscatine, Iowa 00-A-533-S3

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of 

two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an 

orderly manner. These records shall show the following:

A. For all coating operations (EU 5, 6, 7, 12, and 13) record the amount of coating or solvent used (in gallons) 

and the VOC content of all coatings or solvents used (in lbs/gallon) each day.

B. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons each day.

C. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons per 365-day 

rolling period.

D. For each day record the number of hours Railcar Interior Painting/Stencil & Touchup Painting (EU6) is 

operated.

E. Maintain a record of the installation and operation date of Mini-pleat Filters (CE6F).

F. Maintain record of MERV Rating of Mini-pleat filters (CE6F).

G. The owner or operator shall maintain a record for all maintenance and replacement of the Mini-pleat Filters 

(CE6F).

16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.

17. Permit History

Permit No. Project No. Description Date Stack 

Testing

00-A-533 00-142 Original Permit 03/26/00 No

00-A-533-S1 08-621 Amend Operating Limits 10/29/09 No

00-A-533-S2 12-409 Add Particulate Filter, Establish PM2.5 

Limits

04/08/13 No
Union Tank Car Company Railcar Interior Lining Shop (EP6F) Page 10 of 10

Muscatine, Iowa 00-A-533-S3

18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be 

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form 

particulate matter immediately after discharge from the stack

Department Iowa Department of Natural Resources

dia. Diameter

F Degrees Fahrenheit

ft Foot

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM – Federal Particulate Matter that does not include the condensable PM

PM – State Particulate Matter that includes condensable PM

ppm parts per million

ppmv parts per million by volume

ppmw parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year

END OF PERMIT
CPFP|7001048|090214|14097|00A1089S3

PZ

Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Union Tank Car Company-Muscatine Repair Shop

Contact: Responsible Party:

David Herrin Troy McKim

Manger-Environmental Compliance Plant Manager

(312)431-3111 Ext. 3168

175 West Jackson Blvd., Suite 2100 2603 Dick Drake Way

Chicago, Illinois 60604 Muscatine, Iowa 52761

Permitted Equipment

Emission Unit(s): Railcar Rubber Linning Shop (EU7)

Maximum Capacity: 75 gallons of adhesive material per day

Control Equipment: None

Emission Point: EP7A

Equipment Location: 2603 Dick Drake Way

Muscatine, Iowa 52761

Plant Number: 70-01-048

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with 

applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, 

and federal law.

Permit No. Project No. Description Date Stack 

Testing

00-A-1089-S3 14-097 Modify Emission Limit & Remove Control 

Requirement 

09/02/14 No

____________________________________

Under the Direction of the Director of

the Department of Natural Resources
Union Tank Car Company Railcar Rubber Lining Shop (EP7A) Page 2 of 9

Muscatine, Iowa 00-A-1089-S3

PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or 

misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In 

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has 

been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal 

Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the 

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or 

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, 

installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point 

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the 

facility shall assure that the installation of the equipment listed in this permit conforms to the design in the 

application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this 

emission unit(s), control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person 

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring 

that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the 

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and 

control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by 

paragraph 567 IAC 24.2(1) "Maintenance and Repair”.

3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one location to another or from one piece of 

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been 

issued is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) 

days prior to transferring to the new location unless the equipment will be located in an area which is classified as 

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notification shall be given fourteen (14) days prior to the relocation of equipment1(See Permit 

Condition 8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if 

the relocation will cause a violation of the (NAAQS). In such case, a supplemental permit shall be required prior to 

the initiation of construction of additional control equipment or modifications to equipment needed to meet the 

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as 

submitted, and that adequate operation and maintenance is provided to ensure that no condition of air 

pollution is created. 
Union Tank Car Company Railcar Rubber Lining Shop (EP7A) Page 3 of 9

Muscatine, Iowa 00-A-1089-S3

4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or 

operator shall seek a permit amendment in order to revert back to the most recent previous version of the 

permit. The previous, unchanged permit provisions are included in the amendment for your convenience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted 

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected 

emission unit(s) and emission point, together with any previous amendment to the permit, until one of the 

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and 

emission point permitted herein; or

(2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.11(g), where applicable, any credible evidence may be used 

for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this 

permit or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are 

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good 

practice for minimizing emissions except when another regulation applicable to the unit or process provides 

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be 

limited to one (1) six-minute period per one (1) hour period. 

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties 

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the 

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within 

a reasonable period of time, as specified in 567 IAC 24.1. 

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See 

Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all 

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
Union Tank Car Company Railcar Rubber Lining Shop (EP7A) Page 4 of 9

Muscatine, Iowa 00-A-1089-S3

7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two 

(2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days 

following initiation of construction, installation, or alteration;

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be 

transferred from one location to another, the Department shall be notified:

(a) at least fourteen (14) days before equipment relocation if the equipment will be located in a 

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance 

area for the NAAQS; 

(b) at least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership

within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the 

owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of each compliance test required by Permit 

Condition 12 shall be done not less than thirty (30) days before the required test or performance 

evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time, 

 the place, 

 the name of the person who will conduct the tests, 

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not 

consider the test results or performance evaluation results to be a valid demonstration of compliance 

with the applicable rules or permit conditions. Upon written request, the Department may allow a 

notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported

within eight (8) hours or at the start of the first working day following the onset of the incident. The 

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2

shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days 

of the onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified 

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring 

system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days 

following the end of the calendar quarter, on forms provided by the Director.
Union Tank Car Company Railcar Rubber Lining Shop (EP7A) Page 5 of 9

Muscatine, Iowa 00-A-1089-S3

8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, 

whether successful or not, postmarked not later than six (6) weeks after the completion of the test 

period unless other regulations provide for other notification requirements. In that case, the more 

stringent reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit 

shall be available at the plant during normal business hours for inspection and copying by federal, state, or 

local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years 

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9549

Fax: (515) 725-9501

E. The owner or operator shall send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9545

Fax: (515) 725-9502

F. The owner or operator shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9550

Fax: (515) 725-9502

DNR Field Office 6

1023 West Madison

Washington, IA 52353

Telephone: (319) 653-2135

Fax: (319) 653-2856

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless 

they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in 

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of 

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the 

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319

Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319
Union Tank Car Company Railcar Rubber Lining Shop (EP7A) Page 6 of 9

Muscatine, Iowa 00-A-1089-S3

10. Emission Limits

The following emission limits shall not be exceeded: 

Pollutant lb/hr1tons/yr2 Additional 

Limits

Reference

(567 IAC)

Particulate Matter (PM) – Federal NA NA NA NA

Particulate Matter (PM) – State 0.10 NA 0.01 gr/dscf 23.4(13)

PM10 0.103 NA NA NAAQS

PM2.5 0.00854 NA NA NAAQS

Opacity NA NA 40%5, 623.3(2)”d”

Sulfur Dioxide (SO2) NA NA NA NA

Nitrogen Oxides (NOx) NA NA NA NA

Volatile Organic Compounds (VOC) NA 2007 NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA 923.1(4)”cm”8

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a 365-day rolling total.

3 The limit established as part of Project 08-621 that demonstrated predicted compliance with PM10 NAAQS.

4 The limit for PM2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; 

Call for Iowa SIP Revision” for PM2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

5 The emission limit is a six (6) minute average.

6 An exceedance of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly 

investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If 

exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., 

stack testing).

7 Total VOC emissions from coating operations (EU 5, 6, 7, 12, and 13) shall not exceed 200 tons per 365-day rolling 

period. (Note: The VOC PTE of the 17 natural gas heaters is 0.89 tons per year and counts against the 200 ton/yr bubble 

limit).

8

Iowa adoption of NESHAP Subpart MMMM: National Emission Standards for Hazardous Air Pollutants: Surface 

Coating of Miscellaneous Metal Parts and Products

9 Union Tank Car Company (Plant No. 70-01-048) complies with facility-specific emission limit as specified in 40 CFR 

Part63 §63.3890(c)(2). The facility-specific limit is calculated monthly based on 12-month compliance period. 

11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 32 Feet

Discharge Style Vertical Unobstructed Discharge

Stack Opening (inches) 18 inch Diameter

Exhaust Temperature (F) 70 oF

Exhaust Flowrate (scfm) 3,000 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted 

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process 

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values 

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to 

determine if a permit amendment is required or submit a permit application requesting to amend the permit.
Union Tank Car Company Railcar Rubber Lining Shop (EP7A) Page 7 of 9

Muscatine, Iowa 00-A-1089-S3

12. Compliance Demonstration(s) 

Pollutant Compliance 

Demonstration

Compliance Methodology Frequency

PM – Federal No Performance Testing NA

PM – State No Performance Testing NA

PM10 No Performance Testing NA

PM2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO2 No NA NA

NOx No NA NA

VOC Yes Material Usage Tracking Daily &365-day Rolling 

Calculation

CO No NA NA

Pb No NA NA

HAP Yes NESHAP Subpart MMMM Monthly

If an initial compliance demonstration specified above is testing, the owner or the owner’s authorized agent shall 

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days after 

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of 

the proposed equipment. 

If subsequent testing is specified above, the owner or the owner’s authorized agent shall verify compliance with 

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the 

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 1 hour 40 CFR 60, Appendix A, Method 5 

40 CFR 51 Appendix M Method 202

PM10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM2.5 7 hours 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO2 1 hour 40 CFR 60, Appendix A, Method 6C

NOx 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the 

Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs 

shall apply for compliance, unless otherwise indicated by the Department. 

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days 

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the 

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. 

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It 

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the 

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, 

different, or more detailed testing requirements.
Union Tank Car Company Railcar Rubber Lining Shop (EP7A) Page 8 of 9

Muscatine, Iowa 00-A-1089-S3

12. Compliance Demonstration(s) (Continued)

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be 

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate 

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where 

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is 

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this 

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the 

Department to determine whether this unit(s) is in compliance.

13. New Source Performance Standards (NSPS) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart MMMMNational Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and 

Products as specified in 40 CFR Part 63 §63.3881. Union Tank Car Company shall comply with all reporting, 

notification, and recordkeeping requirements as specified 40 CFR Part 63 Subpart MMMM, specifically §63.3910, 

§63.3920, §63.3930, and §63.3931.

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart A-General 

Provisions as specified in 40 CFR Part 63 §63.3901. Union Tank Car Company (Plant No. 70-01-048) shall comply 

with all reporting, notification, and recordkeeping requirements as specified 40 CFR Part 60 Subpart A, §63.3901

(Table 2).

14. Operating Limits

Operating limits for this emission unit shall be:

A. Total VOC emissions from coating operations (EU 5, 6, 7, 12, and 13) shall not exceed 200 tons per 365-

day rolling period. (Note: coating operations include Railcar Exterior Painting (EU-5), Railcar Interior 

Painting/Touchup Painting (EU 6, 12, and 13), and Rubber Lining of Tank Cars (EU-7).

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of 

two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an 

orderly manner. These records shall show the following:

A. For all coating operations (EU 5, 6, 7, 12, and 13) record the amount of coating or solvent used (in gallons) 

and the VOC content of all coatings or solvents used (in lbs/gallon) each day.

B. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons each day.

C. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons per 365-day 

rolling period.

16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.
Union Tank Car Company Railcar Rubber Lining Shop (EP7A) Page 9 of 9

Muscatine, Iowa 00-A-1089-S3

17. Permit History

Permit No. Project No. Description Date Stack 

Testing

00-A-089 00-074 Original Permit 12/15/00 No

00-A-089-S1 08-621 Amend Operating Limits 10/29/09 No

00-A-089-S2 12-409 Add Particulate Filter, Establish PM2.5 

Limits

04/08/13 No

18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be 

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form 

particulate matter immediately after discharge from the stack

Department Iowa Department of Natural Resources

dia. Diameter

F Degrees Fahrenheit

ft Foot

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM – Federal Particulate Matter that does not include the condensable PM

PM – State Particulate Matter that includes condensable PM

ppm parts per million

ppmv parts per million by volume

ppmw parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year

END OF PERMIT
CPFP|7001048|090214|14097|00A1090S3

Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Union Tank Car Company-Muscatine Repair Shop

Contact: Responsible Party:

David Herrin Troy McKim

Manger-Environmental Compliance Plant Manager

(312)431-3111 Ext. 3168

175 West Jackson Blvd., Suite 2100 2603 Dick Drake Way

Chicago, Illinois 60604 Muscatine, Iowa 52761

Permitted Equipment

Emission Unit(s): Railcar Rubber Linning Shop (EU7)

Maximum Capacity: 75 gallons of adhesive material per day

Control Equipment: None

Emission Point: EP7B

Equipment Location: 2603 Dick Drake Way

Muscatine, Iowa 52761

Plant Number: 70-01-048

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with 

applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, 

and federal law.

Permit No. Project No. Description Date Stack 

Testing

00-A-1090-S3 14-097 Modify Emission Limit & Remove Control 

Requirement 

09/02/14 No

____________________________________

Under the Direction of the Director of

the Department of Natural Resources
Union Tank Car Company Railcar Rubber Lining Shop (EP7B) Page 2 of 9

Muscatine, Iowa 00-A-1090-S3

PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or 

misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In 

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has 

been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal 

Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the 

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or 

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, 

installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point 

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the 

facility shall assure that the installation of the equipment listed in this permit conforms to the design in the 

application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this 

emission unit(s), control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person 

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring 

that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the 

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and 

control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by 

paragraph 567 IAC 24.2(1) "Maintenance and Repair”.

3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one location to another or from one piece of 

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been 

issued is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) 

days prior to transferring to the new location unless the equipment will be located in an area which is classified as 

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notification shall be given fourteen (14) days prior to the relocation of equipment1(See Permit 

Condition 8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if 

the relocation will cause a violation of the (NAAQS). In such case, a supplemental permit shall be required prior to 

the initiation of construction of additional control equipment or modifications to equipment needed to meet the 

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as 

submitted, and that adequate operation and maintenance is provided to ensure that no condition of air 

pollution is created. 
Union Tank Car Company Railcar Rubber Lining Shop (EP7B) Page 3 of 9

Muscatine, Iowa 00-A-1090-S3

4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or 

operator shall seek a permit amendment in order to revert back to the most recent previous version of the 

permit. The previous, unchanged permit provisions are included in the amendment for your convenience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted 

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected 

emission unit(s) and emission point, together with any previous amendment to the permit, until one of the 

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and 

emission point permitted herein; or

(2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.11(g), where applicable, any credible evidence may be used 

for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this 

permit or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are 

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good 

practice for minimizing emissions except when another regulation applicable to the unit or process provides 

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be 

limited to one (1) six-minute period per one (1) hour period. 

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties 

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the 

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within 

a reasonable period of time, as specified in 567 IAC 24.1. 

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See 

Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all 

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
Union Tank Car Company Railcar Rubber Lining Shop (EP7B) Page 4 of 9

Muscatine, Iowa 00-A-1090-S3

7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two 

(2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days 

following initiation of construction, installation, or alteration;

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be 

transferred from one location to another, the Department shall be notified:

(a) at least fourteen (14) days before equipment relocation if the equipment will be located in a 

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance 

area for the NAAQS; 

(b) at least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership

within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the 

owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of each compliance test required by Permit 

Condition 12 shall be done not less than thirty (30) days before the required test or performance 

evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time, 

 the place, 

 the name of the person who will conduct the tests, 

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not 

consider the test results or performance evaluation results to be a valid demonstration of compliance 

with the applicable rules or permit conditions. Upon written request, the Department may allow a 

notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported

within eight (8) hours or at the start of the first working day following the onset of the incident. The 

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2

shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days 

of the onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified 

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring 

system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days 

following the end of the calendar quarter, on forms provided by the Director.
Union Tank Car Company Railcar Rubber Lining Shop (EP7B) Page 5 of 9

Muscatine, Iowa 00-A-1090-S3

8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, 

whether successful or not, postmarked not later than six (6) weeks after the completion of the test 

period unless other regulations provide for other notification requirements. In that case, the more 

stringent reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit 

shall be available at the plant during normal business hours for inspection and copying by federal, state, or 

local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years 

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9549

Fax: (515) 725-9501

E. The owner or operator shall send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9545

Fax: (515) 725-9502

F. The owner or operator shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9550

Fax: (515) 725-9502

DNR Field Office 6

1023 West Madison

Washington, IA 52353

Telephone: (319) 653-2135

Fax: (319) 653-2856

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless 

they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in 

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of 

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the 

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319

Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319
Union Tank Car Company Railcar Rubber Lining Shop (EP7B) Page 6 of 9

Muscatine, Iowa 00-A-1090-S3

10. Emission Limits

The following emission limits shall not be exceeded: 

Pollutant lb/hr1tons/yr2 Additional 

Limits

Reference

(567 IAC)

Particulate Matter (PM) – Federal NA NA NA NA

Particulate Matter (PM) – State 0.10 NA 0.01 gr/dscf 23.4(13)

PM10 0.103 NA NA NAAQS

PM2.5 0.00854 NA NA NAAQS

Opacity NA NA 40%5, 6 23.3(2)”d”

Sulfur Dioxide (SO2) NA NA NA NA

Nitrogen Oxides (NOx) NA NA NA NA

Volatile Organic Compounds (VOC) NA 2007 NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA 923.1(4)”cm”8

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a 365-day rolling total.

3 The limit established as part of Project 08-621 that demonstrated predicted compliance with PM10 NAAQS.

4 The limit for PM2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; 

Call for Iowa SIP Revision” for PM2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

5 The emission limit is a six (6) minute average.

6 An exceedance of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly 

investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If 

exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., 

stack testing).

7 Total VOC emissions from coating operations (EU 5, 6, 7, 12, and 13) shall not exceed 200 tons per 365-day rolling 

period. (Note: The VOC PTE of the 17 natural gas heaters is 0.89 tons per year and counts against the 200 ton/yr bubble 

limit).

8

Iowa adoption of NESHAP Subpart MMMM: National Emission Standards for Hazardous Air Pollutants: Surface 

Coating of Miscellaneous Metal Parts and Products

9 Union Tank Car Company (Plant No. 70-01-048) complies with facility-specific emission limit as specified in 40 CFR 

Part63 §63.3890(c)(2). The facility-specific limit is calculated monthly based on 12-month compliance period. 

11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 31 Feet

Discharge Style Vertical Unobstructed Discharge

Stack Opening (inches) 46 inch Diameter

Exhaust Temperature (F) 70 oF

Exhaust Flowrate (scfm) 25,000 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted 

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process 

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values 

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to 

determine if a permit amendment is required or submit a permit application requesting to amend the permit.
Union Tank Car Company Railcar Rubber Lining Shop (EP7B) Page 7 of 9

Muscatine, Iowa 00-A-1090-S3

12. Compliance Demonstration(s) 

Pollutant Compliance 

Demonstration

Compliance Methodology Frequency

PM – Federal No Performance Testing NA

PM – State No Performance Testing NA

PM10 No Performance Testing NA

PM2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO2 No NA NA

NOx No NA NA

VOC Yes Material Usage Tracking Daily &365-day Rolling 

Calculation

CO No NA NA

Pb No NA NA

HAP Yes NESHAP Subpart MMMM Monthly

If an initial compliance demonstration specified above is testing, the owner or the owner’s authorized agent shall 

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days after 

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of 

the proposed equipment. 

If subsequent testing is specified above, the owner or the owner’s authorized agent shall verify compliance with 

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the 

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 6 hours 40 CFR 60, Appendix A, Method 5 

40 CFR 51 Appendix M Method 202

PM10 6 hours 40 CFR 51, Appendix M, 201A with 202

PM2.5 59 hours 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO2 1 hour 40 CFR 60, Appendix A, Method 6C

NOx 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the 

Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs 

shall apply for compliance, unless otherwise indicated by the Department. 

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days 

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the 

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. 

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It 

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the 

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, 

different, or more detailed testing requirements.
Union Tank Car Company Railcar Rubber Lining Shop (EP7B) Page 8 of 9

Muscatine, Iowa 00-A-1090-S3

12. Compliance Demonstration(s) (Continued)

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be 

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate 

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where 

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is 

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this 

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the 

Department to determine whether this unit(s) is in compliance.

13. New Source Performance Standards (NSPS) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart MMMMNational Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and 

Products as specified in 40 CFR Part 63 §63.3881. Union Tank Car Company shall comply with all reporting, 

notification, and recordkeeping requirements as specified 40 CFR Part 63 Subpart MMMM, specifically §63.3910, 

§63.3920, §63.3930, and §63.3931.

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart A-General 

Provisions as specified in 40 CFR Part 63 §63.3901. Union Tank Car Company (Plant No. 70-01-048) shall comply 

with all reporting, notification, and recordkeeping requirements as specified 40 CFR Part 60 Subpart A, §63.3901

(Table 2).

14. Operating Limits

Operating limits for this emission unit shall be:

A. Total VOC emissions from coating operations (EU 5, 6, 7, 12, and 13) shall not exceed 200 tons per 365-

day rolling period. (Note: coating operations include Railcar Exterior Painting (EU-5), Railcar Interior 

Painting/Touchup Painting (EU 6, 12, and 13), and Rubber Lining of Tank Cars (EU-7).

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of 

two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an 

orderly manner. These records shall show the following:

A. For all coating operations (EU 5, 6, 7, 12, and 13) record the amount of coating or solvent used (in gallons) 

and the VOC content of all coatings or solvents used (in lbs/gallon) each day.

B. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons each day.

C. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons per 365-day 

rolling period.

16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.
Union Tank Car Company Railcar Rubber Lining Shop (EP7B) Page 9 of 9

Muscatine, Iowa 00-A-1090-S3

17. Permit History

Permit No. Project No. Description Date Stack 

Testing

00-A-090 00-074 Original Permit 12/15/00 No

00-A-090-S1 08-621 Amend Operating Limits 10/29/09 No

00-A-090-S2 12-409 Add Particulate Filter, Establish PM2.5 

Limits

04/08/13 No

18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be 

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form 

particulate matter immediately after discharge from the stack

Department Iowa Department of Natural Resources

dia. Diameter

F Degrees Fahrenheit

ft Foot

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM – Federal Particulate Matter that does not include the condensable PM

PM – State Particulate Matter that includes condensable PM

ppm parts per million

ppmv parts per million by volume

ppmw parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year

END OF PERMIT
CPFP|7001048|090214|14097|00A1091S3

PZ

Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Union Tank Car Company-Muscatine Repair Shop

Contact: Responsible Party:

David Herrin Troy McKim

Manger-Environmental Compliance Plant Manager

(312)431-3111 Ext. 3168

175 West Jackson Blvd., Suite 2100 2603 Dick Drake Way

Chicago, Illinois 60604 Muscatine, Iowa 52761

Permitted Equipment

Emission Unit(s): Railcar Rubber Linning Shop (EU7)

Maximum Capacity: 75 gallons of adhesive material per day

Control Equipment: None

Emission Point: EP7C

Equipment Location: 2603 Dick Drake Way

Muscatine, Iowa 52761

Plant Number: 70-01-048

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with 

applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, 

and federal law.

Permit No. Project No. Description Date Stack 

Testing

00-A-1091-S3 14-097 Modify Emission Limit & Remove Control 

Requirement 

09/02/14 No

____________________________________

Under the Direction of the Director of

the Department of Natural Resources
Union Tank Car Company Railcar Rubber Lining Shop (EP7C) Page 2 of 9

Muscatine, Iowa 00-A-1091-S3

PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or 

misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In 

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has 

been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal 

Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the 

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or 

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, 

installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point 

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the 

facility shall assure that the installation of the equipment listed in this permit conforms to the design in the 

application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this 

emission unit(s), control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person 

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring 

that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the 

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and 

control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by 

paragraph 567 IAC 24.2(1) "Maintenance and Repair”.

3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one location to another or from one piece of 

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been 

issued is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) 

days prior to transferring to the new location unless the equipment will be located in an area which is classified as 

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notification shall be given fourteen (14) days prior to the relocation of equipment1(See Permit 

Condition 8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if 

the relocation will cause a violation of the (NAAQS). In such case, a supplemental permit shall be required prior to 

the initiation of construction of additional control equipment or modifications to equipment needed to meet the 

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as 

submitted, and that adequate operation and maintenance is provided to ensure that no condition of air 

pollution is created. 
Union Tank Car Company Railcar Rubber Lining Shop (EP7C) Page 3 of 9

Muscatine, Iowa 00-A-1091-S3

4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or 

operator shall seek a permit amendment in order to revert back to the most recent previous version of the 

permit. The previous, unchanged permit provisions are included in the amendment for your convenience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted 

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected 

emission unit(s) and emission point, together with any previous amendment to the permit, until one of the 

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and 

emission point permitted herein; or

(2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.11(g), where applicable, any credible evidence may be used 

for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this 

permit or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are 

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good 

practice for minimizing emissions except when another regulation applicable to the unit or process provides 

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be 

limited to one (1) six-minute period per one (1) hour period. 

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties 

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the 

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within 

a reasonable period of time, as specified in 567 IAC 24.1. 

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See 

Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all 

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
Union Tank Car Company Railcar Rubber Lining Shop (EP7C) Page 4 of 9

Muscatine, Iowa 00-A-1091-S3

7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two 

(2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days 

following initiation of construction, installation, or alteration;

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be 

transferred from one location to another, the Department shall be notified:

(a) at least fourteen (14) days before equipment relocation if the equipment will be located in a 

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance 

area for the NAAQS; 

(b) at least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership

within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the 

owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of each compliance test required by Permit 

Condition 12 shall be done not less than thirty (30) days before the required test or performance 

evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time, 

 the place, 

 the name of the person who will conduct the tests, 

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not 

consider the test results or performance evaluation results to be a valid demonstration of compliance 

with the applicable rules or permit conditions. Upon written request, the Department may allow a 

notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported

within eight (8) hours or at the start of the first working day following the onset of the incident. The 

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2

shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days 

of the onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified 

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring 

system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days 

following the end of the calendar quarter, on forms provided by the Director.
Union Tank Car Company Railcar Rubber Lining Shop (EP7C) Page 5 of 9

Muscatine, Iowa 00-A-1091-S3

8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, 

whether successful or not, postmarked not later than six (6) weeks after the completion of the test 

period unless other regulations provide for other notification requirements. In that case, the more 

stringent reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit 

shall be available at the plant during normal business hours for inspection and copying by federal, state, or 

local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years 

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9549

Fax: (515) 725-9501

E. The owner or operator shall send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9545

Fax: (515) 725-9502

F. The owner or operator shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9550

Fax: (515) 725-9502

DNR Field Office 6

1023 West Madison

Washington, IA 52353

Telephone: (319) 653-2135

Fax: (319) 653-2856

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless 

they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in 

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of 

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the 

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319

Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319
Union Tank Car Company Railcar Rubber Lining Shop (EP7C) Page 6 of 9

Muscatine, Iowa 00-A-1091-S3

10. Emission Limits

The following emission limits shall not be exceeded: 

Pollutant lb/hr1tons/yr2 Additional 

Limits

Reference

(567 IAC)

Particulate Matter (PM) – Federal NA NA NA NA

Particulate Matter (PM) – State 0.10 NA 0.01 gr/dscf 23.4(13)

PM10 0.103 NA NA NAAQS

PM2.5 0.00854 NA NA NAAQS

Opacity NA NA 40%5, 6 23.3(2)”d”

Sulfur Dioxide (SO2) NA NA NA NA

Nitrogen Oxides (NOx) NA NA NA NA

Volatile Organic Compounds (VOC) NA 2007 NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA 923.1(4)”cm”8

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a 365-day rolling total.

3 The limit established as part of Project 08-621 that demonstrated predicted compliance with PM10 NAAQS.

4 The limit for PM2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; 

Call for Iowa SIP Revision” for PM2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

5 The emission limit is a six (6) minute average.

6 An exceedance of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly 

investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If 

exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., 

stack testing).

7 Total VOC emissions from coating operations (EU 5, 6, 7, 12, and 13) shall not exceed 200 tons per 365-day rolling 

period. (Note: The VOC PTE of the 17 natural gas heaters is 0.89 tons per year and counts against the 200 ton/yr bubble 

limit).

8

Iowa adoption of NESHAP Subpart MMMM: National Emission Standards for Hazardous Air Pollutants: Surface 

Coating of Miscellaneous Metal Parts and Products

9 Union Tank Car Company (Plant No. 70-01-048) complies with facility-specific emission limit as specified in 40 CFR 

Part63 §63.3890(c)(2). The facility-specific limit is calculated monthly based on 12-month compliance period. 

11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 31 Feet

Discharge Style Vertical Unobstructed Discharge

Stack Opening (inches) 46 inch Diameter

Exhaust Temperature (F) 70 oF

Exhaust Flowrate (scfm) 25,000 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted 

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process 

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values 

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to 

determine if a permit amendment is required or submit a permit application requesting to amend the permit.
Union Tank Car Company Railcar Rubber Lining Shop (EP7C) Page 7 of 9

Muscatine, Iowa 00-A-1091-S3

12. Compliance Demonstration(s) 

Pollutant Compliance 

Demonstration

Compliance Methodology Frequency

PM – Federal No Performance Testing NA

PM – State No Performance Testing NA

PM10 No Performance Testing NA

PM2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO2 No NA NA

NOx No NA NA

VOC Yes Material Usage Tracking Daily &365-day Rolling 

Calculation

CO No NA NA

Pb No NA NA

HAP Yes NESHAP Subpart MMMM Monthly

If an initial compliance demonstration specified above is testing, the owner or the owner’s authorized agent shall 

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days after 

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of 

the proposed equipment. 

If subsequent testing is specified above, the owner or the owner’s authorized agent shall verify compliance with 

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the 

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 6 hours 40 CFR 60, Appendix A, Method 5 

40 CFR 51 Appendix M Method 202

PM10 6 hours 40 CFR 51, Appendix M, 201A with 202

PM2.5 59 hours 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO2 1 hour 40 CFR 60, Appendix A, Method 6C

NOx 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the 

Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs 

shall apply for compliance, unless otherwise indicated by the Department. 

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days 

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the 

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. 

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It 

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the 

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, 

different, or more detailed testing requirements.
Union Tank Car Company Railcar Rubber Lining Shop (EP7C) Page 8 of 9

Muscatine, Iowa 00-A-1091-S3

12. Compliance Demonstration(s) (Continued)

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be 

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate 

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where 

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is 

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this 

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the 

Department to determine whether this unit(s) is in compliance.

13. New Source Performance Standards (NSPS) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart MMMMNational Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and 

Products as specified in 40 CFR Part 63 §63.3881. Union Tank Car Company shall comply with all reporting, 

notification, and recordkeeping requirements as specified 40 CFR Part 63 Subpart MMMM, specifically §63.3910, 

§63.3920, §63.3930, and §63.3931.

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart A-General 

Provisions as specified in 40 CFR Part 63 §63.3901. Union Tank Car Company (Plant No. 70-01-048) shall comply 

with all reporting, notification, and recordkeeping requirements as specified 40 CFR Part 60 Subpart A, §63.3901

(Table 2).

14. Operating Limits

Operating limits for this emission unit shall be:

A. Total VOC emissions from coating operations (EU 5, 6, 7, 12, and 13) shall not exceed 200 tons per 365-

day rolling period. (Note: coating operations include Railcar Exterior Painting (EU-5), Railcar Interior 

Painting/Touchup Painting (EU 6, 12, and 13), and Rubber Lining of Tank Cars (EU-7).

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of 

two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an 

orderly manner. These records shall show the following:

A. For all coating operations (EU 5, 6, 7, 12, and 13) record the amount of coating or solvent used (in gallons) 

and the VOC content of all coatings or solvents used (in lbs/gallon) each day.

B. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons each day.

C. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons per 365-day 

rolling period.

16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.
Union Tank Car Company Railcar Rubber Lining Shop (EP7C) Page 9 of 9

Muscatine, Iowa 00-A-1091-S3

17. Permit History

Permit No. Project No. Description Date Stack 

Testing

00-A-091 00-074 Original Permit 12/15/00 No

00-A-091-S1 08-621 Amend Operating Limits 10/29/09 No

00-A-091-S2 12-409 Add Particulate Filter, Establish PM2.5 

Limits

04/08/13 No

18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be 

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form 

particulate matter immediately after discharge from the stack

Department Iowa Department of Natural Resources

dia. Diameter

F Degrees Fahrenheit

ft Foot

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM – Federal Particulate Matter that does not include the condensable PM

PM – State Particulate Matter that includes condensable PM

ppm parts per million

ppmv parts per million by volume

ppmw parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year

END OF PERMIT
CPFP|7001048|090214|14097|10A043S3

PZ

Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Union Tank Car Company-Muscatine Repair Shop

Contact: Responsible Party:

David Herrin Troy McKim

Manger-Environmental Compliance Plant Manager

(312)431-3111 Ext. 3168

175 West Jackson Blvd., Suite 2100 2603 Dick Drake Way

Chicago, Illinois 60604 Muscatine, Iowa 52761

Permitted Equipment

Emission Unit(s): Railcar Rubber Linning Shop (EU7)

Maximum Capacity: 75 gallons of adhesive material per day

Control Equipment: None

Emission Point: EP7D

Equipment Location: 2603 Dick Drake Way

Muscatine, Iowa 52761

Plant Number: 70-01-048

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with 

applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, 

and federal law.

Permit No. Project No. Description Date Stack 

Testing

10-A-043-S3 14-097 Modify Emission Limit & Remove Control 

Requirement 

09/02/14 No

____________________________________

Under the Direction of the Director of

the Department of Natural Resources
Union Tank Car Company Railcar Rubber Lining Shop (EP7D) Page 2 of 9

Muscatine, Iowa 10-A-043-S3

PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or 

misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In 

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has 

been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal 

Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the 

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or 

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, 

installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point 

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the 

facility shall assure that the installation of the equipment listed in this permit conforms to the design in the 

application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this 

emission unit(s), control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person 

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring 

that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the 

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and 

control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by 

paragraph 567 IAC 24.2(1) "Maintenance and Repair”.

3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one location to another or from one piece of 

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been 

issued is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) 

days prior to transferring to the new location unless the equipment will be located in an area which is classified as 

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notification shall be given fourteen (14) days prior to the relocation of equipment1(See Permit 

Condition 8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if 

the relocation will cause a violation of the (NAAQS). In such case, a supplemental permit shall be required prior to 

the initiation of construction of additional control equipment or modifications to equipment needed to meet the 

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as 

submitted, and that adequate operation and maintenance is provided to ensure that no condition of air 

pollution is created. 
Union Tank Car Company Railcar Rubber Lining Shop (EP7D) Page 3 of 9

Muscatine, Iowa 10-A-043-S3

4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or 

operator shall seek a permit amendment in order to revert back to the most recent previous version of the 

permit. The previous, unchanged permit provisions are included in the amendment for your convenience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted 

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected 

emission unit(s) and emission point, together with any previous amendment to the permit, until one of the 

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and 

emission point permitted herein; or

(2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.11(g), where applicable, any credible evidence may be used 

for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this 

permit or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are 

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good 

practice for minimizing emissions except when another regulation applicable to the unit or process provides 

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be 

limited to one (1) six-minute period per one (1) hour period. 

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties 

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the 

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within 

a reasonable period of time, as specified in 567 IAC 24.1. 

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See 

Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all 

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
Union Tank Car Company Railcar Rubber Lining Shop (EP7D) Page 4 of 9

Muscatine, Iowa 10-A-043-S3

7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two 

(2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days 

following initiation of construction, installation, or alteration;

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be 

transferred from one location to another, the Department shall be notified:

(a) at least fourteen (14) days before equipment relocation if the equipment will be located in a 

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance 

area for the NAAQS; 

(b) at least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership

within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the 

owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of each compliance test required by Permit 

Condition 12 shall be done not less than thirty (30) days before the required test or performance 

evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time, 

 the place, 

 the name of the person who will conduct the tests, 

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not 

consider the test results or performance evaluation results to be a valid demonstration of compliance 

with the applicable rules or permit conditions. Upon written request, the Department may allow a 

notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported

within eight (8) hours or at the start of the first working day following the onset of the incident. The 

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2

shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days 

of the onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified 

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring 

system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days 

following the end of the calendar quarter, on forms provided by the Director.
Union Tank Car Company Railcar Rubber Lining Shop (EP7D) Page 5 of 9

Muscatine, Iowa 10-A-043-S3

8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, 

whether successful or not, postmarked not later than six (6) weeks after the completion of the test 

period unless other regulations provide for other notification requirements. In that case, the more 

stringent reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit 

shall be available at the plant during normal business hours for inspection and copying by federal, state, or 

local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years 

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9549

Fax: (515) 725-9501

E. The owner or operator shall send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9545

Fax: (515) 725-9502

F. The owner or operator shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9550

Fax: (515) 725-9502

DNR Field Office 6

1023 West Madison

Washington, IA 52353

Telephone: (319) 653-2135

Fax: (319) 653-2856

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless 

they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in 

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of 

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the 

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319

Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319
Union Tank Car Company Railcar Rubber Lining Shop (EP7D) Page 6 of 9

Muscatine, Iowa 10-A-043-S3

10. Emission Limits

The following emission limits shall not be exceeded: 

Pollutant lb/hr1tons/yr2 Additional 

Limits

Reference

(567 IAC)

Particulate Matter (PM) – Federal NA NA NA NA

Particulate Matter (PM) – State 0.103 NA 0.01 gr/dscf 23.4(13)

PM10 0.103 NA NA NA

PM2.5 0.00854 NA NA NAAQS

Opacity NA NA 40%5, 623.3(2)”d”

Sulfur Dioxide (SO2) NA NA NA NA

Nitrogen Oxides (NOx) NA NA NA NA

Volatile Organic Compounds (VOC) NA 2007 NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA 923.1(4)”cm”8

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a 365-day rolling total.

3 Requested limit as part of Project 10-026

4 The limit for PM2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; 

Call for Iowa SIP Revision” for PM2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

5 The emission limit is a six (6) minute average.

6 An exceedance of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly 

investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If 

exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., 

stack testing).

8

Iowa adoption of NESHAP Subpart MMMM: National Emission Standards for Hazardous Air Pollutants: Surface 

Coating of Miscellaneous Metal Parts and Products

9 Union Tank Car Company (Plant No. 70-01-048) complies with facility-specific emission limit as specified in 40 CFR 

Part63 §63.3890(c)(2). The facility-specific limit is calculated monthly based on 12-month compliance period. 

11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 23 Feet

Discharge Style Vertical Unobstructed Discharge

Stack Opening (inches) 16 inch Diameter

Exhaust Temperature (F) 70 oF

Exhaust Flowrate (scfm) 4,000 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted 

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process 

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values 

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to 

determine if a permit amendment is required or submit a permit application requesting to amend the permit.
Union Tank Car Company Railcar Rubber Lining Shop (EP7D) Page 7 of 9

Muscatine, Iowa 10-A-043-S3

12. Compliance Demonstration(s) 

Pollutant Compliance 

Demonstration

Compliance Methodology Frequency

PM – Federal No Performance Testing NA

PM – State No Performance Testing NA

PM10 No Performance Testing NA

PM2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO2 No NA NA

NOx No NA NA

VOC Yes Material Usage Tracking Daily &365-day Rolling 

Calculation

CO No NA NA

Pb No NA NA

HAP Yes NESHAP Subpart MMMM Monthly

If an initial compliance demonstration specified above is testing, the owner or the owner’s authorized agent shall 

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days after 

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of 

the proposed equipment. 

If subsequent testing is specified above, the owner or the owner’s authorized agent shall verify compliance with 

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the 

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 1 hour 40 CFR 60, Appendix A, Method 5 

40 CFR 51 Appendix M Method 202

PM10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM2.5 10 hours 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO2 1 hour 40 CFR 60, Appendix A, Method 6C

NOx 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the 

Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs 

shall apply for compliance, unless otherwise indicated by the Department. 

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days 

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the 

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. 

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It 

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the 

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, 

different, or more detailed testing requirements.
Union Tank Car Company Railcar Rubber Lining Shop (EP7D) Page 8 of 9

Muscatine, Iowa 10-A-043-S3

12. Compliance Demonstration(s) (Continued)

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be 

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate 

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where 

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is 

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this 

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the 

Department to determine whether this unit(s) is in compliance.

13. New Source Performance Standards (NSPS) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart MMMMNational Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and 

Products as specified in 40 CFR Part 63 §63.3881. Union Tank Car Company shall comply with all reporting, 

notification, and recordkeeping requirements as specified 40 CFR Part 63 Subpart MMMM, specifically §63.3910, 

§63.3920, §63.3930, and §63.3931.

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart A-General 

Provisions as specified in 40 CFR Part 63 §63.3901. Union Tank Car Company (Plant No. 70-01-048) shall comply 

with all reporting, notification, and recordkeeping requirements as specified 40 CFR Part 60 Subpart A, §63.3901

(Table 2).

14. Operating Limits

Operating limits for this emission unit shall be:

A. Total VOC emissions from coating operations (EU 5, 6, 7, 12, and 13) shall not exceed 200 tons per 365-

day rolling period. (Note: coating operations include Railcar Exterior Painting (EU-5), Railcar Interior 

Painting/Touchup Painting (EU 6, 12, and 13), and Rubber Lining of Tank Cars (EU-7).

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of 

two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an 

orderly manner. These records shall show the following:

A. For all coating operations (EU 5, 6, 7, 12, and 13) record the amount of coating or solvent used (in gallons) 

and the VOC content of all coatings or solvents used (in lbs/gallon) each day.

B. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons each day.

C. For all coating operations (EU 5, 6, 7, 12, and 13) calculate the total VOC emissions in tons per 365-day 

rolling period.

16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.
Union Tank Car Company Railcar Rubber Lining Shop (EP7D) Page 9 of 9

Muscatine, Iowa 10-A-043-S3

17. Permit History

Permit No. Project No. Description Date Stack 

Testing

10-A-043 10-026 Original Permit 03/12/10 No

10-A-043-S1 10-255 Amend HAP Coating Limit 10/29/09 No

10-A-043-S2 12-409 Add Particulate Filter, Establish PM2.5 

Limits, Vertical Unobstructed Discharge

04/08/13 No

18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be 

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form 

particulate matter immediately after discharge from the stack

Department Iowa Department of Natural Resources

dia. Diameter

F Degrees Fahrenheit

ft Foot

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM – Federal Particulate Matter that does not include the condensable PM

PM – State Particulate Matter that includes condensable PM

ppm parts per million

ppmv parts per million by volume

ppmw parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year

END OF PERMIT
CPFP|7001048|090214|14097|09A009S3

PZ

Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Union Tank Car Company-Muscatine Repair Shop

Contact: Responsible Party:

David Herrin Troy McKim

Manger-Environmental Compliance Plant Manager

(312)431-3111 Ext. 3168

175 West Jackson Blvd., Suite 2100 2603 Dick Drake Way

Chicago, Illinois 60604 Muscatine, Iowa 52761

Permitted Equipment

Emission Unit(s): Inline Tank Car Qualification Process (Cut Shop)

Welding & Metal Arc Cutting (EU 9)

Maximum Capacity: 36 Railcars per day

Control Equipment: Mini-pleat Filters (CE9A)

Emission Point: EP9A

Equipment Location: 2603 Dick Drake Way

Muscatine, Iowa 52761

Plant Number: 70-01-048

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with 

applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, 

and federal law.

Permit No. Project No. Description Date Stack 

Testing

09-A-009-S3 14-097 Modify Stack Configuration & Control Install 

Date

09/02/14 No

____________________________________

Under the Direction of the Director of

the Department of Natural Resources
Union Tank Car Company Inline Tank Car Qualification Process (EP 9A) Page 2 of 10

Muscatine, Iowa 09-A-009-S3

PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or 

misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In 

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has 

been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal 

Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the 

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or 

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, 

installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point 

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the 

facility shall assure that the installation of the equipment listed in this permit conforms to the design in the 

application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this 

emission unit(s), control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person 

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring 

that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the 

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and 

control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by 

paragraph 567 IAC 24.2(1) "Maintenance and Repair”.

3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one location to another or from one piece of 

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been 

issued is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) 

days prior to transferring to the new location unless the equipment will be located in an area which is classified as 

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notification shall be given fourteen (14) days prior to the relocation of equipment1(See Permit 

Condition 8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if 

the relocation will cause a violation of the (NAAQS). In such case, a supplemental permit shall be required prior to 

the initiation of construction of additional control equipment or modifications to equipment needed to meet the 

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as 

submitted, and that adequate operation and maintenance is provided to ensure that no condition of air 

pollution is created. 
Union Tank Car Company Inline Tank Car Qualification Process (EP 9A) Page 3 of 10

Muscatine, Iowa 09-A-009-S3

4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or 

operator shall seek a permit amendment in order to revert back to the most recent previous version of the 

permit. The previous, unchanged permit provisions are included in the amendment for your convenience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted 

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected 

emission unit(s) and emission point, together with any previous amendment to the permit, until one of the 

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and 

emission point permitted herein; or

(2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.11(g), where applicable, any credible evidence may be used 

for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this 

permit or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are 

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good 

practice for minimizing emissions except when another regulation applicable to the unit or process provides 

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be 

limited to one (1) six-minute period per one (1) hour period. 

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties 

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the 

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within 

a reasonable period of time, as specified in 567 IAC 24.1. 

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See 

Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all 

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
Union Tank Car Company Inline Tank Car Qualification Process (EP 9A) Page 4 of 10

Muscatine, Iowa 09-A-009-S3

7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two 

(2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days 

following initiation of construction, installation, or alteration;

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be 

transferred from one location to another, the Department shall be notified:

(a) at least fourteen (14) days before equipment relocation if the equipment will be located in a 

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance 

area for the NAAQS; 

(b) at least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership

within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the 

owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of each compliance test required by Permit 

Condition 12 shall be done not less than thirty (30) days before the required test or performance 

evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time, 

 the place, 

 the name of the person who will conduct the tests, 

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not 

consider the test results or performance evaluation results to be a valid demonstration of compliance 

with the applicable rules or permit conditions. Upon written request, the Department may allow a 

notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported

within eight (8) hours or at the start of the first working day following the onset of the incident. The 

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2

shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days 

of the onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified 

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring 

system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days 

following the end of the calendar quarter, on forms provided by the Director.
Union Tank Car Company Inline Tank Car Qualification Process (EP 9A) Page 5 of 10

Muscatine, Iowa 09-A-009-S3

8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, 

whether successful or not, postmarked not later than six (6) weeks after the completion of the test 

period unless other regulations provide for other notification requirements. In that case, the more 

stringent reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit 

shall be available at the plant during normal business hours for inspection and copying by federal, state, or 

local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years 

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9549

Fax: (515) 725-9501

E. The owner or operator shall send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9545

Fax: (515) 725-9502

F. The owner or operator shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9550

Fax: (515) 725-9502

DNR Field Office 6

1023 West Madison

Washington, IA 52353

Telephone: (319) 653-2135

Fax: (319) 653-2856

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless 

they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in 

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of 

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the 

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319

Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319
Union Tank Car Company Inline Tank Car Qualification Process (EP 9A) Page 6 of 10

Muscatine, Iowa 09-A-009-S3

10. Emission Limits

The following emission limits shall not be exceeded: 

Pollutant lb/hr1tons/yr2 Additional 

Limits

Reference

(567 IAC)

Particulate Matter (PM) – Federal NA NA NA NA

Particulate Matter (PM) – State 2.5 NA 0.1 gr/scf 23.3(2)”a”

PM10 0.653 NA NA NAAQS

PM2.5 0.0274 NA NA NAAQS

Opacity NA NA 40%5,623.3(2)”d”

Sulfur Dioxide (SO2) NA NA NA NA

Nitrogen Oxides (NOx) NA NA NA NA

Volatile Organic Compounds (VOC) NA NA NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

Carbon Dioxide equivalents (CO2e) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA NA NA

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a 12-month rolling total.

3 The limit established as part of Project 08-621 that demonstrated predicted compliance with PM10 NAAQS.

4 The limit for PM2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; 

Call for Iowa SIP Revision” for PM2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

5 The emission limit is a six (6) minute average.

6 An exceedance of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly 

investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If 

exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., 

stack testing).

11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 28 Feet

Discharge Style Horizontal Discharge

Stack Opening (inches) 72 inches by 96 inches

Exhaust Temperature (F) Ambient

Exhaust Flowrate (scfm) 25,000 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted 

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process 

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values 

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to 

determine if a permit amendment is required or submit a permit application requesting to amend the permit.
Union Tank Car Company Inline Tank Car Qualification Process (EP 9A) Page 7 of 10

Muscatine, Iowa 09-A-009-S3

12. Compliance Demonstration(s) 

Pollutant Compliance 

Demonstration

Compliance Methodology Frequency

PM – Federal No Performance Testing NA

PM – State No Performance Testing NA

PM10 No Performance Testing NA

PM2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO2 No NA NA

NOx No NA NA

VOC No NA NA

CO No NA NA

Pb No NA NA

HAP No NA NA

If an initial compliance demonstration specified above is testing, the owner or the owner’s authorized agent shall 

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days after 

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of 

the proposed equipment. 

If subsequent testing is specified above, the owner or the owner’s authorized agent shall verify compliance with 

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the 

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 1 hour 40 CFR 60, Appendix A, Method 5 

40 CFR 51 Appendix M Method 202

PM10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM2.5 19 hours 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO2 1 hour 40 CFR 60, Appendix A, Method 6C

NOx 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the 

Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs 

shall apply for compliance, unless otherwise indicated by the Department. 
Union Tank Car Company Inline Tank Car Qualification Process (EP 9A) Page 8 of 10

Muscatine, Iowa 09-A-009-S3

12. Compliance Demonstration(s) (Continued)

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days 

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the 

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. 

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It 

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the 

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, 

different, or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be 

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate 

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where 

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is 

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this 

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the 

Department to determine whether this unit(s) is in compliance.

13. New Source Performance Standards (NSPS) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart MMMMNational Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and 

Products as specified in 40 CFR Part 63 §63.3881. Union Tank Car Company shall comply with all reporting, 

notification, and recordkeeping requirements as specified 40 CFR Part 63 Subpart MMMM, specifically §63.3910, 

§63.3920, §63.3930, and §63.3931.

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart A-General 

Provisions as specified in 40 CFR Part 63 §63.3901. Union Tank Car Company (Plant No. 70-01-048) shall comply 

with all reporting, notification, and recordkeeping requirements as specified 40 CFR Part 60 Subpart A, §63.3901

(Table 2).

14. Operating Limits

Operating limits for this emission unit shall be:

A. Mini-pleat Filters (CE9A) shall be installed and operational by September 2, 2014.

B. Mini-pleat Filters (CE9A) shall have a MERV rating of no less than 13.

C. Mini-pleat Filters (CE9A) shall be maintained and replaced per manufacturer’s instructions and 

specifications.

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of 

two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an 

orderly manner. These records shall show the following:

A. Maintain a record of the installation and operation date of Mini-pleat Filters (CE9A).

B. Maintain record of MERV Rating of Mini-pleat filters (CE9A).

C. The owner or operator shall maintain a record for all maintenance and replacement of the Mini-pleat Filters

(CE9A).
Union Tank Car Company Inline Tank Car Qualification Process (EP 9A) Page 9 of 10

Muscatine, Iowa 09-A-009-S3

16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.

17. Permit History

Permit No. Project No. Description Date Stack 

Testing

09-A-009 08-621 Original Permit 10/29/09 No

09-A-009-S1 10-340 Remove Operating Hours Restriction 09/02/10 No

09-A-009-S2 12-409 Add Particulate Filter, Establish PM2.5 Limits, 

Add Fan to Increase Flow

04/08/13 No
Union Tank Car Company Inline Tank Car Qualification Process (EP 9A) Page 10 of 10

Muscatine, Iowa 09-A-009-S3

18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be 

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form 

particulate matter immediately after discharge from the stack

Department Iowa Department of Natural Resources

dia. Diameter

F Degrees Fahrenheit

ft Foot

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM – Federal Particulate Matter that does not include the condensable PM

PM – State Particulate Matter that includes condensable PM

ppm parts per million

ppmv parts per million by volume

ppmw parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year

END OF PERMIT
CPFP|7001048|090214|14097|09A010S3

PZ

Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Union Tank Car Company-Muscatine Repair Shop

Contact: Responsible Party:

David Herrin Troy McKim

Manger-Environmental Compliance Plant Manager

(312)431-3111 Ext. 3168

175 West Jackson Blvd., Suite 2100 2603 Dick Drake Way

Chicago, Illinois 60604 Muscatine, Iowa 52761

Permitted Equipment

Emission Unit(s): Inline Tank Car Qualification Process (Cut Shop)

Welding & Metal Arc Cutting (EU 9)

Maximum Capacity: 36 Railcars per day

Control Equipment: Mini-pleat Filters (CE9B)

Emission Point: EP9B

Equipment Location: 2603 Dick Drake Way

Muscatine, Iowa 52761

Plant Number: 70-01-048

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with 

applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, 

and federal law.

Permit No. Project No. Description Date Stack 

Testing

09-A-010-S3 14-097 Modify Stack Configuration & Control Install 

Date

09/02/14 No

____________________________________

Under the Direction of the Director of

the Department of Natural Resources
Union Tank Car Company Inline Tank Car Qualification Process (EP 9B) Page 2 of 10

Muscatine, Iowa 09-A-010-S3

PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or 

misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In 

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has 

been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal 

Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the 

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or 

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, 

installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point 

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the 

facility shall assure that the installation of the equipment listed in this permit conforms to the design in the 

application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this 

emission unit(s), control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person 

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring 

that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the 

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and 

control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by 

paragraph 567 IAC 24.2(1) "Maintenance and Repair”.

3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one location to another or from one piece of 

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been 

issued is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) 

days prior to transferring to the new location unless the equipment will be located in an area which is classified as 

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notification shall be given fourteen (14) days prior to the relocation of equipment1(See Permit 

Condition 8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if 

the relocation will cause a violation of the (NAAQS). In such case, a supplemental permit shall be required prior to 

the initiation of construction of additional control equipment or modifications to equipment needed to meet the 

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as 

submitted, and that adequate operation and maintenance is provided to ensure that no condition of air 

pollution is created. 
Union Tank Car Company Inline Tank Car Qualification Process (EP 9B) Page 3 of 10

Muscatine, Iowa 09-A-010-S3

4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or 

operator shall seek a permit amendment in order to revert back to the most recent previous version of the 

permit. The previous, unchanged permit provisions are included in the amendment for your convenience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted 

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected 

emission unit(s) and emission point, together with any previous amendment to the permit, until one of the 

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and 

emission point permitted herein; or

(2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.11(g), where applicable, any credible evidence may be used 

for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this 

permit or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are 

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good 

practice for minimizing emissions except when another regulation applicable to the unit or process provides 

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be 

limited to one (1) six-minute period per one (1) hour period. 

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties 

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the 

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within 

a reasonable period of time, as specified in 567 IAC 24.1. 

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See 

Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all 

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
Union Tank Car Company Inline Tank Car Qualification Process (EP 9B) Page 4 of 10

Muscatine, Iowa 09-A-010-S3

7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two 

(2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days 

following initiation of construction, installation, or alteration;

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be 

transferred from one location to another, the Department shall be notified:

(a) at least fourteen (14) days before equipment relocation if the equipment will be located in a 

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance 

area for the NAAQS; 

(b) at least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership

within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the 

owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of each compliance test required by Permit 

Condition 12 shall be done not less than thirty (30) days before the required test or performance 

evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time, 

 the place, 

 the name of the person who will conduct the tests, 

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not 

consider the test results or performance evaluation results to be a valid demonstration of compliance 

with the applicable rules or permit conditions. Upon written request, the Department may allow a 

notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported

within eight (8) hours or at the start of the first working day following the onset of the incident. The 

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2

shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days 

of the onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified 

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring 

system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days 

following the end of the calendar quarter, on forms provided by the Director.
Union Tank Car Company Inline Tank Car Qualification Process (EP 9B) Page 5 of 10

Muscatine, Iowa 09-A-010-S3

8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, 

whether successful or not, postmarked not later than six (6) weeks after the completion of the test 

period unless other regulations provide for other notification requirements. In that case, the more 

stringent reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit 

shall be available at the plant during normal business hours for inspection and copying by federal, state, or 

local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years 

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9549

Fax: (515) 725-9501

E. The owner or operator shall send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9545

Fax: (515) 725-9502

F. The owner or operator shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9550

Fax: (515) 725-9502

DNR Field Office 6

1023 West Madison

Washington, IA 52353

Telephone: (319) 653-2135

Fax: (319) 653-2856

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless 

they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in 

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of 

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the 

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319

Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319
Union Tank Car Company Inline Tank Car Qualification Process (EP 9B) Page 6 of 10

Muscatine, Iowa 09-A-010-S3

10. Emission Limits

The following emission limits shall not be exceeded: 

Pollutant lb/hr1tons/yr2 Additional 

Limits

Reference

(567 IAC)

Particulate Matter (PM) – Federal NA NA NA NA

Particulate Matter (PM) – State 2.5 NA 0.1 gr/scf 23.3(2)”a”

PM10 0.653 NA NA NAAQS

PM2.5 0.0274 NA NA NAAQS

Opacity NA NA 40%5,623.3(2)”d”

Sulfur Dioxide (SO2) NA NA NA NA

Nitrogen Oxides (NOx) NA NA NA NA

Volatile Organic Compounds (VOC) NA NA NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA NA NA

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a 12-month rolling total.

3 The limit established as part of Project 08-621 that demonstrated predicted compliance with PM10 NAAQS.

4 The limit for PM2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; 

Call for Iowa SIP Revision” for PM2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

5 The emission limit is a six (6) minute average.

6 An exceedance of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly 

investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If 

exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., 

stack testing).

11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 28 Feet

Discharge Style Horizontal Discharge

Stack Opening (inches) 72 inches by 96 inches

Exhaust Temperature (F) Ambient

Exhaust Flowrate (scfm) 25,000 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted 

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process 

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values 

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to 

determine if a permit amendment is required or submit a permit application requesting to amend the permit.
Union Tank Car Company Inline Tank Car Qualification Process (EP 9B) Page 7 of 10

Muscatine, Iowa 09-A-010-S3

12. Compliance Demonstration(s) 

Pollutant Compliance 

Demonstration

Compliance Methodology Frequency

PM – Federal No Performance Testing NA

PM – State No Performance Testing NA

PM10 No Performance Testing NA

PM2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO2 No NA NA

NOx No NA NA

VOC No NA NA

CO No NA NA

Pb No NA NA

CO2 No NA NA

HAP No NA NA

If an initial compliance demonstration specified above is testing, the owner or the owner’s authorized agent shall 

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days after 

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of 

the proposed equipment. 

If subsequent testing is specified above, the owner or the owner’s authorized agent shall verify compliance with 

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the 

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 1 hour 40 CFR 60, Appendix A, Method 5 

40 CFR 51 Appendix M Method 202

PM10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM2.5 19 hours 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO2 1 hour 40 CFR 60, Appendix A, Method 6C

NOx 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the 

Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs 

shall apply for compliance, unless otherwise indicated by the Department. 
Union Tank Car Company Inline Tank Car Qualification Process (EP 9B) Page 8 of 10

Muscatine, Iowa 09-A-010-S3

12. Compliance Demonstration(s) (Continued)

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days 

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the 

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. 

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It 

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the 

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, 

different, or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be 

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate 

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where 

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is 

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this 

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the 

Department to determine whether this unit(s) is in compliance.

13. New Source Performance Standards (NSPS) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart MMMMNational Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and 

Products as specified in 40 CFR Part 63 §63.3881. Union Tank Car Company shall comply with all reporting, 

notification, and recordkeeping requirements as specified 40 CFR Part 63 Subpart MMMM, specifically §63.3910, 

§63.3920, §63.3930, and §63.3931.

Union Tank Car Company (Plant No. 70-01-048) is subject to the requirements and conditions of Subpart A-General 

Provisions as specified in 40 CFR Part 63 §63.3901. Union Tank Car Company (Plant No. 70-01-048) shall comply 

with all reporting, notification, and recordkeeping requirements as specified 40 CFR Part 60 Subpart A, §63.3901

(Table 2).

14. Operating Limits

Operating limits for this emission unit shall be:

A. Mini-pleat Filters (CE9B) shall be installed and operational by September 2, 2014.

B. Mini-pleat Filters (CE9B) shall have a MERV rating of no less than 13.

C. Mini-pleat Filters (CE9B) shall be maintained and replaced per manufacturer’s instructions and 

specifications.

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of 

two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an 

orderly manner. These records shall show the following:

A. Maintain a record of the installation and operation date of Mini-pleat Filters (CE9B).

B. Maintain record of MERV Rating of Mini-pleat filters (CE9B).

C. The owner or operator shall maintain a record for all maintenance and replacement of the Mini-pleat Filters

(CE9B).
Union Tank Car Company Inline Tank Car Qualification Process (EP 9B) Page 9 of 10

Muscatine, Iowa 09-A-010-S3

16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.

17. Permit History

Permit No. Project No. Description Date Stack 

Testing

09-A-010 08-621 Original Permit 10/29/09 No

09-A-010-S1 10-340 Remove Operating Hours Restriction 09/02/10 No

09-A-010-S2 12-409 Add Particulate Filter, Establish PM2.5 Limits, 

Add Fan to Increase Flow

04/08/13 No
Union Tank Car Company Inline Tank Car Qualification Process (EP 9B) Page 10 of 10

Muscatine, Iowa 09-A-010-S3

18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be 

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form 

particulate matter immediately after discharge from the stack

Department Iowa Department of Natural Resources

dia. Diameter

F Degrees Fahrenheit

ft Foot

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM – Federal Particulate Matter that does not include the condensable PM

PM – State Particulate Matter that includes condensable PM

ppm parts per million

ppmv parts per million by volume

ppmw parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year

END OF PERMIT