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: EP M1

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

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## 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 h as

been evaluated for conformance with Iowa Code Chapte r 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 pe rmit 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 r equired 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, o peration, 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 equi pment 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 fro m 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 notific ation shall be given fourteen (14 ) days prior to the re location of equipment 1 (See Pe rmit

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 (NAAQ S). In such case, a supplemental permit shall be req uired prior to

the initiation of construction of additiona l 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

polluti on is created.

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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 amendm ent 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 unappealab le.

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) month s 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 Specificatio ns

The owner or operator shal l 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 pre vious permit for the affected

emission unit(s) and emission point, toget her 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

emissi on 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 o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess emissions during a period of startup, shutdown, or cleaning of control equip ment 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 c ontrol 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 exped itious 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 appropr iate

field office within eight (8) hours of, or at the start of, the first working day following the onse t 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 i nitial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2)

.

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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) T he 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 t ransfer 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 ea ch compliance test required by P ermit

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. T he 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 o nset 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 t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of those operating parameters sp ecified

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.

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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 requireme nt 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) year s

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 thi s 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

F ax: (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 am endments, 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 unappea lable.

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 Ser vices Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10

. Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 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”

PM 10 0. 87 3 NA NA NA AQS

PM 2.5 0.0 33 4 NA NA NA AQS

Opacity NA NA 40% 5

, 6 23.3(2)”d”

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) 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 PM 10 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” fo r 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 exceedanc e of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly

investigate the em ission 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 flow rate 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 ei ther 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 applicati on requesting to amend the permit.

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12. Compliance Demonstration(s)

Pollutant Compliance

Demonstration Compliance Methodology Frequency

PM

– Federal No Performance Testing NA

PM

– State No Performance Testing NA

PM 10 No Performance Testing NA

PM 2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO 2 No NA NA

NO

x 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 ab ove.

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

PM 10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM 2.5 15 hour s 40 CFR 51, Appendix M, 201A with 202

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

SO 2 1 hour 40 CFR 60, Appendix A, Method 6C

NO

x 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.

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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 coordi nate 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 responsi ble 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 ra te 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 evid ence 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 MMMM

National 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 (CE M1 ) shall have a MERV rating of no less than 13.

C. Mini

- pleat Filters (CE M1 ) shall be maintained and replaced per manufacturer’s instructions and

specifications.



### 15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, a ll 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 (CE M1 )

.

B. Maintain record of MERV Rating of Mini

- pleat filters (CE M1 )

.

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

- pleat Filter s

(CEM1 )

.

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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

- 14 4 Original Permit 12/21 /00 No

00

- A

- 1086

- S 1 08

- 621 Amend Operating Limits 10/29/09 No

00

- A

- 1086

- S 2 12

- 409 Add Particulate Filter, Establish PM2.5

Limits , Add Fan to Increase Flow 04/08/13 No

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### 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 Resourc es

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

PM 2.5 Particulate Matter with an aerodynamic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l 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

ppm

v parts per million by volume

ppm

w parts per mi llion 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 PERMITCPFP|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 R ailcars per day

Control Equipment: Mini

- pleat Filters (CEM2 )

Emission Point: EP M 2

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

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## 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

additio n, 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 Chapte r 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

p otential 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, mainte nance 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 pe rmit conforms to the design in the

application (i.e. type, maximum rated capacity, etc.)

. No person shall constru ct, install, reconstruct or alter this

emission unit (s) , control equipment, or emission point without the r equired amended permit

.

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

who beco mes 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 fro m 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 Quali ty Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notific ation shall be given fourteen (14 ) days prior to the relocation of equipment 1 (See Pe rmit

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

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

the initiation of construction of additiona l control equipment or modifications to equipment needed to me et 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.

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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 permi t amendm ent 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 a ny 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 shal l 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 contro l equipment and the specified operation thereof.

C. Amended Permits

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

emission unit(s) and emission point, toget her with any previous amendment to the permi t

, 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 o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess 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 t o 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 eq uipment 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 b y 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 onse t of the incident (See

Permit Condition 8 .B.1). A written report of an incident of excess emiss ions 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)

.

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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 fur nish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

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

following initiation of construction, installation, or alteration;

(b) The actua l 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 t ransfer 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 a fter the ownership change; and

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

(4) Unless specified per a federal regulation, notification of ea ch compliance test required by P ermit

Condition 12 shall be done not less than thirty (30) da ys 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 condit ions. Upon written request, the Department may allow a

notification period of less than thirty (30) days.

B. T he 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 56 7 IAC 20.2 shall be reported

within eight (8) hours or at the start of the first working day following the o nset 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 t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of t hose 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 quart erly reports to the Director, no later than thirty (30) calendar days

following the end of the calendar quarter, on forms provided by the Director.

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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 cas e, 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) year s

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

F ax: (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 am endments, 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 unappea lable.

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 Ser vices Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10

. Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 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”

PM 10 0. 87 3 NA NA NA AQS

PM 2.5 0.0 33 4 NA NA NA AQS

Opacity NA NA 40% 5

, 6 23.3(2)”d”

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) 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 PM 10 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” fo r 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 exceedanc e of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly

investigate the em ission 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 flow rate 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 r equesting to amend the permit.

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12. Compliance Demonstration(s)

Pollutant Compliance

Demonstration Compliance Methodology Frequency

PM

– Federal No Performance Testing NA

PM

– State No Performance Testing NA

PM 10 No Performance Testing NA

PM 2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO 2 No NA NA

NO

x 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, th e 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

PM 10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM 2.5 15 hour s 40 CFR 51, Appendix M, 201A with 202

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

SO 2 1 hour 40 CFR 60, Appendix A, Method 6C

NO

x 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.

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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 coordi nate 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 responsi ble 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 ra te 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 evid ence 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 MMMM

National 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 (CE M2 ) shall have a MERV rating of no less than 13.

C. Mini

- pleat Filters (CE M2 ) shall be maintained and replaced per manufacturer’s instructions and

specifications.



### 15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, a ll 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 (CE M2 )

.

B. Maintain record of MERV Rating of Mini

- pleat filters (CE M2 )

.

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

- pleat Filter s

(CEM2 )

.

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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

- 108 7 00

- 14 4 Original Permit 12/21 /00 No

00

- A

- 1087

- S 1 08

- 621 Amend Operating Limits 10/29/09 No

00

- A

- 1087

- S 2 12

- 409 Add Particulate Filter, Establish PM2.5

Limits , Add Fan to Increase Flow 04/08/13 No

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### 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 Resourc es

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

PM 2.5 Particulate Matter with an aerodynamic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l 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

ppm

v parts per million by volume

ppm

w parts per mi llion 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 PERMITCPFP|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: EP M 3

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

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## 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 h as

been evaluated for conformance with Iowa Code Chapte r 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 pe rmit 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 r equired 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, o peration, 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 equi pment 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 fro m 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 notific ation shall be given fourteen (14 ) days prior to the re location of equipment 1 (See Pe rmit

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 (NAAQ S). In such case, a supplemental permit shall be req uired prior to

the initiation of construction of additiona l 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

polluti on is created.

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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 amendm ent 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 unappealab le.

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) month s 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 Specificatio ns

The owner or operator shal l 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 pre vious permit for the affected

emission unit(s) and emission point, toget her 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

emissi on 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 o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess emissions during a period of startup, shutdown, or cleaning of control equip ment 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 c ontrol 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 exped itious 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 appropr iate

field office within eight (8) hours of, or at the start of, the first working day following the onse t 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 i nitial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2)

.

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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) T he 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 t ransfer 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 ea ch compliance test required by P ermit

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. T he 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 o nset 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 t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of those operating parameters sp ecified

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.

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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 requireme nt 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) year s

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 thi s 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

F ax: (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 am endments, 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 unappea lable.

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 Ser vices Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10

. Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 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”

PM 10 0. 87 3 NA NA NA AQS

PM 2.5 0.0 33 4 NA NA NA AQS

Opacity NA NA 40% 5

, 6 23.3(2)”d”

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) 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 PM 10 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” fo r 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 exceedanc e of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly

investigate the em ission 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 flow rate 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 ei ther 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 applicati on requesting to amend the permit.

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12. Compliance Demonstration(s)

Pollutant Compliance

Demonstration Compliance Methodology Frequency

PM

– Federal No Performance Testing NA

PM

– State No Performance Testing NA

PM 10 No Performance Testing NA

PM 2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO 2 No NA NA

NO

x 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 ab ove.

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

PM 10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM 2.5 15 hour s 40 CFR 51, Appendix M, 201A with 202

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

SO 2 1 hour 40 CFR 60, Appendix A, Method 6C

NO

x 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.

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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 coordi nate 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 responsi ble 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 ra te 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 evid ence 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 MMMM

National 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 (CE M3 ) shall have a MERV rating of no less than 13.

C. Mini

- pleat Filters (CE M3 ) shall be maintained and replaced per manufacturer’s instructions and

specifications.



### 15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, a ll 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 (CE M3 )

.

B. Maintain record of MERV Rating of Mini

- pleat filters (CE M3 )

.

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

- pleat Filter s

(CEM3 )

.

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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

- 108 8 00

- 14 4 Original Permit 12/21 /00 No

00

- A

- 1088

- S 1 08

- 621 Amend Operating Limits 10/29/09 No

00

- A

- 1088

- S 2 12

- 409 Add Particulate Filter, Establish PM2.5

Limits , Add Fan to Increase Flow 04/08/13 No

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### 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 Resourc es

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

PM 2.5 Particulate Matter with an aerodynamic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l 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

ppm

v parts per million by volume

ppm

w parts per mi llion 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 PERMITCPFP|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 eac h) (EU 12)

Heaters for Hopper Cars (4 @ 4 MMBtu/hr each) (EU 13)

Maximum Capacity: 400 gallons of coating per day

Control Equipment: Mini

- pleat Filters (CE6 A )

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

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## 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 i ssued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has

been evaluated for conformance with Iowa Code Chapte r 455B; 567 IAC Chapters 20

– 35 ; and 40 Code of Federal

Regulations ( CFR ) Parts 51, 52, 60, 61, and 63 an d 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 pe rmit 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 r equ ired 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

th at 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 maintai n 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 fro m 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 notific ation shall be given fourteen (14 ) days prior to the re location of equipment 1 (See Pe rmit

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 (NAAQ S). In such case, a supplemental permit shall be req uired prior to

the initiation of construction of additiona l 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

polluti on is created.

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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 amendm ent 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 unappealab le.

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) month s 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 Specificatio ns

The owner or operator shal l 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 pre vious permit for the affected

emission unit(s) and emission point, toget her 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

emissi on 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 o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess emissions during a period of startup, shutdown, or cleaning of control equip ment 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 c ontrol 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 exped itious 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 appropr iate

field office within eight (8) hours of, or at the start of, the first working day following the onse t 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 i nitial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2)

.

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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) T he 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 t ransfer 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 ea ch compliance test required by P ermit

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. T he 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 o nset 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 t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of those operating parameters sp ecified

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.

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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 requireme nt 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) year s

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 thi s 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

F ax: (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 am endments, 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 unappea lable.

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 Ser vices Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10

. Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 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 )

PM 10 0.6 3 NA NA NA AQS

PM 2.5 0.021 4 NA NA NA AQS

Opacity NA NA 40% 5

, 6 23.3(2)”d”

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) NA NA NA NA

Volatile Organic Compounds (VOC) NA 200 7 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 9 23.1(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 PM 10 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 PM 2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

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

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

investigate the emissi on 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 MMM M: 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 flow rate 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 ei ther 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 applicati on requesting to amend the permit.

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12. Compliance Demonstration(s)

Pollutant Compliance

Demonstration Compliance Methodology Frequency

PM

– Federal No Performance Testing NA

PM

– State No Performance Testing NA

PM 10 No Performance Testing NA

PM 2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO 2 No NA NA

NO

x 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 pr ior 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

PM 10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM 2.5 23 hour s 40 CFR 51, Appendix M, 201A with 202

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

SO 2 1 hour 40 CFR 60, Appendix A, Method 6C

NO

x 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.

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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 coordi nate 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 responsi ble 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 ra te 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 evid ence 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 MMMM

National 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 Paint ing (EU

- 5), Railcar Interior

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

- 7).

B. Railcar Interior Pain ting/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.

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15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, a ll 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/gall on) 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 Pain ting/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

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### 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

PM 2.5 Particulate Matter with an aerodynamic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l 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

ppm

v parts per million by volume

ppm

w parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutan ts

tons/yr Tons per year

yr Year



## END OF PERMITCPFP|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 eac h) (EU 12)

Heaters for Hopper Cars (4 @ 4 MMBtu/hr each) (EU 13)

Maximum Capacity: 400 gallons of coating per day

Control Equipment: Mini

- pleat Filters (CE6 D )

Emissio n Point: EP6 D

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

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## 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 i ssued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has

been evaluated for conformance with Iowa Code Chapte r 455B; 567 IAC Chapters 20

– 35 ; and 40 Code of Federal

Regulations ( CFR ) Parts 51, 52, 60, 61, and 63 an d 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 pe rmit 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 r equ ired 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

th at 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 maintai n 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 fro m 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 Quali ty Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notific ation shall be given fourteen (14 ) days prior to the relocation of equipment 1 (See Pe rmit

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

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

the initiation of construction of additiona l control equipment or modifications to equipment needed to me et 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.

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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 permi t amendm ent 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 a ny 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 shal l 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 contro l equipment and the specified operation thereof.

C. Amended Permits

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

emission unit(s) and emission point, toget her with any previous amendment to the permi t

, 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 o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess 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 t o 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 eq uipment 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 b y 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 onse t of the incident (See

Permit Condition 8 .B.1). A written report of an incident of excess emiss ions 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)

.

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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 fur nish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

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

following initiation of construction, installation, or alteration;

(b) The actua l 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 t ransfer 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 a fter the ownership change; and

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

(4) Unless specified per a federal regulation, notification of ea ch compliance test required by P ermit

Condition 12 shall be done not less than thirty (30) da ys 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 condit ions. Upon written request, the Department may allow a

notification period of less than thirty (30) days.

B. T he 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 56 7 IAC 20.2 shall be reported

within eight (8) hours or at the start of the first working day following the o nset 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 t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of t hose 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 quart erly reports to the Director, no later than thirty (30) calendar days

following the end of the calendar quarter, on forms provided by the Director.

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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) year s

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

D. The owner or operator shall sen d 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

F ax: (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 am endments, 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 unappea lable.

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 Ser vices Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10

. Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 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 )

PM 10 0.6 3 NA NA NAAQS

PM 2.5 0.021 4 NA NA NAAQS

Opacity NA NA 40% 5, 6 23.3(2)”d”

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) NA NA NA NA

Volatile Organic Compounds (VOC) NA 200 7 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 9 23.1(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 PM 10 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 PM 2.5 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 emissi on 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 MMM M: 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 flow rate 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 ei ther 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 applicati on requesting to amend the permit.

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12. Compliance Demonstration(s)

Pollutant Compliance

Demonstration Compliance Methodology Frequency

PM

– Federal No Performance Testing NA

PM

– State No Performance Testing NA

PM 10 No Performance Testing NA

PM 2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO 2 No NA NA

NO

x 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 pr ior 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

PM 10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM 2.5 23 hour s 40 CFR 51, Appendix M, 201A with 202

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

SO 2 1 hour 40 CFR 60, Appendix A, Method 6C

NO

x 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.

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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 c ompliance 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 th e

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

com pliance 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 complianc e.



### 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 MMMM

National 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 §63.3 901 . 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 sha ll 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, an d 13), and Rubber Lining of Tank Cars (EU

- 7).

B. Railcar Interior Pain ting/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.

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15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, a ll 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 t he 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 al l 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 t ons each day.

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

- day

rolling period.

D. For each day record the number of hours Railcar Interior Pain ting/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 Ra ting 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

- S 1 08

- 621 Amend Operating Limits 10/29/09 No

00

- A

- 531

- S 2 12

- 409 Add Particulate Filter, Establish PM2.5

Limits 04/08/13 No

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### 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 dr y 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

PM 2.5 Particulate Matter with an aerodynamic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l to or less than 10 microns

PM

– Federal Particulate Matter that does not include the condensable PM

PM

– State Particulate Matte r that includes condensable PM

ppm parts per million

ppm

v parts per million by volume

ppm

w 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 PERMITCPFP|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 eac h) (EU 12)

Heaters for Hopper Cars (4 @ 4 MMBtu/hr each) (EU 13)

Maximum Capacity: 400 gallons of coating per day

Control Equipment: Mini

- pleat Filters (CE6 F )

Emissio n Point: EP6 F

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

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## 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 i ssued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has

been evaluated for conformance with Iowa Code Chapte r 455B; 567 IAC Chapters 20

– 35 ; and 40 Code of Federal

Regulations ( CFR ) Parts 51, 52, 60, 61, and 63 an d 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 pe rmit 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 r equ ired 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

th at 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 maintai n 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 fro m 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 Quali ty Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notific ation shall be given fourteen (14 ) days prior to the relocation of equipment 1 (See Pe rmit

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

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

the initiation of construction of additiona l control equipment or modifications to equipment needed to me et 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.

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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 permi t amendm ent 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 a ny 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 shal l 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 contro l equipment and the specified operation thereof.

C. Amended Permits

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

emission unit(s) and emission point, toget her with any previous amendment to the permi t

, 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 o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess 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 anoth er 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 em issions 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 pr ocess 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 onse t 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 se ven (7) days of the onset of the upset condition (See Permit Condition 8.B.2)

.

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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) T he 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 t ransfer 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 ea ch compliance test required by P ermit

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. T he 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 o nset 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 t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of those operating parameters sp ecified

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.

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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 requireme nt 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) year s

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 thi s 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

F ax: (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 am endments, 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 unappea lable.

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 Ser vices Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10

. Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 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 )

PM 10 0.6 3 NA NA NAAQS

PM 2.5 0.021 4 NA NA NAAQS

Opacity NA NA 40% 5, 6 23.3(2)”d”

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) NA NA NA NA

Volatile Organic Compounds (VOC) NA 200 7 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 9 23.1(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 PM 10 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 PM 2.5 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 emissi on 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 MMM M: 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 flow rate 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 ei ther 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 applicati on requesting to amend the permit.

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12. Compliance Demonstration(s)

Pollutant Compliance

Demonstration Compliance Methodology Frequency

PM

– Federal No Performance Testing NA

PM

– State No Performance Testing NA

PM 10 No Performance Testing NA

PM 2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO 2 No NA NA

NO

x 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 pr ior 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

PM 10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM 2.5 23 hour s 40 CFR 51, Appendix M, 201A with 202

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

SO 2 1 hour 40 CFR 60, Appendix A, Method 6C

NO

x 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

CO 2 1 hour 40 CFR 60, Appendix A, Method 3

CH 4 1 hour 40 CFR 60, Appendix A, Method 18

N 2 O 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 indic ated by the Department.

### Union Tank Car Company Railcar Interior Lining Shop ( EP6F ) Page 8 of 10

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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 demonstrati on. 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 te sting 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,

diff erent, 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 man ufacturer, 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 owne r'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, rep orts 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 MMMM

National Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and

Products as specified in 4 0 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 operation s (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. Rai lcar Interior Pain ting/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.

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15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, a ll 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/gallo n) each day.

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

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

- day

rolling period.

D. For each day record the number of hours Railcar Interior Pain ting/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 o wner 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

- 53 3 00

- 142 Original Permit 03/26/00 No

00

- A

- 533

- S 1 08

- 621 Amend Operating Limits 10/29/09 No

00

- A

- 533

- S 2 12

- 409 Add Particulate Filter, Establish PM2.5

Limits 04/08/13 No

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### 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 a fter 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 pe r 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

PM 2.5 Particulate Matter with an aerodynamic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l 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 part s per million

ppm

v parts per million by volume

ppm

w 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 PERMITCPFP|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: EP7 A

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

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## 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 Chapte r 455B; 567 IAC Chapters 20

– 35 ; an d 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 equipmen t.



### 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 pe rmit conforms to the design in the

application (i.e. type, maximum rated capacity, etc.)

. No person shall construct, install, reconstruct or alter this

emis sion unit (s) , control equipment, or emission point without the r equired 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, o peration, 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 equi pment 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 fro m 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 notific ation shall be given fourteen (14 ) days prior to the re location of equipment 1 (See Pe rmit

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 (NAAQ S). In such case, a supplemental permit shall be req uired prior to

the initiation of construction of additiona l 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

polluti on is created.

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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 amendm ent 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 unappealab le.

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) month s 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 Specificatio ns

The owner or operator shal l 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 pre vious permit for the affected

emission unit(s) and emission point, toget her 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

emissi on 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 o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess emissions during a period of startup, shutdown, or cleaning of control equip ment 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 c ontrol 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 exped itious 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 appropr iate

field office within eight (8) hours of, or at the start of, the first working day following the onse t 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 i nitial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2)

.

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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) T he 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 t ransfer 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 ea ch compliance test required by P ermit

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. T he 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 o nset 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 t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of those operating parameters sp ecified

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.

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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 requireme nt 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) year s

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 thi s 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

F ax: (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 am endments, 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 unappea lable.

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 Ser vices Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10

. Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 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 )

PM 10 0.10 3 NA NA NA AQS

PM 2.5 0.0085 4 NA NA NA AQS

Opacity NA NA 40% 5

, 6 23.3(2)”d”

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) NA NA NA NA

Volatile Organic Compounds (VOC) NA 200 7 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 9 23.1(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 PM 10 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 PM 2.5 published in the Federal Register (76 FR 41424) on July 14, 2011.

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

6 An exceedanc e 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 adop tion 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 4 0 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 flow rate 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 ei ther 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 applicati on requesting to amend the permit.

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12. Compliance Demonstration(s)

Pollutant Compliance

Demonstration Compliance Methodology Frequency

PM

– Federal No Performance Testing NA

PM

– State No Performance Testing NA

PM 10 No Performance Testing NA

PM 2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO 2 No NA NA

NO

x No NA NA

VOC Yes Material Usage Tracking Daily &365

- day Rolling

C alculation

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 pr ior 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

PM 10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM 2.5 7 hour s 40 CFR 51, Appendix M, 201A with 202

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

SO 2 1 hour 40 CFR 60, Appendix A, Method 6C

NO

x 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 coordi nate 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.

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12. Compliance Demonstrat ion(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

spec ified 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 cap acity 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, o r 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 MMMM

National Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and

Products as specified in 40 CFR Part 63 §6 3.3881

. 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) i s 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 operation s (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, a ll 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 us ed (in lbs/gallon) each day.

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

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

- day

rolling period.



### 16. Continuous Emission Monitoring

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

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### 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

- S 1 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 Celsiu s

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 Fahrenhe it

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

PM 2.5 Particulate Matter with an aerodynamic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l 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

ppm

v parts per million by volume

ppm

w 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 PERMITCPFP|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: EP7 B

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

- 10 90

- 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

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## 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 h as

been evaluated for conformance with Iowa Code Chapte r 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 pe rmit 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 r equired 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, o peration, 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 equi pment 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 fro m 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 notific ation shall be given fourteen (14 ) days prior to the re location of equipment 1 (See Pe rmit

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 (NAAQ S). In such case, a supplemental permit shall be req uired prior to

the initiation of construction of additiona l 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

polluti on is created.

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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 ow ner or

operator shall seek a permit amendm ent 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) month s 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 Specificatio ns

The owner or operator shal l 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 pre vious permit for the affected

emission unit(s) and emission point, toget her 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

emissi on 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 o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess emissions during a period of startup, shutdown, or cleaning of control equip ment 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 c ontrol 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 exped itious 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 appropr iate

field office within eight (8) hours of, or at the start of, the first working day following the onse t 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 i nitial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2)

.

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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) T he 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 t ransfer 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 ea ch compliance test required by P ermit

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. T he 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 o nset 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 t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of those operating parameters sp ecified

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.

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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 requireme nt 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) year s

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 thi s 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

F ax: (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 am endments, 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 unappea lable.

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 Ser vices Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10

. Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 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 )

PM 10 0.10 3 NA NA NAAQS

PM 2.5 0.0085 4 NA NA NAAQS

Opacity NA NA 40% 5, 6 23.3(2)”d”

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) NA NA NA NA

Volatile Organic Compounds (VOC) NA 200 7 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 9 23.1(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 PM 10 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 PM 2.5 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 emissi on 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 MMM M: 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 flow rate 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 ei ther 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 applicati on requesting to amend the permit.

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12. Compliance Demonstration(s)

Pollutant Compliance

Demonstration Compliance Methodology Frequency

PM

– Federal No Performance Testing NA

PM

– State No Performance Testing NA

PM 10 No Performance Testing NA

PM 2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO 2 No NA NA

NO

x 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 pr ior to testing.

Pollutant Test Run Time Test Method

PM

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

PM

– State 6 hour s 40 CFR 60, Appendix A, Method 5

40 CFR 51 Appendix M Method 202

PM 10 6 hour s 40 CFR 51, Appendix M, 201A with 202

PM 2.5 59 hour s 40 CFR 51, Appendix M, 201A with 202

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

SO 2 1 hour 40 CFR 60, Appendix A, Method 6C

NO

x 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 coordi nate 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.

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12. Compliance Demonstrat ion(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

spec ified 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 cap acity 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, o r 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 MMMM

National Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and

Products as specified in 40 CFR Part 63 §6 3.3881

. 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) i s 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 operation s (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, a ll 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 us ed (in lbs/gallon) each day.

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

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

- day

rolling period.



### 16. Continuous Emission Monitoring

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

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### 17. Permit History

Permit No. Project No. Description Date Stack

Testing

00

- A

- 0 90 00

- 074 Original Permit 12/15/00 No

00

- A

- 0 90

- S 1 08

- 621 Amend Operating Limits 10/29/09 No

00

- A

- 0 90

- 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 Fa hrenheit

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

PM 2.5 Particulate Matter with an aerodynamic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l 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

ppm

v parts per million by volume

ppm

w 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 PERMITCPFP|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: EP7 C

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

- 10 91

- 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

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## 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 h as

been evaluated for conformance with Iowa Code Chapte r 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 pe rmit 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 r equired 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, o peration, 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 equi pment 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 fro m 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 notific ation shall be given fourteen (14 ) days prior to the re location of equipment 1 (See Pe rmit

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 (NAAQ S). In such case, a supplemental permit shall be req uired prior to

the initiation of construction of additiona l 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

polluti on is created.

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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 ow ner or

operator shall seek a permit amendm ent 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) month s 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 Specificatio ns

The owner or operator shal l 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 pre vious permit for the affected

emission unit(s) and emission point, toget her 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

emissi on 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 o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess emissions during a period of startup, shutdown, or cleaning of control equip ment 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 c ontrol 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 exped itious 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 appropr iate

field office within eight (8) hours of, or at the start of, the first working day following the onse t 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 i nitial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2)

.

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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) T he 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 t ransfer 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 ea ch compliance test required by P ermit

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. T he 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 o nset 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 t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of those operating parameters sp ecified

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.

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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 requireme nt 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) year s

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 thi s 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

F ax: (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 am endments, 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 unappea lable.

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 Ser vices Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10

. Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 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 )

PM 10 0.10 3 NA NA NAAQS

PM 2.5 0.0085 4 NA NA NAAQS

Opacity NA NA 40% 5, 6 23.3(2)”d”

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) NA NA NA NA

Volatile Organic Compounds (VOC) NA 200 7 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 9 23.1(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 PM 10 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 PM 2.5 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 emissi on 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 MMM M: 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 flow rate 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 ei ther 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 applicati on requesting to amend the permit.

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12. Compliance Demonstration(s)

Pollutant Compliance

Demonstration Compliance Methodology Frequency

PM

– Federal No Performance Testing NA

PM

– State No Performance Testing NA

PM 10 No Performance Testing NA

PM 2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO 2 No NA NA

NO

x 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 pr ior to testing.

Pollutant Test Run Time Test Method

PM

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

PM

– State 6 hour s 40 CFR 60, Appendix A, Method 5

40 CFR 51 Appendix M Method 202

PM 10 6 hour s 40 CFR 51, Appendix M, 201A with 202

PM 2.5 59 hour s 40 CFR 51, Appendix M, 201A with 202

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

SO 2 1 hour 40 CFR 60, Appendix A, Method 6C

NO

x 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 coordi nate 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.

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12. Compliance Demonstrat ion(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

spec ified 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 cap acity 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, o r 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 MMMM

National Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and

Products as specified in 40 CFR Part 63 §6 3.3881

. 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) i s 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 operation s (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, a ll 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 us ed (in lbs/gallon) each day.

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

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

- day

rolling period.



### 16. Continuous Emission Monitoring

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

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### 17. Permit History

Permit No. Project No. Description Date Stack

Testing

00

- A

- 0 9 1 00

- 074 Original Permit 12/15/00 No

00

- A

- 0 91

- S 1 08

- 621 Amend Operating Limits 10/29/09 No

00

- A

- 0 91

- 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 Fa hrenheit

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

PM 2.5 Particulate Matter with an aerodynamic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l 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

ppm

v parts per million by volume

ppm

w 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 PERMITCPFP|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: EP7 D

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

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## 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 h as

been evaluated for conformance with Iowa Code Chapte r 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 pe rmit 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 r equired 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, o peration, 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 equi pment 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 fro m 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 notific ation shall be given fourteen (14 ) days prior to the re location of equipment 1 (See Pe rmit

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 (NAAQ S). In such case, a supplemental permit shall be req uired prior to

the initiation of construction of additiona l 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

polluti on is created.

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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 ow ner or

operator shall seek a permit amendm ent 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) month s 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 Specificatio ns

The owner or operator shal l 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 pre vious permit for the affected

emission unit(s) and emission point, toget her 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

emissi on 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 o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess emissions during a period of startup, shutdown, or cleaning of control equip ment 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 c ontrol 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 exped itious 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 appropr iate

field office within eight (8) hours of, or at the start of, the first working day following the onse t 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 i nitial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2)

.

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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) T he 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 t ransfer 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 ea ch compliance test required by P ermit

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. T he 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 o nset 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 t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of those operating parameters sp ecified

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.

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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 cas e, 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) year s

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

F ax: (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 am endments, 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 unappea lable.

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 Ser vices Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10

. Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 Additional

Limits Reference

(567 IAC)

Particulate Matter (PM)

– Federal NA NA NA NA

Particulate Matter (PM)

– State 0.10 3 NA 0.01 gr/dscf 23. 4 ( 13 )

PM 10 0.10 3 NA NA NA

PM 2.5 0.0085 4 NA NA NA AQS

Opacity NA NA 40% 5

, 6 23.3(2)”d”

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) NA NA NA NA

Volatile Organic Compounds (VOC) NA 200 7 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 9 23.1(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 exceedanc e 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 Charac teristics

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 ) 1 6 inch Diameter

Exhaust Temperature (  F) 70 oF

Exhaust Flowrate (scfm) 4,000 scfm

The temperature and flow rate 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 r equesting to amend the permit.

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12. Compliance Demonstration(s)

Pollutant Compliance

Demonstration Compliance Methodology Frequency

PM

– Federal No Performance Testing NA

PM

– State No Performance Testing NA

PM 10 No Performance Testing NA

PM 2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO 2 No NA NA

NO

x 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 i n 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

PM 10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM 2.5 10 hour s 40 CFR 51, Appendix M, 201A with 202

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

SO 2 1 hour 40 CFR 60, Appendix A, Method 6C

NO

x 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 coordi nate 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.

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12. Compliance Demonstrat ion(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

spec ified 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 cap acity 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, o r 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 MMMM

National Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and

Products as specified in 40 CFR Part 63 §6 3.3881

. 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) i s 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 operation s (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, a ll 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 us ed (in lbs/gallon) each day.

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

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

- day

rolling period.



### 16. Continuous Emission Monitoring

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

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### 17. Permit History

Permit No. Project No. Description Date Stack

Testing

10

- A

- 043 10

- 026 Original Permit 03/12/1 0 No

10

- A

- 043

- S 1 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 Bri tish 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 Hou r

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM 2.5 Particulate Matter with an aerodynamic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l 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

ppm

v parts per million by volume

ppm

w 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 PERMITCPFP|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)

W elding & Metal Arc Cutting (EU 9 )

Maximum Capacity: 36 Railcars per day

Control Equipment: Mini

- pleat Filters (CE9A )

Emission Point: EP 9A

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. D escription 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

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## 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 h as

been evaluated for conformance with Iowa Code Chapte r 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 pe rmit 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 r equired 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, o peration, 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 equi pment 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 fro m 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 notific ation shall be given fourteen (14 ) days prior to the re location of equipment 1 (See Pe rmit

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 (NAAQ S). In such case, a supplemental permit shall be req uired prior to

the initiation of construction of additiona l 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

polluti on is created.

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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 amendm ent 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 unappealab le.

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) month s 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 Specificatio ns

The owner or operator shal l 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 pre vious permit for the affected

emission unit(s) and emission point, toget her 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

emissi on 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 o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess emissions during a period of startup, shutdown, or cleaning of control equip ment 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 c ontrol 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 exped itious 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 appropr iate

field office within eight (8) hours of, or at the start of, the first working day following the onse t 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 i nitial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2)

.

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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) T he 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 t ransfer 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 ea ch compliance test required by P ermit

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. T he 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 o nset 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 t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of those operating parameters sp ecified

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.

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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 requireme nt 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) year s

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 thi s 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

F ax: (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 am endments, 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 unappea lable.

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 Ser vices Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10

. Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 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”

PM 10 0. 65 3 NA NA NA AQS

PM 2.5 0.0 27 4 NA NA NA AQS

Opacity NA NA 40% 5

, 6 23.3(2)”d”

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) 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 (CO 2 e ) 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 PM 10 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” fo r 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 exceedanc e 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 flow rate 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 ei ther 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 applicati on requesting to amend the permit.

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12. Compliance Demonstration(s)

Pollutant Compliance

Demonstration Compliance Methodology Frequency

PM

– Federal No Performance Testing NA

PM

– State No Performance Testing NA

PM 10 No Performance Testing NA

PM 2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO 2 No NA NA

NO

x 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 ab ove.

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

PM 10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM 2.5 19 hour s 40 CFR 51, Appendix M, 201A with 202

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

SO 2 1 hour 40 CFR 60, Appendix A, Method 6C

NO

x 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.

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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 (1 5) 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 t he 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 tes t(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 norm al 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 ma ximum 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 t he 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 MMMM

National Emission Standards for Hazardous Air Pollutants: Surf ace 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 (CE 9A ) shall have a MERV rating of no less than 13.

C. Mini

- pleat Filters (CE 9A ) shall be maintained and replaced per manufacturer’s instructions and

specifications.



### 15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, a ll 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 (CE 9A )

.

B. Maintain record of MERV Rating of Mini

- pleat filters (CE 9A )

.

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

- pleat Filters

(CE9A )

.

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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

- S 2 12

- 409 Add Particulate Filter, Establish PM2.5 Limits

, Add Fan to Increase Flow 04/08/13 No

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### 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 dr y 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

PM 2.5 Particulate Matter with an aerodynamic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l to or less than 10 microns

PM

– Federal Particulate Matter that does not include the condensable PM

PM

– State Particulate Matte r that includes condensable PM

ppm parts per million

ppm

v parts per million by volume

ppm

w parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons pe r year

yr Year



## END OF PERMITCPFP|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)

W elding & Metal Arc Cutting (EU 9 )

Maximum Capacity: 36 Railcars per day

Control Equipment: Mini

- pleat Filters (CE9B )

Emission Point: EP 9 B

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. D escription 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

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## 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

additio n, 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 Chapte r 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

p otential 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, mainte nance 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 pe rmit 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 r equired amended permit

.

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

w ho 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 requi red 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 fro m 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 notific ation shall be given fourteen (14 ) days prior to the re location of equipment 1 (See Pe rmit

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 (NAAQ S). In such case, a supplemental permit shall be req uired prior to

the initiation of construction of additiona l 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

polluti on is created.

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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 amendm ent 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 unappealab le.

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) month s 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 Specificatio ns

The owner or operator shal l 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 pre vious permit for the affected

emission unit(s) and emission point, toget her 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

emissi on 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 o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess emissions during a period of startup, shutdown, or cleaning of control equip ment 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 c ontrol 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 exped itious 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 appropr iate

field office within eight (8) hours of, or at the start of, the first working day following the onse t 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 i nitial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2)

.

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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) T he 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 t ransfer 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 ea ch compliance test required by P ermit

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. T he 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 o nset 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 t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of those operating parameters sp ecified

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

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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 requireme nt 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) year s

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 thi s 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

F ax: (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 am endments, 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 unappea lable.

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 Ser vices Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10

. Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 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”

PM 10 0. 65 3 NA NA NA AQS

PM 2.5 0.0 27 4 NA NA NA AQS

Opacity NA NA 40% 5

, 6 23.3(2)”d”

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) 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 PM 10 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” fo r 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 exceedanc e of the indicator opacity of “No Visible Emissions” will require the owner or operator to promptly

investigate the em ission 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 flow rate 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 ei ther 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 applicati on requesting to amend the permit.

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12. Compliance Demonstration(s)

Pollutant Compliance

Demonstration Compliance Methodology Frequency

PM

– Federal No Performance Testing NA

PM

– State No Performance Testing NA

PM 10 No Performance Testing NA

PM 2.5 No Performance Testing NA

Opacity No Performance Testing NA

SO 2 No NA NA

NO

x No NA NA

VOC No NA NA

CO No NA NA

Pb No NA NA

CO 2 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 ab ove.

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

PM 10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM 2.5 19 hour s 40 CFR 51, Appendix M, 201A with 202

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

SO 2 1 hour 40 CFR 60, Appendix A, Method 6C

NO

x 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.

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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 (1 5) 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 t he 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 tes t(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 norm al 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 ma ximum 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 t he 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 MMMM

National Emission Standards for Hazardous Air Pollutants: Surf ace 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 (CE 9B ) shall have a MERV rating of no less than 13.

C. Mini

- pleat Filters (CE 9B ) shall be maintained and replaced per manufacturer’s instructions and

specifications.



### 15. Operating Con dition Monitoring and Recordkeeping

Unless specified by a federal regulation, a ll 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 (CE 9B )

.

B. Maintain record of MERV Rating of Mini

- pleat filters (CE 9B )

.

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

- pleat Filters

(CE9B )

.

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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

- 0 10 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

- S 2 12

- 409 Add Particulate Filter, Establish PM2.5 Limits

, Add Fan to Increase Flow 04/08/13 No

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### 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 ma tter 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

PM 2.5 Particulate Matter with an aerodynamic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l to or less than 10 microns

PM

– Federal Particulate Matter that does not include the condensable PM

PM

– State Particulate Matter that includes cond ensable PM

ppm parts per million

ppm

v parts per million by volume

ppm

w 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