Excerpts - Silgan Can Inspection Report - 08/22/06

On August 22, 2006, Tom McKinney met with Mike Penland, Plant Manager, and Ken Gustin, Plant Superintendent (910-844-4141) to conduct an air quality inspection of Silgan Can Company. The facility was operating in a normal mode at the time of the inspection. Mr. Penland and Mr. Gustin discussed the can manufacturing process and the operation of the thermal oxidizers to control VOC emissions. In addition, they discussed the minimum temperature requirements for both thermal oxidizer units.

Silgan Can Company manufactures the food cans that are used by the Campbell Soup Supply Company. In 1999 they were split apart as two separate companies and now each facility has its own Title V permit. The primary concern with respect to air pollution from the Silgan Can Company is the VOC/HAP/TAP emissions from the can-making operation. The primary HAPs for this facility are the glycol ethers and n-hexane. The facility currently operates under a Title V permit (air permit no. 08693T03) issued on January 21, 2004, with an expiration date of Dec. 31, 2008.

Silgan Can Company normally operates 24 hours per day and 7 days per week, but during the slow-down periods they do not operate on weekends. The facility has both a 2-piece line and a 3-piece line for manufacturing the cans. The 2-piece line is newer technology and is much better in terms of efficiency, costs, and environmental issues. However, the older soup-making lines are set up with equipment that can only handle the 3-piece type of can. As a result, Silgan Can Company will continue to make both types of cans.

The facility conducted source testing of its two thermal oxidizers in 2004. The two units control a large portion of the VOC emissions from the can manufacturing process. The requirements for source testing the thermal oxidizer units were established during the Title V permit renewal process. At that time a request for additional information was sent to Lisa Stribik, Silgan Can Company, requesting a CAM plan, as defined under 40 CFR 64.4. The VOC emissions are limited to less than 250 tons per 12-month period per the PSD avoidance condition. The performance monitoring approach for the thermal oxidizers meets the definition of existing continuous compliance determination method as provided in CFR Part 64.1, which: