Minnesota Pollution Control Agency

Transcription

1 Minnesota Pollution Control Agency Part 70 Manufacturing General Air Emission Permit PERMITTEE: FACILITY NAME: PERMIT ISSUANCE DATE: EXPIRATION DATE: Permit Characteristics: HNI Corporation Hearth & Home Technologies, Lake City 800 West Jefferson Street Lake City, Wabasha County, Minneosta April 30, 2015 October 31, All Title I Conditions do not expire. Federal; Part 70 General Permit/Limits to avoid NSR The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the Permit Applications Table. This general permit authorizes the Permittee to operate, construct and modify the stationary source at the address listed above unless otherwise noted in the permit. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Signature: Don Smith, P.E., Manager, Air Quality Permits Section for the Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

2 Permit Type Application Date(s) Permit Action Part 70 Manufacturing General Permit 10/27/ TABLE OF CONTENTS Notice to the Permittee Permit Shield Table A: Limits and Other Requirements Table B: Submittals Table C: Compliance Schedule Appendices: Appendix A Source Specific Calculations Appendix B General Provisions Appendix (40 CFR pt. 63, subp. A) Appendix C 40 CFR pt. 63, subp. T supplementary information Appendix D 40 CFR pt. 63, subp. MMMM equations Appendix E 40 CFR pt. 63, subp. PPPP equations Appendix F 40 CFR pt. 63, subp. WWWW supplementary information Page 2 Part 70 Manufacturing General Permit 2014

3 NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area Outside Metro Area TTY The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with specific provisions of the applicable requirements identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. TABLE A: LIMITS AND OTHER REQUIREMENTS Table A contains the limits and other requirements with which your facility must comply. These limits are located in the first column of the table (What to do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A () lists the regulatory basis for these limits. Appendices are included in your permit. Appendices that are included are listed at the end of Table A, under total facility requirements. Requirements in all appendices are enforceable conditions of this permit. Page 3 Part 70 Manufacturing General Permit 2014

4 Table A: LIMITS AND OTHER REQUIREMENTS A.1 Total Facility Requirements What to do GENERAL PERMIT SPECIFIC REQUIREMENTS Type of Emission Units Allowed: The stationary source shall not have any emission units other than the following process operations and emission units: Abrasive blasting, adhesive, bag houses, boilers, burn off ovens, casting, catalytic or thermal afterburners, cleaning (including acid cleaning, degreasers, general cleanup with solvents), dip tanks, fabric filters, fuel storage, furnaces, injection molding, internal combustion engines (generators), lamination, mixing, molding, ovens, resin and gel coating, sanding, screen printing, space heaters, spraying and coating activities, stenciling, storage tanks, wall/panel filters, water wash paint booths, and/or any of the insignificant activities listed in Minn. R and/or conditionally insignificant activities listed in Minn. R Labeling Requirements: The Permittee shall permanently affix the manufacturer s serial number to each piece of equipment for tracking purposes within 60 days of permit issuance. If the serial number is not available, a unique number shall be assigned to the equipment. The number may be affixed by placard, stencil or other means. The number shall be maintained so that it is readable and visible at all times from a safe distance. hdr To qualify for this general permit under Minn. R , and Minn. R , subp. 2 To qualify for this general permit under Minn. R and Minn. R , subp. 2 Page 4

5 What to do Equipment List Inventory: The Permittee shall maintain a written list of each piece of equipment on site, if applicable. Use Form MG EIL. The list shall include: date of revisions the type of equipment o serial number (or assigned number as applicable) o dates of installation, modification and reconstruction all applicable Standards of Performance for New Stationary Sources: o Subpart Kb for volatile organic liquid storage vessels o Subpart IIII for compression ignition internal combustion engines all applicable National Emission Standards for Hazardous Air Pollutants (NESHAP): o Subpart T for halogenated solvent cleaning machines o Subpart MMMM for surface coating of miscellaneous metal parts and products o Subpart PPPP for surface coating of plastic parts and products o Subpart WWWW for reinforced plastic composites production o Subpart ZZZZ for stationary reciprocating internal combustion engines o Subpart DDDDD for industrial/commercial/institutional boilers and process heaters The list shall be updated to include any new, modified or changed equipment before making a change. When the list is updated, the Permittee shall maintain copies of it and all previous equipment lists on site. Eligibility Evaluations: The following eligibility evaluations shall be completed before making any modification or change as allowed by this permit: 1. Re evaluate whether the emission limits in this permit can continue to be met; 2. Evaluate whether any proposed new or replacement equipment is of the type allowed by this permit; and 3. Re evaluate whether the change or modification will result in any part of the facility being subject to any NSPS or NESHAP other than those allowed by this permit. If the emission limits can t be met, or the proposed new equipment is not allowed by this permit, or a NSPS or NESHAP other than what is allowed by this permit will be triggered, the Permittee shall apply for and receive an individual Part 70 permit that authorizes the modification or change and operation of the total stationary source before making the modification or change. Lead Containing Materials Prohibited: The Permittee shall not use painting or coating materials that contain lead. To qualify for this general permit under Minn. R and Minn. R , subp. 2 To qualify for this general permit under Minn. R and Minn. R , subp. 2 To qualify for this general permit under Minn. R ; and Minn. R , subp. 2 Page 5

6 What to do Fuel Usage: The Permittee shall use only distillate oil (diesel, fuel oil #1 or #2), natural gas, biodiesel, liquid petroleum gas, and/or gasoline fuels in stationary combustion sources. The Permittee shall not use any distillate oil with greater than 15 ppm sulfur. Boiler size: The Permittee shall not use or install indirect heating equipment with a maximum design heat input capacity greater than or equal to 10 MMBtu/hr for any individual boiler. Change of name, ownership, or control of stationary source: The Permittee shall submit to the MPCA Form GP 01: General Permit Administrative Changes, within 7 days of the change of name, ownership, or control of the stationary source. If the Commissioner determines that the new owner or operator meets the eligibility requirements of the general permit, then the Commissioner shall issue the general permit to the new owner or operator (the new Permittee). Issuance of a general permit to the new Permittee of an eligible stationary source voids and supersedes the general permit of the previous Permittee. If the Commissioner determines the new owner or operator does not meet the eligibility requirements, the new owner or operator shall submit a permit application for an individual Part 70 or state permit, as applicable, within 120 days of the Commissioner s written request for the application. Prevention of Significant Deterioration: The stationary source shall not be one of the Prevention of Significant Deterioration (PSD) source categories listed in Minn. R , subp. 2(B)(1) (26). New Source Performance Standards: The Permittee shall comply with the following standards, if applicable: Subpart Kb for volatile organic liquid storage vessels Subpart IIII for compression ignition internal combustion engines Sources that are subject to any other NSPS for a source category in 40 CFR pt. 60 are not eligible for this general permit. To qualify for this general permit under Minn. R , and Minn. R , subp. 2 To qualify for this general permit under Minn. R , and Minn. R , subp. 2 To qualify for this general permit under Minn. R , subp. 8 and Minn. R , subp. 2 Title I Condition: To avoid classification as a major source under and Minn. R ; to qualify for this general permit under Minn. R and Minn. R , subp CFR pt. 60, subp. Kb; Minn. R (C); 40 CFR pt. 60, subp. IIII; Minn. R ; and to qualify for this general permit under Minn. R and Minn. R , subp. 2 Page 6

7 What to do National Emission Standards for Hazardous Air Pollutants: The Permittee shall comply with the following standards, if applicable: Subpart T for halogenated solvent cleaning machines Subpart MMMM for surface coating of miscellaneous metal parts and products Subpart PPPP for surface coating of plastic parts and products Subpart WWWW for reinforced plastic composites production Subpart ZZZZ for stationary reciprocating internal combustion engines Subpart DDDDD for industrial/commercial/institutional boilers and process heaters Sources which are subject to any other NESHAP for a source category in 40 CFR pt. 63, are subject to any NESHAP for a source category in 40 CFR pt. 61, or were subject to case by case MACT standards issued through an individual permit under section 112(g) of the Clean Air Act, are not eligible for this general permit. Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices. Stratospheric Ozone Protection: Use Forms MG 09 and MG 09F to determine if the facility is subject to this requirement. If the facility currently uses ozone depleting substances as defined in 40 CFR pt. 82, Sections of the 1990 Clean Air Act Amendments and 40 CFR pt. 82 may apply to the facility. The Permittee shall read Sections and 40 CFR pt. 82 to determine all the requirements that apply to the facility. Federal Ozone Measures: Use Form MG 09 to determine if the facility is subject to this requirement. If the facility currently manufactures consumer and commercial products that emit volatile organic compounds, Section 183(e) of the 1990 Clean Air Act Amendments and 40 CFR pt. 59 may apply to the facility. The Permittee shall read Sections 183(e) and 40 CFR pt. 59 to determine all the requirements that apply to the facility. 40 CFR pt. 63, subp. T; Minn. R ; 40 CFR pt. 63, subp. MMMM; Minn. R ; 40 CFR pt. 63, subp. PPPP; Minn. R ; 40 CFR pt. 63, subp. WWWW; Minn. R ; 40 CFR pt. 63, subp. ZZZZ; Minn. R ; 40 CFR pt. 63, subp. DDDDD; and to qualify for this general permit under Minn. R and Minn. R , subp. 2 To qualify for this general permit under Minn. R ; Minn. R , subp CFR pt CFR pt. 59 Page 7

8 What to do POLLUTANT LIMITS Particulate Matter (PM): Less than or equal to 90 tons per year using a 12 month rolling sum, calculated monthly as described in Appendix A. All PM emitting equipment at the facility is subject to this limit, except insignificant activities under Minn. R subps. 2 and 3, and Minn. R. chapter 7008 (if applicable). If the Permittee replaces any existing PM emitting equipment, adds new PM emitting equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the applicable requirements listed at the Total Facility Level of this permit. Particulate Matter less than Ten Micron (PM 10 ): Less than or equal to 90 tons per year using a 12 month rolling sum, calculated monthly as described in Appendix A. All PM 10 emitting equipment at the facility is subject to this limit, except insignificant activities under Minn. R subps. 2 and 3, and Minn. R. chapter 7008 (if applicable). If the Permittee replaces any existing PM 10 emitting equipment, adds new PM 10 emitting equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the applicable requirements listed at the Total Facility Level of this permit. Particulate Matter less than 2.5 Micron (PM 2.5 ): Less than or equal to 90 tons per year using a 12 month rolling sum, calculated monthly as described in Appendix A.. All PM 2.5 emitting equipment at the facility is subject to this limit, except insignificant activities under Minn. R subps. 2 and 3, and Minn. R. chapter 7008 (if applicable). If the Permittee replaces any existing PM 2.5 emitting equipment, adds new PM 2.5 emitting equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the applicable requirements listed at the Total Facility Level of this permit. Nitrogen Oxides (NO x ): Less than or equal to 90 tons per year using a 12 month rolling sum, calculated monthly as described in Appendix A. All NO x emitting equipment at the facility is subject to this limit, except insignificant activities under Minn. R subps. 2 and 3, and Minn. R. chapter 7008 (if applicable). If the Permittee replaces any existing NO x emitting equipment, adds new NO x emitting equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the applicable requirements listed at the Total Facility Level of this permit. hdr Title I Condition: To avoid classification as a major source under and Minn. R ; To qualify for this general permit under Minn. R Title I Condition: To avoid classification as a major source under and Minn. R ; To qualify for this general permit under Minn. R Title I Condition: To avoid classification as a major source under and Minn. R ; To qualify for this general permit under Minn. R Title I Condition: To avoid classification as a major source under and Minn. R ; To qualify for this general permit under Minn. R Page 8

9 What to do Carbon Monoxide (CO): Less than or equal to 90 tons per year using a 12 month rolling sum, calculated monthly as described in Appendix A. All CO emitting equipment at the facility is subject to this limit, except insignificant activities under Minn. R subps. 2 and 3, and Minn. R. chapter 7008 (if applicable). If the Permittee replaces any existing CO emitting equipment, adds new CO emitting equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the applicable requirements listed at the Total Facility Level of this permit. Volatile Organic Compounds (VOC): Less than or equal to 225 tons per year using a 12 month rolling sum, calculated monthly as described in Appendix A.. All VOC emitting equipment at the facility is subject to this limit, except insignificant activities under Minn. R subps. 2 and 3, and Minn. R. chapter 7008 (if applicable). If the Permittee replaces any existing VOC emitting equipment, adds new VOC emitting equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the applicable requirements listed at the Total Facility Level of this permit. Greenhouse Gas (GHG): Less than or equal to 90,000 tons per year CO2e using a 12 month rolling sum, calculated monthly as described in Appendix A. All GHG emitting equipment at the facility is subject to this limit, except insignificant activities under Minn. R subps. 2 and 3, and Minn. R. chapter 7008 (if applicable). If the Permittee replaces any existing GHG emitting equipment, adds new GHG emitting equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the applicable requirements listed at the Total Facility Level of this permit. Total Hazardous Air Pollutants (HAP): Less than or equal to 90 tons per year using a 12 month rolling sum, calculated monthly as described in Appendix A. All HAP emitting equipment at the facility is subject to this limit, except insignificant activities under Minn. R subps. 2 and 3, and Minn. R. chapter 7008 (if applicable). If the Permittee replaces any existing HAP emitting equipment, adds new HAP emitting equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the applicable requirements listed at the Total Facility Level of this permit. Title I Condition: To avoid classification as a major source under and Minn. R ; To qualify for this general permit under Minn. R Title I Condition: To avoid classification as a major source under and Minn. R ; To qualify for this general permit under Minn. R To qualify for this general permit under Minn. R To qualify for this general permit under Minn. R ; (c); Minn. R Page 9

10 What to do OPERATIONAL REQUIREMENTS Ambient Air Quality Standards: The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R to Compliance shall be demonstrated upon written request by the MPCA. Circumvention: The Permittee shall not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance (O & M) plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Fugitive Emissions: The Permittee shall not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. The Permittee shall also comply with all other requirements listed in Minn. R Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not federally enforceable by the EPA Administrator or citizens under the Clean Air Act. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). General Conditions: The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. hdr Minn. Stat. Section , subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps. 1, 2 & 4; Minn. R Minn. R Minn. R , subp. 14 and Minn. R , subp. 16(J) Minn. R , subp. 4 Minn. R Minn. R Minn. R , subp. 9(A) Minn. R , subp. 16 Page 10

11 What to do POLLUTION CONTROL EQUIPMENT REQUIREMENTS Operation of Air Pollution Control Equipment: The Permittee shall operate all pollution control equipment whenever the corresponding process equipment and emission units are in operation. Air Pollution Control Equipment: The Permittee shall comply with the control equipment rule (Minn. R ) for all fabric filters, wall or panel filters, catalytic oxidizers, and thermal oxidizers, at the facility. If the Permittee replaces any existing control equipment that has requirements in this permit, adds new control equipment of a type listed in this requirement, or modifies control equipment that has requirements in this permit, such equipment is subject to all of the applicable requirements of this permit. Overall Control Efficiency Requirement for Booths: The Permittee shall vent emissions from all booths for abrasive blasting, sanding, and non fiberglass spraying/coating operations; including existing, modified, or new booths for abrasive blasting, sanding and non fiberglass spraying/coating; to control equipment meeting all of the following requirements: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter (PM): greater than or equal to 85% overall control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Particulate Matter less than 10 microns (PM 10 ): greater than or equal to 85% overall control efficiency. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Particulate Matter less than 2.5 microns (PM 2.5 ): greater than or equal to 85% overall control efficiency. hdr Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R ; Minn. R , subp. 2 To qualify for this general permit under Minn. R ; and Minn. R Page 11

12 What to do Capture Efficiency for Control Equipment: For operations that are totally enclosed, the Permittee shall use a capture efficiency of 100% of uncontrolled emissions. Total enclosure means the operation is conducted in a booth or room with all doors, windows, and access opening closed, and all emissions are captured and discharged through ductwork to control equipment. One side or access opening may consist of a curtain of overlapping plastic panels or sliding doors. All capture systems that are not totally enclosed shall be certified to conform to the design and operating practices recommended in The Manual. The Permittee shall submit evidence of certification on Form MGCR 02. In addition, the Permittee shall provide a description of the hood on Form MGHE 01. Once certified, the Permittee shall use for the hood a capture efficiency of 80% of uncontrolled emissions resulting from operations using the certified hood. For all capture systems that are: (1) not fully enclosed, and (2) not certified to the design and operating practices recommended in The Manual, the Permittee shall use a capture efficiency of 0% of uncontrolled emissions resulting from operations that do not use a total enclosure or a certified hood. The Manual: for the purposes of this requirement, The Manual refers to the most recent edition (as of the time of system certification) of Industrial Ventilation A Manual of Recommended Practices by American Conference of Governmental Industrial Hygienists. To qualify for this general permit under Minn. R ; Minn. R Page 12

13 What to do Fugitive Dust Control: The facility shall take reasonable measures to prevent particulate matter from becoming airborne. The Permittee shall minimize or eliminate fugitive emissions from all paved surfaces. If fugitive emissions from paved surfaces are observed, the Permittee shall record the date that fugitive dust was observed, what corrective actions were taken, when the corrective actions were taken, and whether the corrective actions eliminated the fugitive dust. The Permittee shall use water on exposed surfaces such as unpaved roads to control fugitive particulate emissions, except as provided below. If fugitive emissions from exposed surfaces are observed, the Permittee shall record: the date that fugitive dust was observed; what corrective actions were taken, when the corrective actions were taken, and whether the corrective actions eliminated the fugitive dust; if dust control measures were not taken because of a rainfall event or because an area is snow or ice covered, documentation of the event or condition along with the source of measurement for rainfall (e.g. on site rain gauge); if dust control measures were not taken because of weather conditions, documentation of the date and the weather conditions (e.g. documentation that the temperature indicated freezing conditions) The Permittee is not required to use water to control fugitive particulate emissions under any of the following circumstances: If there was a 0.1 inch rainfall during the previous 24 hours, or If the areas to be controlled are covered with snow or ice, or During freezing conditions. PERFORMANCE TESTING REQUIREMENTS Performance Testing: The Permittee shall conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Table A, B, and /or C. Performance Test Notifications and Submittals: Performance Tests are due as outlined in Table A of the permit. See Table B for additional testing requirements. Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R To qualify for this general permit under Minn. R ; Minn. R , subp. 2 hdr Minn. R. ch Minn. R ; Minn. R , subps. 1 4, Minn. R , subps. 1 2 Page 13

14 What to do MONITORING REQUIREMENTS Monitoring Equipment: The Permittee shall install or make needed repairs to monitoring equipment within 60 days of issuance of the permit if monitoring equipment is not installed and operational on the date the permit is issued. Monitoring Equipment Calibration: The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate or replace at the frequency stated in the manufacturer s specifications. For each monitor, the Permittee shall maintain a record of all calibrations/replacements, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration/replacement frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. RECORDKEEPING REQUIREMENTS Recordkeeping: The Permittee shall retain all records at the facility for a period of 5 years from the date of monitoring, emission calculations, sampling, measurement, eligibility evaluation, determination, or reporting. Records that the Permittee shall retain at the facility include all calibration and maintenance records, all original stripchart recordings for continuous monitoring instrumentation, and copies of all reports, records, evaluations, and documentation required by the permit. hdr Minn. R , subp. 4(D) and Minn. R Minn. R , subp. 4(D) Minn. R , subp. 4(D) hdr Minn. R , subp. 5 Records shall conform to the requirements listed in Minn. R , subp. 5(A), including at a minimum: 1. the date, place as defined in the permit, and time of sampling or measurements; 2. the date or dates analyses were performed; 3. the company or entity that performed the analyses; 4. the analytical techniques or methods used; 5. the results of such analyses; and 6. the operating conditions existing at the time of sampling or measurement. Page 14

15 What to do Hood Certification and Recordkeeping: The Permittee shall maintain a copy of the hood certification on site (Form MGCR 02), as well as the annual record of the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable airflow indication method, if applicable, (Form MGHE 01). Fuel Certification: The Permittee shall obtain a producer/manufacturer certification showing the sulfur content of each delivery of diesel fuel. The Permittee shall maintain these fuel certifications according to the Recordkeeping requirement above. Monthly Calculation and Recordkeeping for fuel usage and NO x /CO emissions: By the 15th day of each month, the Permittee shall calculate and record the quantity of fuel burned during the previous month of each type of fuel used. The Permittee shall use this fuel usage record to calculate NO x and CO emissions from fuel combustion using Equation A1 in Appendix A to this permit. The Permittee shall maintain all records of NO x and CO emissions calculations, including the 12 month rolling sum on a monthly basis. The Permittee shall calculate the 12 month rolling sum every month by calculating one month total and adding it to the sum of each month s total from the previous 11 consecutive months. Monthly Calculation and Recordkeeping for PM/PM 10 /PM 2.5 emissions: By the 15th day of each month, the Permittee shall calculate and record the PM, PM 10, and PM 2.5, emissions at the facility using Equation A2 in Appendix A to this permit. The Permittee shall maintain all records of PM/PM 10 /PM 2.5 emissions calculations, including the 12 month rolling sum on a monthly basis. The Permittee shall calculate the 12 month rolling sum every month by calculating one month total and adding it to the sum of each month s total from the previous 11 consecutive months. Monthly Calculation and Recordkeeping for VOC emissions: By the 15th day of each month, the Permittee shall calculate and record the following: 1. Total purchases of all VOC containing materials used during the previous month. This record shall include the VOC content of each material as determined by the material by the Material Content requirement of this permit; 2. The total VOC emissions for the previous month using the A3 equations in Appendix A to this permit; and 3. Total 12 month rolling sum VOC emissions for the previous 12 month period by summing the monthly VOC emissions data for the previous 12 month. The Permittee shall calculate the 12 month rolling sum every month by calculating one month total and adding it to the sum of each month s total from the previous 11 consecutive months. To qualify for this general permit under Minn. R ; Minn. R ; Minn. R , subps. 4, 5, and 14 Minn. R , subps. 2 and 4 Title I Condition: To avoid classification as a major source under and Minn. R ; Minn. R , subps. 4 and 5 Title I Condition: To avoid classification as a major source under and Minn. R ; Minn. R , subps. 4 and 5 Title I Condition: To avoid classification as a major source under and Minn. R ; Minn. R , subps. 4 and 5 Page 15

16 What to do Material Content: VOC contents in all materials shall be determined by the Material Safety Data Sheet (MSDS) or Certification of Analysis (COA) provided by the supplier of each material used. If a material content range is given on the MSDS or COA, the highest number in the range shall be used in all permit calculations. Other alternative methods approved by the MPCA may be used to determine the VOC content. The Commissioner reserves the right to require the Permittee to determine the VOC content of any material according to EPA and or ASTM reference methods. If an EPA or ASTM reference method is used for material content determination, the date obtained shall supersede the MSDS or COA data. Monthly Calculation and Recordkeeping for HAP emissions: By the 15th day of each month, the Permittee shall calculate and record the HAP emissions at the facility using the methods specified in section 5 of Appendix A to this permit. The Permittee shall maintain all records of HAP emissions calculations, including the 12 month rolling sum on a monthly basis. The Permittee shall calculate the 12 month rolling sum every month by calculating one month total and adding it to the sum of each month s total from the previous 11 consecutive months. Monthly Calculation and Recordkeeping for GHG emissions: By the 15th day of each month, the Permittee shall calculate and record the CO 2 e emissions at the facility using the A4 equations of Appendix A to this permit. The Permittee shall maintain all records of CO 2 e emissions calculations, including the 12 month rolling sum on a monthly basis. The Permittee shall calculate the 12 month rolling sum every month by calculating one month total and adding it to the sum of each month s total from the previous 11 consecutive months. REPORTING AND SUBMITTALS REQUIREMENTS Compliance Management Plan: The Permittee shall submit to the MPCA the compliance management plan within 60 days of the issuance of this permit. If the Permittee adds any new, modified or changed equipment, the Permittee will update this plan and submit it to the MPCA at least seven days before the change. Use Form MG CMP. Shutdown Notifications: The Permittee shall notify the Commissioner at least 24 hours in advance of planned shutdown of any control equipment or process equipment if the shutdown would cause an increase in the emissions of any regulated air pollutant. If the Permittee does not have advance knowledge of the shutdown, the Permittee shall notify the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B, and C of Minn. R , subp. 3. Minn. R , subps. 4 and 5 Minn. R , subps. 4 and 5 Minn. R , subps. 4 and 5 hdr To qualify for this general permit under Minn. R and Minn. R , subp. 2 Minn. R , subp. 3 At time of notification, the Permittee shall inform the Commissioner of the cause of the shutdown and the estimated duration. The Permittee shall notify the Commissioner when the shutdown is over. Page 16

17 What to do Breakdown Notifications: The Permittee shall notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes an increase in the emissions of any regulated air pollutant. The 24 hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B, and C of Minn. R , subp. 2. Minn. R , subp. 2 At time of notification or as soon as possible thereafter, the Permittee shall inform the Commissioner of the cause of the breakdown and the estimated duration. The Permittee shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, the Permittee shall notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviations from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, the Permittee shall notify the Commissioner in writing of any deviation from the permit conditions which could endanger human health or the environment. In this written notification, the Permittee shall include the following information: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has not been corrected; 3. whether or not has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Annual Report (applies to NESHAP Subpart T): Due on or before February 1 of each calendar year, if applicable. Use Form TF 07. Semiannual Deviations Report: Due 30 days after end of each calendar half year. The first semiannual report, covering deviations which occurred during the period from January 1 through June 30, is due by July 30 of each year. The second report, covering deviations which occurred during the period from July 1 through December 31, is due by January 30 of each year. If no deviations have occurred, the Permittee shall submit the report stating no deviations. Use Form DRF 2 (or equivalent replacement form or reporting mechanism approved by the Commissioner). Minn. R , subp. 1; Minn. R , subp. 6(A) Minn. R , subp. 1; Minn. R , subp. 6(A) (f); Minn. R Minn. R , subp. 6(A)(2) Page 17

18 What to do Annual Compliance Certification: due 30 days after end of each calendar year following Permit Issuance (for the previous calendar year). The Permittee shall submit this on a form approved by the Commissioner, both to the Commissioner and to the US EPA regional office in Chicago. Use Form MGCR 04 (or equivalent replacement form or reporting mechanism approved by the Commissioner). This report covers all deviations experienced during the calendar year. Minn. R , subp. 6(C) Equipment Inventory List: Due on or before 30 days after end of each calendar year following permit issuance. Use Form MG EIL. Emission Inventory Report: Due on or before April 1 of each calendar year following permit issuance, to be submitted on a form approved by the Commissioner. To qualify for this general permit under Minn. R Minn. R Emission Fees: Due 30 days after receipt of an MPCA bill. Minn. R Risk Management Plan: If the Permittee is required to develop and implement a Risk 40 CFR pt. 68 Management Plan (RMP) for accidental releases, the Permittee shall submit a RMP as required under 40 CFR pt. 68. The Permittee shall use Forms MG 09 and MG 09G to determine whether this requirement applies and maintain copies of this determination onsite. The Permittee of a stationary source at which a regulated substance is present above a threshold quantity in a process shall design and implement an accidental release prevention program. The Permittee shall submit the initial RMP no later than the latest of the following dates: o June 21, 1999; o Three years after the date on which a regulated substance is first listed under ; or o The date on which a regulated substance is first present above a threshold quantity in a process. The Permittee shall fully update and resubmit the RMP least once every five years. The five year anniversary date is reset whenever the RMP is fully updated and resubmitted. The Permittee shall submit RMPs to the Risk Management Plan Reporting Center, P.O. Box 1515, Lanham Seabrook, Maryland RMP information may be obtained at or by calling Application for Permit Reissuance: due 180 days before expiration of existing permit. Minn. R , subp. 2 Submittals: All submittals required by this permit must be certified by a responsible official, defined in Minn. R , subp. 21. Submittals which must be provided on forms approved by the Commissioner are noted in Tables A, B and/or C in this permit. All submittals must be postmarked or received by the date specified in the tables. Minn. R , subp. 6 Page 18

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20 A.2 Degreasers/Cleaning Machines Form MG 05B9 The following are Minnesota Standards of Performance for Industrial Process Equipment A.2.1 Degreasers/Cleaning Machines placed in operation before July 9, 1969 What to do Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20% opacity except for one six minute period per hour of not more than 60% opacity. Minn. R , subp. 1(A); Minn. R , subp. 1(B) A.2.2 Degreasers/Cleaning Machines placed in operation on or after July 9, 1969 What to do Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R or Minn. R Minn. R , subp. 1(A); Opacity: less than or equal to 20% opacity. Minn. R , subp. 1(B) The following are National Emission Standards for Hazardous Air Pollutants for Halogenated Solvent Cleaning Machines (40 CFR pt. 63, subp. T) A.2.3 Degreasers/Cleaning Machines Subject to NESHAP subp. T Affected Source: each individual batch vapor, in line vapor, in line cold, and batch cold solvent cleaning machine that uses any solvent containing methylene chloride (MC), perchloroethylene (PCE), trichloroethylene (TCE), 1,1,1 trichloroethane, carbon tetrachloride or chloroform or any combination with these solvents, in a concentration greater than five weight percent and the holding capacity of a container for cleaning process is greater than two gallons. New Source: affected source constructed or reconstructed after November 29, 1993 Page 20

21 Existing Source: affected source constructed or reconstructed on or before November 29, This includes machines constructed or reconstructed on or before November 29, 1993, or existing nonhalogenated solvent cleaning machine on December 2, 1994, becomes a halogenated solvent machine A Each cold batch cleaning machine What to do For each Immersion Batch Cold Solvent Cleaning Machine, the Permittee shall employ: A tightly fitting cover which shall be closed at all times except during parts entry and removal; and either a water layer at a minimum thickness of 2.5 centimeters (1.0 inch) on the surface of the solvent within the cleaning machine, or a freeboard ratio of 0.75 or greater. For each Remote Reservoir Batch Cold Solvent Cleaning Machine, the Permittee shall employ a tightly fitting cover over the solvent sump that shall be closed at all times except during the cleaning of parts. The Permittee shall use Form TF 06 when submitting an initial notification report, or Form TF 03 when submitting a compliance report. Initial Notification Report for New Sources Only: Prior to construction or reconstruction of a new cleaning machine, the Permittee shall submit an initial notification report as soon as practicable before the construction or reconstruction is planned to commence. 1. The report shall include a brief description of the cleaning machine including machine type, solvent/air interface area, and existing controls. 2. The report shall include the anticipated compliance approach for each solvent cleaning machine. 3. The Permittee must report an estimate of annual halogenated HAP solvent consumption for each solvent cleaning machine (this is instead of the requirements of 63.5(d)(1)(ii)(H)) (a); Minn. R (b); Minn. R (d), 40 CFR Section ; Minn. R , Minn. R (d); 40 CFR Section (b); Minn. R ; Minn. R , subp. 2 Page 21

22 What to do Compliance Report for New Source: must be submitted to the MPCA no later than 150 days after startup. The report shall include: 1. The name and address of the owner or operator 2. The address (physical location) of the solvent cleaning machine 3. A statement, signed by the owner or operator of the solvent cleaning machine, stating that the solvent cleaning machine for which the report is being submitted is in compliance with the provisions of Subpart T. 4. The compliance approach for each solvent cleaning machine. For either an Immersion Batch Cold Solvent Cleaning Machine where the choice of control option is a freeboard ratio, or a Remote Reservoir Batch Cold Solvent Cleaning Machine, the Permittee shall comply with the following work and operational practice requirements: 1. All waste solvent shall be collected and stored in closed containers. The closed container may contain a device that allows pressure relief, but does not allow liquid solvent to drain from the container. 2. If a flexible hose or flushing device is used, flushing shall be performed only within the freeboard area of the solvent cleaning machine. 3. The solvent cleaned parts shall be drained for 15 seconds or until dripping has stopped, whichever is longer. Parts having cavities or blind holes shall be tipped or rotated while draining. 4. The Permittee shall ensure that the solvent level does not exceed the fill line. 5. Spills during solvent transfer shall be wiped up immediately. The wipe rags shall be stored in a closed container. 6. When an air or pump agitated solvent bath is used, the Permittee shall ensure that the agitator is operated to produce a rolling motion of the solvent but not observable splashing against tank walls or parts being cleaned. 7. The Permittee shall ensure that, when the cover is open, the cold cleaning machine is not exposed to drafts greater than 132 feet per minute, as measured between 3.3 and 6.6 feet upwind and at the same elevation as the tank lip. 8. Sponges, fabric, wood, and paper products shall not be cleaned, except as described in item The prohibition in item 8 does not apply to the cleaning of porous materials that are part of polychlorinated biphenyl (PCB) laden transformers if those transformers are handled throughout the cleaning process and disposed of in compliance with an approved PCB disposal permit issued in accordance with the Toxic Substances Control Act (d); 40 CFR Section (c); Minn. R (c); Minn. R Page 22

23 What to do If subject to items 1 8 above, the Permittee may request to use measures other than those described in items 1 8 above. The Permittee must demonstrate to the Administrator that the alternative measures will result in equivalent or better emissions control compared to the measures described in items 1 8. For example, storing solvent and solvent laden materials in an enclosed area that is ventilated to a solvent recovery or destruction device may be considered an acceptable alternative (e); Minn. R Page 23

24 A Each batch vapor, in line vapor, and in line cold cleaning machine What to do All Existing or New Batch Vapor, In Line Vapor, and In Line Cold Cleaning Machines: Each cleaning machine shall meet the following design or operational requirements: 1. EITHER employ an idling and downtime mode cover as described in (d)(1)(i), that may be readily opened or closed, that completely covers the cleaning machine openings when in place, and is free of cracks, holes and other defects, OR operate in a reduced room draft as described in (e)(2)(ii) 2. have a freeboard ratio of 0.75 or greater; 3. have an automated parts handling system capable of moving parts or parts baskets at a speed of 3.4 meters per minute (11 feet per minute) or less from the initial loading of parts through removal of cleaned parts; and 4. if the machine uses a lip exhaust, then the lip exhaust shall be designed and operated to route all collected solvent vapors through a properly operated and maintained carbon adsorber that meets the requirements of (e)(2)(vii). Existing or New Vapor Machines: Each vapor cleaning machine shall meet the following additional design requirements: 1. unless the vapor cleaning machine uses steam to heat the solvent, the vapor cleaning machine shall be equipped with a device that shuts off the sump heat if the sump liquid solvent level drops to the sump heater coils; 2. equipped with a vapor level control device that shuts off sump heat if the vapor level in the vapor cleaning machine rises above the height of the primary condenser; and 3. have a primary condenser. Existing or New Batch Vapor Machines: The Permittee shall either: comply with a control combination option listed in Table T2 in Appendix C of this permit, or achieve and maintain an idling emission limit of lb./hr./sq. ft. Existing or New In line Cleaning Machines: The Permittee shall either: comply with a control combination option in Table T3 in Appendix C of this permit, or achieve and maintain an idling emission limit of lb./hr./sq. ft (a); Minn. R (a); Minn. R (b); Minn. R (c); Minn. R Page 24

25 What to do Existing or New Batch Vapor or In line Solvent Cleaning Machines (except Continuous Web Cleaning Machines): When applicable, each cleaning machine shall meet the following work and operational practices requirements. 1. Control air disturbances across the cleaning machine opening by either employing idling and downtime mode cover or reduced room draft. 2. The parts baskets or the parts being cleaned in an open top batch vapor cleaning machine shall not occupy more than 50% of the solvent/air interface area unless the parts baskets or parts are introduced at a speed of 3 feet per minute or less. 3. Any spraying operation shall be done within the vapor zone or within a section of the solvent cleaning machine that is not directly exposed to the ambient air. 4. Parts shall be oriented so that the solvent drains from them freely. Parts having cavities or blind holes shall be tipped or rotated before being removed from the machine. 5. Parts baskets or parts shall not be removed from the machine until dripping has stopped. 6. During startup of the machine, the primary condenser shall be turned on before the sump heater. 7. During shutdown of the machine, the sump heater shall be turned off and the solvent vapor layer allowed to collapse before the primary condenser is turned off. 8. The solvent shall be transferred to and from the machine using threaded or other leak proof couplings and the end of the pipe in the solvent sump shall be located beneath the liquid solvent surface. 9. When a control option includes control equipment, it shall be maintained as recommended by the manufacturers of the equipment. 10. Each operator shall complete and pass the applicable sections of the test of solvent cleaning procedures in appendix A to 40 CFR pt. 63, subp. T, if requested during an inspection by the MPCA. 11. Waste solvent, still bottoms, and sump bottoms shall be collected and stored in closed containers. The closed containers may contain a device that would allow pressure relief, but would not allow liquid solvent to drain from the container. 12. Sponges, fabric, wood, and paper products shall not be cleaned (d); Minn. R Page 25

26 What to do Compliance with the NESHAP: If the Permittee chooses to comply with an idling emission limit under (b) or (c), the Permittee must do the following: 1. Conduct an initial performance test using the Reference Method 307 to demonstrate compliance with the applicable idling emission limit and to establish parameters that will be monitored to demonstrate compliance. The Permittee shall submit a test report in accordance with Minn. R A Permittee employing the control devices in Table T1 in Appendix C of this permit to meet the idling emission limit shall comply with the applicable control device requirement (performance, monitoring, and recordkeeping) in Table T1 in Appendix C of this permit. 3. A Permittee using control devices which are not listed in Table T1 in Appendix C of this permit shall indicate whether the exceedance of the parameters that are monitored to determine whether it would be classified as an immediate exceedance or whether a 15 days repair period would be allowed and the monitoring frequency for each control. The information must be submitted in the initial test report for approval by the MPCA. 4. Operate the solvent cleaning machine within parameters identified in the initial performance test. 5. Report all exceedances and all subsequent adjustments and corrections as described in (h) (f), 40 CFR Section , and (f); 40 CFR Section (h); Minn. R , Page 26

27 What to do Continuous Web Cleaning Machines (except Remote Reservoir): When applicable, each cleaning machine shall meet the following work and operational practices requirements. (1) Install, maintain, and operate one of the following control combinations on each continuous web cleaning machine. (i) For each existing continuous web cleaning machine, the following control combinations are allowed: (A) Superheated vapor or superheated part technology, and a freeboard ratio of 1.0 or greater. (B) Freeboard refrigeration device and a freeboard ratio of 1.0 or greater. (C) Carbon adsorption system meeting the requirements of (e)(2)(vii). (ii) For each new continuous web cleaning machine, the following control combinations are allowed: (A) Superheated vapor or superheated part technology, and a freeboard refrigeration device. (B) A freeboard refrigeration device and a carbon adsorber meeting the requirements of (e)(2)(vii). (C) Superheated vapor or superheated part technology, and a carbon adsorber meeting the requirements of (e)(2)(vii). [continued below] (g); Minn. R Page 27

28 What to do Continuous Web Cleaning Machines (except Remote Reservoir): [continued from above] (2) (i) Each cleaning machine shall meet one of the following control equipment or technique requirements: (A) An idling and downtime mode cover, as described in (d)(1)(i), that may be readily opened or closed; that completely covers the cleaning machine openings when in place; and is free of cracks, holes, and other defects. A continuous web part that completely occupies an entry or exit port when the machine is idle is considered to meet this requirement. (B) A reduced room draft as described in (e)(2)(ii). (C) Gasketed or leakproof doors that separate both the continuous web part feed reel and take up reel from the room atmosphere if the doors are checked according to the requirements of (e)(2)(iii). (D) A cleaning machine that is demonstrated to the Administrator's satisfaction to be under negative pressure during idling and downtime and is vented to a carbon adsorption system that meets the requirements of either (e)(2)(vii) or (g)(2). (ii) Each continuous web cleaning machine shall have a freeboard ratio of 0.75 or greater unless that cleaning machine is a remote reservoir continuous web cleaning machine. (iii) Each cleaning machine shall have an automated parts handling system capable of moving parts or parts baskets at a speed of 3.4 meters per minute (11 feet per minute) or less from the initial loading of parts through removal of cleaned parts, unless the cleaning machine is a continuous web cleaning machine that has a squeegee system or air knife system installed, maintained, and operated on the continuous web cleaning machine meeting the requirements of paragraph (e) of this section. (iv) Each vapor cleaning machine shall be equipped with a device that shuts off the sump heat if the sump liquid solvent level drops to the sump heater coils. This requirement does not apply to a vapor cleaning machine that uses steam to heat the solvent. (v) Each vapor cleaning machine shall be equipped with a vapor level control device that shuts off sump heat if the vapor level in the vapor cleaning machine rises above the height of the primary condenser. (vi) Each vapor cleaning machine shall have a primary condenser. (vii) Each cleaning machine that uses a lip exhaust or any other exhaust within the solvent cleaning machine shall be designed and operated to route all collected solvent vapors through a properly operated and maintained carbon adsorber that meets the requirements of either (e)(2)(vii) or (g)(2). [continued below] (g); Minn. R Page 28

29 What to do Continuous Web Cleaning Machines (except Remote Reservoir): [continued from above] (3) (i) Control air disturbances across the cleaning machine opening(s) by incorporating one of the following control equipment or techniques: (A) Cover(s) to each solvent cleaning machine shall be in place during the idling mode and during the downtime mode unless either the solvent has been removed from the machine or maintenance or monitoring is being performed that requires the cover(s) in place. A continuous web part that completely occupies an entry or exit port when the machine is idle is considered to meet this requirement. (B) A reduced room draft as described in (e)(2)(ii). (C) Gasketed or leakproof doors or covers that separate both the continuous web part feed reel and take up reel from the room atmosphere if the doors are checked according to the requirements of (e)(2)(iii) (D) A cleaning machine that is demonstrated to the Administrator's satisfaction to be under negative pressure during idling and downtime and is vented to a carbon adsorption system that meets either the requirements of 40 CFR Part (e)(2)(vii) or (g)(2). [continued below] (g); Minn. R Page 29

30 What to do Continuous Web Cleaning Machines (except Remote Reservoir): [continued from above] (3) (ii) Any spraying operations shall be conducted in a section of the solvent cleaning machine that is not directly exposed to the ambient air (i.e., a baffled or enclosed area of the solvent cleaning machine) or within a machine having a door or cover that meets the requirements of (g)(4)(i)(C). (iii) During startup of each vapor cleaning machine, the primary condenser shall be turned on before the sump heater. (iv) During shutdown of each vapor cleaning machine, the sump heater shall be turned off and the solvent vapor layer allowed to collapse before the primary condenser is turned off. (v) When solvent is added or drained from any solvent cleaning machine, the solvent shall be transferred using threaded or other leakproof couplings, and the end of the pipe in the solvent sump shall be located beneath the liquid solvent surface. (vi) Each solvent cleaning machine and associated controls shall be maintained as recommended by the manufacturers of the equipment or using alternative maintenance practices that have been demonstrated to the Administrator's satisfaction to achieve the same or better results as those recommended by the manufacturer. (vii) Waste solvent, still bottoms, sump bottoms, and waste absorbent materials used in the cleaning process for continuous web cleaning machines shall be collected and stored in waste containers. The closed containers may contain a device that would allow pressure relief, but would not allow liquid solvent to drain from the container. (viii) Except for absorbent materials used as part of the cleaning process of continuous web cleaning machines, including rollers and roller covers, sponges, fabric, wood, and paper products shall not be cleaned (g); Minn. R Page 30

31 What to do Remote Reservoir Continuous Web Cleaning Machines: When applicable, each cleaning machine shall meet the following work and operational practices requirements. (1) Install, maintain, and operate one of the following controls on each new remote reservoir continuous web cleaning machine. (i) Superheated vapor or superheated part technology. (ii) A carbon adsorber meeting the requirements of (e)(2)(vii). (iii) If a carbon adsorber system can be demonstrated to the Administrator's satisfaction to have an overall solvent control efficiency (i.e., capture efficiency removal efficiency) of 70 percent or greater, this system is equivalent to the options in s (h)(1)(i) and (h)(1)(ii). (2) (i) Each cleaning machine shall have an automated parts handling system capable of moving parts or parts baskets at a speed of 3.4 meters per minute (11 feet per minute) or less from the initial loading of parts through removal of cleaned parts, unless the cleaning machine is a continuous web cleaning machine that has a squeegee system or air knife system installed, maintained, and operated on the continuous web cleaning machine meeting the requirements of (e). (ii) Each vapor cleaning machine shall be equipped with a device that shuts off the sump heat if the sump liquid solvent level drops to the sump heater coils. (iii) Each vapor cleaning machine shall be equipped with a vapor level control device that shuts off sump heat if the vapor level in the vapor cleaning machine rises above the height of the primary condenser. (iv) Each vapor cleaning machine shall have a primary condenser. (v) Each cleaning machine that uses a lip exhaust or any other exhaust within the solvent cleaning machine shall be designed and operated to route all collected solvent vapors through a properly operated and maintained carbon adsorber that meets the requirements of either (e)(2)(vii) or (g)(2). [continued below] (h); Minn. R Page 31

32 What to do Remote Reservoir Continuous Web Cleaning Machines: [continued from above] (3) (i) Any spraying operations shall be conducted in a section of the solvent cleaning machine that is not directly exposed to the ambient air (i.e., a baffled or enclosed area of the solvent cleaning machine) or within a machine having a door or cover that meets the requirements of (g)(4)(i)(C). (ii) During startup of each vapor cleaning machine, the primary condenser shall be turned on before the sump heater. (iii) During shutdown of each vapor cleaning machine, the sump heater shall be turned off and the solvent vapor layer allowed to collapse before the primary condenser is turned off. (iv) When solvent is added or drained from any solvent cleaning machine, the solvent shall be transferred using threaded or other leakproof couplings, and the end of the pipe in the solvent sump shall be located beneath the liquid solvent surface. (v) Each solvent cleaning machine and associated controls shall be maintained as recommended by the manufacturers of the equipment or using alternative maintenance practices that have been demonstrated to the Administrator's satisfaction to achieve the same or better results as those recommended by the manufacturer. (vi) Waste solvent, still bottoms, sump bottoms, and waste absorbent materials used in the cleaning process for continuous web cleaning machines shall be collected and stored in waste containers. The closed containers may contain a device that would allow pressure relief, but would not allow liquid solvent to drain from the container. (vii) Except as provided in (h)(3)(viii), sponges, fabric, wood, and paper products shall not be cleaned. (viii) The prohibition on cleaning sponges, fabric, wood, and paper products does not apply to absorbent materials that are used as part of the cleaning process of continuous web cleaning machines, including rollers and roller covers (h); Minn. R Page 32

33 What to do Monitoring for Batch Vapor, In Line Vapor, and In Line Cold Cleaning Machines: (1) Conduct monitoring of each control device used as provided in (2) Determine during each monitoring period whether each control device used to comply with these standards meets the following requirements: (i) If a freeboard refrigeration device is used to comply with these standards, the owner or operator shall ensure that the chilled air blanket temperature (in F), measured at the center of the air blanket, is no greater than 30 percent of the solvent's boiling point. (ii) If a reduced room draft is used to comply with these standards, the owner or operator shall comply with the following requirements: (A) Ensure that the flow or movement of air across the top of the freeboard area of the solvent cleaning machine or within the solvent cleaning machine enclosure does not exceed 50 feet per minute at any time as measured using the procedures in (d). (B) Establish and maintain the operating conditions under which the wind speed was demonstrated to be 50 feet per minute or less as described in 40 CFR Section (d). (iii) If a working mode cover is used to comply with these standards, the owner or operator shall comply with the following requirements: (A) Ensure that the cover opens only for part entrance and removal and completely covers the cleaning machine openings when closed. (B) Ensure that the working mode cover is maintained free of cracks, holes, and other defects. (iv) If an idling mode cover is used to comply with these standards, the owner or operator shall comply with the following requirements: (A) Ensure that the cover is in place whenever parts are not in the solvent cleaning machine and completely covers the cleaning machine openings when in place. (B) Ensure that the idling mode cover is maintained free of cracks, holes, and other defects. [continued below] (e); Minn. R Page 33

34 What to do Monitoring for Batch Vapor, In Line Vapor, and In Line Cold Cleaning Machines: [continued from above] (2) (v) If a dwell is used to comply with these standards, the owner or operator shall comply with the following requirements: (A) Determine the appropriate dwell time for each type of part or parts basket, or determine the maximum dwell time using the most complex part type or parts basket, as described in (d). (B) Ensure that, after cleaning, each part is held in the solvent cleaning machine freeboard area above the vapor zone for the dwell time determined for that particular part or parts basket, or for the maximum dwell time determined using the most complex part type or parts basket. (vi) If a superheated vapor system is used to comply with these standards, the owner or operator shall comply with the following requirements: (A) Ensure that the temperature of the solvent vapor at the center of the superheated vapor zone is at least 10 F above the solvent's boiling point. (B) Ensure that the manufacturer's specifications for determining the minimum proper dwell time within the superheated vapor system is followed. (C) Ensure that parts remain within the superheated vapor for at least the minimum proper dwell time. (vii) If a carbon adsorber in conjunction with a lip exhaust or other exhaust internal to the cleaning machine is used to comply with these standards, the owner or operator shall comply with the following requirements: (A) Ensure that the concentration of organic solvent in the exhaust from this device does not exceed 100 parts per million of any halogenated HAP compound as measured using the procedure in (e). If the halogenated HAP solvent concentration in the carbon adsorber exhaust exceeds 100 parts per million, the owner or operator shall adjust the desorption schedule or replace the disposable canister, if not a regenerative system, so that the exhaust concentration of halogenated HAP solvent is brought below 100 parts per million. (B) Ensure that the carbon adsorber bed is not bypassed during desorption (C) Ensure that the lip exhaust is located above the solvent cleaning machine cover so that the cover closes below the lip exhaust level. [continued below] (e); Minn. R Page 34

35 What to do Monitoring for Batch Vapor, In Line Vapor, and In Line Cold Cleaning Machines: [continued from above] (2) (viii) If a superheated part system is used to comply with the standards for continuous web cleaning machines in (g) of this section, the owner or operator shall ensure that the temperature of the continuous web part is at least 10 degrees Fahrenheit above the solvent boiling point while the part is traveling through the cleaning machine. (ix) If a squeegee system is used to comply with the continuous web cleaning requirements of (g)(3)(iii) or (h)(2)(i), the owner or operator shall comply with the following requirements. (A) Determine the appropriate maximum product throughput for the squeegees used in the squeegee system, as described in (f). (B) Conduct the weekly monitoring required by (a)(3). Record the results required by (a)(6). (C) Calculate the total amount of continuous web product processed since the squeegees were replaced and compare to the maximum product throughput for the squeegees. (D) Ensure squeegees are replaced at or before the maximum product throughput is attained. (E) Redetermine the maximum product throughput for the squeegees if any solvent film is visible on the continuous web part immediately after it exits the cleaning machine. (x) If an air knife system is used to comply with the continuous web cleaning requirements of s (g)(3)(iii) or (h)(2)(i), the owner or operator shall comply with the following requirements. (A) Determine the air knife parameter and parameter value that demonstrate to the Administrator's satisfaction that the air knife is properly operating. An air knife is properly operating if no visible solvent film remains on the continuous web part after it exits the cleaning machine. (B) Maintain the selected air knife parameter value at the level determined in paragraph (a) of this section. (C) Conduct the weekly monitoring required by (a)(3). (D) Redetermine the proper air knife parameter value if any solvent film is visible on the continuous web part immediately after it exits the cleaning machine. [continued below] (e); Minn. R Page 35

36 What to do Monitoring for Batch Vapor, In Line Vapor, and In Line Cold Cleaning Machines: [continued from above] (2) (xi) If a combination squeegee and air knife system is used to comply with the continuous web cleaning requirements of s (g)(3)(iii) or (h)(2)(i), the owner or operator shall comply with the following requirements. (A) Determine the system parameter and value that demonstrate to the Administrator's satisfaction that the system is properly operating. (B) Maintain the selected parameter value at the level determined in paragraph (a) of this section. (C) Conduct the weekly monitoring required by (a)(3). (D) Redetermine the proper parameter value if any solvent film is visible on the continuous web part immediately after it exits the cleaning machine. (3) If any of the requirements of (e)(2) are not met, determine whether an exceedance has occurred using the following criteria: (i) An exceedance has occurred if the requirements of s (e)(2)(i)(B), (e)(2)(iii)(A), (e)(2)(iv)(A), (e)(2)(v), (e)(2)(vi)(B), (e)(2)(vi)(C), (e)(2)(vii)(B), or (e)(2)(vii)(C) have not been met. (ii) An exceedance has occurred if the requirements or (e)(2)(i), (e)(2)(ii)(A), (e)(2)(iii)(B), (e)(2)(iv)(B), (e)(2)(vi)(A), or (e)(2)(vii)(A) have not been met and are not corrected within 15 days of detection. Adjustments or repairs shall be made to the solvent cleaning system or control device to reestablish required levels. The parameter must be remeasured immediately upon adjustment or repair and demonstrated to be within required limits. (4) The owner or operator shall report all exceedances and all corrections and adjustments made to avoid an exceedance as specified in (h) (e); Minn. R Page 36

37 A Each individual batch vapor, in line vapor, in line cold, and batch cold solvent cleaning machine What to do Existing or New Machines: Each cleaning machine complying with equipment or idling standards shall monitor the hoist speed (HS) as described as follows: 1. Determine the HS by measuring the time it takes for the hoist to travel a measured distance. The speed is equal to the distance in meters divided by the time in minutes. 2. The monitoring shall be conducted monthly. If after the first 12 months, no exceedances are measured, the monitoring frequency may be changed to quarterly. 3. If an exceedance occurs during quarterly monitoring, the monitoring frequency shall return to monthly until another 12 months without an exceedance is demonstrated. 4. If the Permittee can demonstrate that the hoist cannot exceed a speed of 11 ft/min (3.4m/min) the HS monitoring shall be done each quarter at all times. Control Combination Options: The Permittee using a control combination option in Appendix C or complying with the idling emission limit shall maintain the following applicable records in written or electronic form for the lifetime of the machine: 1. Owner s manual, or if not available, written maintenance and operating procedures, for the solvent cleaning machine and control equipment. 2. Installation date of the solvent cleaning machine and all of its control devices. 3. If a dwell is used to show compliance with 40 CFR pt. 63, subp. T, the Permittee shall supply records of the tests required in (d) to determine dwell time for each part or parts basket. 4. Records of the halogenated HAP solvent content for each solvent used in the solvent cleaning machine. 5. (idling emission limit) records of the initial performance test, including the idling emission rate and values of the monitoring parameters measured during the test. 6. If a squeegee system is used to comply with these standards, records of the test required by (f) to determine the maximum product throughput for the squeegees and records of both the weekly monitoring required by (a)(3) for visual inspection and the length of continuous web product cleaned during the previous week. 7. If an air knife system or a combination squeegee and air knife system is used to comply with these standards, records of the determination of the proper operating parameter and parameter value for the air knife system (c); Minn. R (a); Minn. R Page 37

38 What to do Control Combination Options: The Permittee using a control options in Appendix C or complying with the idling emission limit shall maintain following applicable records in written or electronic form for a period of 5 years: 1. applicable monitoring and recordkeeping requirement in Table T1 in Appendix C of this permit; 2. information on the actions taken to comply with a selected control option or idling emission limit, which shall include records of written or verbal orders for replacement parts, a description of the repairs made, and additional monitoring conducted to demonstrate that monitored parameters have returned to accepted levels; 3. estimates of annual solvent consumption for each solvent cleaning machine; and 4. the weekly measurement of the halogenated HAP solvent concentration in the carbon adsorber exhaust. The Permittee shall use TF Series Forms (TF 01 through TF 09), as applicable, when submitting an initial notification report compliance report, exceedance report and annual report as mentioned below. Initial Notification Report for New Sources Only: Prior to construction or reconstruction of a new solvent cleaning machine, the Permittee shall submit an initial notification report as soon as practicable before the construction or reconstruction is planned to commence. Compliance Report for New Sources: must be submitted to the MPCA no later than 150 days after startup. Annual Report: Using Form TF 07, the Permittee shall submit an annual report by February 1 of the year following the one for which the report is being made. The Permittee shall submit all annual reports for halogenated solvent cleaning machines to both the MPCA and the EPA, as indicated on Form TF 07. Exceedance Report: Using Form TF 08, the Permittee shall submit an exceedance report semiannually. However, once an exceedance has occurred the Permittee shall submit the exceedance report 30 days following the end of that quarter. The Permittee shall submit all exceedance reports for halogenated solvent cleaning machines to both the MPCA and the EPA, as indicated on Form TF (b); Minn. R ; Minn. R ; Minn. R , subp (g); Minn. R (f); Minn. R (h); Minn. R Page 38

39 A Facility Wide Standards for facilities subject to 40 CFR pt. 63, subp. T For Facility Wide Standards, the affected facility means all solvent cleaning machines, except solvent cleaning machines used in the manufacture and maintenance of aerospace products, solvent cleaning machines used in the manufacture of narrow tubing, and continuous web cleaning machines, located at a major source that are subject to the facility wide limits in Table T4 of Appendix C to this permit. What to do Recordkeeping: The Permittee of an affected facility shall maintain a log of solvent additions and deletions for each solvent cleaning machine. General Provisions Appendix: This permit contains an appendix which lists the requirements of the general provisions in s 63.1 through 63.15, and shows which parts of the general provisions apply to sources subject to 40 CFR pt. 63, subp. T. The Permittee shall comply with all applicable requirements contained in the General Provisions Appendix (Appendix B). Facility Wide Emission Limits for Facilities With Solvent Cleaning Machines: The Permittee of an affected facility shall ensure that the total emissions of perchloroethylene (PCE), trichloroethylene (TCE) and methylene chloride (MC) used at the affected facility are equal to or less than the applicable facility wide 12 month rolling total emission limit presented in Table T4 of Appendix C to this permit as determined using the procedures in (c) (b)(1); Minn. R (b), Appendix B to 40 CFR pt. 63, subp. T; Minn. R ; Minn. R , subp (b)(2); Minn. R Page 39

40 What to do Monthly Calculations: The Permittee of an affected facility shall on the first operating day of every month, demonstrate compliance with the applicable facility wide 12 month rolling total emission limit presented in Table T4 of Appendix C to this permit, using the procedures in paragraphs (1) through (5). For the purposes of this requirement, each solvent cleaning machine means each solvent cleaning machine that is part of an affected facility regulated by (1) Each Permittee shall ensure that each solvent cleaning machine system contains only clean liquid solvent. This includes, but is not limited to, fresh unused solvent, recycled solvent, and used solvent that has been cleaned of soiled materials. The Permittee shall indicate a fill line during the first month the measurements are made. The Permittee shall return the solvent level within the machine to the same fill line each month, immediately prior to calculating monthly emissions as specified in paragraphs (2) and (3) of this requirement. The solvent cleaning machine does not have to be emptied and filled with fresh unused solvent prior to the calculations. (2) The Permittee shall determine solvent emissions (E unit ) from each solvent cleaning machine using the records of all solvent additions and deletions for the previous month and using Equation T2 of Appendix C to this permit. (3) The Permittee shall determine the total amount of halogenated HAP solvent removed from the solvent cleaning machine in solid waste during the most recent month (SSR i ), using one of the following methods: (i) From tests conducted using EPA reference method 25d; or (ii) By engineering calculations included in the compliance report. (4) After 12 months of emissions data are available, the Permittee shall determine the 12 month rolling total emissions for each solvent cleaning machine (ET unit ) for the 12 month period ending with the most recent month using Equation T4 of Appendix C to this permit. (5) After 12 months of emissions data are available, the Permittee shall determine the 12 month rolling total emissions for all cleaning machines at the facility (ET facility ) for the 12 month period ending with the most recent month using Equation T5 of Appendix C to this permit (c); Minn. R Page 40

41 What to do Recordkeeping: The Permittee of an affected facility shall maintain records specified in paragraphs (1) through (3) either in electronic or written form for a period of 5 years. For purposes of this paragraph, each solvent cleaning machine means each solvent cleaning machine that is part of an affected facility regulated. (1) The dates and amounts of solvent that are added to each solvent cleaning machine. (2) The solvent composition of wastes removed from each solvent cleaning machines as determined using the procedure described (c)(3). (3) Calculation sheets showing how monthly emissions and the 12 month rolling total emissions from each solvent cleaning machine were determined, and the results of all calculations. Exceedance Report: If the applicable facility wide emission limit presented in Table T4 in Appendix C to this permit is not met, an exceedance has occurred. All exceedances shall be reported as required in (h) using Form TF 08. The Permittee shall submit all exceedance reports for halogenated solvent cleaning machines to both the MPCA and the EPA, as indicated on Form TF 08. Annual Solvent Emission Report: The Permittee of an affected facility shall submit a solvent emission report every year. This solvent emission report shall contain the following: 1. The average monthly solvent consumption for the affected facility in kilograms per month. 2. The 12 month rolling total solvent emission estimates calculated each month using the method as described in (c). 3. This report can be combined with the annual report required in (f) and (g) (Form TF 07) into a single report for each facility. The Permittee shall submit all annual reports for halogenated solvent cleaning machines to both the MPCA and the EPA, as indicated on Form TF (e)(1) (e)(3); Minn. R (d); Minn. R (h)(1) (h)(3); Minn. R Page 41

42 A.3 Coating of parts (non Fiberglassing) Forms MG 05B6 and MG 05B8 The following are Minnesota Standards of Performance for Industrial Process Equipment A Booths: Spraying/Coating (non Fiberglassing) placed in operation before July 9, 1969 What to do Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20% opacity except for one six minute period per hour of not more than 60% opacity. Minn. R , subp. 1(A); Minn. R , subp. 1(B) A Booths: Spraying/Coating (non Fiberglassing) placed in operation on or after July 9, 1969 What to do Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R or Minn. R Minn. R , subp. 1(A); Opacity: less than or equal to 20% opacity. Minn. R , subp. 1(B) Page 42

43 The following are National Emission Standards for Hazardous Air Pollutants for Coating Operations A.3.2 Booths: Spraying/Coating (non Fiberglassing) Dip Tanks Subject to NESHAPs MMMM and/or PPPP If the Permittee owns or operates an affected source that meets the applicability criteria of either subparts MMMM or PPPP of 40 CFR pt. 63, and at the same facility also performs surface coating that meets the applicability criteria of the other subpart (PPPP or MMMM), the Permittee may elect to comply with these subparts as specified below: 1) The Permittee may have each surface coating operation that meets the applicability criteria of a separate NESHAP comply with that NESHAP separately. 2) The Permittee may comply with the emission limitation representing the predominant surface coating activity at the facility, as determined according to paragraphs (e)(2)(i) and (ii) of 40 CFR sections and However, the Permittee shall not establish high performance, rubber to metal, extreme performance fluoropolymer, assembled on road vehicle, or automotive lamp coating operations as the predominant activity. i) If a surface coating operation accounts for 90 percent or more of the surface coating activity at the facility (that is, the predominant activity), then compliance with the emission limits of the predominant activity for all surface coating operations constitutes compliance with both of these surface coating NESHAP (MMMM and PPPP). In determining predominant activity, the Permittee shall include coating activities that meet the applicability criteria of 40 CFR pt. 63, subps. MMMM or PPPP and constitute more than 1 percent of total coating activities at the facility. The Permittee shall include coating activities that meet the applicability criteria of either surface coating NESHAP but comprise less than 1 percent of coating activities in the compliance calculation, but is not required to include such activities in the determination of predominant activity. ii) The Permittee shall use gallons (gal) of solids used (for coating activities subject to MMMM) or pounds (lbs) of solids used (for activities subject to PPPP) as a measure of relative surface coating activity over a representative period of operation. The Permittee may estimate the relative volume (MMMM) or relative mass (PPPP) of coating solids used from parameters other than coating consumption and volume or mass solids content (e.g., design specification for the parts or products coated and the number of items produced). The determination of predominant activity shall accurately reflect current and project coating operations and shall be verifiable through appropriate documentation. The use of parameters other than coating consumption and volume or mass solids content must be approved by the Administrator. The Permittee may use data for any reasonable time period of at least 1 year in determining the relative amount of coating activity, as long as these data represent the way the source will continue to operate in the future and are approved by the Administrator. The Permittee shall determine the predominant activity at the facility and submit the results of that determination with the initial notification required by s (b) and (b). The Permittee shall also determine the predominant activity annually and include Page 43

44 the determination in the next semi annual compliance report required by s (a) and (a). 3) The Permittee may comply with a facility specific emission limit calculated from the relative amount of coating activity that is subject to each emission limit. If the Permittee elects to comply using the facilityspecific emission limit alternative, then compliance with the facility specific emission limit and the emission limitations in 40 CFR pt. 63, subps. MMMM or PPPP for all surface coating operations constitutes compliance with both of these surface coating NESHAP. The procedures for calculating the facility specific emission limit are specified in 40 CFR sections and In calculating a facility specific emission limit, the Permittee shall include coating activities that meet the applicability criteria of 40 CFR pt. 63, subps. MMMM or PPPP and constitute more than 1 percent of total coating activities at the facility. The Permittee shall include coating activities that meet the applicability criteria of either surface coating NESHAP but comprise less than 1 percent of coating activities in the compliance calculation, but is not required to include such activities in the determination of predominant activity. (Also see 40 CFR subsection (e) and 40 CFR subsection (e)) Page 44

45 The following are National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products (40 CFR pt. 63, subp. MMMM) A Booths: Spraying/Coating (non Fiberglassing) Dip Tanks Subject to NESHAP subp. MMMM Affected Source: The collection of all items listed below: 1) All coating operations as defined in 40 CFR section ; 2) All storage containers and mixing vessels in which coatings, thinners and/or other additives, and cleaning materials are stored or mixed; 3) All manual and automated equipment and containers used for conveying coatings, thinners and/or other additives, and cleaning materials; and 4) All storage containers and all manual and automated equipment and containers used for conveying waste materials generated by a coating operation. New Source: commenced construction or reconstruction after August 13, 2002 Existing Source: commenced construction or reconstruction on or before August 13, 2002 (Also see 40 CFR section (c)) Compliance dates: All compliance dates have passed for this standard. For existing affected sources, the compliance date was January 2, For new affected sources, the compliance date was January 2, 2004, or the date of initial startup of the affected source, whichever was later. (Also see 40 CFR section and 40 CFR sections 63.6(b) and (c)) The Permittee is subject to the requirements below if the Permittee owns or operates a new, reconstructed, or existing affected source that uses 250 gallons or more per year of coatings that contain hazardous air pollutants (HAP) in the surface coating of miscellaneous metal parts and products. The Permittee is not required to include coatings that meet the definition of non HAP coating contained in 40 CFR section in determining whether 250 gallons, or more, of coatings in the surface coating of miscellaneous metal parts and products is used. Definitions: (Also see 40 CFR section ) Miscellaneous metal parts and products include, but are not limited to: Metal components of the following types of products as well as the products themselves: motor vehicle parts and accessories, bicycles and sporting goods, recreational vehicles, extruded aluminum structural components, railroad cars, heavy duty trucks, medical equipment, lawn and garden equipment, electronic equipment, magnet wire, steel drums, industrial machinery, metal pipes, and numerous other industrial, household, and consumer products. Coating operation: Equipment used to apply cleaning materials to a substrate to prepare it for coating application (surface preparation) or to remove dried coating; to apply coating to a substrate (coating application) and to dry or cure the coating after the application; or to clean coating operation equipment (equipment cleaning). A single coating operation may include any combination of these types of equipment, but always includes at least the point at which a given quantity of coating or cleaning material is applied to a given part and all subsequent points in the affected source where organic HAP are emitted from the specific quantity of coating or Page 45

46 cleaning material on the specific part. There may be multiple coating operations in an affected source. Coating application with handheld, non refillable aerosol containers, touch up markers, or marking pens is not a coating operation for the purposes of 40 CFR pt. 63, subp. MMMM. General use coating: Any material that meets the definition of coating but does not meet the definition of high performance coating, rubber to metal coating, magnet wire coating, or extreme performance fluoropolymer coating as defined in 40 CFR section High performance coating: Any coating applied to architectural subsections which is required to meet the specifications of Architectural Aluminum Manufacturer s Association s publication number AAMA ; Any coating applied to a substrate which during normal use must withstand temperatures of at least 538 degrees Celsius (1000 degrees Fahrenheit). Magnet wire coatings (commonly referred to as magnet wire enamels): Coatings applied to a continuous strand of wire which will be used to make turns (windings) in electrical devices such as coils, transformers, or motors. Magnet wire coatings provide high dielectric strength and turn to turn conductor insulation. This allows the turns of an electrical device to be placed in close proximity to one another which leads to increased coil effectiveness and electrical efficiency. Rubber to metal coatings: Coatings that contain heat activated polymer systems in either solvent or water that, when applied to metal substrates, dry to a non tacky surface and react chemically with the rubber and metal during a vulcanization process. Extreme performance fluoropolymer coating: Coatings that are formulated systems based on fluoropolymer resins which often contain bonding matrix polymers dissolved in non aqueous solvents as well as other ingredients. Once applied to a substrate, extreme performance fluoropolymer coatings undergo a curing process that typically requires high temperatures, a chemical reaction, or other specialized technology. This rule does not cover the following, which are applicable to this permit: Extrusion of a plastic covering onto plastic parts of products to form a coating; and In mold coating operations or gel coating operations in the manufacture of reinforced plastic composite parts that meet the requirements of 40 CFR pt. 63, subp. WWWW. Page 46

47 What to do Based on the current and expected operations of the affected source, this permit only includes the compliant material option specified in (a) and the emission rate without add on controls option specified in (b). If the Permittee later chooses to switch to or add the other compliance options allowed in the standard, the Permittee shall comply with all applicable portions of 40 CFR pt. 63, subp. MMMM for those options. In addition, the Permittee shall apply for an individual Part 70 permit prior to making this switch. Unless otherwise noted, all equations for 40 CFR pt. 63, subp. MMMM referenced in the requirements for NESHAP subp. MMMM in this general permit can be found in Appendix D of this permit. HAP EMISSION LIMITS NEW SOURCE HAPs Organic: less than or equal to 1.9 lbs/gallon coating solids used during each 12 month compliance period for each new general use coating affected source. HAPs Organic: less than or equal to 27.5 lbs/gallon coating solids used during each 12 month compliance period for each new high performance coating affected source. HAPs Organic: less than or equal to 0.44 lbs/gallon coating solids used during each 12 month compliance period for each new magnet wire coating affected source. HAPs Organic: less than or equal to 6.8 lbs/gallon coating solids used during each 12 month compliance period for each new rubber to metal coating affected source. HAPs Organic: less than or equal to 12.4 lbs/gallon coating solids used during each 12 month compliance period for each new extreme performance fluoropolymer coating affected source. HAP EMISSION LIMITS EXISTING SOURCE HAPs Organic: less than or equal to 2.6 lbs/gallon coating solids used during each 12 month compliance period for each existing general use coating affected source. HAPs Organic: less than or equal to 27.5 lbs/gallon coating solids used during each 12 month compliance period for each existing high performance coating affected source. HAPs Organic: less than or equal to 1.0 lbs/gallon coating solids used during each 12 month compliance period for each existing magnet wire coating affected source ; Minn. R ; Minn. R , subp. 2 Minn. R , subp. 4 and 5 hdr (a)(1); Minn. R (a)(2); Minn. R (a)(3); Minn. R (a)(4); Minn. R (a)(5); Minn. R hdr (b)(1); Minn. R (b)(2); Minn. R (b)(3); Minn. R Page 47

48 What to do HAPs Organic: less than or equal to 37.7 lbs/gallon coating solids used during each 12 month compliance period for each existing rubber to metal coating affected source. HAPs Organic: less than or equal to 12.4 lbs/gallon coating solids used during each 12 month compliance period for each existing extreme performance fluoropolymer coating affected source. HAP EMISSION LIMITS NEW AND EXISTING SOURCES Emission limit alternatives: If the surface coating operations at the facility meet the applicability criteria for more than one of the subcategory emission limits specified above, the Permittee shall comply separately with each applicable subcategory emission limit, except that the Permittee may elect to comply using one of the following alternatives. Alternative 1 Facilities with surface coating operations that are predominantly either general use or magnet wire: If the general use or magnet wire surface coating operations subject to only one of the emission limits specified in 40 CFR paragraphs (a)(1), (b)(3), (b)(1), or (b)(3) account for 90 percent or more of the surface coating activity at the facility then compliance with that one emission limitation for all surface coating operations constitutes compliance with the other applicable emission limits. Refer to Appendix D for determining eligibility to use Alternative 1 to demonstrate compliance with the applicable emission limits. Alternative 2 Facility specific emission limit: The Permittee shall calculate and comply with a facility specific emission limit as described in Appendix D. If the Permittee elects to comply using the facility specific emission limit (Alternative 2), then compliance with the facility specific emission limit and the emission limitations in 40 CFR pt. 63, subp. MMMM for all surface coating operations constitutes compliance with this and other applicable surface coating NESHAP. OPERATIONAL REQUIREMENTS For any coating operation(s) on which the Permittee uses the compliant material option or the emission rate without add on controls option, the Permittee is not required to meet any operating limits. For any coating operation(s) on which the Permittee uses the compliant material option or the emission rate without add on controls option, the Permittee is not required to meet any work practice standards (b)(4); Minn. R (b)(5); Minn. R hdr (c); Minn. R hdr (a); Minn. R (a); Minn. R Page 48

49 What to do COMPLIANCE REQUIREMENTS Compliance Options: The Permittee shall include all coatings (as defined in 40 CFR Section ), thinners and/or other additives, and cleaning materials used in the affected source when determining whether the organic HAP emission rate is equal to or less than the applicable emission limit above. To make this determination, the Permittee shall use at least one of these two compliance options: compliant material option or emission rate without add on controls option. hdr s , , and ; Minn. R The Permittee shall use either the compliant materials option or the emission rate without add on controls option for every coating operation in the affected source. The Permittee shall not have any affected source coating operations that do not use one of these two compliance options. The Permittee may apply any of the compliance options to an individual coating operation, or to multiple coating operations as a group, or to the entire affected source. The Permittee may use different compliance options for different coating operations or at different times on the same coating operation. The Permittee may employ different compliance options when different coatings are applied to the same part, or when the same coating is applied to different parts. However, the Permittee may not use different compliance options at the same time on the same coating operation. If the Permittee switches between compliance options for any coating operation or group of coating operations, the Permittee shall document this switch as required by (c), and the Permittee shall report it in the next semiannual compliance report listed in Table B of this permit. The Permittee shall conduct a separate initial compliance demonstration for each general use, high performance, magnet wire, rubber to metal, and extreme performance fluoropolymer coating operation unless the Permittee has elected to comply with a predominant activity (Alternative 1) or facility specific emission limit (Alternative 2) as provided in (c). s , and ; Minn. R If the Permittee has elected to comply with one of these emission limit alternatives, the Permittee shall demonstrate that all coating operations included in the predominant activity determination or calculation of the facility specific emission limit comply with that limit. The Permittee shall comply with the emission limitations as specified below: 1) Any coating operation(s) for which the Permittee uses the compliant material option or the emission rate without add on controls option, as specified in 40 CFR Section (a) and (b), shall be in compliance with the HAP emission limit at all times. 2) The Permittee shall always operate and maintain the affected source according to the provisions in 63.6(e)(1)(i) (a)(1) and (b); Minn. R Page 49

50 What to do A compliance period consists of 12 months. Each month, after the end of the initial compliance period described in s and , is the end of a compliance period consisting of that month and the preceding 11 months. The initial compliance period described in s and has passed. The Permittee shall continue to use the subsequent compliance periods as described above. General Provisions Appendix: This permit contains an appendix which lists the requirements of the general provisions in s 63.1 through 63.15, and shows which parts of the general provisions apply to sources subject to 40 CFR pt. 63, subp. MMMM. The Permittee shall comply with all applicable requirements contained in the General Provisions Appendix (Appendix B). COMPLIANT MATERIAL OPTION REQUIREMENTS Compliant Material Option: The Permittee shall demonstrate that the organic HAP content of each coating used in the coating operation(s) is less than or equal to the applicable HAP emission limit(s), determined on a monthly basis; and that each thinner and/or other additive and cleaning material used contains no organic HAP. The Permittee shall meet all the requirements of s , , and to demonstrate compliance with the emission limit using this option. Compliance Demonstration: For each compliance period, the Permittee shall use no coating for which the organic HAP content (determined according to the Organic HAP Content requirement below) exceeds the applicable organic HAP emission limit in this permit, and use no thinner and/or other additive, or cleaning material that contains organic HAP, determined according to the requirements below. Facility Specific Emission Limit (Alternative 2): If the Permittee has elected to comply with a facility specific emission limit under (c), the Permittee shall also perform the calculation using Equation M1 in Appendix B on a monthly basis using the data from the previous 12 months of operation. s (a) and (a); Minn. R , Table 2 to 40 CFR pt. 63, subp. MMMM; Minn. R ; Minn. R , subp. 2 hdr (a); Minn. R s (a) and (e); Minn. R (a); Minn. R Page 50

51 What to do To demonstrate compliance with the Compliant Materials option, the Permittee shall use the procedures in the Compliant Material Option Requirements section of this permit on each coating, thinner and/or other additive, and cleaning material in the condition it is in when it is received from its manufacturer or supplier and prior to any alteration. The Permittee is not required to redetermine the organic HAP content of coatings, thinners and/or other additives, and cleaning materials that are reclaimed on site (or reclaimed off site if the Permittee has documentation showing that the Permittee received back the exact same materials that were sent off site) and reused in the coating operation for which the Compliant Materials option is used, provided these materials in their condition as received were demonstrated to comply with the compliant material option ; Minn. R Page 51

52 What to do Mass Fraction: The Permittee shall determine the mass fraction of organic HAP (pounds of organic HAP per pound of coating) for each coating, thinner and/or other additive, and cleaning material used during the compliance period by using one of the following options: s (a) and (a); Minn. R ) Method 311 (appendix A to 40 CFR pt. 63). The Permittee may use Method 311 for determining the mass fraction of organic HAP. To use Method 311, the Permittee shall: Count each organic HAP that is measured to be present at 0.1 percent by mass or more for Occupational Safety and Health Administration (OSHA) defined carcinogens as specified in 29 CFR Section (d)(4) and at 1.0 percent by mass or more for other compounds. Express the mass fraction of each organic HAP counted as a value truncated to four places after the decimal point. Calculate the total mass fraction of organic HAP in the test material by adding up the individual organic HAP mass fractions and truncating the result to three places after the decimal point; 2) Method 24 (appendix A to 40 CFR pt. 60). For coatings, the Permittee may use Method 24 to determine the mass fraction of nonaqueous volatile matter and use that value as a substitute for mass fraction of organic HAP. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may use the alternative method described in appendix A to 40 CFR pt. 63, subp. PPPP, rather than Method 24. The Permittee may use the volatile fraction that is emitted, as measured by the alternative method in appendix A to 40 CFR pt. 63, subp. PPPP, as a substitute for the mass fraction of organic HAP; 3) Alternative Method. The Permittee may use an alternative test method for determining the mass fraction of organic HAP once the Administrator has approved it. The Permittee shall follow the procedure in 63.7(f) to submit an alternative test method for approval; [continued below] Page 52

53 Mass Fraction: [continued from above] What to do 4) Information from the supplier or manufacturer of the material. The Permittee may rely on information other than that generated by items 1 3 above, such as manufacturer's formulation data, if it represents each organic HAP that is present in 0.1 percent by mass or more for OSHA defined carcinogens as specified in 29 CFR Section (d)(4) and at 1.0 percent by mass or more for the other compounds. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may rely on manufacturer's data that expressly states the organic HAP or volatile matter mass fraction emitted. If there is a disagreement between such information and the results of a test conducted according to items 1 3 above, then the test method results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct; or 5) Solvent blends. Solvent blends may be listed as single components for some materials in data provided by manufacturers or suppliers. Solvent blends may contain organic HAP which must be counted toward the total organic HAP mass fraction of the materials. When test data and manufacturer's data for solvent blends are not available, The Permittee may use the default values for the mass fraction of organic HAP in these solvent blends listed in Table 3 or 4 of Appendix D. If the tables are used, the Permittee shall use the values in Table 3 for all solvent blends that match the Table 3 entries according to the instructions for Table 3, and Table 4 may be used only if the solvent blends in the materials used do not match any of the solvent blends in Table 3 and it is known only whether the blend is aliphatic or aromatic. However, if the results of a Method 311 (appendix A to 40 CFR pt. 63) test indicate higher values than those listed in Tables 3 or 4, the Method 311 results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct. s (a) and (a); Minn. R Page 53

54 What to do Volume Fraction: The Permittee shall determine the volume fraction of coating solids (gallons of coating solids per gallons of coating) for each coating used during the compliance period as specified below. If test results obtained according to item 1 below do not agree with the information obtained under items 3 or 4 below, the test results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct. 1) ASTM Method D (reapproved 1998) or ASTM Method D (Reapproved 2003). The Permittee may use ASTM methods as specified in 40 CFR Section (b)(1) to determine the volume fraction of coating solids for each coating. The Permittee shall divide the nonvolatile volume percent obtained with the methods by 100 to calculate volume fraction of coating solids; 2) Alternative Method. The Permittee may use an alternative test method for determining the solids content of each coating once the Administrator has approved it. The Permittee shall follow the procedure in 63.7(f) to submit an alternative test method for approval; 3) Information from the supplier or manufacturer of the material. The Permittee may obtain the volume fraction of coating solids for each coating from the supplier or manufacturer; or (4) Calculation of volume fraction of coating solids. The Permittee may determine the volume fraction of coating solids by using Equation MC1 in Appendix D. Density: The Permittee shall determine the density of each coating used during the compliance period from test results using ASTM Method D , "Standard Test Method for Density of Liquid Coatings, Inks, and Related Products" (incorporated by reference, see 40 CFR 63.14), information from the supplier or manufacturer of the material, or specific gravity data for pure chemicals. If there is disagreement between ASTM Method D test results and the supplier's or manufacturer's information, the test results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct. Organic HAP Content: The Permittee shall calculate the organic HAP content, pounds of organic HAP emitted per gallon coating solids used, of each coating used during the compliance period using Equation MC2 in Appendix D. Deviation: The use of any coating, thinner and/or other additive, or cleaning material that does not meet the criteria specified in (a) is a deviation from the emission limitations. The Permittee shall report such a deviation as specified in s (c)(6) and (a)(5). s (b) and (a); Minn. R s (c) and (a); Minn. R s (d) and (a); Minn. R (b); Minn. R Page 54

55 What to do EMISSION RATE WITHOUT ADD ON CONTROLS OPTION REQUIREMENTS Emission Rate without Add on Controls Option: The Permittee shall demonstrate that, based on the coatings, thinners, and/or other additives, and cleaning materials used in the coating operation(s), the organic HAP emission rate for the coating operation(s) is less than or equal to the applicable HAP emission limit(s), calculated as a rolling 12 month emission rate and determined on a monthly basis. The Permittee shall meet all the requirements of s , , and to demonstrate compliance with the emission limit using this option. Compliance Demonstration: For each compliance period, the organic HAP emission rate, determined according to the following requirements ( (a) through (g)), shall be less than or equal to the applicable organic HAP emission limit for each subcategory in this permit or the predominant activity or facility specific emission limit allowed in (c). The Permittee shall perform the calculations in the Emission Rate without Add on Controls Option Requirements section of this permit on a monthly basis (by the 15 th of the month for the previous month) using data from the previous 12 months of operation. Facility Specific Emission Limit (Alternative 2): If the Permittee has elected to comply with a facility specific emission limit under (c), the Permittee shall also perform the calculation using Equation M1 in Appendix D on a monthly basis (by the 15 th of the month for the previous month) using the data from the previous 12 months of operation. To demonstrate compliance with the Emission Rate without Add On Controls option, the Permittee shall use the procedures below on each coating, thinner and/or other additive, and cleaning material used in the coating operations for which the emission rate without add on controls option is applied. When calculating the organic HAP emission rate according to this section, the Permittee shall not include any coatings, thinners and/or other additives, or cleaning materials used on coating operations for which the Permittee uses the compliant material option The Permittee is not required to re determine the organic HAP content of coatings, thinners and/or other additives, and cleaning materials that are reclaimed on site (or reclaimed off site if the Permittee has documentation showing that the Permittee received back the exact same materials that were sent off site) and reused in the coating operation for which the Emission Rate without Add On Controls option is used. If the affected source uses coatings, thinners and/or other additives, or cleaning materials that have been reclaimed on site, in the calculations the Permittee may reduce the amount of each used in a month by the amount of each that is reclaimed. hdr s (b) and (a); Minn. R s (a) and (h); Minn. R (a); Minn. R ; Minn. R Page 55

56 What to do Mass Fraction: By the 15 th of the month, the Permittee shall determine the mass fraction of organic HAP (pounds of organic HAP per pound of coating) for each coating, thinner and/or other additive, and cleaning material used during the previous month by using one of the following options: 1) Method 311 (appendix A to 40 CFR pt. 63). The Permittee may use Method 311 for determining the mass fraction of organic HAP. To use Method 311, count each organic HAP that is measured to be present at 0.1 percent by mass fraction or more for Occupational Safety and Health Administration (OSHA) defined carcinogens as specified in 29 CFR Section (d)(4) and at 1.0 percent by mass or more for other compounds. Express the mass fraction of each organic HAP counted as a value truncated to four places after the decimal point. Calculate the total mass fraction of organic HAP in the test material by adding up the individual organic HAP mass fractions and truncating the result to three places after the decimal point; 2) Method 24 (appendix A to 40 CFR pt. 60). For coatings, the Permittee may use Method 24 to determine the mass fraction of nonaqueous volatile matter and use that value as a substitute for mass fraction of organic HAP. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may use the alternative method described in appendix A to 40 CFR pt. 63, subp. PPPP, rather than Method 24. The Permittee may use the volatile fraction that is emitted, as measured by the alternative method in appendix A to 40 CFR pt. 63, subp. PPPP, as a substitute for the mass fraction of organic HAP; 3) Alternative Method. The Permittee may use an alternative test method for determining the mass fraction of organic HAP once the Administrator has approved it. The Permittee must follow the procedure in 63.7(f) to submit an alternative test method for approval; [continued below] s (a) and (a); Minn. R Page 56

57 Mass Fraction: [continued from above] What to do 4) Information from the supplier or manufacturer of the material. The Permittee may rely on information other than that generated by items 1 3 above, such as manufacturer's formulation data, if it represents each organic HAP that is present in 0.1 percent by mass or more for OSHA defined carcinogens as specified in 29 CFR Section (d)(4) and at 1.0 percent by mass or more for the other compounds. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may rely on manufacturer's data that expressly states the organic HAP or volatile matter mass fraction emitted. If there is a disagreement between such information and the results of a test conducted according to items 1 3 above, then the test method results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct; or 5) Solvent blends. Solvent blends may be listed as single components for some materials in data provided by manufacturers or suppliers. Solvent blends may contain organic HAP which must be counted toward the total organic HAP mass fraction of the materials. When test data and manufacturer's data for solvent blends are not available, The Permittee may use the default values for the mass fraction of organic HAP in these solvent blends listed in Table 3 or 4 of Appendix D. If the tables are used, the Permittee shall use the values in Table 3 for all solvent blends that match the Table 3 entries according to the instructions for Table 3, and Table 4 may be used only if the solvent blends in the materials used do not match any of the solvent blends in Table 3 and it is known only whether the blend is aliphatic or aromatic. However, if the results of a Method 311 (appendix A to 40 CFR pt. 63) test indicate higher values than those listed in Tables 3 or 4, the Method 311 results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct. s (a) and (a); Minn. R Page 57

58 What to do Volume Fraction: By the 15 th of the month, the Permittee shall determine the volume fraction of coating solids (gallons of coating solids per gallons of coating) for each coating used during the previous month as specified below. If test results obtained according to item 1 below do not agree with the information obtained under items 3 or 4 below, the test results will take precedence unless, after consultation, the Permittee can demonstrate to the satisfaction of the Agency that the formulation data are correct. 1) ASTM Method D (reapproved 1998) or ASTM Method D (Reapproved 2003). The Permittee may use ASTM methods as specified in 40 CFR Section (b)(1) to determine the volume fraction of coating solids for each coating. The Permittee shall divide the nonvolatile volume percent obtained with the methods by 100 to calculate volume fraction of coating solids; 2) Alternative Method. The Permittee may use an alternative test method for determining the solids content of each coating once the Administrator has approved it. The Permittee must follow the procedure in 63.7(f) to submit an alternative test method for approval; 3) Information from the supplier or manufacturer of the material. The Permittee may obtain the volume fraction of coating solids for each coating from the supplier or manufacturer; or (4) Calculation of volume fraction of coating solids. The Permittee may determine the volume fraction of coating solids by using Equation MC1 in Appendix D. Density of Each Material: By the 15 th of the month, the Permittee shall determine the density of each liquid coating, thinner and/or additive, and cleaning material used during the previous month from test results using ASTM Method D , "Standard Test Method for Density of Liquid Coatings, Inks, and Related Products" (incorporated by reference, see 40 CFR 63.14), information from the supplier or manufacturer of the material, or reference sources providing density or specific gravity data for pure materials. If there is disagreement between ASTM Method D or ASTM Method D test results and other information sources, the test results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct. If the Permittee includes powder coatings in this compliance determination option, the Permittee shall determine the density of powder coatings, using ASTM Method D , Standard Test Methods for Specific Gravity of Coating Powers (incorporated by reference, see 40 CFR 63.14), or information from the supplier. If the Permittee purchases materials or monitors consumption by weight instead of volume, the Permittee is not required to determine material density. Instead, the Permittee may use the material weight in place of the combined terms for density and volume in Equations ME1a, ME1b, ME1c, and ME2 in Appendix D. s (b) and (a); Minn. R s (c) and (a); Minn. R Page 58

59 What to do Volume of Each Material: By the 15 th of the month, the Permittee shall determine the volume (gallons) of each coating, thinner and/or other additive, and cleaning material used during the previous month by measurement or usage records. If the Permittee purchases materials or monitors consumption by weight instead of volume, the Permittee is not required to determine the volume of each material used. Instead, the Permittee may use the material weight in place of the combined terms for density and volume in Equations ME1a, ME1b, ME1c, and ME2 in Appendix D. Organic HAP Emissions: The organic HAP emissions is the combined mass of organic HAP contained in all coatings, thinners and/or other additives, and cleaning materials used during the previous month minus the organic HAP in certain waste materials. By the 15 th of the month, the Permittee shall calculate the mass of organic HAP emissions for the previous month, using Equation ME1 in Appendix D. Total Volume Used: By the 15 th of the month, the Permittee shall determine the total volume of coating solids used, gallons, which is the combined volume of coating solids for all the coatings used during the previous month, using Equation ME2 in Appendix D. Organic HAP Emission Rate: By the 15 th of the month, the Permittee shall calculate the organic HAP emission rate for the previous month and for the rolling compliance period (lb organic HAP emitted per gallon coating solids used) using Equation ME3 in Appendix D. Deviation: If the organic HAP emission rate for any 12 month compliance period exceeds the applicable HAP emission limit, this is a deviation from the emission limitation for that compliance period. The Permittee shall report such a deviation as specified in s (c)(6) and (a)(6). s (d) and (a); Minn. R s (e) and (a); Minn. R s (f) and (a); Minn. R s (g) and (a); Minn. R (b); Minn. R Page 59

60 What to do RECORDKEEPING The Permittee shall collect and keep records of each of the data and information items specified below. Failure to collect and keep these records is a deviation from the applicable standard. 1) A copy of each notification and report that the Permittee submitted to comply with 40 CFR pt. 63, subp. MMMM, and the documentation supporting each notification and report. If the Permittee uses the predominant activity alternative under 40 CFR (c), the Permittee shall keep records of the data and calculations used to determine the predominant activity for each 12 month compliance period included in the semi annual compliance reports. If the Permittee uses the facility specific emission limit alternative under 40 CFR Section (c), the Permittee shall keep records of the data used to calculate the facility specific emission limit for the initial compliance demonstration and for each 12 month compliance period included in the semiannual compliance reports. 2) A current copy of information provided by materials suppliers or manufacturers, such as manufacturer's formulation data, or test data used to determine the mass fraction of organic HAP and density for each coating, thinner and/or other additive, and cleaning material, and the volume fraction of coating solids for each coating. If the Permittee conducted testing to determine mass fraction of organic HAP, density, or volume fraction of coating solids, the Permittee shall keep a copy of the complete test report. If the Permittee uses information provided by the manufacturer or supplier of the material that was based on testing, the Permittee shall keep the summary sheet of results provided to the Permittee by the manufacturer or supplier. The Permittee is not required to obtain the test report or other supporting documentation from the manufacturer or supplier. [continued below] hdr , 40 CFR Sections (d) and (d); Minn. R Page 60

61 [continued from above] What to do 3) For each compliance period, the records specified below: A record of the coating operations on which the Permittee used each compliance option and the time periods (beginning and ending dates and times) for each option the Permittee used; For the compliant material option, a record of the calculation of the organic HAP content for each coating, using Equation MC2; and For the emission rate without add on controls option, a record of the calculation of the total mass of organic HAP emissions for the coatings, thinners and/or other additives, and cleaning materials used each month using Equations ME1, ME1a, ME1b, ME1c, and ME2; and if applicable, the calculation used to determine mass of organic HAP in waste materials according to 40 CFR Section (e)(4); and the calculation of the total volume of coating solids used each month using Equation ME2; and the calculation of each 12 month organic HAP emission rate using Equation ME3. 4) A record of the name and volume of each coating, thinner and/or other additive, and cleaning material used during each compliance period. If the Permittee uses the compliant material option for all coatings at the source, the Permittee may elect to maintain purchase records for each material used rather than a record of the volume used. 5) A record of the mass fraction of organic HAP for each coating, thinner and/or other additive, and cleaning material used during each compliance period unless the material is tracked by weight; 6) A record of the volume fraction of coating solids for each coating used during each compliance period; 7) If the Permittee uses the emission rate without add on controls, the density for each coating, thinner and/or other additive, and cleaning material used during each compliance period; [continued below] , 40 CFR Sections (d) and (d); Minn. R Page 61

62 [continued from above] What to do 8) If the Permittee uses an allowance in Equation ME1 for organic HAP contained in waste materials according to (e)(4), the Permittee shall keep the following records: The name and address of each TSDF to which the Permittee sent waste materials for which the Permittee uses an allowance in Equation ME1 in Appendix D of this permit; a statement of which subparts under 40 CFR parts 262, 264, 265, and 266 apply to the facility; and the date of each shipment; Identification of the coating operations producing waste materials included in each shipment and the month or months in which the Permittee used the allowance for these materials in Equation ME1; The methodology used in accordance with (e)(4) to determine the total amount of waste materials sent to or the amount collected, stored, and designated for transport to a TSDF each month; and the methodology to determine the mass of organic HAP contained in these waste materials. This shall include the sources for all data used in the determination, methods used to generate the data, frequency of testing or monitoring, and supporting calculations and documentation, including the waste manifest for each shipment. 9) The Permittee shall keep records of the date, time, and duration of each deviation. The Permittee shall keep all required records in a form suitable and readily available for expeditious review, according to 63.10(b)(1). Where appropriate, the records may be maintained as electronic spreadsheets or as a database. As specified in 63.10(b)(1), the Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The Permittee shall keep each record on site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record according to 63.10(b)(1). The Permittee may keep the records off site for the remaining 3 years. REPORTING AND SUBMITTALS The Permittee shall meet the notification requirements in according to the dates specified in that section and in 40 CFR pt. 63, subp. A. Some of the notifications are due before the compliance dates described in 40 CFR paragraphs (a) (c) , 40 CFR Sections (d) and (d); Minn. R , 40 CFR Sections (e) (h), 40 CFR Sections (d) (d); Minn. R hdr ; Minn. R Page 62

63 What to do General: The Permittee shall submit the applicable notifications in 40 CFR sections 63.7(b) & (c), 63.8(f)(4), and 63.9(b) (e) & (h), by the dates specified in those sections, except as provided in the Initial Notification and Notification of Compliance Status requirements below. The requirements for these sections are listed in the General Provisions Appendix to this permit (Appendix B). Initial Notification: i) For a new or reconstructed affected source: due by 120 days after initial startup or by May 1, 2004, whichever is later. ii) For an existing affected source: due by January 2, If the Permittee is complying with another NESHAP that constitutes the predominant activity at the facility under 40 CFR section (e)(2) to constitute compliance with 40 CFR pt. 63, subp. MMMM for metal parts coating operations, then the Permittee shall include a statement to this effect in the initial notification (a); Minn. R (b), 40 CFR Section 63.9(b); Minn. R Page 63

64 What to do Notification of Compliance Status: due 30 days after 1/31/08. The Permittee shall submit this notification to EPA. The report shall contain the following information as well as the information specified in 63.9(h): 1) Company name and address; 2) Statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report; 3) Date of the report and beginning and ending dates of the reporting period. The reporting period is the initial compliance period described in s , , or that applies to the affected source; 4) Identification of the compliance option or options specified in that were used on each coating operation in the affected source during the initial compliance period; 5) Statement of whether or not the affected source achieved the emission limitations for the initial compliance period; 6) If the Permittee had a deviation, the Permittee shall include the following information: A description and statement of the cause of the deviation. If the Permittee failed to meet the HAP emission limit, the Permittee shall include all the calculations used to determine the lb of organic HAP emitted per gal coating solids used. The Permittee is not required to submit information provided by the materials' suppliers or manufacturers, or test reports; 7) For each of the data items listed below, include an example of how the Permittee determined the value, including calculations and supporting data. Supporting data may include a copy of the information provided by the supplier or manufacturer of the example coating or material, or a summary of the results of testing conducted according to 40 CFR sections (a), (b), or (c). The Permittee is not required to submit copies of any test reports. Mass fraction of organic HAP for one coating, for one thinner and/or other additive, and for one cleaning material. Volume fraction of coating solids for one coating. Density for one coating, one thinner and/or other additive, and one cleaning material, except that if the Permittee uses the compliant material option, only the example coating density is required. The amount of waste materials and the mass of organic HAP contained in the waste materials for which the Permittee claims an allowance in Equation ME1; [continued below] s (b) and (c); Minn. R Page 64

65 What to do Notification of Compliance Status: [continued from above] 8) The calculation of lb of organic HAP emitted per gal coating solids used for the compliance option used, as specified below. For the compliant material option, the Permittee shall provide an example calculation of the organic HAP content for one coating, using Equation MC2. For the emission rate without add on controls option, the Permittee shall provide the calculation of the total mass of organic HAP emissions for each month; the calculation of the total volume of coating solids used each month; and the calculation of the 12 month organic HAP emission rate using Equations ME1, ME1a, ME1b, ME1c, ME2, and ME3, respectively; 9) If the Permittee is complying with a single emission limit representing the predominant activity under 40 CFR paragraph (c)(1), the Permittee shall include the calculations and supporting information used to demonstrate that this emission limit represents the predominant activity as specified in paragraph (c)(1); and 10) If the Permittee is complying with a facility specific emission limit under 40 CFR paragraph (c)(2), the Permittee shall include the calculation of the facility specific emission limit and any supporting information as specified in paragraph (c)(2). If the Permittee is complying with another NESHAP that constitutes the predominant activity at the facility under 40 CFR paragraph (e)(2) to constitute compliance with 40 CFR pt. 63, subp. MMMM for metal parts coating operations, then the Permittee shall include a statement to this effect in the initial notification, and no other notifications are required under this subpart in regard to those metal parts coating operations. s (b) and (c); Minn. R Page 65

66 What to do Semiannual Compliance Report: due 31 days after the end of each calendar half year starting 02/01/2008, for each affected source. The report shall contain the information specified below. The Permittee may submit this report with the Semiannual Deviations Report also listed in Table B of this permit. Content of semiannual compliance report: At a minimum, the report shall include: 1) Company name and address; 2) Statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report; 3) Date of report and beginning and ending dates of the reporting period. The reporting period is the 6 month period ending on June 30 or December 31. Note that the information reported for each of the 6 months in the reporting period will be based on the last 12 months of data prior to the date of each monthly calculation; 4) Identification of the compliance option or options specified in that the Permittee used on each coating operation during the reporting period. If the Permittee switched between compliance options during the reporting period, the Permittee shall report the beginning and ending dates for each option the Permittee used. 5) If the Permittee used the emission rate without add on controls ( (b)), the Permittee shall include the calculation results for each rolling 12 month organic HAP emission rate during the 6 month reporting period; 6) If the Permittee used the predominant activity alternative ( (c)(1)), the Permittee shall include the annual determination of predominant activity if it was not included in the previous semiannual compliance report; 7) If the Permittee used the facility specific emission limit alternative (40 CFR Section (c)(2)), the Permittee shall include the calculation of the facilityspecific emission limit for each 12 month compliance period during the 6 month reporting period; and 8) Whether any deviations occurred during the reporting period, according to the Deviation Reporting requirement below (a), 40 CFR Sections (c) and (c); Minn. R Page 66

67 What to do Deviation Reporting for semiannual compliance report: The semiannual compliance report shall contain the following deviation reporting information: 1) If there were no deviations from the applicable HAP emission limit, the Permittee shall include in the semiannual compliance report a statement that there were no deviations during the reporting period, as well as the following information: Compliant material option: If the Permittee used the compliant material option and there were no deviations from the applicable HAP emission limit, the Permittee shall submit a statement that the coating operation(s) was (were) in compliance with the emission limitations during the reporting period because the Permittee used no coatings for which the organic HAP content exceeded the applicable HAP emission limit, and the Permittee used no thinner and/or other additive, or cleaning material that contained organic HAP, determined according to (a). Emission rate without add on controls option: If the Permittee used the compliant material option and there were no deviations from the applicable HAP emission limit, the Permittee shall submit a statement that the coating operation(s) was (were) in compliance with the emission limitations during the reporting period because the organic HAP emission rate for each compliance period was less than or equal to the applicable HAP emission limit, determined according to s (a) through (g); and [continued below] s (a)(4) (6), 40 CFR Sections (c) and (c); Minn. R Page 67

68 What to do Deviation Reporting for semiannual compliance report: [continued from above] 2) If there was a deviation from the applicable HAP emission limit, the semiannual compliance report shall contain the following information: Compliant material option: If the Permittee used the compliant material option and there was a deviation from the applicable organic HAP content requirement in , the semiannual compliance report shall contain the following information: (i) Identification of each coating used that deviated from the applicable emission limit, and each thinner and/or other additive, and cleaning material used that contained organic HAP, and the dates and time periods each was used; (ii) The calculation of the organic HAP content (using Equation MC2 for reach coating identified in paragraph (i) above. The Permittee is not required to submit background data supporting this calculation; (iii) The determination of mass fraction of organic HAP for each thinner and/or other additive, and cleaning material identified in paragraph (i) above. The Permittee is not required to submit background data supporting this calculation; and (iv) A statement of the cause of each deviation. Emission rate without add on controls option: If the Permittee used the emission rate without add on controls option and there was a deviation from the applicable organic HAP emission limit in , the semiannual compliance report shall contain the following information: (i) The beginning and ending dates of each compliance period during which the 12 month organic HAP emission rate exceeded the applicable HAP emission limit; (ii) The calculations used to determine the 12 month organic HAP emission rate for the compliance period in which the deviation occurred. The Permittee shall submit the calculations for Equations ME1, ME1a, ME1b, ME1c, ME2, and ME3; and if applicable, the calculation used to determine mass of organic HAP in waste materials according to 40 CFR paragraph (e)(4). The Permittee is not required to submit background data supporting these calculations; and (iii) A statement of the cause of each deviation. s (a)(4) (6), 40 CFR Sections (c) and (c); Minn. R Page 68

69 What to do Alternative 1 reporting: If the Permittee elects to comply with Emission Limits new and existing sources using Alternative 1, the Permittee shall determine the predominant surface coating activity at the facility and submit the results of that determination with the initial notification required by section (b). Additionally, the Permittee shall determine the facility's predominant activity annually and include the determination in the next semi annual compliance report required by section (a). Alternative 2 reporting: If the Permittee elects to comply with Emission Limits new and existing sources using Alternative 2, the Permittee shall calculate the facilityspecific emission limit when the Permittee submits the notification of compliance status required in 40 CFR section (c), and on a monthly basis afterward using the coating data for the relevant 12 month compliance period (c)(1); Minn. R (c)(2)(i); Minn. R Page 69

70 The following are National Emission Standards for Hazardous Air Pollutants for Surface Coating of Plastic Parts and Products (40 CFR pt. 63, subp. PPPP) A Booths: Spraying/Coating (non Fiberglassing) Dip Tanks Subject to NESHAP subp. PPPP Affected Source: The collection of all items listed below: 1) All coating operations as defined in 40 CFR section ; 2) All storage containers and mixing vessels in which coatings, thinners and/or other additives, and cleaning materials are stored or mixed; 3) All manual and automated equipment and containers used for conveying coatings, thinners and/or other additives, and cleaning materials; and 4) All storage containers and all manual and automated equipment and containers used for conveying waste materials generated by a coating operation. New Source: commenced construction or reconstruction after December 4, 2002 Existing Source: commenced construction or reconstruction on or before December 4, 2002 (Also see 40 CFR section (c)) Compliance dates: All compliance dates have passed for this standard. For existing affected sources, the compliance date was April 19, For new affected sources, the compliance date was April 19, 2004, or the date of initial startup of the affected source, whichever was later. The Permittee is subject to the requirements below if the Permittee owns or operates a new, reconstructed, or existing affected source that uses 100 gallons or more per year of coatings that contain hazardous air pollutants (HAP) in the surface coating of plastic parts and products. The Permittee is not required to include coatings that meet the definition of non HAP coating contained in 40 CFR section in determining whether 100 gallons, or more, of coatings in the surface coating of plastic parts and products is used. Definitions: (Also see 40 CFR section ) Plastic part and product: Any piece or combination of pieces of which at least one has been formed from one or more resins. Such pieces may be solid, porous, flexible or rigid. Plastic parts and products include, but are not limited to: Plastic components of the following types of products as well as the products themselves: motor vehicle parts and accessories for automobiles, trucks, recreational vehicles; sporting and recreational goods; toys; business machines; laboratory and medical equipment; and household and other consumer products. Coating operation: Equipment used to apply cleaning materials to a substrate to prepare it for coating application (surface preparation) or to remove dried coating; to apply coating to a substrate (coating application) and to dry or cure the coating after the application; or to clean coating operation equipment (equipment cleaning). A single coating operation may include any combination of these types of equipment, but always includes at least the point at which a given quantity of coating or cleaning material is applied to a given part and all subsequent points in the affected source where organic HAP are emitted from the specific quantity of coating or cleaning material on the specific part. There may be multiple coating operations in an affected Page 70

71 source. Coating application with handheld, non refillable aerosol containers, touch up markers, or marking pens is not a coating operation for the purposes of 40 CFR pt. 63, subp. PPPP. TPO coating (thermoplastic olefin coating): Any coating operation in which the coatings are components of a system of coatings applied to a TPO substrate, including adhesion promoters, primers, color coatings, clear coatings and topcoats. Thermoplastic olefin coating does not include the coating of TPO substrates on assembled on road vehicles. General use coating: Any coating operation that is not an automotive lamp, TPO, or assembled on road vehicle coating operation. Automotive lamp coating: Any coating operation in which coating is applied to the surface of some component of the body of an exterior automotive lamp, including the application of reflective argent coatings and clear topcoats. Exterior automotive lamps include head lamps, tail lamps, turn signals, brake lights, and side marker lights. Automotive lamp coating does not include any coating operation performed on an assembled on road vehicle. Assembled on road vehicle coatings: Any coating operation in which coating is applied to the surface of some component or surface of a fully assembled motor vehicle or trailer intended for on road use including, but not limited to, components or surfaces on automobiles and light duty trucks that have been repaired after a collision or otherwise repainted, fleet delivery trucks, and motor homes and other recreational vehicles (including camping trailers and fifth wheels). Assembled on road vehicle coating includes the concurrent coating of parts of the assembled on road vehicle that are painted off vehicle to protect systems, equipment, or to allow full coverage. Assemble don road vehicle coating does not include surface coating operations that meet the applicability criteria of the Automobiles and Light Duty Trucks NESHAP. Assembled onroad vehicle coating also does not include the use of adhesives, sealants, and caulks used in assembling on road vehicles. This rule does not cover the following, which are applicable to this permit: Extrusion of a plastic covering onto plastic parts of products to form a coating; and In mold coating operations or gel coating operations in the manufacture of reinforced plastic composite parts that meet the requirements of 40 CFR pt. 63, subp. WWWW. Page 71

72 What to do Based on the current and expected operations of the affected source, this permit only includes the compliant material option specified in (a) and the emission rate without add on controls option specified in (b). If the Permittee later chooses to switch to or add the other compliance options allowed in the standard, the Permittee shall comply with all applicable portions of 40 CFR pt. 63, subp. PPPP for those options. In addition, the Permittee shall apply for an individual Part 70 permit prior to making this switch. Unless otherwise noted, all equations for 40 CFR pt. 63, subp. PPPP referenced in the requirements for NESHAP subp. PPPP in this general permit can be found in Appendix E of this permit. HAP EMISSION LIMITS NEW SOURCE HAPs Organic: less than or equal to 0.16 lb/lb coating solids used during each 12 month compliance period for each new general use coating affected source. HAPs Organic: less than or equal to 0.26 lb/lb coating solids used during each 12 month compliance period for each automotive lamp coating affected source. HAPs Organic: less than or equal to 0.22 lb/lb coating solids used during each 12 month compliance period for each new TPO coating affected source. HAPs Organic: less than or equal to 1.34 lb/lb coating solids used during each 12 month compliance period for each new assembled on road vehicle coating affected source. HAP EMISSION LIMITS EXISTING SOURCE HAPs Organic: less than or equal to 0.16 lb/lb coating solids used during each 12 month compliance period for each existing general use coating affected source. HAPs Organic: less than or equal to 0.45 lb/lb coating solids used during each 12 month compliance period for each existing automotive lamp coating affected source. HAPs Organic: less than or equal to 0.26 lb/lb coating solids used during each 12 month compliance period for each existing TPOcoating affected source. HAPs Organic: less than or equal to 1.34 lb/lb coating solids used during each 12 month compliance period for each existing assembled on road vehicle coating affected source ; Minn. R ; Minn. R , subp. 2 Minn. R , subp. 4 and 5 hdr (a)(1); Minn. R (a)(2); Minn. R (a)(3); Minn. R (a)(4); Minn. R hdr (b)(1); Minn. R (b)(2); Minn. R (b)(3); Minn. R (b)(4); Minn. R Page 72

73 What to do HAP EMISSION LIMITS NEW AND EXISTING SOURCES Emission limit alternatives: If the surface coating operations at the facility meet the applicability criteria for more than one of the subcategory emission limits specified above, the Permittee shall comply separately with each applicable subcategory emission limit, except that the Permittee may elect to comply using one of the following alternatives. Alternative 1 Facilities with surface coating operations that are predominantly either general use or TPO: If the general use or TPO surface coating operations subject to only one of the emission limits specified in 40 CFR paragraphs (a)(1), (b)(3), (b)(1), or (b)(3) account for 90 percent or more of the surface coating activity at the facility then compliance with that emission limitation for all surface coating operations constitutes compliance with the other applicable emission limits. Refer to Appendix E for determining eligibility to use Alternative 1 to demonstrate compliance with the applicable emission limits. Alternative 2 Facility specific emission limit: The Permittee shall calculate and comply with a facility specific emission limit as described in Appendix E. If the Permittee elects to comply using the facility specific emission limit (Alternative 2), then compliance with the facility specific emission limit and the emission limitations in 40 CFR pt. 63, subp. PPPP for all surface coating operations constitutes compliance with this and other applicable surface coating NESHAP. OPERATIONAL REQUIREMENTS For any coating operation(s) on which the Permittee uses the compliant material option or the emission rate without add on controls option, the Permittee is not required to meet any operating limits. For any coating operation(s) on which the Permittee uses the compliant material option or the emission rate without add on controls option, the Permittee is not required to meet any work practice standards. hdr (c); Minn. R hdr (a); Minn. R (a); Minn. R Page 73

74 What to do COMPLIANCE REQUIREMENTS Compliance Options: The Permittee shall include all coatings (as defined in 40 CFR Section ), thinners and/or other additives, and cleaning materials used in the affected source when determining whether the organic HAP emission rate is equal to or less than the applicable emission limit above. To make this determination, the Permittee shall use at least one of these two compliance options: compliant material option or emission rate without add on controls option. hdr s , , and ; Minn. R The Permittee shall use either the compliant materials option or the emission rate without add on controls option for every coating operation in the affected source. The Permittee shall not have any affected source coating operations that do not use one of these two compliance options. The Permittee may apply any of the compliance options to an individual coating operation, or to multiple coating operations as a group, or to the entire affected source. The Permittee may use different compliance options for different coating operations or at different times on the same coating operation. The Permittee may employ different compliance options when different coatings are applied to the same part, or when the same coating is applied to different parts. However, the Permittee may not use different compliance options at the same time on the same coating operation. If the Permittee switches between compliance options for any coating operation or group of coating operations, the Permittee shall document this switch as required by (c), and the Permittee shall report it in the next semiannual compliance report listed in Table B of this permit. The Permittee shall conduct a separate initial compliance demonstration for each general use coating, TPO coating, automotive lamp coating, and assembled on road vehicle coating affected source unless the Permittee has elected to comply with a predominant activity (Alternative 1) or facility specific emission limit (Alternative 2) as provided in (c). s , and ; Minn. R If the Permittee has elected to comply with one of these emission limit alternatives, the Permittee shall demonstrate that all coating operations included in the predominant activity determination or calculation of the facility specific emission limit comply with that limit. The Permittee shall comply with the emission limitations as specified below: 1) Any coating operation(s) for which the Permittee uses the compliant material option or the emission rate without add on controls option, as specified in 40 CFR Section (a) and (b), shall be in compliance with the HAP emission limit at all times. 2) The Permittee shall always operate and maintain the affected source according to the provisions in 63.6(e)(1)(i) (a)(1) and (b); Minn. R Page 74

75 What to do A compliance period consists of 12 months. Each month, after the end of the initial compliance period described in s and , is the end of a compliance period consisting of that month and the preceding 11 months. The initial compliance period described in s and has passed. The Permittee shall continue to use the subsequent compliance periods as described above. General Provisions Appendix: This permit contains an appendix which lists the requirements of the general provisions in s 63.1 through 63.15, and shows which parts of the general provisions apply to sources subject to 40 CFR pt. 63, subp. PPPP. The Permittee shall comply with all applicable requirements contained in the General Provisions Appendix (Appendix B). COMPLIANT MATERIAL OPTION REQUIREMENTS Compliant Material Option: The Permittee shall demonstrate that the organic HAP content of each coating used in the coating operation(s) is less than or equal to the applicable HAP emission limit(s), and determined on a monthly basis; and that each thinner and/or other additive and cleaning material used contains no organic HAP. The Permittee shall meet all the requirements of s , , and to demonstrate compliance with the emission limit using this option. Compliance Demonstration: For each compliance period, the Permittee shall use no coating for which the organic HAP content (determined according to the Organic HAP Content requirement below) exceeds the applicable organic HAP emission limit in this permit, and use no thinner and/or other additive, or cleaning material that contains organic HAP, determined according to the requirements below. Facility Specific Emission Limit (Alternative 2): If the Permittee has elected to comply with a facility specific emission limit under (c), the Permittee shall also perform the calculation using Equation M1 in Appendix E on a monthly basis using the data from the previous 12 months of operation. s (a) and (a); Minn. R , Table 2 to 40 CFR pt. 63, subp. PPPP; Minn. R ; Minn. R , subp. 2 hdr (a); Minn. R s (a) and (e); Minn. R (a); Minn. R Page 75

76 What to do To demonstrate compliance with the Compliant Materials option, the Permittee shall use the procedures in the Compliant Material Option Requirements section of this permit on each coating, thinner and/or other additive, and cleaning material in the condition it is in when it is received from its manufacturer or supplier and prior to any alteration ; Minn. R The Permittee is not required to redetermine the organic HAP content of coatings, thinners and/or other additives, and cleaning materials that are reclaimed on site (or reclaimed off site if the Permittee has documentation showing that the Permittee received back the exact same materials that were sent off site) and reused in the coating operation for which the Compliant Materials option is used, provided these materials in their condition as received were demonstrated to comply with the compliant material option. Mass Fraction of Organic HAP: The Permittee shall determine the mass fraction of organic HAP (pounds of organic HAP per pound of coating) for each coating, thinner and/or other additive, and cleaning material used during the compliance period by using one of the following options: s (a) and (a); Minn. R ) Method 311 (appendix A to 40 CFR pt. 63). The Permittee may use Method 311 for determining the mass fraction of organic HAP. To use Method 311, the Permittee shall: Count each organic HAP that is measured to be present at 0.1 percent by mass or more for Occupational Safety and Health Administration (OSHA) defined carcinogens as specified in 29 CFR Section (d)(4) and at 1.0 percent by mass or more for other compounds. Express the mass fraction of each organic HAP counted as a value truncated to four places after the decimal point. Calculate the total mass fraction of organic HAP in the test material by adding up the individual organic HAP mass fractions and truncating the result to three places after the decimal point; 2) Method 24 (appendix A to 40 CFR pt. 60). For coatings, the Permittee may use Method 24 to determine the mass fraction of nonaqueous volatile matter and use that value as a substitute for mass fraction of organic HAP. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may use the alternative method described in appendix A to 40 CFR pt. 63, subp. PPPP, rather than Method 24. The Permittee may use the volatile fraction that is emitted, as measured by the alternative method in appendix A to 40 CFR pt. 63, subp. PPPP, as a substitute for the mass fraction of organic HAP; 3) Alternative Method. The Permittee may use an alternative test method for determining the mass fraction of organic HAP once the Administrator has approved it. The Permittee shall follow the procedure in 63.7(f) to submit an alternative test method for approval; Page 76

77 What to do 4) Information from the supplier or manufacturer of the material. The Permittee may rely on information other than that generated by items 1 3 above, such as manufacturer's formulation data, if it represents each organic HAP that is present in 0.1 percent by mass or more for OSHA defined carcinogens as specified in 29 CFR Section (d)(4) and at 1.0 percent by mass or more for the other compounds. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may rely on manufacturer's data that expressly states the organic HAP or volatile matter mass fraction emitted. If there is a disagreement between such information and the results of a test conducted according to items 1 3 above, then the test method results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct; or 5) Solvent blends. Solvent blends may be listed as single components for some materials in data provided by manufacturers or suppliers. Solvent blends may contain organic HAP which must be counted toward the total organic HAP mass fraction of the materials. When test data and manufacturer's data for solvent blends are not available, The Permittee may use the default values for the mass fraction of organic HAP in these solvent blends listed in Table 3 or 4 of Appendix E. If the tables are used, the Permittee shall use the values in Table 3 for all solvent blends that match the Table 3 entries according to the instructions for Table 3, and Table 4 may be used only if the solvent blends in the materials used do not match any of the solvent blends in Table 3 and it is known only whether the blend is aliphatic or aromatic. However, if the results of a Method 311 (appendix A to 40 CFR pt. 63) test indicate higher values than those listed in Tables 3 or 4, the Method 311 results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct. Page 77

78 What to do Mass Fraction of Coating Solids: The Permittee shall determine the mass fraction of coating solids (pounds of coating solids per pounds of coating) for each coating used during the compliance period by using one of the following options: 1) Method D (appendix A to 40 CFR part 60). The Permittee shall use Method 24 for determining the mass fraction of coating solids. For reactive adhesives in which some of the liquid fraction reacts to form solids, the Permittee may use the alternative method contained in appendix A to 40 CFR pt. 63, subp. PPPP, rather than Method 24, to determine the mass fraction of coating solids. 2) Alternative Method. The Permittee may use an alternative test method for determining the solids content of each coating once the Administrator has approved it. The Permittee shall follow the procedure in 63.7(f) to submit an alternative test method for approval; or 3) Information from the supplier or manufacturer of the material. The Permittee may obtain the mass fraction of coating solids for each coating from the supplier or manufacturer. If there is disagreement between such information and the test method results, then the test method results will take precedence unless, after consultation the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct. Organic HAP Content: The Permittee shall calculate the organic HAP content, pounds of organic HAP emitted per pound coating solids used, of each coating used during the compliance period using Equation PC1 in Appendix E. Deviation: The use of any coating, thinner and/or other additive, or cleaning material that does not meet the criteria specified in (a) is a deviation from the emission limitations. The Permittee shall report such a deviation as specified in s (c)(6) and (a)(5). EMISSION RATE WITHOUT ADD ON CONTROLS OPTION REQUIREMENTS Emission Rate without Add on Controls Option: The Permittee shall demonstrate that, based on the coatings, thinners, and/or other additives, and cleaning materials used in the coating operation(s), the organic HAP emission rate for the coating operation(s) is less than or equal to the applicable HAP emission limit(s), calculated as a rolling 12 month emission rate and determined on a monthly basis. The Permittee shall meet all the requirements of s , , and to demonstrate compliance with the emission limit using this option. s (b) and (a); Minn. R s (c) and (a); Minn. R (b); Minn. R hdr s (b) and (a); Minn. R Page 78

79 What to do Compliance Demonstration: For each compliance period, the organic HAP emission rate, determined according to the following requirements ( (a) through (g)), shall be less than or equal to the applicable organic HAP emission limit for each subcategory in this permit or the predominant activity or facility specific emission limit allowed in (c). The Permittee shall perform the calculations in the Emission Rate without Add on Controls Option Requirements section of this permit on a monthly basis (by the 15 th of the month for the previous month) using data from the previous 12 months of operation. Facility Specific Emission Limit (Alternative 2): If the Permittee has elected to comply with a facility specific emission limit under (c), the Permittee shall also perform the calculation using Equation P1 in Appendix E on a monthly basis (by the 15 th of the month for the previous month) using the data from the previous 12 months of operation. To demonstrate compliance with the Emission Rate without Add On Controls option, the Permittee shall use the procedures below on each coating, thinner and/or other additive, and cleaning material used in the coating operations for which the emission rate without add on controls option is used. When calculating the organic HAP emission rate according to this section, the Permittee shall not include any coatings, thinners and/or other additives, or cleaning materials used on coating operations for which the Permittee uses the compliant material option. The Permittee is not required to redetermine the organic HAP content of coatings, thinners and/or other additives, and cleaning materials that are reclaimed on site (or reclaimed off site if the Permittee has documentation showing that the Permittee received back the exact same materials that were sent off site) and reused in the coating operation for which the Emission Rate without Add On Controls option is used. If the affected source uses coatings, thinners and/or other additives, or cleaning materials that have been reclaimed on site, in the calculations the Permittee may reduce the amount of each used in a month by the amount of each that is reclaimed. s (a) and (h); Minn. R (a); Minn. R ; Minn. R Page 79

80 What to do Mass Fraction of Organic HAP: By the 15 th of the month, the Permittee shall determine the mass fraction of organic HAP (pounds of organic HAP per pound of coating) for each coating, thinner and/or other additive, and cleaning material used during the previous month by using one of the following options: s (a) and (a); Minn. R ) Method 311 (appendix A to 40 CFR pt. 63). The Permittee may use Method 311 for determining the mass fraction of organic HAP. To use Method 311, the Permittee shall: Count each organic HAP that is measured to be present at 0.1 percent by mass or more for Occupational Safety and Health Administration (OSHA) defined carcinogens as specified in 29 CFR Section (d)(4) and at 1.0 percent by mass or more for other compounds. Express the mass fraction of each organic HAP counted as a value truncated to four places after the decimal point. Calculate the total mass fraction of organic HAP in the test material by adding up the individual organic HAP mass fractions and truncating the result to three places after the decimal point; 2) Method 24 (appendix A to 40 CFR pt. 60). For coatings, the Permittee may use Method 24 to determine the mass fraction of nonaqueous volatile matter and use that value as a substitute for mass fraction of organic HAP. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may use the alternative method described in appendix A to 40 CFR pt. 63, subp. PPPP, rather than Method 24. The Permittee may use the volatile fraction that is emitted, as measured by the alternative method in appendix A to 40 CFR pt. 63, subp. PPPP, as a substitute for the mass fraction of organic HAP; 3) Alternative Method. The Permittee may use an alternative test method for determining the mass fraction of organic HAP once the Administrator has approved it. The Permittee shall follow the procedure in 63.7(f) to submit an alternative test method for approval; [continued below] Page 80

81 What to do Mass Fraction of Organic HAP: [continued from above] 4) Information from the supplier or manufacturer of the material. The Permittee may rely on information other than that generated by items 1 3 above, such as manufacturer's formulation data, if it represents each organic HAP that is present in 0.1 percent by mass or more for OSHA defined carcinogens as specified in 29 CFR Section (d)(4) and at 1.0 percent by mass or more for the other compounds. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may rely on manufacturer's data that expressly states the organic HAP or volatile matter mass fraction emitted. If there is a disagreement between such information and the results of a test conducted according to items 1 3 above, then the test method results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct; or 5) Solvent blends. Solvent blends may be listed as single components for some materials in data provided by manufacturers or suppliers. Solvent blends may contain organic HAP which must be counted toward the total organic HAP mass fraction of the materials. When test data and manufacturer's data for solvent blends are not available, The Permittee may use the default values for the mass fraction of organic HAP in these solvent blends listed in Table 3 or 4 of Appendix E. If the tables are used, the Permittee shall use the values in Table 3 for all solvent blends that match the Table 3 entries according to the instructions for Table 3, and Table 4 may be used only if the solvent blends in the materials used do not match any of the solvent blends in Table 3 and it is known only whether the blend is aliphatic or aromatic. However, if the results of a Method 311 (appendix A to 40 CFR pt. 63) test indicate higher values than those listed in Tables 3 or 4, the Method 311 results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct. s (a) and (a); Minn. R Page 81

82 What to do Mass Fraction of Coating Solids: By the 15 th of the month, the Permittee shall determine the mass fraction of coating solids (pounds of coating solids per pounds of coating) for each coating used during the previous month by using one of the following options: 1) Method D (appendix A to 40 CFR part 60). The Permittee shall use Method 24 for determining the mass fraction of coating solids. For reactive adhesives in which some of the liquid fraction reacts to form solids, the Permittee may use the alternative method contained in appendix A to 40 CFR pt. 63, subp. PPPP, rather than Method 24, to determine the mass fraction of coating solids. 2) Alternative Method. The Permittee may use an alternative test method for determining the solids content of each coating once the Administrator has approved it. The Permittee shall follow the procedure in 63.7(f) to submit an alternative test method for approval; or 3) Information from the supplier or manufacturer of the material. The Permittee may obtain the mass fraction of coating solids for each coating from the supplier or manufacturer. If there is disagreement between such information and the test method results, then the test method results will take precedence unless, after consultation the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct. Density of Each Material: By the 15 th of the month, the Permittee shall determine the density of each liquid coating, thinner and/or additive, and cleaning material used during the previous month from test results using ASTM Method D , "Standard Test Method for Density of Liquid Coatings, Inks, and Related Products" (incorporated by reference, see 40 CFR 63.14), information from the supplier or manufacturer of the material, or reference sources providing density or specific gravity data for pure materials. If there is disagreement between ASTM Method D and other such information sources, the test results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct. If the Permittee purchases materials or monitors consumption by weight instead of volume, the Permittee is not required to determine material density. Instead, the Permittee may use the material weight in place of the combined terms for density and volume in Equations PE1a, PE1b, PE1c, and PE2 in Appendix E. Volume of Each Material: By the 15 th of the month, the Permittee shall determine the volume (gallons) of each coating, thinner and/or other additive, and cleaning material used during the previous month by measurement or usage records. If the Permittee purchases materials or monitors consumption by weight instead of volume, the Permittee is not required to determine the volume of each material used. Instead, the Permittee may use the material weight in place of the combined terms for density and volume in Equations PE1a, PE1b, PE1c, and PE2 in Appendix E. s (b) and (a); Minn. R s (c) and (a); Minn. R s (d) and (a); Minn. R Page 82

83 What to do Mass of Organic HAP Emissions: The mass of organic HAP emissions is the combined mass of organic HAP contained in all coatings, thinners and/or other additives, and cleaning materials used during each month minus the organic HAP in certain waste materials. By the 15 th of the month, the Permittee shall calculate the mass of organic HAP emissions for the previous month, using Equation PE1 in Appendix E. Total Mass of Coating Solids: By the 15 th of the month, the Permittee shall determine the total mass of coating solids used, lb mass, which is the combined mass of coating solids for all the coatings used during the previous month, using Equation PE2 in Appendix E. Organic HAP Emission Rate: By the 15 th of the month, the Permittee shall calculate the organic HAP emission rate for the previous month and for the rolling compliance period (lb organic HAP emitted per lb coating solids used) using Equation PE3 in Appendix E. Deviation: If the organic HAP emission rate for any 12 month compliance period exceeds the applicable HAP emission limit, this is a deviation from the emission limitation for that compliance period. The Permittee shall report such a deviation as specified in s (c)(6) and (a)(6). s (e) and (a); Minn. R s (f) and (a); Minn. R s (g) and (a); Minn. R (b); Minn. R Page 83

84 What to do RECORDKEEPING The Permittee shall collect and keep records of each of the data and information items specified below. Failure to collect and keep these records is a deviation from the applicable standard. 1) A copy of each notification and report that the Permittee submitted to comply with 40 CFR pt. 63, subp. PPPP, and the documentation supporting each notification and report. If the Permittee uses the predominant activity alternative under 40 CFR (c), the Permittee shall keep records of the data and calculations used to determine the predominant activity for each 12 month compliance period included in the semi annual compliance reports. If the Permittee uses the facility specific emission limit alternative under 40 CFR Section (c), the Permittee shall keep records of the data used to calculate the facility specific emission limit for the initial compliance demonstration and for each 12 month compliance period included in the semiannual compliance reports. 2) A current copy of information provided by materials suppliers or manufacturers, such as manufacturer's formulation data, or test data used to determine the mass fraction of organic HAP and density for each coating, thinner and/or other additive, and cleaning material, and the volume fraction of coating solids for each coating. If the Permittee conducted testing to determine mass fraction of organic HAP, density, or mass fraction of coating solids, the Permittee shall keep a copy of the complete test report. If the Permittee uses information provided by the manufacturer or supplier of the material that was based on testing, the Permittee shall keep the summary sheet of results provided to the Permittee by the manufacturer or supplier. The Permittee is not required to obtain the test report or other supporting documentation from the manufacturer or supplier. [continued below] hdr , 40 CFR Sections (d) and (d); Minn. R Page 84

85 [continued from above] What to do 3) For each compliance period, the records specified below: A record of the coating operations on which the Permittee used each compliance option and the time periods (beginning and ending dates and times) for each option the Permittee used; For the compliant material option, a record of the calculation of the organic HAP content for each coating, using Equation PC2; and For the emission rate without add on controls option, a record of the calculation of the total mass of organic HAP emissions for the coatings, thinners and/or other additives, and cleaning materials used each month using Equations PE1, PE1a, PE1b, PE1c, and PE2; and if applicable, the calculation used to determine mass of organic HAP in waste materials according to 40 CFR Section (e)(4); and the calculation of the total mass of coating solids used each month using Equation PE2; and the calculation of each 12 month organic HAP emission rate using Equation PE3. 4) A record of the name and mass of each coating, thinner and/or other additive, and cleaning material used during each compliance period. If the Permittee uses the compliant material option for all coatings at the source, the Permittee may elect to maintain purchase records for each material used rather than a record of the volume used. 5) A record of the mass fraction of organic HAP for each coating, thinner and/or other additive, and cleaning material used during each compliance period; 6) A record of the mass fraction of coating solids for each coating used during each compliance period; [continued below] , 40 CFR Sections (d) and (d); Minn. R Page 85

86 [continued from above] What to do 7) If the Permittee uses an allowance in Equation PE1 for organic HAP contained in waste materials according to (e)(4), the Permittee shall keep the following records: The name and address of each TSDF to which the Permittee sent waste materials for which the Permittee uses an allowance in Equation PE1 in Appendix E of this permit; a statement of which subparts under 40 CFR parts 262, 264, 265, and 266 apply to the facility; and the date of each shipment; Identification of the coating operations producing waste materials included in each shipment and the month or months in which the Permittee used the allowance for these materials in Equation PE1; The methodology used in accordance with (e)(4) to determine the total amount of waste materials sent to or the amount collected, stored, and designated for transport to a TSDF each month; and the methodology to determine the mass of organic HAP contained in these waste materials. This shall include the sources for all data used in the determination, methods used to generate the data, frequency of testing or monitoring, and supporting calculations and documentation, including the waste manifest for each shipment. 8) The Permittee shall keep records of the date, time, and duration of each deviation. The Permittee shall keep all required records in a form suitable and readily available for expeditious review, according to 63.10(b)(1). Where appropriate, the records may be maintained as electronic spreadsheets or as a database. As specified in 63.10(b)(1), the Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The Permittee shall keep each record on site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record according to 63.10(b)(1). The Permittee may keep the records off site for the remaining 3 years. REPORTING AND SUBMITTALS The Permittee shall meet the notification requirements in according to the dates specified in that section and in 40 CFR pt. 63, subp. A. Some of the notifications are due before the compliance dates described in 40 CFR paragraphs (a) (c) , 40 CFR Sections (d) and (d); Minn. R , 40 CFR Sections (d) (h), 40 CFR Sections (d) (d); Minn. R hdr ; Minn. R Page 86

87 What to do General: The Permittee shall submit the applicable notifications in 40 CFR sections 63.7(b) & (c), 63.8(f)(4), and 63.9(b) (e) & (h), by the dates specified in those sections, except as provided in the Initial Notification and Notification of Compliance Status requirements below. The requirements for these sections are listed in the General Provisions Appendix to this permit (Appendix B). Initial Notification: iii) For a new or reconstructed affected source: due by 120 days after initial startup or by August 17, 2004, whichever is later. iv) For an existing affected source: due by April 19, If the Permittee is complying with another NESHAP that constitutes the predominant activity at the facility under 40 CFR paragraph (e)(2) to constitute compliance with 40 CFR pt. 63, subp. PPPP for plastic parts coating operations, then the Permittee shall include a statement to this effect in the initial notification (a); Minn. R (b), 40 CFR Section 63.9(b); Minn. R Page 87

88 What to do Notification of Compliance Status: due 30 days after 4/30/08, or as specified in 40 CFR section (c) for new or reconstructed sources. The report shall contain the following information as well as the information specified in 63.9(h): 1) Company name and address; 2) Statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report; 3) Date of the report and beginning and ending dates of the reporting period. The reporting period is the initial compliance period described in s , , or that applies to the affected source; 4) Identification of the compliance option or options specified in that were used on each coating operation in the affected source during the initial compliance period; 5) Statement of whether or not the affected source achieved the emission limitations for the initial compliance period; 6) If the Permittee had a deviation, the Permittee shall include the following information: A description and statement of the cause of the deviation. If the Permittee failed to meet the HAP emission limit, the Permittee shall include all the calculations used to determine the lb of organic HAP emitted per lb coating solids used. The Permittee is not required to submit information provided by the materials' suppliers or manufacturers, or test reports; 7) For each of the data items listed below, include an example of how the Permittee determined the value, including calculations and supporting data. Supporting data may include a copy of the information provided by the supplier or manufacturer of the example coating or material, or a summary of the results of testing conducted according to 40 CFR sections (a), (b), or (c). The Permittee is not required to submit copies of any test reports. Mass fraction of organic HAP for one coating, for one thinner and/or other additive, and for one cleaning material. Volume fraction of coating solids for one coating. Density for one coating, one thinner and/or other additive, and one cleaning material, except that if the Permittee uses the compliant material option, only the example coating density is required. The amount of waste materials and the mass of organic HAP contained in the waste materials for which the Permittee claims an allowance in Equation PE1; [continued below] s (b) and (c); Minn. R Page 88

89 What to do Notification of Compliance Status: [continued from above] 8) The calculation of lb of organic HAP emitted per lb coating solids used for the compliance option used, as specified below. For the compliant material option, the Permittee shall provide an example calculation of the organic HAP content for one coating, using Equation PC1. For the emission rate without add on controls option, the Permittee shall provide the calculation of the total mass of organic HAP emissions for each month; the calculation of the total mass of coating solids used each month; and the calculation of the 12 month organic HAP emission rate using Equations PE1, PE1a, PE1b, PE1c, PE2, and PE3, respectively; 9) If the Permittee is complying with a single emission limit representing the predominant activity under 40 CFR paragraph (c)(1), the Permittee shall include the calculations and supporting information used to demonstrate that this emission limit represents the predominant activity as specified in paragraph (c)(1); and 10) If the Permittee is complying with a facility specific emission limit under 40 CFR paragraph (c)(2), the Permittee shall include the calculation of the facility specific emission limit and any supporting information as specified in paragraph (c)(2). If the Permittee is complying with another NESHAP that constitutes the predominant activity at the facility under 40 CFR paragraph (e)(2) to constitute compliance with 40 CFR pt. 63, subp. PPPP for plastic parts coating operations, then the Permittee shall include a statement to this effect in the initial notification, and no other notifications are required under this subpart in regard to those metal parts coating operations. s (b) and (c); Minn. R Page 89

90 What to do Semiannual Compliance Report: due 31 days after the end of each calendar half year starting 05/01/2008, for each affected source. The report shall contain the information specified below. The Permittee may submit this report with the Semiannual Deviations Report also listed in Table B of this permit. Content of semiannual compliance report: At a minimum, the report shall include: 1) Company name and address; 2) Statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report; 3) Date of report and beginning and ending dates of the reporting period. The reporting period is the 6 month period ending on June 30 or December 31. Note that the information reported for each of the 6 months in the reporting period will be based on the last 12 months of data prior to the date of each monthly calculation; 4) Identification of the compliance option or options specified in that the Permittee used on each coating operation during the reporting period. If the Permittee switched between compliance options during the reporting period, the Permittee shall report the beginning and ending dates for each option the Permittee used. 5) If the Permittee used the emission rate without add on controls ( (b)), the Permittee shall include the calculation results for each rolling 12 month organic HAP emission rate during the 6 month reporting period; 6) If the Permittee used the predominant activity alternative ( (c)(1)), the Permittee shall include the annual determination of predominant activity if it was not included in the previous semiannual compliance report; 7) If the Permittee used the facility specific emission limit alternative (40 CFR Section (c)(2)), the Permittee shall include the calculation of the facilityspecific emission limit for each 12 month compliance period during the 6 month reporting period; and 8) Whether any deviations occurred during the reporting period, according to the Deviation Reporting requirement below (a), 40 CFR Sections (c) and (c); Minn. R Page 90

91 What to do Deviation Reporting for semiannual compliance report: The semiannual compliance report shall contain the following deviation reporting information: 1) If there were no deviations from the applicable HAP emission limit, the Permittee shall include in the semiannual compliance report a statement that there were no deviations during the reporting period, as well as the following information: Compliant material option: If the Permittee used the compliant material option and there were no deviations from the applicable HAP emission limit, the Permittee shall submit a statement that the coating operation(s) was (were) in compliance with the emission limitations during the reporting period because the Permittee used no coatings for which the organic HAP content exceeded the applicable HAP emission limit, and the Permittee used no thinner and/or other additive, or cleaning material that contained organic HAP, determined according to (a). Emission rate without add on controls option: If the Permittee used the compliant material option and there were no deviations from the applicable HAP emission limit, the Permittee shall submit a statement that the coating operation(s) was (were) in compliance with the emission limitations during the reporting period because the organic HAP emission rate for each compliance period was less than or equal to the applicable HAP emission limit, determined according to s (a) through (g); and [continued below] s (a)(4) (6), 40 CFR Sections (c) and (c), 40 CFR Sections (d) and (d); Minn. R Page 91

92 What to do Deviation Reporting for semiannual compliance report: [continued from above] 2) If there was a deviation from the applicable HAP emission limit, the semiannual compliance report shall contain the following information: Compliant material option: If the Permittee used the compliant material option and there was a deviation from the applicable organic HAP content requirement in , the semiannual compliance report shall contain the following information: (v) Identification of each coating used that deviated from the applicable emission limit, and each thinner and/or other additive, and cleaning material used that contained organic HAP, and the dates and time periods each was used; (vi) The calculation of the organic HAP content (using Equation PC1 for each coating identified in paragraph (i) above. The Permittee is not required to submit background data supporting this calculation; (vii) The determination of mass fraction of organic HAP for each thinner and/or other additive, and cleaning material identified in paragraph (i) above. The Permittee is not required to submit background data supporting this calculation; and (viii) A statement of the cause of each deviation. Emission rate without add on controls option: If the Permittee used the emission rate without add on controls option and there was a deviation from the applicable organic HAP emission limit in , the semiannual compliance report shall contain the following information: (iv) The beginning and ending dates of each compliance period during which the 12 month organic HAP emission rate exceeded the applicable HAP emission limit; (v) The calculations used to determine the 12 month organic HAP emission rate for the compliance period in which the deviation occurred. The Permittee shall submit the calculations for Equations PE1, PE1a, PE1b, PE1c, PE2, and PE3; and if applicable, the calculation used to determine mass of organic HAP in waste materials according to 40 CFR paragraph (e)(4). The Permittee is not required to submit background data supporting these calculations; and (vi) A statement of the cause of each deviation. s (a)(4) (6), 40 CFR Sections (c) and (c), 40 CFR Sections (d) and (d); Minn. R Page 92

93 What to do Alternative 1 reporting: If the Permittee elects to comply with Emission Limits new and existing sources using Alternative 1, the Permittee shall determine the predominant surface coating activity at the facility and submit the results of that determination with the initial notification required by section (b). Additionally, the Permittee shall determine the facility's predominant activity annually and include the determination in the next semi annual compliance report required by section (a). Alternative 2 reporting: If the Permittee elects to comply with Emission Limits new and existing sources using Alternative 2, the Permittee shall calculate the facilityspecific emission limit when the Permittee submits the notification of compliance status required in 40 CFR section (c), and on a monthly basis afterward using the coating data for the relevant 12 month compliance period (c)(1); Minn. R (c)(2)(i); Minn. R Page 93

94 A.4 Fiberglass Operations Form MG 05B7 The following are Minnesota Standards of Performance for Industrial Process Equipment A.4.1 Fiberglass Operations placed in operation before July 9, 1969 What to do Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20% opacity except for one six minute period per hour of not more than 60% opacity. Minn. R , subp. 1(A); Minn. R , subp. 1(B) A.4.2 Fiberglass Operations placed in operation on or after July 9, 1969 What to do Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R or Minn. R Minn. R , subp. 1(A); Opacity: less than or equal to 20% opacity. Minn. R , subp. 1(B) Page 94

95 The following are National Emission Standards for Hazardous Air Pollutants for Reinforced Plastic Composites Production (40 CFR pt. 63, subp. WWWW) A.4.3 Fiberglass Operations (spraying/coating, molding, casting, lamination, mixing and cleaning) Subject to NESHAP subp. WWWW Affected Source: All parts of the facility engaged in the following reinforced plastic composites production operations: Open molding, closed molding, centrifugal casting, continuous lamination, continuous casting, polymer casting, pultrusion, sheet molding compound (SMC) manufacturing, bulk molding compound (BMC) manufacturing, mixing, cleaning of equipment used in reinforced plastic composites manufacture, HAP containing materials storage, and repair operations on parts manufactured by the facility. New Source: commenced construction after August 2, 2001 Existing Source: commenced construction on or before August 2, 2001 (Also see 40 CFR section ) Compliance dates: All compliance dates have passed for this standard. For existing affected sources, the compliance date was April 21, For new affected sources, the compliance date was April 21, 2003, or the date of initial startup of the affected source, whichever was later. The Permittee is subject to the requirements below if the Permittee owns or operates an affected source and the reinforced plastic composites operations at the facility use 1.2 tons per year or more of thermoset resins and gel coats that contain styrene combined. (Also see 40 CFR section ) Definitions: (Also see 40 CFR section ) CR/HS: Corrosion resistant and/or high strength This rule does not cover the following, which are applicable to this permit: Non gel coat surface coatings that meet the requirements of subparts MMMM or PPPP What to do GENERAL COMPLIANCE REQUIREMENTS Unless otherwise noted, all equations and emission factors for 40 CFR pt. 63, subp. WWWW referenced in the requirements for NESHAP subp. WWWW in this general permit can be found in Appendix F of this permit. hdr Minn. R , subp. 4 and 5 Page 95

96 What to do General Provisions Appendix: This permit contains an appendix which lists the requirements of the general provisions in s 63.1 through 63.15, and shows which parts of the general provisions apply to sources subject to 40 CFR pt. 63, subp. WWWW. The Permittee shall comply with all applicable requirements contained in the General Provisions Appendix (Appendix B). Military exemption: Production resins that must meet military specifications are allowed to meet the organic HAP limit contained in that specification. In order for this exemption to be used, the Permittee shall supply to the permitting authority the specifications certified as accurate by the military procurement officer, and those specifications must state a requirement for a specific resin, or a specific resin HAP content. Production resins for which this exemption is used must be applied with nonatomizing resin application equipment unless the Permittee can demonstrate this is infeasible. The Permittee shall keep a record of the resins for which this exemption is used. HAP EMISSION LIMITS NEW AND EXISTING CENTRIFUGAL CASTING AND CONTINUOUS CASTING/LAMINATION HAPs Organic: less than or equal to 25 lb/ton resin for centrifugal casting CR/HS operations that use resin application with the mold closed or open, and the mold is vented during spinning and cure, based on a 12 month rolling average. For compliance purposes, the Permittee shall calculate the emission factor using only the appropriate centrifugal casting equation in item 2 of Table W1 in Appendix F to this permit. HAPs Organic: for centrifugal casting CR/HS operations that use resin application with the mold open, and the mold is not vented during spinning and cure, the Permittee shall use the appropriate open molding emission limit. The Permittee shall calculate the emission factor using the appropriate open molding covered cure emission factor in item 1 of Table W1 in Appendix F to this permit. HAPs Organic: less than or equal to 20 lb/ton resin for centrifugal casting non CR/HS operations that use resin application with the mold closed or open, and the mold is vented during spinning and cure, based on a 12 month rolling average. For compliance purposes, the Permittee shall calculate the emission factor using only the appropriate centrifugal casting equation in item 2 of Table W1 in Appendix F to this permit , Table 15 in 40 CFR pt. 63, subp. WWWW; Minn. R ; Minn. R , subp (d); Minn. R hdr 40 CFR pt. 63, subp. WWWW: Section (a) and Table 3; Minn. R CFR pt. 63, subp. WWWW: Section (a) and Table 3; Minn. R CFR pt. 63, subp. WWWW: Section (a) and Table 3; Minn. R Page 96

97 What to do HAPs Organic: for centrifugal casting non CR/HS operations that use resin application with the mold open, and the mold is not vented during spinning and cure, the Permittee shall use the appropriate open molding emission limit. The Permittee shall calculate the emission factor using the appropriate open molding covered cure emission factor in item 1 of Table W1 in Appendix F to this permit. HAPs Organic: less than or equal to 15.7 lb/ton neat resin plus and neat gel coat plus for continuous lamination/casting operations, based on a 12 month rolling average. Alternative: as an alternative to the lb/ton limit, the Permittee may instead elect to reduce total organic HAP emissions by at least 58.5 weight percent for continuous lamination/casting operations. HAP EMISSION LIMITS NEW AND EXISTING OPEN MOLDING HAPs Organic: less than or equal to 113 lb/ton resin for open molding CR/HS operations that use mechanical resin application, based on a 12 month rolling average. HAPs Organic: less than or equal to 171 lb/ton for open molding CR/HS operations that use filament application, based on a 12 month rolling average. HAPs Organic: less than or equal to 123 lb/ton resin for open molding CR/HS operations that use manual resin application, based on a 12 month rolling average. HAPs Organic: less than or equal to 88 lb/ton resin for open molding non CR/HS operations that use mechanical resin application, based on a 12 month rolling average. HAPs Organic: less than or equal to 188 lb/ton for open molding non CR/HS operations that use filament application, based on a 12 month rolling average. HAPs Organic: less than or equal to 87 lb/ton resin for open molding non CR/HS operations that use manual resin application, based on a 12 month rolling average. 40 CFR pt. 63, subp. WWWW: Section (a) and Table 3; Minn. R CFR pt. 63, subp. WWWW: Section (a) and Table 3; Minn. R hdr s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R Page 97

98 What to do HAPs Organic: less than or equal to 254 lb/ton resin for open molding tooling operations that use mechanical resin application, based on a 12 month rolling average. HAPs Organic: less than or equal to 157 lb/ton resin for open molding tooling operations that use manual resin application, based on a 12 month rolling average. HAPs Organic: less than or equal to 497 lb/ton resin for open molding low flame spread/low smoke products operations that use mechanical resin application, based on a 12 month rolling average. HAPs Organic: less than or equal to 270 lb/ton for open molding low flame spread/low smoke products operations that use filament application, based on a 12 month rolling average. HAPs Organic: less than or equal to 238 lb/ton resin for open molding low flame spread/low smoke products operations that use manual resin application, based on a 12 month rolling average. HAPs Organic: less than or equal to 354 lb/ton resin for open molding shrinkage controlled resins operations that use mechanical resin application, based on a 12 month rolling average. This emission limit applies regardless of whether the shrinkage controlled resin is used as a production resin or a tooling resin. HAPs Organic: less than or equal to 215 lb/ton for open molding shrinkage controlled resins operations that use filament application, based on a 12 month rolling average. This emission limit applies regardless of whether the shrinkage controlled resin is used as a production resin or a tooling resin. HAPs Organic: less than or equal to 180 lb/ton resin for open molding shrinkage controlled resins operations that use manual resin application, based on a 12 month rolling average. This emission limit applies regardless of whether the shrinkage controlled resin is used as a production resin or a tooling resin. s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R Page 98

99 What to do HAPs Organic: less than or equal to 440 lb/ton gel coat for open molding gel coat operations that use tooling gel coating, based on a 12 month rolling average. If the facility only applies gel coat with manual application, for compliance purposes the Permittee shall treat the gel coat as if it were applied using atomized spray guns to determine both emission limits and emission factors. If the facility uses multiple application methods and any portion of a specific gel coat is applied using nonatomized spray, the Permittee may use the nonatomized spray gel coat equation to calculate an emission factor for the manually applied portion of that gel coat. Otherwise the Permittee shall use the atomized spray gel coat application equation to calculate emission factors. HAPs Organic: less than or equal to 267 lb/ton gel coat for open molding gel coat operations that use white/off white pigmented gel coating, based on a 12 month rolling average. If the facility only applies gel coat with manual application, for compliance purposes the Permittee shall treat the gel coat as if it were applied using atomized spray guns to determine both emission limits and emission factors. If the facility uses multiple application methods and any portion of a specific gel coat is applied using nonatomized spray, the Permittee may use the nonatomized spray gel coat equation to calculate an emission factor for the manually applied portion of that gel coat. Otherwise the Permittee shall use the atomized spray gel coat application equation to calculate emission factors. HAPs Organic: less than or equal to 377 lb/ton gel coat for open molding gel coat operations that use all other pigmented gel coating, based on a 12 month rolling average. If the facility only applies gel coat with manual application, for compliance purposes the Permittee shall treat the gel coat as if it were applied using atomized spray guns to determine both emission limits and emission factors. If the facility uses multiple application methods and any portion of a specific gel coat is applied using nonatomized spray, the Permittee may use the nonatomized spray gel coat equation to calculate an emission factor for the manually applied portion of that gel coat. Otherwise the Permittee shall use the atomized spray gel coat application equation to calculate emission factors. s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R Page 99

100 What to do HAPs Organic: less than or equal to 605lb/ton gel coat for open molding gel coat operations that use CR/HS or high performance gel coating, based on a 12 month rolling average. If the facility only applies gel coat with manual application, for compliance purposes the Permittee shall treat the gel coat as if it were applied using atomized spray guns to determine both emission limits and emission factors. If the facility uses multiple application methods and any portion of a specific gel coat is applied using nonatomized spray, the Permittee may use the nonatomized spray gel coat equation to calculate an emission factor for the manually applied portion of that gel coat. Otherwise the Permittee shall use the atomized spray gel coat application equation to calculate emission factors. HAPs Organic: less than or equal to 854lb/ton gel coat for open molding gel coat operations that use fire retardant gel coating, based on a 12 month rolling average. If the facility only applies gel coat with manual application, for compliance purposes the Permittee shall treat the gel coat as if it were applied using atomized spray guns to determine both emission limits and emission factors. If the facility uses multiple application methods and any portion of a specific gel coat is applied using nonatomized spray, the Permittee may use the nonatomized spray gel coat equation to calculate an emission factor for the manually applied portion of that gel coat. Otherwise the Permittee shall use the atomized spray gel coat application equation to calculate emission factors. HAPs Organic: less than or equal to 522lb/ton gel coat for open molding gel coat operations that use clear production gel coating, based on a 12 month rolling average. If the facility only applies gel coat with manual application, for compliance purposes the Permittee shall treat the gel coat as if it were applied using atomized spray guns to determine both emission limits and emission factors. If the facility uses multiple application methods and any portion of a specific gel coat is applied using nonatomized spray, the Permittee may use the nonatomized spray gel coat equation to calculate an emission factor for the manually applied portion of that gel coat. Otherwise the Permittee shall use the atomized spray gel coat application equation to calculate emission factors. HAP EMISSION LIMITS NEW AND EXISTING PULTRUSION MACHINES HAPs Organic: greater than or equal to 60 weight percent reduction of total organic HAP emissions for pultrusion machines, except: Pultrusion machines that produce parts that meet the following criteria: 1,000 or more reinforcements or the glass equivalent of 1,000 ends of 113 yield roving or more; and have a cross sectional area of 60 square inches or more are not subject to this organic HAP emission limit. s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R hdr s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 3; Minn. R Page 100

101 What to do WORK PRACTICE STANDARDS For new or existing closed molding operations using compression/injection molding, the Permittee shall uncover, unwrap or expose only one charge per mold cycle per compression/injection molding machine. For machines with multiple molds, one charge means sufficient material to fill all molds for one cycle For machines with robotic loaders, no more than one charge may be exposed prior to the loader. For machines fed by hoppers, sufficient material may be uncovered to fill the hopper. Hoppers shall be closed when not adding materials. Materials may be uncovered to feed to slitting machines. Materials shall be recovered after slitting. For new or existing cleaning operations, the Permittee shall not use cleaning solvents that contain HAP, except that styrene may be used as a cleaner in closed systems, and organic HAP containing cleaners may be used to clean cured resin from application equipment. Application equipment includes any equipment that directly contacts resin. For new or existing materials HAP containing materials storage operations, the Permittee shall keep containers that store HAP containing materials closed or covered except during the addition or removal of materials. Bulk HAP containing materials storage tanks may be vented as necessary for safety. For existing or new SMC manufacturing operations, the Permittee shall: Close or cover the resin delivery system to the doctor box on each SMC manufacturing machine. The doctor box itself may be open; and Use a nylon containing film to enclose SMC. For all mixing or BMC manufacturing operations, the Permittee shall: Use mixer covers with no visible gaps present in the mixer covers, except that gaps of up to 1 inch are permissible around mixer shafts and any required instrumentation; Close any mixer vents when actual mixing is occurring, except that venting is allowed during addition of materials, or as necessary prior to adding materials or opening the cover for safety; and Keep the mixer covers closed while actual mixing is occurring except when adding materials or changing covers to the mixing vessels. Exceptions: Containers of 5 gallons or less may be open when active mixing is taking place, or during periods when they are in process (i.e., they are actively being used to apply resin). For polymer casting mixing operations, containers with a surface area of 500 square inches or less may be open while active mixing is taking place. hdr s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 4; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 4; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 4; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 4; Minn. R s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 4; Minn. R Page 101

102 What to do For new or existing pultrusion operation manufacturing parts that meet the following criteria: 1,000 or more reinforcements or the glass equivalent of 1,000 ends of 113 yield roving or more; and have a cross sectional area of 60 square inches or more: the Permittee shall: Not allow vents from the building ventilation system, or local or portable fans to blow directly on or across the wet out area(s); Not permit point suction of ambient air in the wet out area(s); Use devices such as deflectors, baffles, and curtains when practical to reduce air flow velocity across the wet out area(s); Direct any compressed air exhausts away from resin and wet out area(s); Convey resin collected from drip off pans or other devices to reservoirs, tanks, or sumps via covered troughs, pipes or other covered conveyance that shields the resin from the ambient air; Cover all reservoirs, tanks, sumps, or HAP containing materials storage vessels except when they are being charged or filled; and Cover or shield from ambient air resin delivery systems to the wet out area(s) from reservoirs, tanks, or sumps where practical. s (b) and (c); 40 CFR pt. 63, subp. WWWW Table 4; Minn. R Page 102

103 What to do COMPLIANCE OPTIONS NEW AND EXISTING OPEN MOLDING AND CENTRIFUGAL CASTING OPERATIONS The Permittee shall use one of the following methods to meet the standards for open molding or centrifugal casting operations listed above in the HAP Emission Limits and Work Practice Standards sections. (a) Demonstrate that an individual resin or gel coat, as applied, meets the applicable HAP Emission Limit. (b) Demonstrate that, on average, each combination of operation type and resin application method or gel coat type meets the applicable HAP Emission Limits. (c) Demonstrate compliance with a weighted average emission limit. (d) Meet the HAP Emission Limit for one application method and use the same resin(s) for all application methods of that resin type. hdr ; Minn. R The Permittee may use any control method that reduces organic HAP emissions, including reducing resin and gel coat organic HAP content, changing to nonatomized mechanical application, and using uncovered curing techniques. The Permittee may use different compliance options for the different operations listed above in the HAP Emission Limits and Work Practice Standards sections. The Permittee may switch between the compliance options above in paragraphs (a) through (d). When the Permittee changes to an option based on a 12 month rolling average, the Permittee shall base the average on the previous 12 months of data calculated using the compliance option they are changing to, unless the Permittee was previously using an option that did not require maintaining records of resin and gel coat use. In this case, the Permittee shall immediately begin collecting resin and gel coat use data and demonstrate compliance 12 months after changing options. Definition of Process Stream: A process stream is each individual combination of resin or gel coat, application technique, and control technique. Process streams within operation types are considered different from each other if any of the following four characteristics vary o the neat resin plus or neat gel coat plus organic HAP content, o the gel coat type, o the application technique, or o the control type (a); Minn. R Page 103

104 What to do Demonstrate that an individual resin or gel coat, as applied, meets the applicable HAP Emission Limit. The Permittee shall perform the following calculations prior to beginning the use of a new individual resin or gel coat, or within 30 days of permit issuance, whichever is later. (1) The Permittee shall calculate the actual organic HAP emissions factor for each different process stream within each operation type, using the appropriate equations in Table W1 of Appendix F to this permit for open molding and for centrifugal casting. If the Permittee uses vapor suppressants to reduce HAP emissions, the Permittee shall determine the vapor suppressant effectiveness (VSE) by conducting testing according to the procedures specified in Appendix A to 40 CFR pt. 63, subp. WWWW. The emission factor calculation should include any and all emission reduction techniques used. (2) If the calculated emission factor is less than or equal to the appropriate HAP Emission Limit, the Permittee has demonstrated that this process stream complies with the HAP Emission Limit in the NESHAP subp. WWWW section of this permit. It is not necessary that all process streams at the facility, considered individually, demonstrate compliance to use this option for some process streams. However, for any individual resin or gel coat used, if any of the process streams that include that resin or gel coat are to be used in any averaging calculations described in options (b) through (d) below, then the Permittee shall include all process streams using that individual resin or gel coat in the averaging calculations (a); Minn. R Page 104

105 What to do Demonstrate that, on average, each combination of operation type and resin application method or gel coat type meets the applicable HAP Emission Limits. Within 30 days following the end of each month, the Permittee shall demonstrate that, on average, each unique combination of operation type and resin application method or gel coat type listed above in the HAP Emission Limits section meets the applicable HAP Emission Limits using the following procedures: (1) (i) Group the process streams by operation type and resin application method or gel coat type listed in the HAP Emission Limit section above and then calculate a weighted average emission factor based on the amounts of each individual resin or gel coat used for the last 12 months, using Equation W1 in Appendix F to this permit. (ii) The Permittee may, but is not required to, include process streams where they have demonstrated compliance as described above in the Demonstrate that an individual resin or gel coat, as applied, meets the applicable HAP Emission Limit requirement. (2) The Permittee shall compare each organic HAP emissions factor calculated in paragraph (1) in this requirement with its corresponding HAP Emissions Limit. If all emission factors are equal to or less than their corresponding emission limits then the source is in compliance. Demonstrate compliance with a weighted average emission limit. Each month the Permittee shall demonstrate that the facility meets each weighted average of applicable HAP emission limits in the NESHAP subp. WWWW section of this permit. When using this option, the Permittee shall demonstrate compliance with the weighted average organic HAP emissions limit for all open molding operations at the facility, and then separately demonstrate compliance with the weighted average organic HAP emissions limit for all centrifugal casting operations at the facility. The Permittee shall not average open molding operations and centrifugal casting operations together. (1) Within 30 days following the end of each month, the Permittee shall calculate the weighted average organic HAP emissions limit for all open molding operations and the weighted average organic HAP emissions limit for all centrifugal casting operations at the facility for the last 12 month period to determine the organic HAP emissions limit that the Permittee shall meet, using Equation W2 in Appendix F to this permit. (2) Within 30 days following the end of each month, the Permittee shall calculate the weighted average organic HAP emissions factor for open molding and centrifugal casting, using Equation W3 in Appendix F to this permit. (3) Within 30 days following the end of each month, the Permittee shall compare the values calculated in paragraphs (1) and (2) of this requirement. If each 12 month rolling average organic HAP emissions factor is less than or equal to the corresponding 12 month rolling average organic HAP emissions limit, then the source is in compliance (b); Minn. R (c); Minn. R Page 105

106 What to do Meet the HAP Emission Limit for one application method and use the same resin(s) for all application methods of that resin type. The Permittee shall perform the compliance demonstration for this option within 30 days following the end of each month. This option is limited to resins of the same type. The resin types for which this option may be used are noncorrosion resistant, corrosion resistant and/or high strength, and tooling (d); Minn. R (1) For any combination of manual resin application, mechanical resin application, filament application, or centrifugal casting, the Permittee may elect to meet the organic HAP emissions limit for any one of these application methods and use the same resin in all of the resin application methods listed in this paragraph. The possible combinations based on a facility selecting the application process that results in the highest allowable organic HAP content resin are presented in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section below. If the resin organic HAP content is below the applicable value shown in the next section of the NESHAP subp. WWWW section of this permit, the resin is in compliance. (2) The Permittee may also use a weighted average organic HAP content for each application method described in paragraph (1) of this requirement. To do so, the Permittee shall calculate the weighted average organic HAP content monthly using the following procedures: Use Equation W1 in Appendix F to this permit, except substitute organic HAP content for organic HAP emissions factor. The Permittee is in compliance if the weighted average organic HAP content based on the last 12 months of resin use is less than or equal to the applicable organic HAP contents in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section below. (3) The Permittee may simultaneously use the averaging provisions in options (b) or (c) above to demonstrate compliance for any operations and/or resins not included in the compliance demonstration in paragraphs (1) and (2) of this requirement. However, any resins for which the Permittee claims compliance under the option in paragraphs (1) and (2) of this requirement may not be included in any of the averaging calculations described in options (b) or (c) above. (4) The Permittee is not required to keep records of resin use for any of the individual resins where compliance is demonstrated under the option in paragraph (1) of this requirement unless the Permittee elects to include that resin in the averaging calculations described in paragraph (2) of this requirement. Page 106

107 What to do EMISSION FACTORS OPEN MOLDING AND CENTRIFUGAL CASTING OPERATIONS Calculating Organic HAP Emission Factors for Open Molding and Centrifugal Casting: The Permittee shall use the equations in Table W1 of Appendix F to this permit to calculate the emission factors. Equations are available for each open molding operation and centrifugal casting operation and have units of pounds of organic HAP emitted per ton (lb/ton) of resin or gel coat applied. Emission factors are used to determine compliance with certain organic HAP emission limits in the HAP Emission Limits section above. These equations are intended to provide a compliance demonstration method without the need to conduct HAP emission testing. The Permittee may also use the organic HAP emissions factors calculated using the equations in Table W1, combined with resin and gel coat use data, to calculate the organic HAP emissions from fiberglass operations at the facility. Determining organic HAP content of resins and gel coats: To determine the organic HAP content of resins and gel coats, the Permittee may rely on information provided by the material manufacturer, such as manufacturer s formulation data and material safety data sheets (MSDS), using the following procedures: (a) Include in the organic HAP total each organic HAP that is present at 0.1 percent by mass or more for Occupational Safety and Health Administration defined carcinogens, as specified in 29 CFR (d)(4) and at 1.0 percent by mass or more for other organic HAP compounds. (b) If the organic HAP content is provided by the material supplier or manufacturer as a range, the Permittee shall use the upper limit of the range for determining compliance. If a separate measurement of the total organic HAP content, such as an analysis of the material by EPA Method 311 of appendix A to 40 CFR part 63, exceeds the upper limit of the range of the total organic HAP content provided by the material supplier or manufacturer, then the Permittee shall use the measured organic HAP content to determine compliance. (c) If the organic HAP content is provided as a single value, the Permittee may use that value to determine compliance. If a separate measurement of the total organic HAP content is made and is less than 2 percentage points higher than the value for total organic HAP content provided by the material supplier or manufacturer, then the Permittee still may use the provided value to demonstrate compliance. If the measured total organic HAP content exceeds the provided value by 2 percentage points or more, then the Permittee shall use the measured organic HAP content to determine compliance. hdr ; Minn. R ; Minn. R Page 107

108 What to do Calculating organic HAP emissions for applicability determination: The Permittee shall use the following procedures to calculate the facility s organic HAP emissions in tpy for purposes of determining which paragraphs of 40 CFR section apply to the source. (a) For new facilities prior to startup, calculate a weighted average organic HAP emissions factor for the operations specified in 40 CFR sections (c) and (d) on a lbs/ton of resin and gel coat basis. Base the weighted average on the projected operation for the 12 months subsequent to facility startup. Multiply the weighted average organic HAP emissions factor by projected resin use over the same period. The Permittee may calculate the organic HAP emissions factor based on the factors in Table W1 of Appendix F to this permit, or the Permittee may use any HAP emissions factor approved by the MPCA, such as factors from the Compilation of Air Pollutant Emissions Factors, Volume I: Stationary Point and Area Sources (AP 42), or organic HAP emissions test data from similar facilities. [continued below] ; Minn. R Page 108

109 What to do Calculating organic HAP emissions for applicability determination: [continued from above] (b) For existing facilities and new facilities after startup, the Permittee may use the procedures in either paragraph (b)(1) or (2) below. If the emission factors for an existing facility have changed over the period of time prior to their initial compliance date due to incorporation of pollution prevention control techniques, existing facilities may base the average emission factor on their operations as they exist on the compliance date. If an existing facility has accepted an enforceable permit limit that would result in less than 100 tpy of HAP measured prior to any add on controls, and can demonstrate that they will operate at that level subsequent to the compliance date, they can be deemed to be below the 100 tpy threshold. (1) Use a calculated emission factor. Calculate a weighted average organic HAP emissions factor on a lbs/ton of resin and gel coat basis. Base the weighted average on the prior 12 months of operation. Multiply the weighted average organic HAP emissions factor by resin and gel coat use over the same period. The Permittee may calculate this organic HAP emissions factor based on the equations in Table W1 of Appendix F to this permit, or the Permittee may use any organic HAP emissions factor approved by the MPCA, such as factors from AP 42, or site specific organic HAP emissions factors if they are supported by HAP emissions test data. (2) Conduct performance testing. Conduct performance testing using the test procedures in 40 CFR section to determine a site specific organic HAP emissions factor in units of lbs/ton of resin and gel coat used. Conduct the test under conditions expected to result in the highest possible organic HAP emissions. Multiply this factor by annual resin and gel coat use to determine annual organic HAP emissions. This calculation must be repeated and reported to MPCA and EPA annually by February 2 for the previous year. (c) The Permittees of existing facilities shall initially perform this calculation based on their 12 months of operation prior to April 21, 2003, and include this information with their initial notification report. The Permittees of existing facilities shall repeat the calculation based on their resin and gel coat use in the 12 months prior to their initial compliance date, and submit this information with their initial compliance report. After their initial compliance date, existing and new facilities shall recalculate organic HAP emissions over the 12 month period ending June 30 or December 31, whichever date is the first date following their compliance date specified in 40 CFR section Subsequent calculations should cover the periods in the semiannual compliance reports. [continued below] ; Minn. R Page 109

110 What to do Calculating organic HAP emissions for applicability determination: [continued from above] The Permittee is not required to calculate or report emissions under this requirement if the source is an existing facility that does not have centrifugal casting or continuous lamination/casting operations, or a new facility that does not have any of the following operations: Open molding, centrifugal casting, continuous lamination/casting, pultrusion, SMC and BMC manufacturing, and mixing. Emissions calculation and emission reporting procedures in other sections of 40 CFR pt. 63, subp. WWWW still apply. For centrifugal casting operations at existing facilities, the Permittee shall not include any organic HAP emissions where resin or gel coat is applied to an open centrifugal mold using open application techniques. Table W1 and the Table W1 footnotes in Appendix F to this permit present more information on calculating centrifugal casting organic HAP emissions. ORGANIC HAP CONTENT FOR USE OF THE SAME RESIN ACROSS DIFFERENT OPERATIONS OF THE SAME RESIN TYPE If the Permittee elects to use the same resin(s) for multiple resin applications, the Permittee shall use any resin(s) with an organic HAP content less than or equal to the values in the following requirements, or any combination of resins whose weighted average organic HAP content based on a 12 month rolling average is less than or equal to the values in the following requirements. For centrifugal casting CR/HS resins, resin weight must be less than or equal to: 48.0 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS mechanical. Nonatomized mechanical application must be used percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS filament application percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS manual. The Permittee shall not blow heated air through the molds for these centrifugal casting operations. If the centrifugal casting molds are not vented, the Permittee may treat the centrifugal casting operations as if they were vented if the Permittee elects to use this compliance option ; Minn. R hdr 40 CFR pt. 63, subp. WWWW: Section (d) and Table 7; Minn. R CFR pt. 63, subp. WWWW: Section (d) and Table 7; Minn. R Page 110

111 What to do For nonatomized mechanical CR/HS resins, resin weight must be less than or equal to: 46.4 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS filament application percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS manual. For filament application CR/HS resins, resin weight must be less than or equal to: 42.0 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS manual. For filament application non CR/HS resins, resin weight must be less than or equal to: 45.0 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS manual percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS mechanical. Nonatomized mechanical application must be used percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS centrifugal casting. The Permittee shall not blow heated air through the molds for these centrifugal casting operations. If the centrifugal casting molds are not vented, the Permittee may treat the centrifugal casting operations as if they were vented if the Permittee elects to use this compliance option. For nonatomized mechanical non CR/HS resins, resin weight must be less than or equal to: 38.5 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS centrifugal casting percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS manual. The Permittee shall not blow heated air through the molds for these centrifugal casting operations. If the centrifugal casting molds are not vented, the Permittee may treat the centrifugal casting operations as if they were vented if the Permittee elects to use this compliance option. 40 CFR pt. 63, subp. WWWW: Section (d) and Table 7; Minn. R CFR pt. 63, subp. WWWW: Section (d) and Table 7; Minn. R CFR pt. 63, subp. WWWW: Section (d) and Table 7; Minn. R CFR pt. 63, subp. WWWW: Section (d) and Table 7; Minn. R Page 111

112 What to do For centrifugal casting non CR/HS resins, resin weight must be less than or equal to: 37.5 percent organic HAP content, or weighted average weight percent organic HAP content, for non CR/HS manual. The Permittee shall not blow heated air through the molds for these centrifugal casting operations. If the centrifugal casting molds are not vented, the Permittee may treat the centrifugal casting operations as if they were vented if the Permittee elects to use this compliance option. For nonatomized mechanical tooling resins, resin weight must be less than or equal to: 91.4 percent organic HAP content, or weighted average weight percent organic HAP content, for tooling manual. For manual tooling resins, resin weight must be less than or equal to: 45.9 percent organic HAP content, or weighted average weight percent organic HAP content, for tooling atomized mechanical. COMPLIANCE OPTIONS NEW AND EXISTING CONTINUOUS LAMINATION/CASTING OPERATIONS The Permittee shall use one or more of the following options to meet the standards for continuous lamination/casting operations listed above in the HAP Emission Limits and Work Practice Standards sections: (a) Compliant line option: The Permittee shall demonstrate that each continuous lamination line and each continuous casting line complies with the applicable standard. (b) Averaging option: The Permittee shall demonstrate that all continuous lamination and continuous casting lines combined, comply with the applicable standard. (c) Combination option: The Permittee shall use any combination of options in paragraphs (a) and (b) of this requirement to demonstrate compliance. 40 CFR pt. 63, subp. WWWW: Section (d) and Table 7; Minn. R CFR pt. 63, subp. WWWW: Section (d) and Table 7; Minn. R CFR pt. 63, subp. WWWW: Section (d) and Table 7; Minn. R hdr ; Minn. R Page 112

113 What to do COMPLIANCE OPTIONS PULTRUSION OPERATIONS The Permittee shall use one or more of the following options to meet the standards for pultrusion operations subject to the 60 weight percent organic HAP emission reductions requirement listed above in the HAP Emission Limits and Work Practice Standards sections: hdr ; Minn. R (a) Use direct die injection pultrusion machines with resin drip collection systems that meet all the following criteria: All the resin that is applied to the reinforcement is delivered directly to the die; No exposed resin is present, except at the face of the die; and Resin drip is captured in a closed system and recycled back to the process. (b) Use a preform injection system that meets the following definition: A form of pultrusion where liquid resin is injected to saturate reinforcements in an enclosed system containing one or more chambers with openings only large enough to admit reinforcements. Resin, which drips out of the chamber(s) during the process, is collected in closed piping or covered troughs and then into a covered reservoir for recycle. Resin storage vessels, reservoirs, transfer systems, and collection systems are covered or shielded from the ambient air. Preform injection differs from direct die injection in that the injection chambers are not directly attached to the die. (c) Use any combination of options in paragraphs (a) or (b) of this requirement in which different pultrusion lines comply with different options described in paragraphs (a) or (b) of this requirement, and: Each individual pultrusion machine meets the 60 percent reduction requirement; or The weighted average reduction based on resin throughput of all machines combined is 60 percent. For purposes of the average percent reduction calculation, wet area enclosures reduce organic HAP emissions by 60 percent, and direct die injection and preform injection reduce organic HAP emissions by 90 percent. Page 113

114 What to do TESTING AND INITIAL COMPLIANCE DEMONSTRATION REQUIREMENTS Initial Performance Testing: The Permittee shall conduct performance tests, performance evaluations, design evaluations, and other initial compliance demonstrations by the compliance date specified in Table 2 to 40 CFR pt. 63, subp. WWWW. Exceptions: For open molding and centrifugal casting operations that elect to meet an organic HAP emissions limit on a 12 month rolling average, the Permittee shall initiate collection of the required data on the compliance date, and demonstrate compliance 1 year after the compliance date. Initial Compliance: The Permittee shall demonstrate initial compliance with each organic HAP emissions standard that applies to the fiberglass operations at the facility by using the procedures in the requirements below. Initial Compliance: For open molding and centrifugal casting operations that must meet an organic HAP emissions limit in the HAP Emissions Limit section above, or an organic HAP content limit in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section above, the Permittee has demonstrated initial compliance if: (i) The Permittee has met the appropriate organic HAP emissions limits for these operations as calculated using the procedures in the Compliance Options New and Existing Open Molding and Centrifugal Casting Operations section above on a 12 month rolling average 1 year after the appropriate compliance date; and/or (ii) The Permittee demonstrates that any individual resins or gel coats not included in (i) above, as applied, meet their applicable emission limits; or (iii) The Permittee demonstrates using the appropriate values in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section above that the weighted average of all resins and gel coats for each resin type and application method meet the appropriate organic HAP contents. Initial Compliance: For continuous lamination/casting operations that must: (a) reduce total organic HAP emissions by at least 58.5 weight percent, the Permittee has demonstrated initial compliance if total organic HAP emissions, based on the calculation procedures specified in 40 CFR sections through , are reduced by at least 58.5 percent by weight. (b) not exceed an organic HAP emissions limit of 15.7 lbs of organic HAP per ton of neat resin plus and neat gel coat plus, the Permittee has demonstrated initial compliance if total organic HAP emissions, based on the calculation procedures specified in 40 CFR sections through , do not exceed 15.7 lbs of organic HAP per ton of neat resin plus and neat gel coat plus. hdr ; Minn. R ; Minn. R CFR pt. 63, subp. WWWW: section (a) and Table 8; Minn. R CFR pt. 63, subp. WWWW: section (a) and Table 8; Minn. R Page 114

115 What to do Initial Compliance: For pultrusion operations that must reduce total organic HAP emissions by at least 60 percent by weight, the Permittee has demonstrated initial compliance if, as part of the notification of initial compliance status, the Permittee submits a certified statement that all pultrusion lines for which an emission reduction is being claimed are using direct die injection and/or wet area enclosures that meet the criteria listed in the Compliance Options Pultrusion Operations section above. Initial Compliance: For new or existing closed molding operations using compression/injection molding that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits a certified statement in the notice of compliance status that only one charge is uncovered, unwrapped, or exposed per mold cycle per compression/injection molding machine, or prior to the loader, hoppers are closed except when adding materials, and materials are recovered after slitting. Initial Compliance: For new or existing closed molding operations using compression/injection molding that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits a certified statement in the notice of compliance status that only one charge is uncovered, unwrapped, or exposed per mold cycle per compression/injection molding machine, or prior to the loader, hoppers are closed except when adding materials, and materials are recovered after slitting. Initial Compliance: For new or existing cleaning operations that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits a certified statement in the notice of compliance status that all cleaning materials, except styrene contained in closed systems, or materials used to clean cured resin from application equipment, contain no HAP. Initial Compliance: For new or existing materials HAP containing materials storage operations that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits a certified statement in the notice of compliance status that all HAP containing storage containers are kept closed or covered except when adding or removing materials, and that any bulk storage tanks are vented only as necessary for safety. Initial Compliance: For existing or new SMC manufacturing operations that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits a certified statement in the notice of compliance status that the resin system is closed or covered and that a nylon containing film is used to enclose SMC. 40 CFR pt. 63, subp. WWWW: section (a) and Table 8; Minn. R CFR pt. 63, subp. WWWW: section (a) and Table 9; Minn. R CFR pt. 63, subp. WWWW: section (a) and Table 9; Minn. R CFR pt. 63, subp. WWWW: section (a) and Table 9; Minn. R CFR pt. 63, subp. WWWW: section (a) and Table 9; Minn. R CFR pt. 63, subp. WWWW: section (a) and Table 9; Minn. R Page 115

116 What to do Initial Compliance: For existing or new mixing or BMC manufacturing operations that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits certified statements in the notice of compliance status that: mixer covers are closed during mixing except when adding materials to the mixers, and that gaps around mixer shafts and required instrumentation are less than 1 inch; mixers are not actively vented to the atmosphere when the agitator is turning except when adding materials or as necessary for safety; and mixers are closed except when adding materials to the mixing vessels. Initial Compliance: For new or existing pultrusion operation manufacturing parts that meet the following criteria: 1,000 or more reinforcements or the glass equivalent of 1,000 ends of 113 yield roving or more; and have a cross sectional area of 60 square inches or more; and that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits a certified statement in the notice of compliance status that they have complied with all the requirements listed in 40 CFR pt. 63, subp. WWWW Table 9, items 9.i through 9.vii. CONTINUOUS COMPLIANCE REQUIREMENTS Facilities meeting an organic HAP emissions standard based on a 12 month rolling average shall begin collecting data on the compliance date in order to demonstrate compliance. 40 CFR pt. 63, subp. WWWW: section (a) and Table 9; Minn. R CFR pt. 63, subp. WWWW: section (a) and Table 9; Minn. R hdr 40 CFR section ; Minn. R Page 116

117 What to do The Permittee shall demonstrate continuous compliance with each standard in the HAP Emission Limits and Work Practice Standards sections above according to the following methods: Compliance with organic HAP emissions limits is demonstrated by maintaining an organic HAP emissions factor value less than or equal to the appropriate organic HAP emission limit listed in the HAP Emission Limits section above, on a 12 month rolling average, and/or by including in each compliance report a statement that individual resins and gel coats, as applied, meet the appropriate organic HAP emission limits, as discussed below in the Recordkeeping section. Compliance with organic HAP content limits in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section above is demonstrated by maintaining an average organic HAP content value less than or equal to the appropriate organic HAP contents listed in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section above, on a 12 month rolling average, and/or by including in each compliance report a statement that resins and gel coats individually meet the appropriate organic HAP content limits in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section above, as discussed below in the Recordkeeping section. Compliance with the work practice standards in the Work Practice Standards section above is demonstrated by performing the work practice required for the operation. The Permittee shall meet the organic HAP limits and work practice standards that apply to operations at the facility during periods of startup, shutdown, or malfunction. The Permittee shall report each deviation from each applicable standard in the HAP Emission Limits and Work Practice Standards sections above. The deviations shall be reported according to the requirements in the Reporting, Notifications, and Submittals section below (a) and (e); Minn. R (b); Minn. R Page 117

118 What to do COMPLIANCE DEMONSTRATIONS CONTINUOUS LAMINATION CASTING OPERATIONS Calculations for wet out areas and ovens: To calculate the annual uncontrolled organic HAP emissions from the wet out areas and ovens at the facility, the Permittee shall: develop uncontrolled wet out area and uncontrolled oven organic HAP emissions estimation equations or factors to apply to each formula applied on the line, determine how much of each formula for each end product is applied each year on each line, and assign uncontrolled wet out area and uncontrolled oven organic HAP emissions estimation equations or factors to each formula. hdr ; Minn. R Page 118

119 What to do Uncontrolled organic HAP emissions estimation equations and factors: To develop uncontrolled organic HAP emissions estimations and factors, the Permittee shall, at a minimum, do the following: (1) Identify each end product and the thickness of each end product produced on the line. Separate end products into the following end product groupings, as applicable: corrosion resistant gel coated end products, noncorrosionresistant gel coated end products, corrosion resistant nongel coated end products, and noncorrosion resistant nongel coated end products. This step creates end product/thickness combinations. (2) Identify each formula used on the line to produce each end product/thickness combination. Identify the amount of each such formula applied per year. Rank each formula used to produce each end product/thickness combination according to usage within each end product/thickness combination. (3) For each end product/thickness combination being produced, select the formula with the highest usage rate for testing. (4) If not already selected, also select the worst case formula (likely to be associated with the formula with the highest organic HAP content, type of HAP, application of gel coat, thin product, low line speed, higher resin table temperature) amongst all formulae. (The Permittee may use the results of the worst case formula test for all formulae if desired to limit the amount of testing required.) (5) For each formula selected for testing, conduct at least one test (consisting of three runs). During the test, track information on organic HAP content and type of HAP, end product thickness, line speed, and resin temperature on the wet out area table. (6) Using the test results, develop uncontrolled and controlled organic HAP emissions estimation equations (or factors) or series of equations (or factors) that best fit the results for estimating uncontrolled and controlled organic HAP emissions, taking into account the organic HAP content and type of HAP, end product thickness, line speed, and resin temperature on the wet out area table. [continued below] s (a) and (b); Minn. R Page 119

120 What to do Uncontrolled organic HAP emissions estimation equations and factors: [continued from above] In lieu of using the method specified above in this requirement for developing uncontrolled organic HAP emissions estimation equations and factors, the Permittee may elect to use the following method: For uncontrolled organic HAP emissions estimates, the Permittee may use previously established, facility specific organic HAP emissions equations or factors, provided they allow estimation of both wet out area and oven organic HAP emissions, where necessary, and have been approved by the MPCA. If a previously established equation or factor is specific to the wet out area only, or to the oven only, then the Permittee shall develop the corresponding uncontrolled or controlled equation or factor for the other organic HAP emissions source. Determine how much of each formula for each end product is applied each year on each line: The Permittee shall assign to each formula an uncontrolled organic HAP emissions estimation equation or factor based on the end product/thickness combination for which that formula is used. Calculate annual uncontrolled organic HAP emissions: (1) To calculate the annual uncontrolled organic HAP emissions from wet out areas that do not have any capture and control and from wet out areas that are captured by an enclosure but are vented to the atmosphere and not to a control device, multiply each formula s annual usage by its appropriate uncontrolled organic HAP emissions estimation equation or factor and sum the individual results. (2) To calculate the annual uncontrolled oven organic HAP emissions, multiply each formula s annual usage by its appropriate uncontrolled organic HAP emissions estimation equation or factor and sum the individual results. Calculations for application of neat resin plus and neat gel coat plus: The Permittee shall use the following procedures to determine how much neat resin plus and neat gel coat plus is applied to each line for continuous lamination/casting operations each year: (a) Track formula usage by end product/thickness combinations; (b) Use in house records to show usage. This may be either from automated systems or manual records; (c) Record daily the usage of each formula/end product combination on each line. This is to be recorded at the end of each run (i.e., when a changeover in formula or product is made) and at the end of each shift; and (d) Sum the amounts from the daily records to calculate annual usage of each formula/end product combination by line. s (a) and (b); Minn. R (c); Minn. R (d); Minn. R ; Minn. R Page 120

121 What to do Calculating organic HAP emissions factors: The Permittee shall use one of the following options to calculate an organic HAP emissions factor to demonstrate compliance for continuous lamination/casting operations: (a) Compliant line option: use Equation W4 of Appendix F to this permit to calculate an organic HAP emission factor in lbs/ton. (b) Averaging option: use Equation W5 of Appendix F to this permit to demonstrate compliance. (c) Combination option: use Equations W4 and W5 of Appendix F to this permit, as applicable, to demonstrate compliance. RECORDKEEPING Calculations for new and existing open molding and casting operations: Within 30 days following the end of each month, the Permittee shall complete the necessary calculations to demonstrate compliance with the standards for new and existing open molding and casting operations. These calculations are described above in the Compliance Options New and Existing Open Molding and Casting Operations Section. Monitor and Collect Data to Demonstrate Continuous if not Using an Add On Control Device: The Permittee shall monitor and collect data as specified below: (1) Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the Permittee shall conduct all monitoring in continuous operation (or collect data at all required intervals) at all times that the affected source is operating. (2) The Permittee shall not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities for purposes to this subpart, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. The Permittee shall use all the data collected during all other periods in assessing the operation of the control device and associated control system. (3) At all times, the Permittee shall maintain necessary parts for routine repairs of the monitoring equipment. (4) A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring equipment to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions ; Minn. R hdr ; Minn. R (b); Minn. R Page 121

122 What to do Recording and Recordkeeping to meet organic HAP emissions: The Permittee shall collect and keep records of resin and gel coat use, organic HAP content, and operation where the resin is used if the Permittee is meeting any organic HAP emissions limits based on an organic HAP emissions limit in the HAP Emission Limit section above. The Permittee shall collect and keep records of resin and gel coat use, organic HAP content, and operation where the resin is used if the Permittee is meeting any organic HAP content limits listed in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section above, if you are averaging organic HAP contents. Resin use records may be based on purchase records if the Permittee can reasonably estimate how the resin is applied. The organic HAP content records may be based on MSDS or on resin specifications supplied by the resin supplier. Recording and Recordkeeping for all resins and gel coats: For the individual resins and gel coats for which the Permittee demonstrates, as applied, meet their applicable emission limit as defined in the Demonstrate that an individual resin or gel coat, as applied, meets the applicable HAP Emission Limit requirement in the Compliance Options New and Existing Open Molding and Centrifugal Casting Operations section above, resin and gel coat use records are not required. However, the Permittee shall retain the records of resin and gel coat organic HAP content, and shall include the list of these resins and gel coats and identify their application methods in the semiannual compliance reports. If, after the Permittee has initially demonstrated that a specific combination of an individual resin or gel coat, application method, and controls meets its applicable emission limit, the resin or gel coat changes or the organic HAP content increases, or the Permittee changes the application method or controls; then the Permittee again shall demonstrate that the individual resin or gel coat meets its emission limit as specified in the HAP Emission Limits section above. o If any of these changes results in a situation where an individual resin or gel coat now exceeds its applicable emission limit as specified in the Demonstrate that an individual resin or gel coat, as applied, meets the applicable HAP Emission Limit requirement in the Compliance Options New and Existing Open Molding and Centrifugal Casting Operations section above, the Permittee shall begin collecting resin and gel coat use records and calculate compliance using one of the averaging options on a 12 month rolling average. Recording and Recordkeeping for pultrusion machines: For each pultrusion machine at the facility, the Permittee shall record all times that the wet area enclosures doors or covers are open and there is resin present in the resin bath (c);minn. R (d); Minn. R (d); Minn. R Page 122

123 What to do Recording and Recordkeeping for continuous lamination/casting operations: For continuous lamination/casting affected sources complying with a percent reduction requirement or a lbs/ton limit, the Permittee shall generate the following data: For each wet out area, the Permittee shall determine the annual uncontrolled wet out area organic HAP emissions. For each oven, the Permittee shall determine the annual uncontrolled oven organic HAP emissions. For each line, the Permittee shall determine the amount of neat resin plus applied, and the amount of neat gel coat plus applied. 40 CFR pt. 63, subp. WWWW: sections (a) and (b), Tables 11 and 12; Minn. R Page 123

124 What to do Records: The Permittee shall keep the records of the following: (a)(1) A copy of each notification and report the Permittee submits to comply with 40 CFR pt. 63, subp. WWWW, including all documentation supporting any Initial Notification or Notification of Compliance Status the Permittee submit, according to the requirements in 63.10(b)(2)(xiv). (2) The records in 63.6(e)(3)(iii) through (v) related to startup, shutdown, and malfunction. (3) Records of performance tests, design, and performance evaluations as required in 63.10(b)(2). (c) The Permittee shall keep all data, assumptions, and calculations used to determine organic HAP emissions factors or average organic HAP contents for operations listed in the HAP Emission Limits and Work Practice Standards sections above. (d) The Permittee shall keep a certified statement that the Permittee is in compliance with the requirements in the Work Practice Standards section above, as applicable. (e) For a new or existing continuous lamination/ casting operation, the Permittee shall keep the records listed in paragraphs (e)(1) through (4) of this section, when complying with the percent reduction and/or lbs/ton requirements specified in paragraphs (a) and (c) through (d) of (1) The Permittee shall keep all data, assumptions, and calculations used to determine percent reduction and/or lbs/ton as applicable; (2) The Permittee shall keep a brief description of the rationale for the assignment of an equation or factor to each formula; (3) When using facility specific organic HAP emissions estimation equations or factors, the Permittee shall keep all data, assumptions, and calculations used to derive the organic HAP emissions estimation equations and factors and identification and rationale for the worst case formula; and (4) For all organic HAP emissions estimation equations and organic HAP emissions factors, the Permittee shall keep documentation that the appropriate permitting authority has approved them. s (a) and (c) (e); Minn. R Page 124

125 What to do Records Retention: The Permittee shall maintain all applicable records in such a manner that they can be readily accessed and are suitable for inspection according to 63.10(b)(1). As specified in 63.10(b)(1), the Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The Permittee shall keep each record onsite for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to Section 63.10(b)(1). The Permittee may keep the records offsite for the remaining 3 years. The Permittee may keep records in hard copy or computer readable form including, but not limited to, paper, microfilm, computer floppy disk, magnetic tape, or microfiche. REPORTING, NOTIFICATIONS, AND SUBMITTALS Notification of threshold exceedance: If the facility emits greater than or equal to 100 tpy of HAP in any calendar year, the Permittee shall notify the MCPA in the compliance report. Note: exceeding the 40 CFR pt. 63, subp. WWWW threshold of 100tpy of HAP also exceeds the 90 tpy permit cap on HAP emissions and is a violation of the permit terms. This notification of exceeding the 40 CFR pt. 63, subp WWWW 100tpy threshold is in addition to any other actions required as a result of violating the permit terms. Initial Notification for an existing source: The Permittee shall submit an initial notification with the information specified in 63.9(b)(c), no later than 120 calendar days after April 21, 2004, (or within 120 calendar days after the source becomes subject to Subpart WWWW). Use Form 4W 01. Initial Notification for a new source: The Permittee shall submit an initial notification with the information specified in 63.9(b)(4) and (5), delivered or postmarked within 15 calendar days after the actual date of startup of the source. Use Form 4W ; Minn. R hdr (e); Minn. R (b)(c); 40 CFR Section (a) and Table 13 to 40 CFR pt. 63, subp. WWWW; Minn. R (b)(4) and (5); 40 CFR Section (a) and Table 13 to 40 CFR pt. 63, subp. WWWW; Minn. R Page 125

126 What to do Notice of Compliance Status, existing sources: The Permittee of an existing affected source shall submit a notification of compliance status as specified in 63.9 if the Permittee is complying with organic HAP emission limit averaging provisions by May 21, Notice of Compliance Status, existing sources: The Permittee of an existing affected source shall submit a notification of compliance status as specified in 63.9 if the Permittee is complying with organic HAP contents limits, application equipment requirements or organic HAP emissions limit other than organic HAP emission limit averaging by May 21, Notice of Compliance Status, new sources: The Permittee of a new affected source shall submit a notification of compliance status as specified in 63.9 if the Permittee is complying with organic HAP emission limit averaging provisions by May 21, 2004, or no later than one year and 30 days after the date of initial startup of the affected source, whichever is later. Notice of Compliance Status, new sources: The Permittee of a new affected source shall submit a notification of compliance status as specified in 63.9 if the Permittee is complying with organic HAP contents limits, application equipment requirements or organic HAP emissions limit other than organic HAP emission limit averaging by May 21, 2004, or no later than one year and 30 days after the date of initial startup of the affected source, whichever is later. Notification of Changes to Previous Notifications: The Permittee must submit the changes in writing to the Administrator within 15 calendar days after the change, if the Permittee changed any information submitted in any previous notification. 63.9(h); (a) and Table 13 to 40 CFR pt. 63, subp. WWWW; Minn. R (h); (a) and Table 13 to 40 CFR pt. 63, subp. WWWW; Minn. R (h); (a) and Table 13 to 40 CFR pt. 63, subp. WWWW; Minn. R (h); (a) and Table 13 to 40 CFR pt. 63, subp. WWWW; Minn. R (b); Minn. R Page 126

127 What to do Semiannual Compliance Report: due 31 days after the end of each calendar half year starting on the compliance date for each affected source. The report shall contain the information specified below: (1) Company name and address; (2) Statement by a responsible official with that official s name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report; (3) Date of the report and beginning and ending dates of the reporting period; (4) If there was a startup, shutdown, or malfunction during the reporting period and the Permittee took actions consistent with the startup, shutdown, and malfunction plan, the compliance report shall include the information in 40 CFR Section 63.10(d)(5)(i); (5) If there are no deviations from any applicable organic Hap emissions limitations (emissions limit and operating limit), and there are no deviations from the requirements in the Work Practice Standards section above, a statement that there were no deviations from the organic HAP emissions limitations or work practice standards during the reporting period; (6) For each deviation from an organic HAP emissions limitation and each deviation from the requirements for work practice standards that occurs at an affected source, the total operating time of each affected source during the reporting period and information on the number, duration, and cause of deviations (including unknown cause, if applicable) as applicable, and the corrective action taken; (7) If organic HAP emissions in the fiberglass operations at the facility have exceeded the 100 tpy emission threshold; and (8) Where multiple compliance options are available, a statement if the Permittee has changed compliance options since the last compliance report. Immediate Startup, Shutdown, and Malfunction Report: The Permittee shall submit to the MPCA actions taken for the event by fax or telephone within 2 working days after starting actions inconsistent with the plan. Immediate Startup, Shutdown, and Malfunction Report: The Permittee shall submit the information in 40 CFR 63.10(d)(5)(ii) by letter within 7 working days after the end of the event unless the Permittee has made alternative arrangements with the MPCA. s (a) (d) and (f) (i); Minn. R CFR pt. 63, subp. WWWW: section (h) and Table 14; Minn. R CFR pt. 63, subp. WWWW: section (h) and Table 14; 63.10(d)(5)(ii); Minn. R Page 127

128 A.5 Engines Form MG 05B4 The following are Minnesota Standards of Performance for Stationary Internal Combustion Engines A.5.1 Engines Stationary Internal Combustion Engines What to do Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input. Minn. R , subp. 2 Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. Fuel type: No. 2 fuel oil/diesel fuel meeting the requirements of (c) or biodiesel only, and having less than or equal to 15 ppm sulfur. Minn. R , subp. 1 Minn. R , subp. 35a; to qualify for this general permit under Minn. R , and Minn. R , subp. 2 Page 128

129 The following are National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (40 CFR pt. 63, subp. ZZZZ) and Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (40 CFR pt. 60, subp. IIII) A.5.2 Engines Stationary Internal Combustion Engines subject to NESHAP ZZZZ and/or NSPS IIII Requirements for the following engine types are included in this General Permit: Existing, major source, 100 hp 300, non emergency, compression ignition (CI) stationary engines Existing, major source < 500 hp, emergency, CI engines New (model year 2014 or later), major source, < 500 hp, non emergency, CI stationary engines with a displacement of less than 30 liters per cylinder New (model year 2014 or later), major source, < 500 hp, emergency, CI stationary engines with a displacement of less than 30 liters per cylinder New (model year 2014 or later), major source, < 500 hp, fire pump, CI stationary engines with a displacement of less than 30 liters per cylinder Affected source (40 CFR pt. 63, subp. ZZZZ): any existing or new stationary RICE located at a major or area source of HAP emissions, excluding stationary RICE being tested at a stationary RICE test cell/stand. New Source (40 CFR pt. 63, subp. ZZZZ): constructed or reconstructed on or after June 12, 2006 Existing sources (40 CFR pt. 63, subp. ZZZZ): constructed or reconstructed before June 12, 2006 Affected source (40 CFR pt. 60, subp. IIII): any stationary CI ICE that commence construction after July 11, 2005, where the stationary CI ICE are manufactured after January 1, For the purposes of 40 CFR pt. 60, subp. IIII, the date that construction commences is the date the engine is ordered by the Permittee. Definitions: see 40 CFR section and 40 CFR section A Engines Existing CI stationary engines < 500 hp What to do The Permittee shall comply with the applicable emission and operational limitations from 40 CFR pt. 63, subp. ZZZZ no later than May 3, OPERATING REQUIREMENTS The Permittee shall be in compliance with the emission limitations and operating limitations in 40 CFR pt. 63, subp. ZZZZ that apply at all times. 40 CFR section (a); Minn. R hdr 40 CFR section (a); Minn. R Page 129

130 What to do At all times the Permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the Permittee to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. The Permittee shall minimize the engine s time spent at idle during startup and minimize the engine s startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup apply. The Permittee shall demonstrate continuous compliance with each emission limitation, operating limitation, and other requirements in Tables 1a and 1b, Tables 2a and 2b, Table 2c and Table 2d of 40 CFR pt. 63, subp. ZZZZ that apply according to the methods specified in Table 6 of 40 CFR pt. 63, subp. ZZZZ. General Provisions Appendix: This permit contains an appendix which lists the requirements of the general provisions in s 63.1 through 63.15, and shows which parts of the general provisions apply to sources subject to 40 CFR pt. 63, subp. ZZZZ. The Permittee shall comply with all applicable requirements contained in the General Provisions Appendix (Appendix B). RECORDKEEPING REQUIREMENTS The Permittee shall maintain the following records: 1. A copy of each notification and report submitted to comply with this subpart, including all documentation supporting any Initial Notification or Notification of Compliance Status submitted, according to the requirement in 40 CFR section 63.10(b)(2)(xiv). 2. Records of the occurrence and duration of each malfunction of operation or the air pollution control and monitoring equipment. 3. Records of performance tests and performance evaluations as required in 40 CFR section 63.10(b)(2)(viii). 4. Records of all required maintenance performed on the air pollution control and monitoring equipment. Records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR section (b), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. 40 CFR section (b); Minn. R CFR section (h); Minn. R CFR section (a) , Table 8 to 40 CFR pt. 63, subp. ZZZZ; Minn. R ; Minn. R , subp. 2 hdr 40 CFR section (a); Minn. R Page 130

131 What to do The Permittee shall maintain all records in a form suitable and readily available for expeditious review according to 40 CFR section 63.10(b)(1). As specified in 40 CFR section 63.10(b)(1), the Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. 40 CFR section ; 40 CFR section 63.10(b)(1); Minn. R ; Minn. R , subp. 2(B) The Permittee shall keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to 40 CFR section 63.10(b)(1). REPORTING REQUIREMENTS The Permittee shall report each instance in which the stationary RICE did not meet each applicable emission limitation or operating limitation. These instances are deviations from the emission and operating limitations. These deviations shall be reported according to the requirements in 40 CFR section The Permittee shall report each instance when the applicable requirements in Table 8 of 40 CFR pt. 63, subp. ZZZZ were not met. hdr 40 CFR section (b); Minn. R CFR section (e); 40 CFR pt. 63, subp. ZZZZ, Table 8; Minn. R A Engines Existing CI non emergency stationary engines 100 hp 300, complying by using diesel oxidation catalyst What to do EMISSION AND OPERATING LIMITATIONS Carbon Monoxide: less than or equal to 230 parts per million, volumetric, dry at 15 percent oxygen. Pressure Drop: within 2 inches of water column plus or minus 10 percent from the pressure drop across the catalyst that was measured at 100 percent load during the performance test. (for example, if the pressure drop measured during the performance test was 5 in. W.C., then the pressure drop range would be 2.5 to 7.5 in. W.C.) hdr 40 CFR section ; 40 CFR pt. 63, subp. ZZZZ, Table 2c; Minn. R Minn. R , subp. 2 Page 131

132 What to do Temperature: greater than or equal to 450 degrees Fahrenheit and less than or equal to 1350 degrees Fahrenheit. The Permittee shall comply with the CO emission limit. Compliance is based on the results of testing the average of three 1 hour runs using the testing requirements and procedures in 40 CFR section and Table 4 of 40 CFR pt. 63, subp. ZZZZ. PERFORMANCE TESTING REQUIREMENTS The Permittee shall conduct the initial performance test according to Tables 4 and 5 of 40 CFR pt. 63, subp. ZZZZ. Initial Performance Test: due 180 days after May 3, 2013, and according to the provisions in 40 CFR section 63.7(a)(2). An initial performance test on units for which a performance test has been previously conducted is not required if the test meets all of the conditions described below: 1. The test must have been conducted using the same methods specified in 40 CFR pt. 63, subp. ZZZZ, and these methods must have been followed correctly. 2. The test must not be older than 2 years. 3. The test must be reviewed and accepted by the Administrator. Either no process or equipment changes have been made since the test was performed, or the owner or operator must be able to demonstrate that the results of the performance test, with or without adjustments, reliably demonstrate compliance despite process or equipment changes. The Permittee shall conduct each performance test in Table 4 of 40 CFR pt. 63, subp. ZZZZ that applies. Each performance test shall be conducted according to the requirements specified in 40 CFR section and Table 4 of 40 CFR pt. 63, subp. ZZZZ. Minn. R , subp CFR section ; Minn. R hdr 40 CFR section (a); 40 CFR pt. 63, subp. ZZZZ, Table 4; Minn. R CFR section (a); Minn. R CFR section (b); Minn. R CFR section (a), (b), and (d); 40 CFR pt. 63 subp. ZZZZ, Tables 3 and 4; Minn. R The Permittee shall conduct three separate test runs for each performance test required by 40 CFR pt. 63, subp. ZZZZ, as specified in 40 CFR section 63.7(e)(3). Each test run shall last at least 1 hour. The engine percent load during a performance test shall be determined by documenting the calculations, assumptions, and measurement devices used to measure or estimate the percent load in a specific application. A written report of the average percent load determination shall be included in the notification of compliance status. The information required by 40 CFR section (i) shall be included in the written report 40 CFR section (i); Minn. R Page 132

133 What to do MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS The Permittee shall submit all of the notifications in 40 CFR section 63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e) and (g) and (h) that apply by the dates specified. Notification of Intent to conduct a performance test: due 60 days before Performance Test as required in 40 CFR section 63.7(b)(1). Notification of Compliance Status: due 60 days after Initial Performance Test for each initial compliance demonstration, including performance test results. The notification shall be sent to the Commissioner as specified in 40 CFR section 63.10(d)(2). The results of the performance test shall be submitted as part of the notification of compliance status required un 40 CFR section 63.9(h). The Permittee shall submit each report in Table 7 of 40 CFR pt. 63, subp. ZZZZ, as applicable. Semiannual Compliance Report: due 31 days after each calendar half year starting May 3, The report shall cover the semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. Each subsequent Compliance report shall be postmarked or delivered no later than July 31 or January 31, whichever date is the first date following the end of the semiannual reporting period. The Semiannual Compliance report shall contain the following information: 1. Company name and address 2. Statement by a responsible official, with that official s name, title, and signature, certifying the accuracy of the content of the report. 3. Date of report and beginning and ending dates of the reporting period. 4. If the engine or associated equipment malfunctioned during the reporting period, the compliance report shall include the number, duration, and brief description of each type of malfunction that occurred during the reporting period and what caused or may have caused any applicable emission limitation to be exceeded. The report shall also include a description of actions taken by the Permittee during a malfunction of an affected source to minimize emissions in accordance with 40 CFR section (b), including actions taken to correct a malfunction. 5. If there were no deviations from any emission or operating limitations that apply, a statement that there were no deviations from the emission or operating limitations during the reporting period. hdr 40 CFR section (a); Minn. R CFR section (g); Minn. R CFR section (c); 40 CFR section (h)(2); Minn. R CFR (a); 40 CFR pt. 63 subp. ZZZZ, Table 7; Minn. R CFR section (b)(1) (4); Minn. R CFR section (c); Minn. R Page 133

134 What to do For each deviation from an emission or operating limitation, the Compliance report shall contain the information in paragraphs (c)(1) through (c)(4) of 40 CFR section and the information the following information: 1. The total operating time of the stationary RICE at which the deviation occurred during the reporting period. 2. Information on the number, duration and cause of deviations (including unknown cause, if applicable), as applicable, and the corrective action taken. 40 CFR section (d) and (f); Minn. R A Engines Existing CI emergency engines < 500 hp What to do EMISSION AND OPERATING LIMITATIONS Change oil and filter every 500 hours of operation or annually, whichever comes first. The Permittee has the option of utilizing an oil analysis program as described in 40 CFR section (i) in order to extend the oil change requirement as described in Table 2c of 40 CFR pt. 63, subp. ZZZZ. The Permittee has the option to utilize an oil analysis program described by this permit in order to extend the specified oil change requirement. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. The Permittee shall minimize the engine s time spent at idle during startup and minimize the engine s startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the non startup emission limitations apply. The Permittee shall report any failure to perform the work practice on the schedule required in 40 CFR pt. 63, Table 2c due to an emergency or an unacceptable risk under Federal, State or local law. The work practice shall be performed as soon as practicable after the emergency has ended or the unacceptable risk under Federal, State, or local law has abated. hdr 40 CFR section ; 40 CFR pt. 63, subp. ZZZZ, Table 2c; Minn. R CFR section ; 40 CFR pt. 63, subp. ZZZZ, Table 2c; Minn. R CFR section ; 40 CFR pt. 63, subp. ZZZZ, Table 2c; Minn. R CFR section (h); 40 CFR section ; 40 CFR pt. 63, subp. ZZZZ, Table 2c; Minn. R CFR section ; 40 CFR pt. 63, subp. ZZZZ, Table 2c; Minn. R Page 134

135 What to do Beginning January 1, 2015, for engines with a site rating of more than 100 brake hp and a displacement of less than 30 liters per cylinder and operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in 40 CFR section (f)(2)(ii) and (iii), the Permittee shall use nonroad diesel fuel only, except that any existing diesel fuel purchased prior to January 1, 2015, may be used until depleted. Nonroad diesel fuel: The Permittee shall use diesel fuel that meets the requirements of 40 CFR section (b) for nonroad diesel fuel only: (1) Sulfur content: maximum of 15 ppm (2) Cetane index or aromatic content: minimum cetane index of 40 or maximum aromatic content of 35 volume percent. The Permittee shall obtain from the manufacturer/distributer and maintain onsite certification from each diesel fuel delivery that the diesel fuel meets the above specifications for all fuel used in engines with a site rating of more than 100 brake hp and a displacement of less than 30 liters per cylinder and operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in 40 CFR section (f)(2)(ii) and (iii). The Permittee shall operate and maintain the stationary RICE and after treatment control device (if any) according to the manufacturer s emission related written instructions or develop a maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. The Permittee shall install a non resettable hour meter if one is not already installed by May 3, The Permittee has the option of utilizing an oil analysis program in order to extend the specified oil change requirement. The oil analysis shall be performed at the same frequency specified for changing the oil. The analysis program shall at a minimum analyze the following 3 parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. If none of the condemning limits are exceeded, the Permittee is not required to change the oil. If any of the limits are exceeded, the Permittee shall change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the Permittee shall change the oil within 2 business days or before commencing operation, whichever is later. The Permittee shall keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program shall be part of the maintenance plan for the engine. 40 CFR section (b); Minn. R CFR section (e); Minn. R CFR section (f); Minn. R CFR section (i); Minn. R Page 135

136 What to do The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, but is not limited to: 1. The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere; 2. The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions. REQUIREMENTS FOR EMERGENCY STATIONARY RICE The Permittee shall operate the emergency stationary RICE according to the requirements in paragraphs 40 CFR section (f)(1) through (4) of 40 CFR section (f). Any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non emergency situations for 50 hours per year, as described in 40 CFR section (f)(1) through (4), is prohibited. If the engine is not operated according to the requirements in 40 CFR section (f)(1) through (4), the engine will not be considered an emergency engine under 40 CFR pt. 63, subp. ZZZZ and will need to meet all requirements for non emergency engines. 40 CFR section ; 40 CFR section 63.4(b); Minn. R hdr 40 CFR section (f); Minn. R Page 136

137 What to do (1) There is no time limit on the use of emergency stationary RICE in emergency situations. (2) The Permittee may operate the emergency stationary RICE for any combination of the purposes specified in paragraphs (i) through (iii) below for a maximum of 100 hours per calendar year. Any operation for non emergency situations as allowed by paragraph (3) of this permit counts as part of the 100 hours per calendar year allowed by this paragraph. i. The Permittee may operate the emergency stationary RICE for the purpose of maintenance checks and readiness testing, provided that the tests are recommended by Federal, State or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The Permittee may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indication that Federal, State, or local standards require maintenance and testing of emergency RICE beyond 100 hours per year. ii. Emergency stationary RICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP 002 3, Capacity and Energy Emergencies (incorporated by reference, see section 63.14), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined iii. in the NERC Reliability Standard EOP Emergency stationary RICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. (3) The Permittee may operate the emergency stationary RICE up to 50 hours per calendar year in non emergency situations, but those 50 hours are counted towards the 100 hours per calendar year provided for maintenance and testing and emergency demand response provided in 40 CFR section (f)(2). The 50 hours per year for non emergency situations cannot be used for peak shaving or non emergency demand response, or to generate income for a facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity. 40 CFR section (f); Minn. R Page 137

138 What to do MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS If the Permittee operates the emergency stationary RICE or is contractually obligated to make the emergency station RICE available for more than 15 hours per year for the purposes specified in 40 CFR section (f)(2)(ii) and (iii), the Permittee shall submit a report to the commissioner that contains the information in 40 CFR section (h)(1) annually according to the requirements in 40 CFR section (h)(2) (3). 1. The report shall contain the following information: a. Company name and address where the engine is located. b. Date of the report and beginning and ending dates of the reporting period. c. Engine site rating and model year. d. Latitude and longitude of the engine in decimal degrees reported to the fifth decimal place. e. Hours operated for the purposes specified in 40 CFR section (f)(2)(ii) and (iii), including the date, start time, and end time for engine operation for the purposes specified in 40 CFR section (f)(2)(ii) and (iii). f. Number of hours the engine is contractually obligated to be available for the purposes specified in 40 CFR section (f)(2)(ii) and (iii). g. If there were no deviations from the fuel requirements in 40 CFR section that apply to the engine, a statement that there were no deviations from the fuel requirements during the reporting period. h. If there were deviations from the fuel requirements in 40 CFR section that apply to the engine, information on the number, duration, and cause of deviations, and the corrective action taken. 2. The first annual report shall cover the calendar year 2015 and shall be submitted no later than March 31, Subsequent annual reports for each calendar year shall be submitted no later than March 31 of the following calendar year. 3. The annual report shall be submitted electronically using the subpart specific reporting form in the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA s Central Data Exchange (CDX) ( However, if the reporting form specific to this engine is not available in CEDRI at the time that the report is due, the written report shall be submitted to the Administrator at the appropriate address listed in 40 CFR section The Permittee shall keep the records required in Table 6 of 40 CFR pt. 63, subp. ZZZZ, to show continuous compliance with each emission or operating limitation that applies. hdr 40 CFR section (a); 40 CFR pt. 63, subp. ZZZZ, Table 7; Minn. R CFR section (d); Minn. R Page 138

139 What to do The Permittee shall keep records of the maintenance conducted on the stationary RICE in order to demonstrate that the Permittee operated and maintained the stationary RICE and after treatment control device (if any) according to the maintenance plan. The Permittee shall keep records of the hours of operation of the engine that are recorded through the non resettable hour meter. The Permittee shall document how many hours are spent for emergency operation; including what classified the operation as emergency and how many hours are spent for non emergency operation. If the engine is used for the purposes specified in 40 CFR section (f)(2)(ii) or (iii) or 40 CFR section (f)(4)(ii), the Permittee shall keep records of the notification of the emergency situation, and the date, start time, and end time of engine operation for these purposes. 40 CFR section (e); Minn. R CFR section (f); Minn. R A Engines New CI stationary engines < 500 hp, displacement < 30 liters per cylinder What to do The Permittee shall meet the requirements of 40 CFR pt. 63, subp. ZZZZ for new compression ignition stationary RICE with a site rating of less than or equal to 500 brake hp located at a major source of HAP emissions by meeting the requirements of 40 CFR pt. 60, subp. IIII. No further requirements of 40 CFR pt. 63, subp. ZZZZ apply to new compression ignition stationary RICE with a site rating of less than or equal to 500 brake hp located at a major source of HAP emissions. The Permittee shall operate and maintain the stationary CI ICE so that the stationary CI ICE meet the emission standards as required in 40 CFR section over the entire life of the engine. The Permittee shall use diesel fuel that meets the requirements of 40 CFR section (b) for nonroad diesel fuel only: (1) Sulfur content: maximum of 15 ppm (2) Cetane index or aromatic content: minimum cetane index of 40 or maximum aromatic content of 35 volume percent. The Permittee shall obtain from the manufacturer/distributer and maintain onsite certification from each diesel fuel delivery that the diesel fuel meets the above specifications for all fuel used in new CI stationary engines less than 500 hp and displacement less than 30 liters per cylinder 40 CFR section (c); Minn. R CFR section ; Minn. R CFR section (b); 40 CFR section (b); Minn. R Page 139

140 What to do If a diesel particulate filter is used to comply with the emission standards in 40 CFR section , the Permittee shall install the diesel particulate filter with a backpressure monitor that notifies the Permittee when the high backpressure limit of the engine is approached. The Permittee shall comply with the emission standards specified in 40 CFR pt. 60, subp. IIII and shall: 1. Operate and maintain the stationary CI internal combustion engine and control device according to the manufacturer s emission related written instructions; 2. Change only those emission related settings that are permitted by the manufacturer; and 3. Meet the requirements of 40 CFR pt. 89 as applicable. RECORDKEEPING REQUIREMENTS If the stationary CI internal combustion engine is equipped with a diesel particulate filter, the Permittee shall keep records of any corrective action taken after the backpressure monitor has notified the Permittee that the high backpressure limit of the engine is approached. GENERAL PROVISIONS Circumvention: The Permittee shall not build, erect, install, or use any article, machine equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. 40 CFR section (b); Minn. R CFR section (a); Minn. R hdr 40 CFR section (c); Minn. R hdr 40 CFR section 60.12; Minn. R Page 140

141 A Engines New CI non emergency stationary engines < 500 hp, displacement <30 liters per cylinder What to do EMISSION AND OPERATING LIMITATIONS The Permittee shall comply with the emission standards for new CI engines for 2014 model year stationary CI ICE with a displacement of less than 10 liters per cylinder as follows: Emission standards for model year 2014 engines: a. Maximum engine power < 8 kw: i. PM: less than or equal to 0.40 g/kw hr ii. NOx + NMHC: less than or equal to 7.5 g/kw hr iii. CO: less than or equal to 8.0 g/kw hr b. Maximum engine power 8 kw < 19: i. PM: less than or equal to 0.40 g/kw hr ii. NOx + NMHC: less than or equal to 7.5 g/kw hr iii. CO: less than or equal to 6.6 g/kw hr c. Maximum engine power 19 kw < 37: i. PM: less than or equal to 0.03 g/kw hr ii. NOx + NMHC: less than or equal to 4.7 g/kw hr iii. CO: less than or equal to 5.5 g/kw hr d. Maximum engine power 37 kw < 56: iv. PM: less than or equal to 0.03 g/kw hr v. NOx + NMHC: less than or equal to 4.7 g/kw hr vi. CO: less than or equal to 5.0 g/kw hr e. Maximum engine power 56 kw < 130: i. PM: less than or equal to 0.02 g/kw hr ii. NOx: less than or equal to 0.40 g/kw hr iii. NMHC: less than or equal to 0.19 g/kw hr iv. CO: less than or equal to 5.0 g/kw hr f. Maximum engine power 130 kw < 373: i. PM: less than or equal to 0.02 g/kw hr ii. NOx: less than or equal to 0.40 g/kw hr iii. NMHC: less than or equal to 0.19 g/kw hr iv. CO: less than or equal to 3.5 g/kw hr hdr 40 CFR section (b); 40 CFR section ; 40 CFR section ; 40 CFR section ; Minn. R Page 141

142 What to do The Permittee shall comply with the emission standards for new CI engines for 2014 model year and later stationary CI ICE with a displacement of less than 10 liters per cylinder as follows: Smoke emission standard: 1. Exhaust opacity from CI engines shall not exceed: a. 20 percent during the acceleration mode; b. 15 percent during the lugging mode; c. 50 percent during the peaks in either the acceleration or lugging modes. 2. Opacity levels shall be measured and calculated as set forth in 40 CFR pt. 86, subp. I. The Permittee shall comply with the emission standards for new CI engines for 2015 model year and later stationary CI ICE with a displacement of less than 10 liters per cylinder as follows: Emission standards for model year 2015 and later engines: a. Maximum engine power < 19 kw: i. PM: less than or equal to 0.40 g/kw hr ii. NOx + NMHC: less than or equal to 7.5 g/kw hr iii. CO: less than or equal to 6.6 g/kw hr b. Maximum engine power 19 kw < 56: i. PM: less than or equal to 0.03 g/kw hr ii. NOx + NMHC: less than or equal to 4.7 g/kw hr iii. CO: less than or equal to 5.0 g/kw hr c. Maximum engine power 56 kw < 130: i. PM: less than or equal to 0.02 g/kw hr ii. NOx: less than or equal to 0.40 g/kw hr iii. NMHC: less than or equal to 0.19 g/kw hr iv. CO: less than or equal to 5.0 g/kw hr d. Maximum engine power 130 kw < 373: i. PM: less than or equal to 0.02 g/kw hr ii. NOx: less than or equal to 0.40 g/kw hr iii. NMHC: less than or equal to 0.19 g/kw hr iv. CO: less than or equal to 3.5 g/kw hr 40 CFR section (b); 40 CFR section ; 40 CFR section ; 40 CFR section ; Minn. R CFR section (b); 40 CFR section ; 40 CFR section ; Minn. R Page 142

143 What to do The Permittee shall comply with the emission standards for new CI engines for 2014 model year and later stationary CI ICE with a displacement of less than 10 liters per cylinder as follows: a. Crankcase emissions: The Permittee shall not discharge crankcase emissions directly into the ambient atmosphere from any engine throughout the useful life of the crankcase. b. Adjustable parameters: Engines that have adjustable parameters shall meet all the requirements of 40 CFR pt for any adjustment in the physically adjustable range. An operating parameter is not considered adjustable if you permanently seal it or if it is not normally accessible using ordinary tools. The MPCA may require that adjustable parameters are set to any specification within the adjustable range during any testing, including certification testing, selective enforcement auditing, or in use testing. c. Prohibited controls: The Permittee shall not design engines with emissioncontrol devices, systems, or elements of design that cause or contribute to an unreasonable risk to public health, welfare, or safety while operating. d. Defeat devices: The Permittee shall not equip engines with a defeat device. The Permittee shall comply with the emission standards for new CI engines for 2014 model year and later stationary CI ICE with a displacement of greater than or equal to 10 liters per cylinder and less than 30 liters per cylinder as follows: a. Engine displacement 10.0 liters/cylinder < 15.0 i. PM: less than or equal to 0.14 g/kw hr ii. NOx + HC: less than or equal to 6.2 g/kw hr b. Engine displacement 15.0 liters/cylinder < 20.0 i. PM: less than or equal to 0.34 g/kw hr ii. NOx + HC: less than or equal to 7.0 g/kw hr c. Engine displacement 20.0 liters/cylinder < 25.0 i. PM: less than or equal to 0.27 g/kw hr ii. NOx + HC: less than or equal to 9.8 g/kw hr d. Engine displacement 25.0 liters/cylinder < 30.0 i. PM: less than or equal to 0.27 g/kw hr ii. NOx + HC: less than or equal to 11.0 g/kw hr New CI engines for 2014 model year and later stationary CI ICE with a displacement of greater than or equal to 10 liters per cylinder and less than 30 liters per cylinder equipped with SCR systems using a reductant other than the engine s fuel shall meet the requirements of 40 CFR section , as applicable. 40 CFR section (b); 40 CFR section ; 40 CFR section ; Minn. R CFR section (b); 40 CFR section (e)(2); 40 CFR section ; Minn. R CFR section (b); 40 CFR section (e)(2); 40 CFR section ; Minn. R Page 143

144 What to do The Permittee shall comply with the emission standards for new CI engines for 2014 model year and later stationary CI ICE with a displacement of greater than or equal to 10 liters per cylinder and less than 30 liters per cylinder as follows: e. Crankcase emissions: The Permittee shall not discharge crankcase emissions directly into the ambient atmosphere from any engine throughout the useful life of the crankcase. f. Torque broadcasting: electronically controlled engines shall broadcast their speed and output shaft torque (in newton meters). Engines shall broadcast engine parameters such that they can be read with a remote device, or broadcast them directly to their controller are networks. g. EPA access to broadcast information: If requested by the EPA, the Permittee shall provide any hardware or tools needed by EPA to readily read, interpret, and record all information broadcast by an engine s on board computers and electronic control modules. h. Adjustable parameters: An operating parameter is not considered adjustable if you permanently seal it or if it is not normally accessible using ordinary tools. 1. Category 1 engines that have adjustable parameters must meet all the requirements of this part for any adjustment in the physically adjustable range. The EPA may require that the Permittee set adjustable parameters to any specification within the adjustable range during any testing, including certification testing, selective enforcement auditing, or in use testing. 2. Category 2 and Category 3 engines that have adjustable parameters shall meet all the requirements of 40 CFR section for any adjustment in the specified adjustable range. The Permittee shall specify in the application for certification the adjustable range of each adjustable parameter on a new engine to i. Ensure that safe engine operating characteristics are available within that range, as required by section 202(a)(4) of the Clean Air Act (42 U.S.C. 7521(a)(4)), taking into consideration the production tolerances. ii. Limit the physical range of adjustability to the maximum extent practicable to the range that is necessary for proper operation of the engine. i. Prohibited controls: The Permittee shall not design engines with emissioncontrol devices, systems, or elements of design that cause or contribute to an unreasonable risk to public health, welfare, or safety while operating. j. Defeat devices: The Permittee shall not equip engines with a defeat device. k. On off controls for Category 3 engines: The Permittee shall not install or operate an engine with features that disable Tier 3 NOx emission controls. The Permittee shall comply with the emission standards specified in 40 CFR section (b) by purchasing an engine certified to the emission standards in 40 CFR section (b) for the same model year and maximum engine power. The engine shall be installed and configured according to the manufacturer s emission related specifications. 40 CFR section (b); 40 CFR section (e)(2); 40 CFR section ; Minn. R CFR section (c); Minn. R Page 144

145 What to do GENERAL PROVISIONS Notification of the Date Construction (or reconstruction) Began: due 30 days after start of construction (or reconstruction). The Permittee shall submit the name and number of each unit and the date construction of each unit began. Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. Notification of Anticipated Date for Conducting Opacity Observations: due 30 day prior to observation date Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records for at least five years. 60.7(f) specifies two years. The Permittee shall not build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. hdr 60.7(a)(1); Minn. R , subp (a)(3); Minn. R , subp (a)(4); Minn. R , subp (a)(6); Minn. R , subp (b), Minn. R , subp. 1 Minn. R , subp. 5(C); meets requirements of 40 CFR Section 60.7(f); Minn. R , subp ; Minn. R Page 145

146 A Engines New CI emergency stationary engines < 500 hp that are not fire pumps What to do EMISSION AND OPERATING LIMITATIONS The Permittee shall comply with the emission standards for new CI engines for 2008 model year and later stationary CI ICE, with maximum engine power less than 37 kw, with a displacement of less than 30 liters per cylinder that are not fire pump engines as follows: Emission standards for model year 2008 and later engines: a. Maximum engine power < 8 kw: i. NMHC + NOx: less than or equal to 7.5 g/kw hr ii. CO: less than or equal to 8.0 g/kw hr iii. PM: less than or equal to 0.40 g/kw hr b. Maximum engine power 8 kw < 19: i. NMHC + NOx: less than or equal to 7.5 g/kw hr ii. CO: less than or equal to 6.6 g/kw hr iii. PM: less than or equal to 0.40 g/kw hr c. Maximum engine power 19 kw < 37: i. NMHC + NOx: less than or equal to 7.5 g/kw hr ii. CO: less than or equal to 5.5g/kW hr iii. PM: less than or equal to 0.30 g/kw hr The Permittee shall comply with the emission standards for new CI engines for 2008 model year and later stationary CI ICE, with maximum engine power less than 37 kw, with a displacement of less than 30 liters per cylinder that are not fire pump engines as follows: Emission standards for model year 2008 and later engines: Smoke emission standard: a. Measure smoke as specified in 40 CFR section (c). Smoke from an engine shall not exceed: i. 20 percent during the acceleration mode; ii. 15 percent during the lugging mode; iii. 50 percent during the peaks in either the acceleration or lugging modes. hdr 40 CFR section (b); 40 CFR section (a)(1)(ii); 40 CFR pt. 60, subp. IIII, Table 2; Minn. R CFR section (b); 40 CFR section (a)(1)(ii); 40 CFR section (b); Minn. R Page 146

147 What to do The Permittee shall comply with the emission standards for new CI engines for 2008 model year and later stationary CI ICE with a displacement of less than 30 liters per cylinder as follows: a. Crankcase emissions: The Permittee shall not discharge crankcase emissions directly into the ambient atmosphere from any engine throughout the useful life of the crankcase. b. Adjustable parameters: Engines that have adjustable parameters shall meet all the requirements of 40 CFR pt for any adjustment in the physically adjustable range. An operating parameter is not considered adjustable if it is permanently sealed or if it is not normally accessible using ordinary tools. The MPCA may require that adjustable parameters are set to any specification within the adjustable range during any testing, including certification testing, selective enforcement auditing, or in use testing. c. Prohibited controls: The Permittee shall not design engines with emissioncontrol devices, systems, or elements of design that cause or contribute to an unreasonable risk to public health, welfare, or safety while operating. Defeat devices: The Permittee shall not equip engines with a defeat device. The Permittee shall comply with the emission standards for new CI engines for 2007 model year and later stationary CI ICE, with maximum engine power greater than 37 kw, with a displacement of less than 30 liters per cylinder that are not fire pump engines as follows: Emission standards for model year 2008 and later engines: a. Maximum engine power 37 kw < 75: i. NOx + NMHC: less than or equal to 4.7 g/kw hr ii. CO: less than or equal to 5.0 g/kw hr iii. PM: less than or equal to 0.40 g/kw hr b. Maximum engine power 75 kw < 130: i. NOx + NMHC: less than or equal to 4.0 g/kw hr ii. CO: less than or equal to 5.0 g/kw hr iii. PM: less than or equal to 0.3 g/kw hr c. Maximum engine power 130 kw < 225: i. NOx + NMHC: less than or equal to 4.0 g/kw hr ii. CO: less than or equal to 3.5 g/kw hr iii. PM: less than or equal to 0.20 g/kw hr d. Maximum engine power 225 kw < 373: i. NOx + NMHC: less than or equal to 4.0 g/kw hr ii. CO: less than or equal to 3.5 g/kw hr iii. PM: less than or equal to 0.20 g/kw hr 40 CFR section (b); 40 CFR section (a)(1)(ii); 40 CFR section ; Minn. R CFR section (b); 40 CFR section ; 40 CFR section ; Minn. R Page 147

148 What to do The Permittee shall comply with the emission standards for new CI engines for 2007 model year and later stationary CI ICE, with maximum engine power greater than 37 kw, with a displacement of less than 30 liters per cylinder that are not fire pump engines as follows: Smoke emission standard: a. Exhaust opacity from CI engines shall not exceed: i. 20 percent during the acceleration mode; ii. 15 percent during the lugging mode; iii. 50 percent during the peaks in either the acceleration or lugging modes. b. Opacity levels shall be measured and calculated as set forth in 40 CFR pt. 86, subp. I. The Permittee shall install a non resettable hour meter prior to startup of any emergency stationary CI internal combustion engine that does not meet the standards applicable to non emergency engines. 40 CFR section (b); 40 CFR section ; 40 CFR section ; Minn. R CFR section (a); Minn. R Page 148

149 What to do EMERGENCY ENGINE REQUIREMENTS The Permittee shall operate the emergency ICE according to paragraphs (1) through (3) below. In order for the engine to be considered an emergency stationary ICE under 40 CFR pt. 60, subp. IIII, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in nonemergency situations for 50 hours per year, as described in paragraphs (1) through (3) below, is prohibited. If you do not operate the engine according to the requirements in paragraphs (1) through (3) below, the engine will not be considered an emergency engine under this subpart and must meet all requirements for nonemergency engines. 1. There is no time limit on the use of emergency stationary ICE in emergency situations. 2. The Permittee may operate emergency stationary ICE for any combination of the purposes specified in (i) through (iii) below for a maximum of 100 hours per calendar year. Any operation for non emergency situations as allowed by paragraph (3) below counts as part of the 100 hours per calendar year allowed by this paragraph. i. Emergency stationary ICE may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The Permittee may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar year. ii. Emergency stationary ICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP 002 3, Capacity and Energy Emergencies (incorporated by reference, see section 60.17), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP iii. Emergency stationary ICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. (Continued on next page) hdr 40 CFR section (f); Minn. R Page 149

150 What to do 3. Emergency stationary ICE may be operated for up to 50 hours per calendar year in non emergency situations. The 50 hours of operation in nonemergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in 40 CFR section (2). Except as provided in paragraph (3)(i) below, the 50 hours per calendar year for non emergency situations cannot be used for peak shaving or non emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. i. The 50 hours per year for non emergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met: A. The engine is dispatched by the local balancing authority or local transmission and distribution system operator. B. The dispatch is intended to mitigate local transmission and/or distribution limitations to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. C. The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. D. The power is provided only to the facility itself or to support the local transmission and distribution system. E. The Permittee identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator. RECORDKEEPING REQUIREMENTS The Permittee shall keep records of the operation of the engine in emergency and non emergency service that are recorded through the non resettable hour meter. The Permittee shall record the time of operation of the engine and the reason the engine was in operation during that time. 40 CFR section (f); Minn. R (continued) hdr 40 CFR section (b); Minn. R Page 150

151 What to do Engines with a maximum engine power greater than 100 hp, or engines that are contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in 40 CFR section (f) (2)(i) and (2)(ii), the Permittee shall submit an annual report according to the requirements in paragraphs (1) through (3) below: 1. The Permittee shall include the following information in the report: a. Company name and address where the engine is located. b. Date of the report and beginning and ending dates of the reporting period. c. Engine site rating and model year. d. Latitude and longitude of the engine in decimal degrees reported to the fifth decimal place. e. Hours operated for the purposes specified in 40 CFR section (f)(2)(ii) and (iii), including the date, start time, and end time for engine operation for the purposes specified in 40 CFR section (f)(2)(ii) and (iii). f. Number of hours the engine is contractually obligated to be available for the purposes specified in 40 CFR section (f)(2)(ii) and (iii). g. Hours spent for operation for the purposes specified in section (f)(3)(i), including the date, start time, and end time for engine operation for the purposes specified in section (f)(3)(i). The report must also identify the entity that dispatched the engine and the situation that necessitated the dispatch of the engine. 2. The first annual report shall cover the calendar year 2015 and shall be submitted no later than March 31, Subsequent annual reports for each calendar year shall be submitted no later than March 31 of the following calendar year. 3. The Permittee shall submit the report electronically using the subpart specific reporting form in the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX) ( However, if the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, the written report must be submitted to the Administrator at the appropriate address listed in 40 CFR section GENERAL PROVISIONS Notification of the Date Construction (or reconstruction) Began: due 30 days after start of construction (or reconstruction). The Permittee shall submit the name and number of each unit and the date construction of each unit began. Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup 40 CFR section (d); Minn. R hdr 60.7(a)(1); Minn. R , subp (a)(3); Minn. R , subp. 1 Page 151

152 What to do The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. Notification of Anticipated Date for Conducting Opacity Observations: due 30 day prior to observation date Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records for at least five years. 60.7(f) specifies two years. The Permittee shall not build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. 60.7(a)(4); Minn. R , subp (a)(6); Minn. R , subp (b), Minn. R , subp. 1 Minn. R , subp. 5(C); meets requirements of 40 CFR Section 60.7(f); Minn. R , subp ; Minn. R Page 152

153 A Engines New CI stationary engines < 500 hp that are fire pumps What to do EMISSION AND OPERATING LIMITATIONS The Permittee shall comply with the emission standards for new CI fire pump engines for 2011 model year and later stationary CI ICE, with a displacement of less than 30 liters per cylinder as follows: Emission standards for model year 2011 and later engines: e. Maximum engine power < 8 kw: i. NOx + NMHC: less than or equal to 7.5 g/kw hr ii. PM: less than or equal to 0.40 g/kw hr f. Maximum engine power 8 kw < 19: i. NOx + NMHC: less than or equal to 7.5 g/kw hr ii. PM: less than or equal to 0.40 g/kw hr g. Maximum engine power 19 kw < 37: i. NOx + NMHC: less than or equal to 7.5 g/kw hr ii. PM: less than or equal to 0.30 g/kw hr h. Maximum engine power 37 kw < 56 i. NOx + NMHC: less than or equal to 4.7 g/kw hr ii. PM: less than or equal to 0.40 g/kw hr i. Maximum engine power 56 kw < 75: i. NOx + NMHC: less than or equal to 4.7 g/kw hr ii. PM: less than or equal to 0.40 g/kw hr j. Maximum engine power 75 kw < 130: i. NOx + NMHC: less than or equal to 4.0 g/kw hr ii. PM: less than or equal to 0.30 g/kw hr k. Maximum engine power 130 kw < 225: i. NOx + NMHC: less than or equal to 4.0 g/kw hr ii. PM: less than or equal to 0.20 g/kw hr l. Maximum engine power 225 kw < 373: i. NOx + NMHC: less than or equal to 4.0 g/kw hr ii. PM: less than or equal to 0.2 g/kw hr The Permittee shall install a non resettable hour meter prior to startup of any emergency stationary CI internal combustion engine that does not meet the standards applicable to non emergency engines. RECORDKEEPING REQUIREMENTS The Permittee shall keep records of the operation of the engine in emergency and non emergency service that are recorded through the non resettable hour meter. The Permittee shall record the time of operation of the engine and the reason the engine was in operation during that time. hdr 40 CFR section (c); 40 CFR pt. 60, subp. IIII, Table 4; Minn. R CFR section (a); Minn. R hdr 40 CFR section (b); Minn. R Page 153

154 What to do GENERAL PROVISIONS Notification of the Date Construction (or reconstruction) Began: due 30 days after start of construction (or reconstruction). The Permittee shall submit the name and number of each unit and the date construction of each unit began. Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. Notification of Anticipated Date for Conducting Opacity Observations: due 30 day prior to observation date Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records for at least five years. 60.7(f) specifies two years. The Permittee shall not build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. hdr 60.7(a)(1); Minn. R , subp (a)(3); Minn. R , subp (a)(4); Minn. R , subp (a)(6); Minn. R , subp (b), Minn. R , subp. 1 Minn. R , subp. 5(C); meets requirements of 40 CFR Section 60.7(f); Minn. R , subp ; Minn. R Page 154

155 A.6 Boilers Form MG 05B1 The following are Minnesota Standards of Performance for Indirect Heating Equipment (Minn. R ) New boilers: construction, modification, or reconstruction commenced after January 31, 1977 Existing boilers: construction, modification, or reconstruction did not commence after January 31, 1977 Air Quality Control Region (AQCR) 131: Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington counties A.6.1 New and Existing Boilers located within AQCR 131 What to do Total Particulate Matter: less than or equal to 0.40 pounds per million BTU using a 3 hour rolling average The potential to emit from the boilers allowed with this permit is lb/mmbtu due to equipment design and allowable fuels. Opacity: less than or equal to 20% opacity; except for one six minute period per hour of not more than 60% opacity. An exceedance of this opacity standard occurs whenever any one hour period contains two or more six minute periods during which the average opacity exceeds 20 percent or whenever any one hour period contains one or more six minute periods during which the average opacity exceeds 60 percent. Sulfur Dioxide: less than or equal to 1.6 pounds per million BTU using a 3 hour rolling average when combusting liquid fuels The potential to emit from the boilers allowed with this permit is lb/mmbtu due to equipment design and allowable fuels. Minn. R , subp. 1 and ; Minn. R and Minn. R , subp. 2; Minn. R , subp. 2 Minn. R , subp. 1 and ; Minn. R and A.6.2 New and Existing Boilers located within the City of Duluth What to do Total Particulate Matter: less than or equal to 0.40 pounds per million BTU using a 3 hour rolling average The potential to emit from the boilers allowed with this permit is lb/mmbtu due to equipment design and allowable fuels. Minn. R , subp. 1 and ; Minn. R and Page 155

156 Opacity: less than or equal to 20% opacity; except for one six minute period per hour of not more than 60% opacity. An exceedance of this opacity standard occurs whenever any one hour period contains two or more six minute periods during which the average opacity exceeds 20 percent or whenever any one hour period contains one or more six minute periods during which the average opacity exceeds 60 percent. Sulfur Dioxide: less than or equal to 2.0 pounds per million BTU using a 3 hour rolling average when combusting liquid fuels The potential to emit from the boilers allowed with this permit is lb/mmbtu due to equipment design and allowable fuels. Minn. R , subp. 2; Minn. R , subp. 2 Minn. R , subp. 1 and ; Minn. R and A.6.3 New boilers, located outside AQCR 131 and outside the City of Duluth What to do Total Particulate Matter: less than or equal to 0.40 pounds per million BTU using a 3 hour rolling average The potential to emit from the boilers allowed with this permit is lb/mmbtu due to equipment design and allowable fuels. Opacity: less than or equal to 20% opacity; except for one six minute period per hour of not more than 60% opacity. An exceedance of this opacity standard occurs whenever any one hour period contains two or more six minute periods during which the average opacity exceeds 20 percent or whenever any one hour period contains one or more six minute periods during which the average opacity exceeds 60 percent. Sulfur Dioxide: less than or equal to 2.0 pounds per million BTU using a 3 hour rolling average when combusting liquid fuels The potential to emit from the boilers allowed with this permit is lb/mmbtu due to equipment design and allowable fuels. Minn. R , subp. 1 and Minn. R , subp. 2 Minn. R , subp. 1 and Page 156

157 A.6.4 Existing boilers, located outside AQCR 131 and outside the City of Duluth What to do Total Particulate Matter: less than or equal to 0.60 pounds per million BTU using a 3 hour rolling average The potential to emit from the boilers allowed with this permit is lb/mmbtu due to equipment design and allowable fuels. Opacity: less than or equal to 20% opacity; except for one six minute period per hour of not more than 60% opacity. An exceedance of this opacity standard occurs whenever any one hour period contains two or more six minute periods during which the average opacity exceeds 20 percent or whenever any one hour period contains one or more six minute periods during which the average opacity exceeds 60 percent. Sulfur Dioxide: less than or equal to 2.0 pounds per million BTU using a 3 hour rolling average when combusting liquid fuels The potential to emit from the boilers allowed with this permit is lb/mmbtu due to equipment design and allowable fuels. Minn. R and Minn. R , subp. 2 Minn. R and Page 157

158 The following are National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers (40 CFR pt. 63, subp. DDDDD) A.6.5 All boilers subject to 40 CFR pt. 63, subp. DDDDD Affected Source: 1. The collection at the facility of all existing industrial, commercial, and institutional boilers within a subcategory. (Subcategories defined in ) 2. Each new or reconstructed industrial, commercial, or institutional boiler. New Source: construction or reconstruction commenced after June 4, Existing sources: construction or reconstruction commenced on or before June 4, What to do Compliance dates: The Permittee shall comply with 40 CFR pt. 63, subp. DDDDD no later than the following compliance dates, except as provided in 40 CFR 63.6(i): For any boiler constructed or reconstructed after June 4, 2010, the compliance date is January 31, 2013, or upon startup of the boiler, whichever is later. For any boiler constructed or reconstructed on or before June 4, 2010, the compliance date is January 31, EMISSION LIMITS AND OPERATIONAL REQUIREMENTS The Permittee shall at all times operate and maintain each boiler at the facility in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the EPA Administrator that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. The Permittee shall comply with the emission limits, work practice standards, and operating limits in 40 CFR pt. 63, subp. DDDDD. These limits apply at all times the affected unit is operating except during periods of startup and shutdown during which time the Permittee shall comply only with the tune up and energy assessment requirements below hdr (a)(3) s (a) and (f). Page 158

159 Tune up means adjustments made to a boiler in accordance with the procedures outlined in (a)(10)(i) (vi): i) As applicable, the Permittee shall inspect the burner, and clean or replace any components of the burner as necessary. The Permittee may delay the burner inspection until the next scheduled unit shutdown. Units that produce electricity for sale may delay the burner inspection until the first outage, not to exceed 36 months (72 months for those units requiring a tune up only every 5 years) from the previous inspection. At units where entry into a piece of process equipment or into a storage vessel is required to complete the tune up inspections, inspections are required only during planned entries into the storage vessel or process equipment; ii) The Permittee shall inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer s specifications, if available; iii) The Permittee shall inspect the system controlling the air to fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly. The Permittee may delay the inspection until the next scheduled unit shutdown. Units that produce electricity for sale may delay the inspection until the first outage, not to exceed 36 months (72 months for those units requiring a tune up only every 5 years) from the previous inspection; iv) The Permittee shall optimize total emissions of CO. The optimization should be consistent with manufacturer s specifications, if available, and with any NOx requirement to which the unit is subject; v) The Permittee shall measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made Measurements may be either on a dry or wet basis, as long as it is the same basis before and after adjustments are made Measurements may be taken using a portable CO analyzer; and vi) The Permittee shall maintain on site and submit, if requested by the Administrator, an annual report as described in the Recordkeeping requirements below. General Provisions Appendix: This permit contains an appendix which lists the requirements of the general provisions in s 63.1 through 63.15, and shows which parts of the general provisions apply to sources subject to 40 CFR pt. 63, subp. DDDDD. The Permittee shall comply with all applicable requirements contained in the General Provisions Appendix (Appendix B) (a)(10) , Table 10 to 40 CFR pt. 63, subp. DDDDD; Minn. R , subp. 2 Page 159

160 RECORDKEEPING Daily Recordkeeping Startup and Shutdown: On each day that a boiler is started up or shut down, the Permittee shall record and maintain: 1) the Emission Unit ID Number of the boiler (as designated on form MG 02); 2) the calendar date, time, occurrence and duration of each startup and shutdown; and 3) the type and amount of fuels used during each startup and shutdown. The Permittee shall maintain on site and submit, if requested by the Administrator, a biennial (or five year for those units requiring a tune up only every 5 years) report containing the following information: (A) The concentrations of CO in the effluent stream in parts per million by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune up of the boiler; (B) A description of any corrective actions taken as a part of the tune up; and (C) The type and amount of fuel used over the 24 (or 60 for those units requiring a tune up only every 5 years) months prior to the tune up, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel used by each unit. hdr s (i) and (j); Minn. R , subp. 2 s (a)(10)(vi) and (a)(11) (12) Page 160

161 The Permittee shall maintain relevant records of: 1) The occurrence and duration of each startup, shutdown, or malfunction of operation (i.e., process equipment); 2) The occurrence and duration of each malfunction of the required air pollution control and monitoring equipment; 3) All required maintenance performed on the air pollution control and monitoring equipment; 4) Actions taken during periods of startup, shutdown, and malfunction (including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation) when such actions are different from the procedures specified in the SSMP; 5) All information necessary to demonstrate conformance with the SSMP when all actions taken during periods of startup, shutdown, and malfunction (including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation) are consistent with the procedures specified in such plan. (The information needed to demonstrate conformance with the SSMP may be recorded using a checklist, or some other effective form of recordkeeping, in order to minimize the recordkeeping burden for conforming events); 6) All required measurements needed to demonstrate compliance with a relevant standard (including, but not limited to and raw performance testing measurements that support data that the source is required to report); 7) All results of performance tests; 8) All measurements as may be necessary to determine the conditions of performance tests; and 9) All documentation supporting initial notifications and notifications of compliance status under The Permittee shall keep the following records: 1) A copy of each notification and report that was submitted to comply with subpart DDDDD, including all documentation supporting any Initial Notification or Notification of Compliance Status or Semi Annual Compliance Report that was submitted, according to the requirements in 63.10(b)(2)(xiv); and 2) Records of performance tests, fuel analyses, or other compliance demonstrations and performance evaluations as required in 63.10(b)(2)(viii). The Permittee shall keep the required records in a form suitable and readily available for expeditious review, according to 63.10(b)(1). The Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The Permittee shall keep each record on site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record. The Permittee may keep the records off site for the remaining 3 years. Such files may be maintained on microfilm, on a computer, on computer floppy disks, on magnetic tape disks, or on microfiche (b)(2) (a) ; 40 CFR Section 63.10(b)(1) Page 161

162 REPORTING Submittals and notifications under 40 CFR pt. 63, subp. DDDDD shall be sent to both the MPCA and EPA contacts listed on the first page of Table B of this permit, unless otherwise noted. The Permittee shall submit all of the notifications in s 63.7(b) and (c), 63.8 (e), (f)(4) and (6), and 63.9(b) through (h) that apply by the dates specified. See the General Provisions Appendix B to this permit for these requirements. Initial Notification: The Permittee shall submit an Initial Notification not later than 120 days after January 31, 2013, for each industrial boiler unit started up before January 31, Initial Notification: The Permittee shall submit an Initial Notification not later than 15 days after actual the actual date of startup, for each industrial boiler unit started up on or after January 31, Notification of compliance status: due 60 days after Demonstration Completion. The Permittee shall submit a Notification of Compliance Status according to 40 CFR Section 63.9(h)(2)(ii). The Notification of Compliance Status report shall contain the information specified below: A description of the affected unit(s) including identification of which subcategories the unit is in, the design heat input capacity of the unit, description of the fuel(s) burned; A signed certification that the affected units have met all applicable emission limits and work practice standards; If there was a deviation from any emission limit, work practice standard, or operating limit, the Permittee shall also submit a description of the deviation, the duration of the deviation, and the corrective action taken in the Notification of Compliance Status report; In addition to the information required in 63.9(h)(2), the Notification of Compliance Status shall include the following certification(s) of compliance, as applicable, and signed by a responsible official: o This facility complies with the required initial tune up according to the procedures in s (a)(10(i) through (vi). o This facility has had an energy assessment performed according to 40 CFR 7530(e). o Except for units that burn only natural gas, refinery gas, or other gas 1 fuel, or units that qualify for a statutory exemption as provided in section 129(g)(1) of the Clean Air Act, the Permittee shall also include the following: No secondary materials that are solid waste were combusted in any affected unit. hdr Minn. R , subp (a) (b); 40 CFR Section 63.9(b)(2) (c) (e); 40 CFR Sections (d) (f); 63.9(h) Page 162

163 Compliance Report: due 31 days after end of each calendar 24 months following Permit Issuance for those units requiring a tune up every two years. The reporting period shall be [year 1] January 1 to [year 2] December 31. The Compliance Report is due 31 days after the end of the reporting period. The first compliance report shall cover the period beginning on the compliance date that is specified for each boiler in and ending on July 31 or January 31, whichever date is the first date that occurs at least 2 years after the compliance date that is specified for the emission unit in Section Each subsequent compliance report shall cover the 2 year period from January 1 to December 31. Compliance Report: due 31 days after end of each calendar 60 months following Permit Issuance for those units requiring a tune up every five years. The reporting period shall be [year 1] January 1 to [year 5] December 31. The Compliance Report is due 31 days after the end of the reporting period. The first compliance report shall cover the period beginning on the compliance date that is specified for each boiler in and ending on July 31 or January 31, whichever date is the first date that occurs at least 5 years after the compliance date that is specified for the emission unit in Section Each subsequent compliance report shall cover the 5 year period from January 1 to December (b) (b) Page 163

164 Report Compliance Report report contents (biennial and 5 year) The report shall contain: a. If the facility is subject to the requirements of a tune up, the Permittee shall include the following information in the compliance report: Company and Facility name and address, Process unit information, emissions limitations, and operating parameter limitations, Date of report and beginning and ending dates of the reporting period, The total operating time during the reporting period, If a malfunction occurred during the reporting period, the report shall include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. The report shall also include a description of actions taken by the Permittee during malfunction of a boiler to minimize emissions in accordance with 40 CFR section (a)(3), including actions taken to correct the malfunction, For each unit subject only to the requirement to conduct an biennial or 5 year tune up according to 40 CFR section (a)(10), (11), or (12) respectively, the Permittee shall include the date of the most recent tune up. The Permittee shall also include the date of the most recent burner inspection if it was not done biennially or on a 5 year period and was delayed until the next scheduled or unscheduled unit shutdown, Statement by a responsible official with that official s name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report; b. If there are no deviations from the requirements for work practice standards in Table 3 to subpart DDDDD that apply to the boiler, a statement that there were no deviations from the work practice standards during the reporting period; and c. If there was a deviation from a work practice standard during the reporting period, the report must contain the following information: A description of the deviation and which emission limit or operating limit from which it deviated, and Information on the number, duration, and cause of deviations (including unknown cause), as applicable, and the corrective action taken. Notification of fuel switch: If the Permittee switches fuels or makes a physical change to an affected boiler and the fuel switch or physical change results in the applicability of a different subcategory, the Permittee shall provide notice of the date of the switch/change within 30 days of the switch/change. The notification shall identify: The name of the Permittee, the location of the source, the boiler(s) that have switched fuels or were physically changed, and the date of the notice; The currently applicable subcategory under 40 CFR pt. 63, subp. DDDDD; and The date upon which the fuel switch or physical change occurred. s (b) and (c); 40 CFR pt. 63, subp. DDDDD, Table (h) Page 164

165 A Boilers subject to 40 CFR pt. 63, subp. DDDDD in the Units Designed to Burn Light Liquid Fuel Subcategory What to do EMISSION LIMITS AND OPERATIONAL REQUIREMENTS Fuel Type: natural gas or distillate oil only Performance Tune Up: At least once every two years (24 month period starting with Permit Issuance), the Permittee shall complete a tune up for each boiler with heat input capacity between 5 10 MMBtu/hr, not to exceed 25 calendar months between tune ups. This tune up shall be conducted as specified in the Tune up requirements in the boilers section of this permit. If the unit is not operating on the required date for a tune up, the Permittee must conduct the tune up within 30 calendar days of startup. Performance Tune Up: At least once every five years (60 month period starting with Permit Issuance), the Permittee shall complete a tune up for each boiler with heat input capacity less than or equal to 5 MMBtu/hr, not to exceed 61 calendar months between tune ups. This tune up shall be conducted as specified in the Tune up requirement in the boilers section of this permit. If the unit is not operating on the required date for a tune up, the Permittee must conduct the tune up within 30 calendar days of startup. ADDITIONAL REQUIREMENTS FOR UNITS CONSTRUCTED BEFORE JUNE 4, 2010 The Permittee shall comply with the Maximum Achievable Control Technology (MACT) Standard for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources as of January 31, 2016 (the Compliance Date), except as provided in 40 CFR section 60.6(i). hdr ; Minn. R , subp. 2; To qualify for this general permit under Minn. R s ; (d); and (a)(11) s ; (d); and (a)(12) hdr (b) Page 165

166 Energy Assessment: The Permittee shall have a one time energy assessment performed by a qualified energy assessor for each existing boiler at the facility. The energy assessment must include the following with extent of the evaluation for items a. to e. appropriate for the on site technical hours listed in : a. A visual inspection of the boiler system; b. An evaluation of operating characteristics of the boiler systems, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints; c. An inventory of major energy use systems consuming energy from affected boilers and which are under the control of the boiler owner/operator; d. A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage; e. A review of the facility's energy management practices and provide recommendations for improvements consistent with the definition of energy management practices, if identified; f. A list of cost effective energy conservation measures that are within the facility's control; g. A list of the energy savings potential of the energy conservation measures identified; h. A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in Table 3 to 40 CFR pt. 63, subp. DDDDD, satisfies the energy assessment requirement. A facility that operates under an energy management program compatible with ISO that includes the affected unit also satisfies the energy assessment requirement. A Boilers subject to 40 CFR pt. 63, subp. DDDDD in the Units Designed to Burn Gas 1 Fuel Subcategory What to do EMISSION LIMITS AND OPERATIONAL REQUIREMENTS Fuel Type: natural gas or distillate oil only hdr ; Minn. R , subp. 2; To qualify for this general permit under Minn. R Page 166

167 Fuel Usage: less than or equal to 48 hours as a combined total per calendar year using liquid fuel for periodic testing of liquid fuel, maintenance, or operator training; except during periods of gas curtailment or gas supply interruptions of any duration. Liquid fuel may be used during periods of gas curtailment or gas supply interruptions of any duration. "Combined total" refers to the total hours for which liquid fuel was burned at each subject boiler at the facility. Performance Tune Up: At least once every two years (24 month period starting with Permit Issuance), the Permittee shall complete a tune up for each boiler with heat input capacity between 5 10 MMBtu/hr, not to exceed 25 calendar months between tune ups. This tune up shall be conducted as specified in the Tune up requirement in the boilers section of this permit ; Minn. R , subp. 2 s (e); (d); and (a)(11) If the unit is not operating on the required date for a tune up, the Permittee must conduct the tune up within 30 calendar days of startup. Performance Tune Up: At least once every five years (60 month period starting with Permit Issuance), the Permittee shall complete a tune up for each boiler with heat input capacity less than or equal to 5 MMBtu/hr, not to exceed 61 calendar months between tune ups. This tune up shall be conducted as specified in the Tune up requirement in the boilers section of this permit. s (e); (d); and (a)(12) If the unit is not operating on the required date for a tune up, the Permittee must conduct the tune up within 30 calendar days of startup. Period of gas curtailment or supply interruption means a period of time during which the supply of gaseous fuel to an affected boiler is restricted or halted for reasons beyond the control of the facility. The act of entering into a contractual agreement with a supplier of natural gas established for curtailment purposes does not constitute a reason that is under the control of the facility for the purposes of this definition. An increase in the cost or unit price of natural gas due to normal market fluctuations not during periods of supplier delivery restriction does not constitute a period of natural gas curtailment or supply interruption. On site gaseous fuel system emergencies or equipment failures qualify as periods of supply interruption when the emergency or failure is beyond the control of the facility. ADDITIONAL REQUIREMENTS FOR UNITS CONSTRUCTED BEFORE JUNE 4, 2010 The Permittee shall comply with the Maximum Achievable Control Technology (MACT) Standard for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources as of January 31, 2016 (the Compliance Date), except as provided in 40 CFR section 60.6(i) hdr (b) Page 167

168 Energy Assessment: The Permittee shall have a one time energy assessment performed by a qualified energy assessor for each existing boiler at the facility. The energy assessment must include the following with extent of the evaluation for items a. to e. appropriate for the on site technical hours listed in : a. A visual inspection of the boiler system; b. An evaluation of operating characteristics of the boiler systems, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints; c. An inventory of major energy use systems consuming energy from affected boilers and which are under the control of the boiler owner/operator; d. A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage; e. A review of the facility's energy management practices and provide recommendations for improvements consistent with the definition of energy management practices, if identified; f. A list of cost effective energy conservation measures that are within the facility's control; g. A list of the energy savings potential of the energy conservation measures identified; h. A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in Table 3 to 40 CFR pt. 63, subp. DDDDD, satisfies the energy assessment requirement. A facility that operates under an energy management program compatible with ISO that includes the affected unit also satisfies the energy assessment requirement. RECORDKEEPING Daily Recordkeeping Alternative fuel usage: On each day that a boiler in the Unit designed to burn gas 1 subcategory burns a fuel other than natural gas, the Permittee shall record and maintain: 1) The Emission Unit ID Number of the boiler (as designated on form MG 02); 2) The number of hours that the boiler burned the alternative fuel; 3) The reason for burning the alternative fuel (e.g. periodic testing of liquid fuel, maintenance, or operator training; period of gas curtailment or gas supply interruptions); and 4) The type of fuel burned. hdr (h); Minn. R , subp. 2 Page 168

169 Monthly Recordkeeping Alternative fuel usage: By the 15th of each month following a calendar month during which a boiler in the Unit designed to burn gas 1 subcategory burned a fuel other than natural gas, the Permittee shall record and maintain: 1) The Emission Unit ID Number of the boiler (as designated on form MG 02) and total number of hours for the previous calendar month that an alternative fuel was burned for periodic testing of liquid fuel, maintenance, or operator training for each boiler in the Unit designed to burn gas 1 subcategory that burned an alternative fuel; 2) The combined total number of hours for the current calendar year (from January 1 through the end of the previous calendar month) that alternative fuels were burned for periodic testing of liquid fuel, maintenance, or operator training for all boilers in Unit designed to burn gas 1 subcategory that burned alternative fuels; 3) The Emission Unit ID Number of the boiler (as designated on form MG 02) and total number of hours for the previous calendar month that an alternative fuel was burned for any reason for each boiler in the Unit designed to burn gas 1 subcategory that burned an alternative fuel; and 4) The combined total number of hours for the current calendar year (from January 1 through the end of the previous calendar month) that alternative fuels were burned for any reason for all boilers in Unit designed to burn gas 1 subcategory that burned alternative fuels. REPORTING Notification of Alternative Fuel Use: The Permittee shall submit a notification of alternative fuel use within 48 hours of the declaration of each period of natural gas curtailment or supply interruption, as defined in The notification shall include the information specified in (f) paragraphs (1) through (5) below, and shall be sent to both MPCA and EPA. (1) Company name and address. (2) Identification of the affected unit. (3) Reason the Permittee is unable to use natural gas or equivalent fuel, including the date when the natural gas curtailment was declared or the natural gas supply interruption began. (4) Type of alternative fuel that the Permittee intends to use. (5) Dates when the alternative fuel use is expected to begin and end (h); Minn. R , subp. 2 hdr (f) Page 169

170 A.7 Storage Tanks Form MG 05C The following are the Minnesota Standards of Performance for Liquid Petroleum and Volatile Organic Liquid Storage Vessels A.7.1 Storage Tanks Constructed on or after July 7, 1969, but before June 11, 1973 Storage capacity of greater than 2,000 gallons but less than or equal to 65,000 gallons What to do The storage tank shall be equipped with a permanent submerged fill pipe; or If the true vapor pressure of the petroleum liquid, as stored, is greater than or equal to 78 millimeters of mercury (mmhg) (1.5 pounds per square inch [psia]) and less than or equal to 570 mmhg (11.1 psia), the storage vessel shall be equipped with a floating roof, a vapor recovery system or their equivalents; or If the true vapor pressure of the petroleum liquid, as stored, is greater than 570 mmhg (11.1 psia), the storage vessel shall be equipped with a vapor recovery system or its equivalent. Minn. R , subp. 2(B) A.7.2 Storage Tanks Constructed on or after July 7, 1969, but before June 11, 1973 Storage capacity of greater than 65,000 gallons What to do If the true vapor pressure of the petroleum liquid, as stored, is greater than or equal to 128 millimeters of mercury (mmhg) (2.5 pounds per square inch [psia]) and less than or equal to 642 mmhg (12.5 psia), the storage vessel shall be equipped with a floating roof, a vapor recovery system or their equivalents; or If the true vapor pressure of the petroleum liquid, as stored, is greater than 642 mmhg (12.5 psia), the storage vessel shall be equipped with a vapor recovery system or its equivalent. Minn. R , subp. 2(C) Page 170

171 A.7.3 Storage Tanks Constructed on or after June 11, 1973, with storage capacity of greater than 2,000 gallons and less than 19,812 gallons (75 cubic meters [m 3 ]) Constructed on or after June 11, 1973 and before July 23, 1984, with storage capacity of greater than 2, 000 gallons and less than or equal to 40,000 gallons Constructed, modified, or reconstructed after July 23, 1984, with storage capacity greater than 2,000 gallons and less than or equal to 151 m 3 (39,890 gallons), storing a liquid with a maximum true vapor pressure less than 15 kilopascals (kpa) What to do The storage tank shall be equipped with a permanent submerged fill pipe; or If the true vapor pressure of the petroleum liquid, as stored, is greater than or equal to 78 millimeters of mercury (mmhg) (1.5 pounds per square inch [psia]) and less than or equal to 570 mmhg (11.1 psia), the storage vessel shall be equipped with a floating roof, a vapor recovery system or their equivalents; or If the true vapor pressure of the petroleum liquid, as stored, is greater than 570 mmhg (11.1 psia), the storage vessel shall be equipped with a vapor recovery system or its equivalent. Minn. R , subp. 3 (B) A.7.4 Storage Tanks Constructed on or after July 1, 1973 and before July 23, 1984, with storage capacity of greater than 40, 000 gallons Constructed, modified, or reconstructed after July 23, 1984, with storage capacity greater than 151 m3 (39,890 gallons), storing a liquid with a maximum true vapor pressure less than 3.5 kilopascals (kpa) What to do If the true vapor pressure of the petroleum liquid, as stored, is greater than or equal to 78 millimeters of mercury (mmhg) (1.5 pounds per square inch [psia]) and less than or equal to 570 mmhg (11.1 psia), the storage vessel shall be equipped with a floating roof, a vapor recovery system or their equivalents; or If the true vapor pressure of the petroleum liquid, as stored, is greater than 570 mmhg (11.1 psia), the storage vessel shall be equipped with a vapor recovery system or its equivalent. The Permittee shall maintain a file of each type of petroleum liquid stored, the typical Reid vapor pressure of each type of petroleum liquid stored, the dates of storage and withdrawals, and the date on which the storage vessel is empty. Minn. R , subp. 3 (C) Minn. R , subp. 1 (A) Page 171

172 If (1) the petroleum liquid has a true vapor pressure, as stored, greater than 26 mmhg (0.5 psia) but less than 78 mm Hg (1.5 psia) and is stored in a storage vessel other than one equipped with a floating roof, a vapor recovery system or their equivalents; or (2) the petroleum liquid has a true vapor pressure, as stored, greater than 470 mm Hg (9.1 psia) and is stored in a storage vessel other than one equipped with a vapor recovery system or its equivalent. Determine and record the average monthly storage temperature and true vapor pressure of the petroleum liquid stored at that temperature. Minn. R , subp. 1 (B) The following are the Standards of Performance for Volatile Organic Liquid Storage Vessels (including Petroleum Liquid Storage Vessels) for which Construction, Reconstruction, or Modification Commenced after July 23, 1984 (40 CFR pt. 60, subp. Kb) A.7.5 Storage Tanks Constructed, modified, or reconstructed after July 23, 1984 with storage capacity greater than or equal to 75 m 3 but less than 151 m 3, storing a liquid with a maximum true vapor pressure greater than or equal to 15.0 kilopascals (kpa) but less than 27.6 kpa What to do Recordkeeping: Maintain records showing the dimension of the storage tank and an analysis showing the capacity of the storage tanks b (b); Minn. R (C) Page 172

173 A.8 Ovens Form MG 05B2 Furnaces Form MG 05B3 The following are Minnesota Standards of Performance for Direct Heating Fossil Fuel Burning Equipment Note: Air Quality control Region (AQCR) 131 is comprised of Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington Counties. A.8.1 Ovens and Furnaces located within AQCR 131 What to do Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R to Minn. R , subp. 1(A)(1) Opacity: less than or equal to 20% opacity except for one six minute period per hour Minn. R , of not more than 60% opacity. subp. 1(A)(2) SO 2 : less than or equal to 1.6 pounds per million BTU using a 3 hour rolling average Minn. R , subp. 2(A)(1) A.8.2 Ovens and Furnaces located outside AQCR 131 What to do Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R to Minn. R , subp. 1(A)(1) Opacity: less than or equal to 20% opacity except for one six minute period per hour Minn. R , of not more than 60% opacity. subp. 1(A)(2) SO 2 : less than or equal to 4.0 pounds per million BTU using a 3 hour rolling average Minn. R , subp. 2(B) Page 173

174 A.9 Booths: Abrasive Blasting and/or Sanding Form MG 05B5 The following are Minnesota Standards of Performance for Industrial Process Equipment A.9.1 Booths: Abrasive Blasting and/or Sanding placed in operation before July 9, 1969 What to do Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20% opacity except for one six minute period per hour of not more than 60% opacity. Minn. R , subp. 1(A); Minn. R , subp. 1(B) A.9.2 Booths: Abrasive Blasting and/or Sanding placed in operation on or after July 9, 1969 What to do Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R or Minn. R Minn. R , subp. 1(A); Opacity: less than or equal to 20% opacity. Minn. R , subp. 1(B) Page 174

175 A.10 Fabric Filters Form MG 05A1 A.10.1 Fabric Filters subject to 40 CFR pt. 64 Compliance Assurance Monitoring (CAM) controlling Other (not Large) PSEUs This carat (<>) means to input a numerical number according to the design of the fabric filter. The Permittee shall record this data in the Operation and Maintenance (O & M) plan within 30 days after permit issuance or 30 days after installation of any new control equipment for which there are such operating parameter requirements. What to do Operation and Maintenance of Fabric Filter: The Permittee shall operate and maintain the fabric filter according to the control equipment manufacturer s specifications, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I). The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. PM control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency of particulate matter: greater than or equal to <99/79> percent efficiency. PM10 control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency of particulate matter with an aerodynamic diameter less than or equal to 10 microns: greater than or equal to <93/74> percent efficiency. PM2.5 control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency of particulate matter with an aerodynamic diameter less than or equal to 2.5 microns: greater than or equal to <93/74> percent efficiency. Pressure Drop: Maintain greater than or equal to <> inches of water column and less than or equal to <> inches of water column. 64.8; Minn. R ; Minn. R ; Minn. R , subp. 14 Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Page 175

176 Recordkeeping of Pressure Drop. If the spray booth is in operation, then the Permittee shall record: 1) the pressure drop once every 24 hours, 2) whether or not the recorded pressure drop was within the range specified in the compliance management plan, and 3) the time and date of the pressure drop reading. 64.9; Minn. R ; Minn. R ; Minn. R , subp. 4 If the pressure drop is not within the range specified in the compliance management plan, then it will be considered a deviation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions (VE): The Permittee shall keep records on the time and date of VE inspections, and whether or not any VEs were observed. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur:: if visible emissions are observed; if the recorded pressure drop is outside the required operating range; or if the fabric filter or any of its components are found during the inspections to need repair. Minn. R ; Minn. R , subp ; Minn. R ; Minn. R , subp (d); Minn. R ; Minn. R , subp. 5 Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Reporting of Corrective Actions: All situations warranting corrective actions are deviations, the Permittee shall report the deviations in the semiannual deviations report as required in the total facility section of this general permit. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. Periodic Inspections: At least one per calendar quarter or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. 64.9(c); Minn. R ; Minn. R , subp (b); Minn. R ; Minn. R , subp ; Minn. R ; Minn. R , subps. 4, 5, and 14 Page 176

177 The Permittee shall calibrate or replace the pressure gauge at least once every 12 months and shall maintain a written record of any action resulting from the calibration. Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and update the Permittee s records to address the necessary monitoring change. As required by 64.9(a)(2), for the Semi Annual Deviations Report listed in Table B of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Table A of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 64.3; Minn. R (e); Minn. R (a)(2); Minn. R (b); Minn. R A.10.2 Fabric Filters NOT subject to 40 CFR pt. 64 Compliance Assurance Monitoring (CAM) This carat (<>) means to input a numerical number according to the design of the fabric filter. The Permittee shall record this data in the Operation and Maintenance (O & M) plan within 30 days after permit issuance or 30 days after installation of any new control equipment for which there are such operating parameter requirements. What to do Operation and Maintenance of Fabric Filter: The Permittee shall operate and maintain the fabric filter according to the control equipment manufacturer s specifications, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I). The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. PM control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency of particulate matter: greater than or equal to <99/79> percent efficiency. Minn. R ; Minn. R , subp. 14 Minn. R ; Minn. R , subp. 4 Page 177

178 PM10 control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency of particulate matter with an aerodynamic diameter less than or equal to 10 microns: greater than or equal to <93/74> percent efficiency. PM2.5 control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency of particulate matter with an aerodynamic diameter less than or equal to 2.5 microns: greater than or equal to <93/74> percent efficiency. Pressure Drop: Maintain greater than or equal to <> inches of water column and less than or equal to <> inches of water column. Recordkeeping of Pressure Drop. If the spray booth is in operation, then the Permittee shall record: 1) the pressure drop once every 24 hours, 2) whether or not the recorded pressure drop was within the range specified in the compliance management plan, and 3) the time and date of the pressure drop reading. If the pressure drop is not within the range specified in the compliance management plan, then it will be considered a deviation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions (VE): The Permittee shall keep records on the time and date of VE inspections, and whether or not any VEs were observed. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur:: if visible emissions are observed; if the recorded pressure drop is outside the required operating range; or if the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Reporting of Corrective Actions: All situations warranting corrective actions are deviations, the Permittee shall report the deviations in the semiannual deviations report as required in the total facility section of this general permit. Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 5 Minn. R , subp. 5 Minn. R , subp. 5 Minn. R , subp. 6 Page 178

179 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. The Permittee shall calibrate or replace the pressure gauge at least once every 12 months and shall maintain a written record of any action resulting from the calibration. Periodic Inspections: At least one per calendar quarter or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Minn. R , subp. 4 Minn. R , subps. 4, 5, and 14 Minn. R , subps. 4, 5, and 14 Page 179

180 A.11 Wall/Panel Filters Form MG 05A2 A.11.1 Wall/Panel Filters subject to 40 CFR pt. 64 Compliance Assurance Monitoring (CAM) controlling Other (not Large) PSEUs The Permittee shall record this data in the Operation and Maintenance (O & M) plan within 30 days after permit issuance or 30 days after installation of any new control equipment for which there are such operating parameter requirements. What to do Operation and Maintenance of Wall/Panel Filter: The Permittee shall operate and maintain the wall/panel filter according to the control equipment manufacturer s specifications, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I). The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. PM control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency of particulate matter: greater than or equal to <85/68> percent efficiency. PM10 control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency of particulate matter with an aerodynamic diameter less than 10 microns: greater than or equal to <85/68> percent efficiency. PM2.5 control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency of particulate matter with an aerodynamic diameter less than 2.5 microns: greater than or equal to <85/68> percent efficiency. Daily Inspections: Once each operating day, if the spray booth in operation, the Permittee shall visually inspect the condition of each wall/panel filter with respect to alignment, saturation, tears, holes and any other matter than may affect the filter's performance. The Permittee shall maintain a daily written record of filter inspections. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. 64.8; Minn. R ; Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Page 180

181 Recordkeeping of Corrective Actions: If the filters or any of their components are found during the inspections to need repair, the Permittee shall follow the O & M Plan for the wall/panel filter and take corrective action as soon as possible. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Reporting of Corrective Actions: All situations warranting corrective actions are deviations, the Permittee shall report the deviations in the semiannual deviations report as required in the total facility section of this general permit. 64.7(d); Minn. R ; Minn. R , subp (c); Minn. R ; Minn. R , subp. 6 A.11.2 Wall/Panel Filters NOT subject to 40 CFR pt. 64 Compliance Assurance Monitoring (CAM) The Permittee shall record this data in the Operation and Maintenance (O & M) plan within 30 days after permit issuance or 30 days after installation of any new control equipment for which there are such operating parameter requirements. What to do Operation and Maintenance of Wall/Panel Filter: The Permittee shall operate and maintain the wall/panel filter according to the control equipment manufacturer s specifications, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I). The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. PM control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency of particulate matter: greater than or equal to <85/68> percent efficiency. PM10 control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency of particulate matter with an aerodynamic diameter less than 10 microns: greater than or equal to <85/68> percent efficiency. PM2.5 control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency of particulate matter with an aerodynamic diameter less than 2.5 microns: greater than or equal to <85/68> percent efficiency. Daily Inspections: Once each operating day, if the spray booth in operation, the Permittee shall visually inspect the condition of each wall/panel filter with respect to alignment, saturation, tears, holes and any other matter than may affect the filter's performance. The Permittee shall maintain a daily written record of filter inspections. Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Page 181

182 Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Recordkeeping of Corrective Actions: If the filters or any of their components are found during the inspections to need repair, the Permittee shall follow the O & M Plan for the wall/panel filter and take corrective action as soon as possible. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Reporting of Corrective Actions: All situations warranting corrective actions are deviations, the Permittee shall report the deviations in the semiannual deviations report as required in the total facility section of this general permit. Minn. R ; Minn. R , subp. 4 Minn. R , subp. 5 Minn. R , subp. 6 Page 182

183 A.12 Thermal Oxidizer Form MG 05A4 A.12.1 Thermal Oxidizer subject to 40 CFR pt. 64 Compliance Assurance Monitoring (CAM) controlling Large PSEUs This carat (<>) means to input a numerical number according to the design of the fabric filter. The Permittee shall record this data in the Operation and Maintenance (O & M) plan within 30 days after permit issuance or 30 days after installation of any new control equipment for which there are such operating parameter requirements. What to do Operation and Maintenance of Thermal Oxidizer: The Permittee shall operate and maintain the Thermal Oxidizer according to the control equipment manufacturer s specifications, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I). The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. VOC control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to <97/78> percent efficiency Temperature: The Permittee shall maintain a minimum combustion temperature of <> (º F) when operating, using a 3 hour rolling average. Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/ 0.75 percent of the temperature being measured or +/ 4.5 degrees Fahrenheit. The recording device shall also calculate the threehour rolling average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R , subp. 8a. Temperature Recordkeeping: The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three hour rolling average temperatures for the combustion chamber. 64.8; Minn. R ; Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp ; Minn. R ; Minn. R ; Minn. R , subp (b)(4)(ii); Minn. R ; Minn. R , subps. 2 and (b); Minn. R ; Minn. R ; Minn. R , subp. 4 Page 183

184 Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. Recordkeeping of corrective actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall follow the O& M Plan for the oxidizer and take corrective action as soon as possible. The Permittee shall keep a record of the type and date of any corrective action taken. Reporting of Corrective Actions: All situations warranting corrective actions are deviations, the Permittee shall report the deviations in the semiannual deviations report as required in the total facility section of this general permit. Daily Monitoring: The Permittee shall physical verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of daily verifications. Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing minimum combustion chamber temperature(s), the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring changes. Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system component, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and take action resulting from the calibration. 64.7(d); Minn. R (b); Minn. R ; Minn. R ; Minn. R , subp (c); Minn. R ; Minn. R , subp (b); Minn. R ; Minn. R , subps. 4 and (b); Minn. R (e); Minn. R Minn. R , subps. 4, 5, and ; Minn. R (b)(4); Minn. R ; Minn. R , subps. 4, 5, and 14 Page 184

185 As required by 64.9(a)(2), for the Semi Annual Deviations Report listed in Table B of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Table A of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 64.9(a)(2); Minn. R (b); Minn. R A.12.2 Thermal Oxidizer subject to 40 CFR pt. 64 Compliance Assurance Monitoring (CAM) controlling Other (not Large) PSEUs This carat (<>) means to input a numerical number according to the design of the fabric filter. The Permittee shall record this data in the Operation and Maintenance (O & M) plan within 30 days after permit issuance or 30 days after installation of any new control equipment for which there are such operating parameter requirements. What to do Operation and Maintenance of Thermal Oxidizer: The Permittee shall operate and maintain the Thermal Oxidizer according to the control equipment manufacturer s specifications, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I). The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. VOC control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to <97/78> percent efficiency Temperature: The Permittee shall maintain a minimum combustion temperature of <> (º F) when operating. 64.8; Minn. R ; Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp ; Minn. R ; Minn. R ; Minn. R , subp. 4 Page 185

186 Temperature Recordkeeping: If the emission unit(s) controlled by the thermal oxidizer is in operation, then the Permittee shall record: 1) the combustion temperature once every 24 hours, 2) whether or not the recorded combustion temperature was above the minimum specified in the compliance management plan, and 3) the time and date of the temperature reading. If the combustion temperature is not above the minimum combustion temperature specified in the compliance management plan, then it will be considered a deviation. Recordkeeping of corrective actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall follow the O& M Plan for the oxidizer and take corrective action as soon as possible. The Permittee shall keep a record of the type and date of any corrective action taken. Reporting of Corrective Actions: All situations warranting corrective actions are deviations, the Permittee shall report the deviations in the semiannual deviations report as required in the total facility section of this general permit. Daily Monitoring: The Permittee shall physical verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of daily verifications. Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system component, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. Annual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and take action resulting from the calibration. Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing minimum combustion chamber temperature(s), the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring changes. 64.9; Minn. R ; Minn. R ; Minn. R , subp (b); Minn. R ; Minn. R ; Minn. R , subp (c); Minn. R ; Minn. R , subp. 6 Minn. R , subps. 4 and 5 Minn. R , subps. 4, 5, and (b)(4); Minn. R ; Minn. R , subps. 4, 5, and (b); Minn. R (e); Minn. R Page 186

187 As required by 64.9(a)(2), for the Semi Annual Deviations Report listed in Table B of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Table A of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 64.9(a)(2); Minn. R (b); Minn. R A.12.3 Thermal Oxidizer NOT subject to 40 CFR pt. 64 Compliance Assurance Monitoring (CAM) This carat (<>) means to input a numerical number according to the design of the fabric filter. The Permittee shall record this data in the Operation and Maintenance (O & M) plan within 30 days after permit issuance or 30 days after installation of any new control equipment for which there are such operating parameter requirements. What to do Operation and Maintenance of Thermal Oxidizer: The Permittee shall operate and maintain the Thermal Oxidizer according to the control equipment manufacturer s specifications, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I). The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. VOC control efficiency: The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to <97/78> percent efficiency Temperature: The Permittee shall maintain a minimum combustion temperature of <> (º F) when operating. Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Page 187

188 Temperature Recordkeeping: If the emission unit(s) controlled by the thermal oxidizer is in operation, then the Permittee shall record: 1) the combustion temperature once every 24 hours, 2) whether or not the recorded combustion temperature was above the minimum specified in the compliance management plan, and 3) the time and date of the temperature reading. If the combustion temperature is not above the minimum combustion temperature specified in the compliance management plan, then it will be considered a deviation. Recordkeeping of corrective actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall follow the O& M Plan for the oxidizer and take corrective action as soon as possible. The Permittee shall keep a record of the type and date of any corrective action taken. Reporting of Corrective Actions: All situations warranting corrective actions are deviations, the Permittee shall report the deviations in the semiannual deviations report as required in the total facility section of this general permit. Daily Monitoring: The Permittee shall physical verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of daily verifications. Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system component, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. Annual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and take action resulting from the calibration. Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R , subp. 6 Minn. R , subps. 4 and 5 Minn. R , subps. 4, 5, and 14 Minn. R , subps. 4, 5, and 14 Page 188

189 A.13 Catalytic Oxidizer Form MG 05A3 A.13.1 Catalytic Oxidizer subject to 40 CFR pt. 64 Compliance Assurance Monitoring (CAM) controlling Large PSEUs This carat (<>) means to input a numerical number according to the design of the fabric filter. The Permittee shall record this data in the Operation and Maintenance (O & M) plan within 30 days after permit issuance or 30 days after installation of any new control equipment for which there are such operating parameter requirements. What to do Operation and Maintenance of Catalytic Oxidizer: The Permittee shall operate and maintain the Catalytic Oxidizer according to the control equipment manufacturer s specifications, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I). The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to <94/76> percent efficiency. Temperature: The Permittee shall maintain a minimum inlet temperature of <> (º F) and a minimum outlet temperature of <> (º F) when operating, based on a 3 hour rolling average. Catalyst Reactivity: The Permittee shall verify the catalyst reactivity per the manufacturer's specifications and shall maintain a record of the results. Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/ 0.75 percent of the temperature being measured or +/ 4.5 degrees Fahrenheit. The recording device shall also calculate the threehour rolling average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R , subp. 8a. 64.8; Minn. R ; Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp ; Minn. R ; Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp (b); Minn. R (b)(4)(ii); Minn. R ; Minn. R , subps. 2 and 14 Page 189

190 Temperature Recordkeeping: The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three hour rolling average temperatures for the combustion chamber. Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. Recordkeeping of Corrective Actions: If the temperature is below the minimum specified by this permit or if the catalytic oxidizer or any of its components are found during the inspections to need repair, the Permittee shall follow the O & M Plan for the oxidizer and take corrective action as soon as possible. The Permittee shall keep a record of the type and date of any corrective action taken. Reporting of Corrective Actions: All situations warranting corrective actions are deviations, the Permittee shall report the deviations in the semiannual deviations report as required in the total facility section of this general permit. Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. 64.9(b); Minn. R ; Minn. R ; Minn. R , subp (b); Minn. R ; Minn. R ; Minn. R ; Minn. R (d); Minn. R (d); Minn. R ; Minn. R , subp (c); Minn. R ; Minn. R , subp (b); Minn. R Page 190

191 Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing minimum combustion chamber temperature(s), the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring changes. As required by 64.9(a)(2), for the Semi Annual Deviations Report listed in Table B of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Table A of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 64.7(e); Minn. R (a)(2); Minn. R (b); Minn. R A.13.2 Catalytic Oxidizer subject to 40 CFR pt. 64 Compliance Assurance Monitoring (CAM) controlling Other (not Large) PSEUs This carat (<>) means to input a numerical number according to the design of the fabric filter. The Permittee shall record this data in the Operation and Maintenance (O & M) plan within 30 days after permit issuance or 30 days after installation of any new control equipment for which there are such operating parameter requirements. What to do Operation and Maintenance of Catalytic Oxidizer: The Permittee shall operate and maintain the Catalytic Oxidizer according to the control equipment manufacturer s specifications, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I). The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to <94/76> percent efficiency. 64.8; Minn. R ; Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Page 191

192 Temperature: The Permittee shall maintain a minimum inlet temperature of <> (º F) and a minimum outlet temperature of <> (º F) when operating. Catalyst Reactivity: The Permittee shall verify the catalyst reactivity per the manufacturer's specifications and shall maintain a record of the results. Temperature Recordkeeping: If the emission unit(s) controlled by the thermal oxidizer is in operation, then the Permittee shall record: 1) the inlet and outlet temperatures once every 24 hours, 2) whether or not the recorded inlet and outlet temperatures were above the minimums specified in the compliance management plan, and 3) the time and date of the temperature reading. If the inlet and outlet temperatures are not above the minimum combustion temperatures specified in the compliance management plan, then it will be considered a deviation. Recordkeeping of Corrective Actions: If the temperature is below the minimum specified by this permit or if the catalytic oxidizer or any of its components are found during the inspections to need repair, the Permittee shall follow the O & M Plan for the oxidizer and take corrective action as soon as possible. The Permittee shall keep a record of the type and date of any corrective action taken. Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. Reporting of Corrective Actions: All situations warranting corrective actions are deviations, the Permittee shall report the deviations in the semiannual deviations report as required in the total facility section of this general permit. Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing minimum combustion chamber temperature(s), the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring changes. 64.3; Minn. R ; Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp (b); Minn. R ; Minn. R ; Minn. R , subp (d); Minn. R ; Minn. R , subp ; Minn. R (c); Minn. R ; Minn. R , subp (b); Minn. R (e); Minn. R Page 192

193 As required by 64.9(a)(2), for the Semi Annual Deviations Report listed in Table B of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Table A of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 64.9(a)(2); Minn. R (b); Minn. R A.13.3 Catalytic Oxidizer NOT subject to 40 CFR pt. 64 Compliance Assurance Monitoring (CAM) This carat (<>) means to input a numerical number according to the design of the fabric filter. The Permittee shall record this data in the Operation and Maintenance (O & M) plan within 30 days after permit issuance or 30 days after installation of any new control equipment for which there are such operating parameter requirements. What to do Operation and Maintenance of Catalytic Oxidizer: The Permittee shall operate and maintain the Catalytic Oxidizer according to the control equipment manufacturer s specifications, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I). The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to <94/76> percent efficiency. Temperature: The Permittee shall maintain a minimum inlet temperature of <> (º F) and a minimum outlet temperature of <> (º F) when operating. Catalyst Reactivity: The Permittee shall verify the catalyst reactivity per the manufacturer's specifications and shall maintain a record of the results. Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Minn. R ; Minn. R , subp. 4 Page 193

194 Temperature Recordkeeping: If the emission unit(s) controlled by the thermal oxidizer is in operation, then the Permittee shall record: 1) the inlet and outlet temperatures once every 24 hours, 2) whether or not the recorded inlet and outlet temperatures were above the minimums specified in the compliance management plan, and 3) the time and date of the temperature reading. If the inlet and outlet temperatures are not above the minimum combustion temperatures specified in the compliance management plan, then it will be considered a deviation. Recordkeeping of Corrective Actions: If the temperature is below the minimum specified by this permit or if the catalytic oxidizer or any of its components are found during the inspections to need repair, the Permittee shall follow the O & M Plan for the oxidizer and take corrective action as soon as possible. The Permittee shall keep a record of the type and date of any corrective action taken. Reporting of Corrective Actions: All situations warranting corrective actions are deviations, the Permittee shall report the deviations in the semiannual deviations report as required in the total facility section of this general permit. Annual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and take action resulting from the calibration. Minn. R ; Minn. R , subp. 4 Minn. R , subp. 4 Minn. R , subp. 6 Minn. R , subps. 4, 5, and 14 Page 194

195 TABLE B: SUBMITTALS Table B lists the submittals you must send to the Commissioner. Table B is divided into two sections, for source specific submittal requirements and for submittals required of all Permittees. Source specific submittals are further organized as either one time only or recurrent requirements. You may also be subject to additional reporting requirements contained in the compliance schedule located in Table C of this permit. Return complete permit application to: Minnesota Pollution Control Agency Air Quality Permit Technical Assistant 520 Lafayette Road North, St. Paul, Minnesota Send all other submittals to: Minnesota Pollution Control Agency Air Quality Compliance Tracking Coordinator, 520 Lafayette Road North, St. Paul, Minnesota SOURCE SPECIFIC SUBMITTALS ONE TIME SUBMITTALS OR NOTIFICATIONS: Note: these are one time submittals/notifications only. If the MPCA has already received the required submittal/notification from the Permittee, the Permittee does not need to resend the submittal/notification. When to send Due 180 days before expiration of existing permit Due 60 days after permit issuance, and 7 days before adding any new, modified, or changed equipment. Prior to installation of a New cleaning machine that is subject to the halogenated solvent NESHAP Due no later than a 150 days after startup of New cleaning machine subject to the halogenated solvent NESHAP Due within 120 days of startup of the Affected Source subject to the Surface Coating of Miscellaneous Metal Parts and Products NESHAP What to send Application for Permit Reissuance Compliance Management Plan Initial Notification Report Compliance Report Initial Notification Report Portion of facility affected Total Facility Total Facility Cleaning machines/degreasers Cleaning machines/degreasers Spraying/coating booths (non fiberglassing) and Dip tanks Page 195 Part 70 Manufacturing General Permit 2014, Table B

196 When to send Due ends on the last day of the 12 th full month following the compliance date. What to send Initial Compliance Report Portion of facility affected Spraying/coating booths (non fiberglassing) and Dip tanks Due 15 days after initial startup Initial Notification Report Fiberglass operations Due one year and 30 days after initial startup Due 60 days after initial performance test for each initial compliance demonstration Due 120 days after the source become subject to Reciprocating Internal Combustion Engines NESHAP. Due 30 days after start of construction Due 15 days after initial startup Due 30 days after start of construction Due 15 days after initial startup Due 15 days after initial startup to be submitted with the notification of the actual date of initial startup. Initial Compliance Report Initial Compliance Report Initial Notification Report Notification of the Date Construction Began Notification of Actual Date of Initial Startup Notification of the Date Construction Began Notification of Actual Date of Initial Startup Notification of Design Heat Input, Fuels and Anticipated Annual Capacity Factor The notification shall include the design heat input capacity, identification of fuels to be combusted, and the annual capacity factor at which the Permittee anticipates operating the affected facility based on all fuels fired and based on each individual fuel fired. Fiberglass operations Stationary engines Stationary engines Stationary engines Stationary engines Boilers Boilers Boilers Page 196 Part 70 Manufacturing General Permit 2014, Table B

197 SOURCE SPECIFIC SUBMITTALS RECURRENT SUBMITTALS: When to send Semiannually: January 30, July 30 Annually: January 30, for the previous calendar year Annually: January 30, for the previous calendar year Annually: April 1, for the previous calendar year Annually: Within 30 days of receipt of an MPCA bill Semi annually: January 30, July 30; If applicable, Quarterly: 30 days at the end of each quarter Annually: February 1, for the previous calendar year Semiannually: January 30, July 30 If there are no deviations for subpart MMMM or PPPP, the report must be submitted with the semiannual compliance report. What to send Deviations Reports To be submitted on a Form DRF 2 (or equivalent replacement form or reporting mechanism approved by the Commissioner), with a summary of all instances of deviations from permit conditions. Submit the January 30 report with your annual Compliance Certification. If there are no deviations during a report period, the Permittee shall submit the report stating there are no deviations. Part 70 Manufacturing General Permit Annual Compliance Certification To be submitted on a Form MGCR 04 (or equivalent replacement form or reporting mechanism approved by the Commissioner) Equipment Inventory List Emissions Inventory Report Emission Fees Exceedance Report Annual Report for cleaning machines subject to the halogenated solvent NESHAP No Deviation Report Portion of facility affected Total Facility Total facility Total facility Total facility Total facility Cleaning machines/degreasers Cleaning machines/degreasers Spraying/coating booths (non fiberglassing) and Dip tanks Page 197 Part 70 Manufacturing General Permit 2014, Table B

198 When to send What to send Portion of facility affected Semiannually: January 30, July 30 Semiannual Compliance Report for Units subject to: 1. Surface Coating of Miscellaneous Metal Parts and Products NESHAP, or 2. Surface Coating of Plastic Parts and Products NESHAP Semiannually: January 31, July 31 Semiannual Compliance Report for Units subject to Reinforced Plastic Composites Production NESHAP Due 15 days after making a change to the facility that changes any information submitted in any previous notifications Immediately: within 2 working days after starting actions inconsistent with SSM plan, and within 7 working days after the end of the event Notification of Changes to Previous Notifications Immediate Startup, Shutdown, and Malfunction Report Semiannually: January 31, July 31 Semiannual Compliance Report for Units subject to Stationary Reciprocating Internal Combustion Engines NESHAP Spraying/coating booths (non fiberglassing) and Dip tanks Fiberglass operations Fiberglass operations Fiberglass operations Stationary engines Annually: March 31 Due 60 days before change commences Due 30 days prior to observation date Immediately: within 48 hours of natural gas curtailment or interruption Due 7 days before making a change to the facility Every 5 years: January 30, if a Risk Management Plan is required under 40 CFR pt. 68. Annual Report for Units subject to Stationary Reciprocating Internal Combustion Engines NESHAP Notification of Physical or Operational Change Notification of Anticipated Date for Conducting Opacity Observations Notification of Alternative Fuel Use Compliance Management Plan Update Risk Management Plan for accidental releases Stationary engines Stationary engines Stationary engines Boilers designed to use Gas 1 fuel Emission Unit Total Facility Page 198 Part 70 Manufacturing General Permit 2014, Table B

199 When to send Due within 7 days of the name change in ownership or operational control of the company. What to send Part 70 General Permit Administrative Changes Portion of facility affected Total Facility Page 199 Part 70 Manufacturing General Permit 2014, Table B

200 TABLE C: COMPLIANCE SCHEDULE Table C contains the compliance schedule as required by Minn. R , subp. 2, Item K. You must complete the actions required in Table C by the dates listed in the table. This applies only to stationary sources out of compliance at the time of permit issuance to the source. C.1 Cleaning Machines (Degreasers) Subject to NESHAP 40 CFR pt. 60, subp. T Citation Corrective action When to complete this action To qualify for this general permit under Minn. R and , subp. 2 To qualify for this general permit under Minn. R and , subp. 2 Notifications: Submit initial notification report for all New machines. Use form TF 04. Existing machines. Use form TF 05. Batch cold cleaning machines. Use form TF 06. Notifications: Submit Initial Statement of Compliance Report. Use forms TF 01, TF 02, and/or TF 03, as applicable. Within 30 days of the permit issuance. Within 30 days of the permit issuance. C.2 Booths: Spraying/Coating (non Fiberglassing) Dip Tanks Subject to NESHAP 40 CFR pt. 63, subp. MMMM or NESHAP 40 CFR pt. 63, subp. PPPP Citation Corrective action When to complete this action To qualify for this general permit under Minn. R and , subp. 2 Notifications: Submit initial notification report. Use forms 4M 01 and/or 4P 01, as applicable. Within 30 days of the permit issuance. Page 200 Part 70 Manufacturing General Permit 2014, Table C

201 C.3 Fiberglass Operations (spraying/coating, molding, casting, lamination) Subject to NESHAP 40 CFR pt. 63, subp. WWWW Citation Corrective action When to complete this action To qualify for this general permit under Minn. R and , subp. 2 Notifications: Submit initial notification report. Use form 4W 01. Within 30 days of the permit issuance. C.4 Stationary Internal combustion Engines Subject to NESHAP 40 CFR pt. 60, subp. IIII Citation Corrective action When to complete this action To qualify for this general permit under Minn. R and , subp. 2 Notifications: Submit initial notification report. Within 60 days of the permit issuance. C.5 Stationary Internal combustion Engines Subject to NESHAP 40 CFR pt. 63, subp. ZZZZ Citation Corrective action When to complete this action To qualify for this general permit under Minn. R and , subp. 2 Notifications: Submit initial notification report. Use form 4Z 01. Within 30 days of the permit issuance. Page 201 Part 70 Manufacturing General Permit 2014, Table C

202 C.6 Boilers Subject to NESHAP 40 CFR pt. 63, subp. DDDDD Citation Corrective action When to complete this action To qualify for this general permit under Minn. R and , subp. 2 Notifications: Submit initial notification report. Within 30 days of the permit issuance. C.7 Tanks Subject to NESHAP 40 CFR pt. 60, subp. Kb Citation Corrective action When to complete this action To qualify for this general permit under Minn. R and , subp. 2 Recordkeeping Records showing the dimension of the storage tank and an analysis showing the capacity of the storage tank. Within 30 days of the permit issuance. C.8 Booths: Spraying/Coating (non Fiberglassing) Booths: Abrasive Blasting and/or Sanding Citation Corrective action When to complete this action To qualify for this general permit under Minn. R and , subp. 2 Notification: Submit notification of the date of installation of particulate matter pollution control equipment. Within 60 days of the permit issuance. Page 202 Part 70 Manufacturing General Permit 2014, Table C

203 PERMIT APPENDICES Appendices This permit contains appendices as listed below and in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices. (Minn. R , subp. 2) Appendix A Source Specific Calculations Appendix B General Provisions Appendix (40 CFR pt. 63, subp. A) Appendix C NESHAP subp. T supplementary information Appendix D NESHAP subp. MMMM equations Appendix E NESHAP subp. PPPP equations Appendix F NESHAP subp. WWWW supplementary information Page 203 Part 70 Manufacturing General Permit 2014, Permit Appendices

204 Permit Appendix A: Source Specific Calculations 1. All sources Permittee With No Operating Records Prior to Issuance of this Permit: For emission limits based on a 12 month rolling sum, the Permittee shall calculate the 12 month rolling sum on a monthly basis. For the first 12 months of operation, the Permittee shall use the following Table A1.1 below: Number of Months in Operation TABLE A1.1 Cumulative Pollutant Emission Limits During First 12 Months of Operation For pollutants subject to 90 tpy pollutant limits in the permit: PM, PM 10, PM 2.5, NO x, CO, HAP (ton) For pollutants subject to 225 tpy pollutant limits in the permit: VOC For pollutants subject to 90,000 tpy pollutant limits in the permit: CO 2 e (ton) (ton) , , , , , , , , , , , , Combustion Sources (Indirect heating sources and Internal combustion Engines) NO x and CO emissions are each limited to less than 90 tons per year based on a 12 month rolling sum. The emissions during a given month are calculated using Equation A2: Equation A2: NO x (or CO), tons per month = x [( EF x Q) ng +(EF x Q) lpgb + (EF x Q) lpgp + (EF x Q) do/bio ] ihs + [(EF x Q) ng + (EF x Q) do +( EF x Q) g ] rice where: EF = emission factor (see Table 6.2 and 6.3) Q = actual quantity of fuel burned per month (use the units that are appropriate to the emission factor for each fuel type.) ng = natural gas Page 1 Part 70 Manufacturing General Permit 2014, Permit Appendix A

205 lpgb = liquefied petroleum gas(butane) lpgp = liquefied petroleum gas (propane) do = distillate oil bio = biodiesel g = gasoline ihs = indirect heating source rice = reciprocating internal combustion engines = conversion factor, ton/lb Emission factors from Compilation of "Air Pollutant Emission Factors (AP 42) Fifth Edition, Emission Factor Listing for Criteria Air Pollutants" and Emission Factors for Greenhouse Gas Inventories (April 2014, factors.pdf) are used in Table A2.1 and Table A2.2. Table A2.1 Pollutant Natural Gas (lb/mmft 3 ) Industrial Indirect Heating Sources Emission Factor LPG Butane (lb/1000 gal) LPG Propane (lb/1000 gal) Distillate Oil (lb/1000 gal) PM PM PM SO x S 0.10S 144S NO x VOC CO Pb CO 2 120,000 14,300 12,500 22,300 CH N 2 O Page 2 Part 70 Manufacturing General Permit 2014, Permit Appendix A

206 Table A2.2 Pollutant Stationary Internal Combustion Engines Emission Factor Distillate Oil (Diesel) BioDiesel (lb/mmbtu) (lb/mmbtu) < 600 hp 2 and 4 Cycle Engines PM PM PM SO x NO x VOC CO Pb CO CH N 2 O Notes: (1) PM = Particulate Matter PM 10 = Particulate Matter less than 10 microns in aerodynamic diameter PM 2.5 = Particulate Matter less than 2.5 microns in aerodynamic diameter SO 2 = Sulfur Dioxide NO x = Oxides of Nitrogen VOC = Volatile Organic Compounds CO = Carbon Monoxide Pb = Lead CO 2 = Carbon Dioxide CH 4 = Methane N 2 O = Nitrous Oxide MM = Million Btu = British thermal unit lbs = pounds ft 3 = cubic feet gal = gallons hp = horsepower (2) Natural Gas heating value is 1,050 Btu/standard cubic foot. LPG Butane heating value is 102,600 Btu/gal. LPG Propane heating value is 91,500 Btu/gal Gasoline heating value is 130,000 Btu/gal. Distillate Oil (Diesel) heating value is 140,000 Btu/gal Page 3 Part 70 Manufacturing General Permit 2014, Permit Appendix A

207 (3) S for Distillate Oil: Weight percent sulfur in oil. S indicates that the weight percent of sulfur in the oil should be multiplied by the value given. The maximum weight percent sulfur allowed in this permit is %. (4) S for LPG: Sulfur content expressed on grams/1,000 cubic foot gas vapor. S is assumed to be 0.15 grains/1,000 cubic feet vapor which is equivalent to 0.02% sulfur by weight. (5) Biodiesel Emission Factors for criteria pollutants were taken from EPA document Voluntary Diesel Retrofit Program, biodiesel.htm, and for GHG from EPA document Emission Factors for Greenhouse Gas Inventories (April 2014, factors.pdf ) Permittee With Operating Records Prior to Issuance of this Permit: The Permittee shall not exceed emissions of 90 tons per year of CO calculated as a 12 month rolling sum. Each month s CO emissions shall be calculated with Equation 1, and then added to the previous 11 months emissions. The Permittee shall not exceed emissions of 90 tons per year of NO x calculated as a 12 month rolling sum. Each month s NO x emissions shall be calculated with Equation 1, and then added to the previous 11 months emissions. 3. The Limitation for PM/PM 10 /PM 2.5 Based on a 12 month rolling sum Permittee with Operating Records. To calculate the facility s PM/PM 10 /PM 2.5 emissions based on a 12 month rolling sum in Equation A3 of this permit, the Permittee shall calculate the 12 month rolling sum on a monthly basis. For the first 12 months of operation, the Permittee shall use its actual operating history prior to issuance of this permit. Equation A3: gives PM/PM 10 /PM 2.5 emissions in tons per month for sources which qualify for 100 percent capture efficiency and collection efficiency of 85 percent and greater. PM/PM /PM2.5 = Pc t1 100 [% collection] /100 Pd t [% collection] / where: P c t 1 = uncontrolled particulate emissions (particulate emissions before taking into account the reduction from control equipment) from the painting/coating, gelcoats and resin applications, lamination, casting, sanding; pounds/hour (lb/hr); (This can be obtained by using Actual Usage (gal/hr) x (1 transfer efficiency) x Solid content (lbs/gal)) = operating hours of the painting/coating, gelcoats and resin applications, lamination, casting, sanding; operation during the month; hour/month (hr/month) Page 4 Part 70 Manufacturing General Permit 2014, Permit Appendix A

208 P d = uncontrolled particulate emissions (particulate emissions before taking into account the reduction from control equipment) from abrasive blasting; (lb/hr) t 2 = monthly operating hours of the abrasive blasting operation; (hr/month) [% collection] = collection efficiency of the particulate control equipment = conversion factor; ton/pounds (ton/lbs) The Permittee shall calculate the 12 month rolling sum PM/PM 10 /PM 2.5 emissions for the previous 12 month period by summing the monthly PM/PM 10 /PM 2.5 emissions data for the previous 12 months. Emissions factors for PM/PM 10 /PM 2.5 emissions from abrasive blasting obtained from Volume I of STAPPA ALAPCO " Air Quality Permits" are given in Table A3.1. PM 2.5 is assumed to be equivalent to PM 10. Table A3.1 Emission Factor Abrasive lb PM / lb abrasive lb PM 10 / lb PM Sand Grit Steel Shot Other Table A3.2 Application Method and Transfer Efficiency Booths Application Method Transfer Efficiency Air atomization spray 0.30 Airless spray 0.45 Electrostatic/Air atomization 0.70 Electrostatic/Airless 0.75 High Volume Low Pressure 0.75 Electrode deposition 0.95 Powder 0.95 Page 5 Part 70 Manufacturing General Permit 2014, Permit Appendix A

209 4. The Limitation for VOC Based on a 12 month rolling sum 4.1 The Limitation for VOC Based on a 12 month rolling sum using material contents Permittee With Operating Records. The VOC usage limitation based on a 12 month rolling sum, the Permittee shall calculate the 12 month rolling sum on a monthly basis as specified in Equation A4.1. For the first 12 months of operation, the Permittee shall use its actual operating history prior to issuance of this permit. Equation A4.1: VOC = A ivi B jz j 100 [%control] / C where: i = denotes each separate material used for painting/coating j = denotes each separate material used for cleanup A i = amount of VOC containing materials used for painting/coating as purchased, lb/month V i = percent of VOC in A i as applied, %wt B j = amount of VOC containing materials used for cleaning as purchased, lb/month Z j = percent of VOC in B i as applied, %wt [%control] = overall control efficiency VOC control equipment = 100 * ([% capture efficiency] / 100) * ([%collection/destruction efficiency] / 100); use as indicated in your Compliance Management Plan C i = VOC emissions for the storage tanks, lb/month = conversion factor, ton/lb The Permittee shall also calculate the 12 month rolling sum VOC emissions for the previous 12 month period by summing the monthly VOC emissions data for the previous 12 months. 4.2 The Limitation for VOC Based on a 12 month rolling sum using emission factors Permittee With Operating Records. The VOC usage limitation based on a 12 month rolling sum, the Permittee shall calculate the 12 month rolling sum on a monthly basis as specified in Equation A4.2. For the first 12 months of operation, the Permittee shall use its actual operating history prior to issuance of this permit. Equation A4.2: VOC = [MAT (1) x EF (1)] + [ MAT (2) x EF (2)] + [ MAT (3) x EF (3)] +.. Where: VOC = VOC emissions, in tons per month MAT(#) = Amount of VOC containing material used, in tons/month EF(#) = The total VOC emission factor for each material used in tons per ton of material used. (Use the emission factors in Appendix C) Page 6 Part 70 Manufacturing General Permit 2014, Permit Appendix A

210 Calculate the 12 month rolling sum VOC emissions for the previous 12 month period by summing the monthly VOC emissions data for the previous 12 months. 5. The Limitation for CO 2 equivalent Emissions Based on a 12 month Rolling Sum CO 2 equivalent emissions are limited to less than 90,000 tons per year based on a 12 month rolling sum. Because CO 2 equivalent emissions are defined as a Global Warming Potential weighted sum of several compounds, emissions of those individual compounds must each be calculated first. The CO 2 equivalent emissions during a given month are calculated using Equations 5a, 5b, 5c, and 5d: Equation 5a: CO 2 emissions, tons per month = x [( EF x Q) ng +(EF x Q) lpgb + (EF x Q) lpgp + (EF x Q) do/bio ] ihs + [(EF x Q) ng + (EF x Q) do +( EF x Q) g ] rice where: EF = emission factor (see Table 6.2 and 6.3) Q = actual quantity of fuel burned per month (use the units that are appropriate to the emission factor for each fuel type.) ng = natural gas lpgb = liquefied petroleum gas(butane) lpgp = liquefied petroleum gas (propane) do = distillate oil bio = biodiesel g = gasoline ihs = indirect heating source rice = reciprocating internal combustion engines = conversion factor, ton/lb Equation 5b: CH 4 emissions, tons per month = x [( EF x Q) ng +(EF x Q) lpgb + (EF x Q) lpgp + (EF x Q) do/bio ] ihs + [(EF x Q) ng + (EF x Q) do +( EF x Q) g ] rice where: EF = emission factor (see Table 6.2 and 6.3) Q = actual quantity of fuel burned per month (use the units that are appropriate to the emission factor for each fuel type.) ng = natural gas lpgb = liquefied petroleum gas(butane) lpgp = liquefied petroleum gas (propane) do = distillate oil bio = biodiesel Page 7 Part 70 Manufacturing General Permit 2014, Permit Appendix A

211 g = gasoline ihs = indirect heating source rice = reciprocating internal combustion engines = conversion factor, ton/lb Equation 5c: N 2 O emissions, tons per month = x [( EF x Q) ng +(EF x Q) lpgb + (EF x Q) lpgp + (EF x Q) do/bio ] ihs + [(EF x Q) ng + (EF x Q) do +( EF x Q) g ] rice where: EF = emission factor (see Table 6.2 and 6.3) Q = actual quantity of fuel burned per month (use the units that are appropriate to the emission factor for each fuel type.) ng = natural gas lpgb = liquefied petroleum gas(butane) lpgp = liquefied petroleum gas (propane) do = distillate oil bio = biodiesel g = gasoline ihs = indirect heating source rice = reciprocating internal combustion engines = conversion factor, ton/lb Equation 5d: CO 2 equivalent emissions, tons per month = (GWP CO2 x EQN4a) + (GWP CH4 x EQN4b) + (GWP N2O x EQN4c) + where: i = denotes each separate compound that is: (1) emitted by your facility, (2) listed in Table A5.1, and (3) is not CO2, CH 4, or N 2 O GWP CO2 = Global Warming Potential of CO 2 (see Table 6.XXX) GWP CH4 = Global Warming Potential of CH 4 (see Table 6.XXX) GWP N2O = Global Warming Potential of N 2 O (see Table 6.XXX) GWP i = Global Warming Potential of i, where i is one of n compounds that is emitted by your facility and is listed in Table 6.4 and is not CO 2, CH 4, or N 2 O EQN4a = Results of the calculation of equation 5a, tons per month EQN4b = Results of the calculation of equation 5b, tons per month EQN4c = Results of the calculation of equation 5c, tons per month ER i = Emission Rate of compound i, tons per month Page 8 Part 70 Manufacturing General Permit 2014, Permit Appendix A

212 Table A5.1 Global Warming Potential Pollutant CO 2 1 CH 4 25 N 2 O The Limitation for HAP Based on a 12 month rolling average using Emission Factors Use a calculated emission factor. Calculate a weighted average organic HAP emissions factor on a lbs/ton of resin and gel coat basis. Base the weighted average on the prior 12 months of operation. Multiply the weighted average organic HAP emissions factor by resin and gel coat use over the same period. You may calculate this organic HAP emissions factor based on the equations in Table 1 to 40 CFR pt. 63, subp. WWWW, or you may use any organic HAP emissions factor approved by US EPA, such as factors from AP 42, or site specific organic HAP emissions factors if approved by the MPCA. Also use the formulas in sections 3.1 or 3.2 to calculate the HAP from nonfiberglassing operations, substituting the appropriate HAP emission factor or HAP content for the VOC emission factor or VOC content in those equations. Page 9 Part 70 Manufacturing General Permit 2014, Permit Appendix A

213 Appendix B General Provisions Appendix Guide to Appendix B Appendix B consists of two tables: Table B1 Which general provisions apply to equipment subject to the NESHAPs in this permit Table B1 is too wide to fit on a single page, so has been divided in half: the first half contains NESHAP subparts T, MMMM, and PPPP; and the second half contains NESHAP subparts WWWW, ZZZZ, and DDDDD. Table B2 General provisions requirements Table B2 contains the requirements for the applicable general provisions from 40 CFR pt. 63, subp. A The Permittee shall use Table B1 to determine which general provisions are applicable to the facility, based on which NESHAPs the facility is subject to. For the applicable general provisions, the Permittee shall refer to Table B2 and comply with the corresponding requirements. Appendix B Table B1 Which general provisions apply equipment subject to the NESHAPs in this permit 40 CFR pt. 63, subps. T, MMMM, and PPPP BCC = Batch Cold Cleaning Machines BVI = Batch Vapor and In line Cleaning Machines 40 CFR pt. 63, subp. A Subpart T Subpart MMMM Subpart PPPP Section BCC BVI explanation explanation explanation 63.4(b) Yes Yes Yes Yes. 63.5(b)(3) No No Subpart T overrides the requirement for approval prior to constructing a new or reconstructing an existing major source. Yes Yes Page 1 Part 70 Manufacturing General Permit 2014, Permit Appendix B

214 40 CFR pt. 63, subp. A Subpart T Subpart MMMM Subpart PPPP Section BCC BVI explanation explanation explanation Yes Yes Yes Yes 63.5(b)(4)&(6) 63.6(e)(1) 63.6(e)(3) Yes Yes Yes Yes. No No Subpart T overrides the requirement of a startup, shutdown, and malfunction plan. Subpart T specifies startup and shutdown procedures to be followed by an owner or operator for batch vapor and in line cleaning machines. No Only sources using an addon control device to comply with the standard must complete startup, shutdown, and malfunction plans. Yes Yes No Applies only to sources using an add on control device to comply with the standard. 63.6(f)(1) 63.6(f)(2) and (3) Yes Yes Yes Yes. 63.6(g) Yes Yes Yes Yes. 63.6(h)(1) No No No No 63.6(h)(2) (9) No No No No 63.6(i) Yes Yes Yes Yes. No No Only sources using an add on control device to comply with the standard must complete startup, shutdown, and malfunction plans. Applies only to sources using an add on control device to comply with the standard. Page 2 Part 70 Manufacturing General Permit 2014, Permit Appendix B

215 40 CFR pt. 63, subp. A Subpart T Subpart MMMM Subpart PPPP Section BCC BVI explanation explanation explanation 63.7(a)(2) 63.7(b) 63.7(c)(2) and (3) 63.7(d) No Yes No Applies only to performance tests for capture system and control device efficiency at sources using these to comply with the standard. No Yes This is only required for those owners or operators that choose the idling emission standard as their compliance option. No No Subpart T does not require a site specific test plan for the idling emission performance test. No No Requirements do not apply to the idling emission performance test option. No No No Applies only to performance tests for capture system and addon control device efficiency at sources using these to comply with the standard. Applies only to performance tests for capture system and addon control device efficiency at sources using these to comply with the standard. Applies only to performance tests for capture system and addon control device efficiency at sources using these to comply with the standard. No No No No Applies only to performance tests for capture system and control device efficiency at sources using these to comply with the standards. Applies only to performance tests for capture system and addon control device efficiency at sources using these to comply with the standards. Applies only to performance tests for capture system and addon control device efficiency at sources using these to comply with the standards. Applies only to performance tests for capture system and addon control device efficiency at sources using these to comply with the standards. Page 3 Part 70 Manufacturing General Permit 2014, Permit Appendix B

216 40 CFR pt. 63, subp. A Subpart T Subpart MMMM Subpart PPPP Section BCC BVI explanation explanation explanation No Yes No Applies only to performance tests for capture system and addon control device efficiency at sources using these to comply with the No 63.7(e) standard. 63.7(e)(1) No Yes No No 63.7(e)(2) No Yes No No 63.7(e)(3) No Yes No No No Yes Subpart T specifies what No Applies only to No is required to performance tests for demonstrate idling capture system and addon emission standard control device compliance through the efficiency at sources using use of the these to comply with the Environmental standard. Protection Agency test method 307 and control device monitoring. Reports and records of testing and monitoring are required for compliance verification. Three runs of the test are required for compliance, as specified in section 63.7(e) of 63.7(g) subpart A. 63.8(b) Yes Yes Yes Yes. Applies only to performance tests for capture system and addon control device efficiency at sources using these to comply with the standards. Applies only to performance tests for capture system and addon control device efficiency at sources using these to comply with the standards. Page 4 Part 70 Manufacturing General Permit 2014, Permit Appendix B

217 40 CFR pt. 63, subp. A Subpart T Subpart MMMM Subpart PPPP Section BCC BVI explanation explanation explanation No No No Applies only to monitoring of capture system and add on control device efficiency at sources using these to comply with the standard. Additional requirements for CMS operations and maintenance are specified No 63.8(c)(1) in section (c)(1)(i) No No No No 63.8(c)(1)(ii) No No No No 63.8(c)(1)(iii) No No No No No No No Applies only to monitoring No of capture system and add on control device efficiency at sources using these to comply with the standard. Additional requirements for CMS operations and maintenance are specified 63.8(c)(2) (4) in section No No No Subpart MMMM does not No have opacity or visible 63.8(c)(5) emission standards. Applies only to monitoring of capture system and add on control device efficiency at sources using these to comply with the standard. Additional requirements for CMS operations and maintenance are specified in section Applies only to monitoring of capture system and add on control device efficiency at sources using these to comply with the standard. Additional requirements for CMS operations and maintenance are specified in section Subpart PPPP does not have opacity or visible emission standards. Page 5 Part 70 Manufacturing General Permit 2014, Permit Appendix B

218 40 CFR pt. 63, subp. A Subpart T Subpart MMMM Subpart PPPP Section BCC BVI explanation explanation explanation 63.8(c)(6) (8) No No No Section specifies the requirements for monitoring systems for capture systems and addon control devices at sources using these to comply. No No Subpart T does not require the use of continuous monitoring systems to demonstrate compliance. No Subpart MMMM does not require the use of continuous emissions monitoring systems. No No Section specifies the requirements for monitoring systems for capture systems and addon control devices at sources using these to comply. Subpart PPPP does not require the use of continuous emissions monitoring systems. 63.8(d) 63.8(e) 63.8(f) 63.8(g) 63.9(b)(1) No No Subpart T does not require the use of continuous monitoring systems to demonstrate compliance. No Subpart MMMM does not require the use of continuous emissions monitoring systems. Yes Yes Yes Yes. No No Subpart T does not require continuous opacity monitoring systems and continuous monitoring systems data. No Sections and specify monitoring data reduction. Yes Yes Yes Yes. No No Subpart PPPP does not require the use of continuous emissions monitoring systems. Sections and specify monitoring data reduction. Page 6 Part 70 Manufacturing General Permit 2014, Permit Appendix B

219 40 CFR pt. 63, subp. A Subpart T Subpart MMMM Subpart PPPP Section BCC BVI explanation explanation explanation Yes Yes Subpart T includes all of those requirements stated in subpart A, except that subpart A also requires a statement as to whether the affected source is a major or an area source, and an identification of the relevant standard (including the source's compliance date). Subpart T also has some more specific information requirements specific to the affected source (see subpart T, section Yes Yes. 63.9(b)(2) (a) (b)). No No Subpart T does not require an application for approval of construction or Yes Yes. 63.9(b)(4) reconstruction. 63.9(e) Yes Yes Under subpart T, this requirement only applies to owners or operators choosing to comply with the idling emissions standard. No Applies only to capture system and add on control device performance tests at sources using these to comply with the standard. No Applies only to capture system and add on control device performance tests at sources using these to comply with the Page 7 Part 70 Manufacturing General Permit 2014, Permit Appendix B

220 40 CFR pt. 63, subp. A Subpart T Subpart MMMM Subpart PPPP Section BCC BVI explanation explanation explanation standards. 63.9(f) 63.9(g)(1) No No Subpart T does not require opacity or visible emission observations. No No Subpart T does not require the use of continuous monitoring systems or continuous opacity monitoring systems. No Subpart MMMM does not have opacity or visible emissions standards. No No No 63.9(g)(2) No No 63.9(g)(3) No No 63.9(h) No No Section of subpart T requires an initial statement of compliance for existing sources to be submitted to the Administrator no later than 150 days after the compliance date specified in section (d) of subpart T. For new sources, this report is to be submitted to the Yes Section specifies the dates for submitting the notification of compliance status. Yes Subpart PPPP does not have opacity or visible emission standards. Section specifies the dates for submitting the notification of compliance status. Page 8 Part 70 Manufacturing General Permit 2014, Permit Appendix B

221 40 CFR pt. 63, subp. A Subpart T Subpart MMMM Subpart PPPP Section BCC BVI explanation explanation explanation Administrator no later than 150 days from the date specified in section (c). 63.9(j) Yes Yes Yes Yes (a) Yes Yes Yes Yes (b)(1) No No Recordkeeping requirements are specified in subpart T. Yes Additional requirements are specified in section and Yes 63.10(b)(2)(i) No No Recordkeeping requirements are specified in subpart T. No No Recordkeeping requirements are specified in subpart T. No Requirements for startup, shutdown, and malfunction records only apply to add on control devices used to comply with the standard. No No No 63.10(b)(2)(ii) 63.10(b)(2)(iii) No No No No 63.10(b)(2)(iv) (v) No No No No 63.10(b)(2)(vi) (xii) No No Yes Yes. No No No Subpart MMMM does not require the use of continuous emissions No 63.10(b)(2)(xiii) monitoring systems (b)(2)(xiv) No No Yes Yes. Additional requirements are specified in section and Requirements for startup, shutdown, and malfunction records only apply to add on control devices used to comply with the standards. Subpart PPPP does not require the use of continuous emissions monitoring systems. Page 9 Part 70 Manufacturing General Permit 2014, Permit Appendix B

222 40 CFR pt. 63, subp. A Subpart T Subpart MMMM Subpart PPPP Section BCC BVI explanation explanation explanation No No Subpart T does not require continuous Yes Yes 63.10(c)(1) (6) monitoring systems (c)(7) (8) No No No The same records are required in section (a)(7) (c)(10) (11) No No Yes Yes (c)(12) (13) No No Yes Yes (c)(14) No No Yes Yes (c)(15) No No Yes Yes (d)(1) Yes Yes Yes Additional requirements are specified in section Yes No Subpart MMMM does not No require opacity or visible 63.10(d)(3) emissions observations (d)(4) Yes Yes. No Applies only to add on No control devices at sources using these to comply with 63.10(d)(5) the standard. No No Subpart T does not No Subpart MMMM does not No require continuous require the use of emissions monitoring continuous emissions 63.10(e)(1) systems. monitoring systems. No The same records are required in section (a)(7). Additional requirements are specified in section Subpart PPPP does not require opacity or visible emissions observations. Applies only to add on control devices at sources using these to comply with the standards. Subpart PPPP does not require the use of continuous emissions monitoring systems. Page 10 Part 70 Manufacturing General Permit 2014, Permit Appendix B

223 40 CFR pt. 63, subp. A Subpart T Subpart MMMM Subpart PPPP Section BCC BVI explanation explanation explanation No No Subpart T does not require continuous emissions monitoring No Subpart MMMM does not require the use of continuous emissions No 63.10(e)(2) systems. monitoring systems (e)(2)(i) No No No No 63.10(e)(2)(ii) No No No No No No No No Subpart T does not require continuous monitoring systems. Section (b) specifies the contents of periodic compliance reports. Subpart PPPP does not require the use of continuous emissions monitoring systems. Section (b) specifies the contents of periodic compliance reports (e)(3) No No Subpart T does not No Subpart MMMMM does No require continuous not specify requirements opacity monitoring for opacity or COMS (e)(4) systems No No No No Subpart PPPP does not specify requirements for opacity or COMS. Page 11 Part 70 Manufacturing General Permit 2014, Permit Appendix B

224 Continued for 40 CFR pt. 63, subps. WWWW, ZZZZ, and DDDDD: 40 CFR pt. 63, Subp. A Subpart WWWW Subpart ZZZZ Subpart DDDDD Section explanation explanation explanation 63.4 Yes Yes. Yes. Yes Existing facilities do not Yes Yes 63.5(b)(3) become reconstructed under subpart WWWW of Part (b)(4)&(6) Yes Existing facilities do not become reconstructed under subpart WWWW of Part 63. Yes Yes Yes No No. See section (a)(3) for the general duty 63.6(e)(1) requirement. No Subpart WWWW of Part 63 requires a startup, shutdown, and malfunction plan only for sources using add on No No. 63.6(e)(3) controls. No Subpart WWWW of Part 63 requires compliance during periods of startup, shutdown, and malfunction, except startup, shutdown, and malfunctions for sources No. No. 63.6(f)(1) using add on controls. 63.6(f)(2) Yes Yes. Yes. 63.6(g) Yes Yes. Yes. 63.6(h)(1) No No No. See section (a). Page 12 Part 70 Manufacturing General Permit 2014, Permit Appendix B

225 40 CFR pt. 63, Subp. A Subpart WWWW Subpart ZZZZ Subpart DDDDD Section explanation explanation explanation No No Yes. Except section 63.6(h)(3), 63.6(h)(2) (9) which is reserved. Yes Yes. Yes. Note: Facilities may also request extensions of compliance for the installation of combined heat and power, waste heat recovery, or gas pipeline or fuel feeding infrastructure as a means of complying with 63.6(i) this subpart. No Subpart WWWW of Part 63 initial compliance requirements are in Yes Subpart ZZZZ contains performance test dates at section , Yes. 63.7(a)(2) section , and Yes Yes Except that section 63.7(b)(1) (2) only applies as specified in Yes. 63.7(b) section Yes Except that the test plan must be submitted with the notification of the Yes Except that section 63.7(c) only applies as specified in section Yes. 63.7(c) performance test (d) Yes Yes. Yes. Yes Performance test requirements are contained in section Additional requirements for conducting performance (see below) (see below) 63.7(e) tests for continuous Page 13 Part 70 Manufacturing General Permit 2014, Permit Appendix B

226 40 CFR pt. 63, Subp. A Subpart WWWW Subpart ZZZZ Subpart DDDDD Section explanation explanation explanation lamination/casting are included in section Yes No. Subpart ZZZZ specifies conditions for conducting performance tests at No. 63.7(e)(1) section Yes Yes Subpart ZZZZ specifies Yes. test methods at section 63.7(e)(2) (e)(3) (4) Yes Yes. Yes. 63.7(g) Yes Yes. Yes. 63.8(b) Yes Yes. Yes. Yes This section applies if you Yes. Yes. elect to use a CMS to demonstrate continuous compliance with an 63.8(c)(1) emission limit. Subpart DDDDD specifies conditions for conducting performance tests at section (a) to (c). 63.8(c)(1)(i) Yes No No. See section (a)(3). 63.8(c)(1)(ii) Yes Yes. Yes. 63.8(c)(1)(iii) Yes No No. Page 14 Part 70 Manufacturing General Permit 2014, Permit Appendix B

227 40 CFR pt. 63, Subp. A Subpart WWWW Subpart ZZZZ Subpart DDDDD Section explanation explanation explanation 63.8(c)(2) Yes This section applies if you elect to use a CMS to demonstrate continuous compliance with an emission limit. Yes. Except that subpart ZZZZ does not require Continuous Opacity Monitoring System (COMS). Yes. 63.8(c)(5) 63.8(c)(6) 63.8(d) 63.8(e) No Subpart WWWW of Part 63 does not contain opacity standards. Yes This section applies if you elect to use a CMS to demonstrate continuous compliance with an emission limit. Yes This section applies if you elect to use a CMS to demonstrate continuous compliance with an emission limit. Yes This section applies if you elect to use a CMS to demonstrate continuous compliance with an emission limit. No Yes Subpart ZZZZ does not require COMS. Except that subpart ZZZZ does not require COMS. Yes. Yes. Yes. Yes Except for the last sentence of 63.8(d)(3), which refers to a startup, shutdown, and malfunction plan. Startup, shutdown, and malfunction plans are not required. Yes Except that section 63.8(e) only applies as specified in section Also except for section 63.8(e)(5)(ii), which applies to COMS. Yes Yes Except that section 63.8(f)(4) only applies as specified in section Yes. 63.8(f)(1) (3) (g) Yes Yes Yes. Yes. Page 15 Part 70 Manufacturing General Permit 2014, Permit Appendix B

228 40 CFR pt. 63, Subp. A Subpart WWWW Subpart ZZZZ Subpart DDDDD Section explanation explanation explanation Yes Yes Except that section 63.9(b) only applies as specified in section Yes. 63.9(b)(1) Yes Yes Except that section 63.9(b) only applies as specified in section Yes. 63.9(b)(2) Yes Existing facilities do not become reconstructed under subpart WWWW of Yes Except that section 63.9(b) only applies as specified in section Yes. 63.9(b)(4) Part Yes Yes Except that section 63.9(e) only applies as specified in section Yes. 63.9(e) 63.9(f) 63.9(g)(1) 63.9(g)(2) No Subpart WWWW of Part 63 does not contain opacity or visible emission standards. Yes This section applies if you elect to use a CMS to demonstrate continuous compliance with an emission limit. No Subpart WWWW of Part 63 does not contain opacity emission standards. No Yes No Subpart ZZZZ does not contain opacity or VE standards. Except that section 63.9(g) only applies as specified in section Subpart ZZZZ does not contain opacity or VE standards. Yes. Yes. Yes. Page 16 Part 70 Manufacturing General Permit 2014, Permit Appendix B

229 40 CFR pt. 63, Subp. A Subpart WWWW Subpart ZZZZ Subpart DDDDD Section explanation explanation explanation Yes This section applies if you Yes If alternative is in use. Yes. 63.9(g)(3) elect to use a CMS to demonstrate continuous compliance with an emission limit. Also except that section 63.9(g) only applies as specified in section Yes Yes Except that notifications Yes. 63.9(h) for sources using a CEMS are due 30 days after completion of performance evaluations. Section 63.9(h)(4) is reserved. Also, except that section 63.9(h) only applies as specified in section (j) Yes Yes. Yes (a) Yes Yes. Yes. Yes Yes Except that the most Yes (b)(1) recent 2 years of data do not have to be retained on site (b)(2)(i) No Only applies to facilities that use an add on control device. No. Yes. No (b)(2)(ii) 63.10(b)(2)(iii) Yes. See section (d)(7) for recordkeeping of occurrence and duration and section (d)(8) for actions taken during malfunctions. Page 17 Part 70 Manufacturing General Permit 2014, Permit Appendix B

230 40 CFR pt. 63, Subp. A Subpart WWWW Subpart ZZZZ Subpart DDDDD Section explanation explanation explanation 63.10(b)(2)(iv) (v) No (b)(2)(vii) (xii) Yes Yes. Yes. Yes Yes For CO standard if using Yes (b)(2)(xiii) RATA alternative (b)(2)(xiv) Yes Yes. Yes. Yes This section applies if you Yes Yes (c)(1) (6) elect to use a CMS to demonstrate continuous compliance with an emission limit (c)(7) (8) Yes This section applies if you elect to use a CMS to demonstrate continuous compliance with an emission limit. Yes Yes (c)(10) (11) 63.10(c)(12) (13) 63.10(c)(14) Yes Yes Yes This section applies if you elect to use a CMS to demonstrate continuous compliance with an emission limit. This section applies if you elect to use a CMS to demonstrate continuous compliance with an emission limit. This section applies if you elect to use a CMS to demonstrate continuous compliance with an emission limit. Yes No. See section (d)(7) for recordkeeping of occurrence and duration and section (d)(8) for actions taken during malfunctions. Yes Yes. Yes Page 18 Part 70 Manufacturing General Permit 2014, Permit Appendix B

231 40 CFR pt. 63, Subp. A Subpart WWWW Subpart ZZZZ Subpart DDDDD Section explanation explanation explanation Yes This section applies if you elect to use a CMS to demonstrate continuous compliance with an Yes No (c)(15) emission limit (d)(1) Yes Yes. Yes. No Subpart WWWW of Part 63 No Subpart ZZZZ does not No (d)(3) does not contain opacity or visible emission standards. contain opacity or VE standards (d)(4) Yes Yes. Yes. No 63.10(d)(5) Only applies if you use an add on control device. No. No. See section (c)(11) for malfunction reporting requirements. Yes This section applies if you have an add on control device and elect to use a CEM to demonstrate continuous compliance Yes. Yes (e)(1) with an emission limit. Yes This section applies if you have an add on control device and elect to use a CEM to demonstrate continuous compliance Yes (e)(2) with an emission limit (e)(2)(i) Yes. Yes (e)(2)(ii) No Subpart ZZZZ does not require COMS. Yes. Page 19 Part 70 Manufacturing General Permit 2014, Permit Appendix B

232 40 CFR pt. 63, Subp. A Subpart WWWW Subpart ZZZZ Subpart DDDDD Section explanation explanation explanation Yes This section applies if you Yes. Except that section Yes (e)(3) have an add on control device and elect to use a CEM to demonstrate continuous compliance with an emission limit (e)(3)(i) (C) is reserved. No Subpart WWWW of Part 63 No Subpart ZZZZ does not No 63.10(e)(4) does not contain opacity standards. require COMS No No. No. Page 20 Part 70 Manufacturing General Permit 2014, Permit Appendix B

233 Appendix B, cont General Provisions Appendix: Table B2 General Provisions Requirements Why do it What to do hdr OPERATION AND MAINTENANCE REQUIREMENTS 63.4(b); Minn. R Circumvention: The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, but is not limited to: 1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere or 2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions. 63.5(b)(3); Minn. R (b)(4); Minn. R (b)(6); Minn. R (e)(1); Minn. R (f)(1); Minn. R Prior to construction or reconstruction of a major emitting "affected source" under the promulgated MACT standards, the Permittee shall apply for and obtain an air emission permit. After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, the Permittee who constructs a new affected source that is not major emitting or reconstructs an affected source that is not major emitting that is subject to such standard, or reconstructs a source such that the source becomes an affected source subject to the standard, must notify the Administrator of the intended construction or reconstruction. The notification must be submitted in accordance with the procedures in 63.9(b). After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source. Proper Operation and Maintenance. At all times, including periods of startup, shutdown, and malfunction, the Permittee shall operate and maintain the emission unit subject to the MACT standard and any associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by any relevant standard and as detailed in 63.6(e)(1)(i) (iii). The Permittee shall correct malfunctions as soon as practicable after their occurrence. Applicability. The non opacity emission standards set forth in 63.6(f)(1) (3) shall apply at all times except during periods of startup, shutdown, and malfunction, and as otherwise specified in <applicable subpart of 40 CFR pt. 63>. Page 21 Part 70 Manufacturing General Permit 2014, Permit Appendix B

234 Why do it 63.6(f)(2); Minn. R (f)(3); Minn. R (g); Minn. R (h)(2) 63.6(h)(4) 63.6(h)(5) 63.6(h)(6) What to do Methods for determining compliance. The Administrator will determine compliance, in part, based on the results of performance tests, conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 63.6(f)(2) The Permittee may use the results of performance testing conducted previously if it meets the requirements of 63.6(f)(iii). Finding of compliance. The Administrator will make a finding concerning an affected source's compliance with a non opacity emission standard upon obtaining all the compliance information required by the relevant standard. The Permittee may establish the use of an alternative non opacity emission standard by following the procedure specified in 63.6(g). Methods for determining compliance. Compliance with opacity emission standards shall be determined by conducting observations in accordance with Test Method 9 in 40 CFR, pt. 60, Appendix A or the method specified in 63.6(h)(7)(ii). Whenever a visible emission test method is not specified, compliance with visible emission standards in this part shall be determined by conducting observations in accordance with Test Method 22 in 40 CFR pt. 60, Appendix A. Notification of opacity or visible emission observations. The Permittee shall notify the Administrator in writing of the anticipated date for conducting opacity or visible emission observations in accordance with 63.9(f). Conduct of opacity or visible emission observations. For initial compliance, opacity or visible emission observations shall be conducted concurrently with the initial performance test unless otherwise specified in 63.6(h)(5)(A) and (B). Recordkeeping. The Permittee shall make available, upon request by the Administrator, such records to determine the conditions under which the visual observations were made and shall provide evidence indicating proof of current visible observer emission certification. Page 22 Part 70 Manufacturing General Permit 2014, Permit Appendix B

235 Why do it 63.6(h)(7) 63.6(h)(8) 63.6(h)(9) 63.6(i); Minn. R hdr 63.7(a)(2); Minn. R What to do Use of a continuous opacity monitoring system. (i) The Permittee required to use a continuous opacity monitoring system (COMS) shall record the monitoring data produced during a performance test and shall furnish the Administrator a written report of the monitoring results in accordance with the provisions of 63.10(e)(4). (ii) The Permittee may submit, for compliance purposes, COMS data results produced during any performance test required under 63.7 in lieu of Method 9 data in accordance with the process specified in 63.6(h)(7). (iii) COMS data shall be reduced to 6 minute averages over the duration of the mass emission performance test. (iv) The Permittee is responsible for demonstrating that he/she has complied with the performance evaluation requirements of 63.8(e), that the COMS has been properly maintained, operated, and data quality assured, as specified in 40 CFR Sections 63.8(c) and (d), and that the resulting data have not been altered in any way. Finding of compliance. The Administrator will make a finding concerning an affected source's compliance with an opacity or visible emission standard upon obtaining all the compliance information required by the relevant standard and any information available to the Administrator needed to determine whether proper operation and maintenance practices are being used. If the Administrator finds that affected source is in compliance with all relevant standards for which initial performance tests were conducted, but during the time such performance tests were conducted fails to meet any relevant opacity emission standard, the Permittee may petition the Administrator to make appropriate adjustment to the opacity emission standard for the affected source. Until the Administrator notifies the Permittee, the relevant opacity emission standard remains applicable. The Administrator may grant an extension of compliance with an emission standard, as specified in 63.6(i). Until an extension of compliance has been granted by the Administrator, the Permittee shall comply with all applicable requirements of 40 CFR pt. 63, subp. A. PERFORMANCE TESTING REQUIREMENTS Performance Test due within 180 days of <the compliance date indicated in the applicable subpart of 40 CFR pt. 63> except as provided in 63.7(a)(4). Page 23 Part 70 Manufacturing General Permit 2014, Permit Appendix B

236 Why do it 63.7(b); Minn. R (c)(2); Minn. R (c)(3); Minn. R (d); Minn. R s 63.7(e)(1); Minn. R s 63.7(e)(2); Minn. R (e)(3); Minn. R Notification of performance test. What to do (1) The Permittee shall notify the Administrator of their intention to conduct a performance test at least 60 calendar days before the performance test is initially scheduled to begin. (2) In the event the Permittee is unable to conduct the performance test on the date specified in the notification requirement due to unforeseeable circumstances, the Permittee shall notify the Administrator as soon as practicable and without delay prior to the scheduled performance test date and specify the date when the performance test is rescheduled. Submission of site specific test plan. Before conducting a required performance test, the Permittee shall develop and if requested by the Administrator, shall submit a sitespecific test plan for approval in accordance with the requirements of 63.7(c)(2). Approval of site specific test plan. The Administrator will notify the Permittee of approval or intention to deny approval of the site specific test plan (if review of the site specific test plan is requested) within 30 calendar days after receipt of the original plan and within 30 calendar days after receipt of any supplementary information. Performance testing facilities. The Permittee, at the request of the Administrator, shall provide performance testing facilities as specified in 63.7(d). Performance tests shall be conducted under conditions representative of the affected source. Operations during periods of startup, shutdown, and malfunction shall not constitute representative conditions for the purpose of a performance test. Upon request, the Permittee shall make available to the Administrator such records as may be necessary to determine the conditions of performance tests. Performance tests shall be conducted and data shall be reduced in accordance with the test methods and procedures set forth in 63.7(e), in each relevant standard, and, if required, in applicable appendices of 40 CFR parts 51, 60, 61, and 63. Unless otherwise specified in a relevant standard or test method, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the relevant standard. For the purpose of determining compliance with a relevant standard, the arithmetic mean of the results of the three runs shall apply, unless otherwise approved in accordance with provisions of 63.7(e)(3). Page 24 Part 70 Manufacturing General Permit 2014, Permit Appendix B

237 Why do it 63.7(g); Minn. R hdr 63.8(b); Minn. R (c)(1); Minn. R (c)(1)(i); Minn. R (c)(1)(ii); Minn. R (c)(1)(iii); Minn. R What to do Data analysis, recordkeeping, and reporting. Unless otherwise specified in a relevant standard or test method, or as otherwise approved by the Administrator in writing, results of a performance test shall include the analysis of samples, determination of emissions, and raw data. A performance test is completed when field sample collection is terminated. The Permittee shall report the results of the performance test to the Administrator before the close of business on the 60th day following the completion of the performance test, unless specified otherwise in a relevant standard or as approved otherwise in writing. The results of the performance test shall be submitted as part of the notification of compliance status required under 40 CFR Section 63.9(h) to the appropriate permitting authority. MONITORING REQUIREMENTS Conduct of monitoring. Monitoring shall be conducted as set forth in 63.8(a)(b)(1). When the emissions from two or more affected sources are combined before being released to the atmosphere, the Permittee may install an applicable CMS for each emission stream or for the combined emissions streams, provided the monitoring is sufficient to demonstrate compliance with the relevant standard unless other approved in accordance with 63.8(a)(b)(2). Operation and maintenance of continuous monitoring systems. The Permittee shall maintain and operate each CMS in a manner consistent with good air pollution control practices. Operation and maintenance of continuous monitoring systems. The Permittee shall maintain and operate each CMS as specified in 63.6(e)(1). Operation and maintenance of continuous monitoring systems. The Permittee shall keep the necessary parts for routine repairs of the affected CMS equipment readily available. Operation and maintenance of continuous monitoring systems. The Permittee shall develop a written startup, shutdown, and malfunction plan for CMS as specified in 40 CFR Section 63.6(e)(3). Page 25 Part 70 Manufacturing General Permit 2014, Permit Appendix B

238 Why do it 63.8(c)(2) (4); Minn. R (c)(5); Minn. R What to do Operation and maintenance of continuous monitoring systems. 1) All CMS shall be installed such that representative measures of emissions or process parameters from the affected sources are obtained. In addition, CEMS shall be located according to procedures contained in the applicable performance specification(s). Unless the applicable subpart to 40 CFR pt. 63 states otherwise, the Permittee shall ensure the read out, or other indication of operation, from any CMS required for compliance with the emission standard is readily accessible on site for operational control or inspection. 2) All CMS shall be installed, operational, and the data verified prior to or in conjunction with conducting performance tests. Verification of operational status shall, at a minimum, include completion of the manufacturer's written specifications or recommendations for installation, operation, and calibration of the system. 3) Except for system breakdowns, out of control periods, repairs, maintenance periods, calibration checks, and zero (low level) and high level calibration drift adjustments, all CMS, including COMS and CEMS, shall be in continuous operation and shall meet minimum frequency of operation requirements as follows: i) All COMS shall complete a minimum of one cycle of sampling and analyzing for each successive 10 second period and one cycle of data recording for each successive 6 minute period. ii) All CEMS for measuring emissions other than opacity shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15 minute period. Operation and maintenance of continuous monitoring systems. Unless otherwise approved, minimum procedures for COMS shall include a method for producing a simulated zero opacity condition and an upscale (high level) opacity condition using a certified neutral density filter or other related technique to produce a known obscuration of the light beam. Page 26 Part 70 Manufacturing General Permit 2014, Permit Appendix B

239 Why do it 63.8(c)(6) (8); Minn. R What to do Operation and maintenance of continuous monitoring systems. 1) The Permittee of a CMS that is not a CPMS, must check the zero (low level) and high level calibration drifts at least once daily in accordance with the written procedure specified in the performance evaluation plan. 2) A CMS is out of control if: i) The zero (low level), mid level (if applicable), or high level calibration drift (CD) exceeds two times the applicable CD specification in the applicable performance specification or in the relevant standard; or ii) The CMS fails a performance test audit (e.g., cylinder gas audit), relative accuracy audit, relative accuracy test audit, or linearity test audit; or iii) The COMS CD exceeds two times the limit in the applicable performance specification in the relevant standard. When the CMS is out of control, the Permittee shall take the necessary corrective action and shall repeat all necessary tests which indicate that the system is out of control until the performance requirements are below the applicable limits. The beginning of the out of control period is the hour the Permittee conducts a performance check (e.g., calibration drift) that indicates an exceedance of the performance requirements established under this part. The end of the out of control period is the hour following the completion of corrective action and successful demonstration that the system is within the allowable limits. During the period the CMS is out of control, recorded data shall not be used in data averages and calculations, or to meet any data availability requirement established under this part 3) The Permittee shall submit all information concerning out of control periods, including start and end dates and hours and descriptions of corrective actions taken, in the excess emissions and continuous monitoring system performance report. Page 27 Part 70 Manufacturing General Permit 2014, Permit Appendix B

240 Why do it 63.8(d); Minn. R (e); Minn. R (f); Minn. R (g); Minn. R What to do The Permittee shall develop and implement a CMS quality control program. As part of the quality control program, the Permittee shall develop and submit to the Administrator for approval upon request a site specific performance evaluation test plan for the CMS performance evaluation required in 63.8(e)(3)(i). Each quality control program shall include, at a minimum, a written protocol that describes procedures for each of the following operations: (i) Initial and any subsequent calibration of the CMS; (ii) Determination and adjustment of the calibration drift of the CMS; (iii) Preventive maintenance of the CMS, including spare parts inventory; (iv) Data recording, calculations, and reporting; (v) Accuracy audit procedures, including sampling and analysis methods; and vi) Program of corrective action for a malfunctioning CMS. The Permittee shall keep these written procedures on record for the life of the affected source, to be made available for inspection, upon request. The Permittee shall keep previous versions of the performance evaluation plan on record to be made available for inspection upon request, for a period of 5 years after each revision to the plan. Performance evaluation of continuous monitoring systems 1) When required by a relevant standard, and at any other time the Administrator may require, the Permittee shall conduct a performance evaluation of the CMS according to the applicable specifications and procedures described in 63.8(e) or in the relevant standard. 2) Notification of performance evaluation. The Permittee shall notify the Administrator in writing of the date of the performance evaluation simultaneously with the notification of the performance test date or at least 60 days prior to the date the performance evaluation is scheduled to begin if no performance test is required. 3) Reporting performance evaluation results. The Permittee shall furnish the Administrator a copy of a written report of the results of the performance evaluation simultaneously with the results of the performance test or within 60 days of completion of the performance evaluation if no test is required, unless otherwise specified in a relevant standard. Use of an alternative monitoring method. Until permission to use an alternative monitoring procedure has been granted by the Administrator under s 63.8(f)(1) (6), as appropriate, the Permittee remains subject to the requirements of this section and the relevant standard. Reduction of monitoring data. The Permittee must reduce the monitoring data as specified in 63.8(g)(1) (5). Page 28 Part 70 Manufacturing General Permit 2014, Permit Appendix B

241 Why do it What to do hdr 63.9(b)(1); Minn. R (b)(2); Minn. R (b)(4); Minn. R (e); Minn. R (f); Minn. R NOTIFICATION REQUIREMENTS Initial notification requirements apply to the Permittee when the Permittee s affected source becomes subject to a relevant standard. Initial notifications The Permittee who has an initial startup before the effective date of a relevant standard under this part shall notify the Administrator in writing that the source is subject to the relevant standard not later than 120 calendar days after the effective date of the relevant standard (or within 120 calendar days after the source becomes subject to the relevant standard). The initial notification shall include the information specified in 63.9(b)(2). The Permittee of a new or reconstructed major affected source for which an application for approval of construction or reconstruction is required under 40 CFR Section 63.5(d) must provide the following information in writing to the Administrator: i) A notification of intention to construct a new major emitting affected source, reconstruct a major emitting affected source, or reconstruct a major source such that the source becomes a major emitting affected source; and ii) A notification of the actual date of startup of the source, delivered or postmarked within 15 calendar days after that date. Notification of performance test. The Permittee shall notify the Administrator in writing of his or her intention to conduct a performance test at least 60 calendar days before the performance test is scheduled to begin. Notification of opacity and visible emission observations. The Permittee shall notify the Administrator in writing of the anticipated date for conducting opacity or visible emission observations. The notification shall be submitted with the notification of the performance test date, or if no performance test is required or visibility or other conditions prevent the opacity or visible emission observations from being conducted concurrently with the initial performance test. The Permittee shall deliver or postmark the notification not less than 30 days before the opacity or visible emission observations are scheduled to take place. Page 29 Part 70 Manufacturing General Permit 2014, Permit Appendix B

242 Why do it s 63.9(g)(1) (3); Minn. R (h); Minn. R (j); Minn. R hdr 63.10(a); Minn. R What to do Additional notification requirements for sources with continuous monitoring systems. The Permittee shall submit to the Administrator written notification as follows: (1) A notification of the date the CMS performance evaluation under 63.8(e) is scheduled to begin, submitted simultaneously with the notification of the performance test date required under 63.7(b). If no performance test is required, or if the requirement to conduct a performance test has been waived, the Permittee shall notify the Administrator in writing of the date of the performance evaluation at least 60 calendar days before the evaluation is scheduled to begin; (2) A notification that COMS data results will be used to determine compliance with the applicable opacity emission standard during a performance test required by 40 CFR Section 63.7 in lieu of Method 9 or other opacity emissions test method data. The notification shall be submitted at least 60 calendar days before the performance test is scheduled to begin; and (3) A notification that the criterion necessary to continue use of an alternative to relative accuracy testing, as provided by 63.8(f)(6), has been exceeded. The notification shall be delivered or postmarked no later than 10 days after the occurrence of such exceedance, and it shall include a description of the nature and cause of the increased emissions. Notification of compliance status. Each time a notification of compliance status is required under 40 CFR pt. 63, subp. A, the Permittee shall submit to the MPCA a notification of compliance status containing the information required by 63.9(h), signed by the responsible official who shall certify its accuracy, attesting to whether the source has complied with the relevant standard. The notification must be sent by the 60th day following the completion of the relevant compliance demonstration activity specified in the relevant standard. If no performance test is required but opacity or visible emission observations are required, the notification of compliance status shall be sent by the 30th day following the completion of opacity or visible emission observations. Notifications may be combined as long as the due date requirement for each notification is met. Notification of information change. Any change in the information already provided under 63.9 shall be provided to the Administrator in writing within 15 calendar days after the change. RECORDKEEPING AND REPORTING REQUIREMENTS The Permittee shall submit reports to the MPCA and shall send a copy of each report to the Administrator. Page 30 Part 70 Manufacturing General Permit 2014, Permit Appendix B

243 Why do it 63.10(b)(1); Minn. R , subp. 2(B); Minn. R (b)(2)(iii); Minn. R , subp. 2(B) s 63.10(b)(2)(vi) (xii); Minn. R , subp. 2(B) 63.10(b)(2)(xiii); Minn. R , subp. 2(B) 63.10(b)(2)(xiv); Minn. R , subp. 2(B) 63.10(c); Minn. R What to do General recordkeeping requirements.. The Permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent 2 years of data must be retained on site. General recordkeeping requirements. For each affected source, the Permittee shall maintain the relevant records of All required maintenance performed on the air pollution control and monitoring equipment. General recordkeeping requirements. For each affected source, the Permittee shall maintain the relevant records of each period during which a continuous monitoring system (CMS) is malfunctioning or inoperative; all required measurements needed to demonstrate compliance with a relevant standard; all results of performance test, CMS performance evaluations, and opacity and visible emission observations; all measurements as may be necessary to determine the conditions of performance tests and performance evaluations; all CMS calibration checks; all adjustments and maintenance performed on CMS; any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; General recordkeeping requirements. For each affected source, the Permittee shall maintain the relevant records of All emission levels relative to the criterion for obtaining permission to use an alternative to the relative accuracy test, if the source has been granted such permission under 63.8(f)(6). General recordkeeping requirements. For each affected source, the Permittee shall maintain the relevant records of All documents supporting initial notifications and notifications of compliance status. Additional recordkeeping requirements for sources with continuous monitoring systems. The Permittee shall maintain records as specified within 63.10(c); including CMS measurements (including monitoring data recorded during breakdowns and out of control periods) and corrective actions. Page 31 Part 70 Manufacturing General Permit 2014, Permit Appendix B

244 Why do it 63.10(d)(1); Minn. R (d)(3); Minn. R (d)(4); Minn. R (e)(1) and (2)(i) and (ii); Minn. R s 63.10(e)(3)(i) (iv); Minn. R What to do Notwithstanding the requirements in s 63.10(d) and 63.10(e), the Permittee shall submit reports to the Administrator in accordance with the reporting requirements in the relevant standard. Reporting results of opacity or visible emission observations. The Permittee shall report the opacity or visible emission results along with the results of the performance test. If no performance test is required, or if visibility or other conditions prevent the opacity or visible emission observations from being conducted concurrently with the performance test, the Permittee shall report the opacity or visible emission results before the close of business on the 30th day following the completion of the opacity or visible emission observations. Progress reports. The Permittee who is required to submit progress reports as a condition of receiving an extension of compliance under 63.6(i) shall submit such reports to the Administrator by the dates specified in the written extension of compliance. Additional reporting requirements for sources with continuous monitoring systems 1) When more than one CEMS is used to measure the emissions from one affected source, the Permittee shall report the results as required for each CEMS. 2) (i) The Permittee shall furnish the Administrator a copy of a written report of the results of the CMS performance evaluation simultaneously with the results of the performance test, unless otherwise specified in the relevant standard. (ii) A Permittee using a COMS to determine opacity compliance during any performance test shall furnish the Administrator two or, upon request, three copies of a written report of the results of the COMS performance evaluation. The copies shall be furnished at least 15 calendar days before the performance test is conducted. Excess emissions and continuous monitoring system performance report and summary report. Excess emissions and parameter monitoring exceedances are defined in relevant standards. The Permittee shall submit an excess emissions and continuous monitoring system performance report and/or a summary report to the Administrator semiannually, except when more frequent reporting is specifically required by a relevant standard or a reduction in frequency is approved pursuant to 63.10(e)(3). Page 32 Part 70 Manufacturing General Permit 2014, Permit Appendix B

245 Why do it 63.10(e)(3)(v); Minn. R (e)(3)(vi); Minn. R (e)(3)(vii); Minn. R What to do Content and submittal dates for excess emissions and monitoring system performance reports. All excess emissions and monitoring system performance reports and all summary reports, if required, shall be delivered or postmarked by the 30th day following the end of each calendar half or quarter, as appropriate. Written reports of excess emissions or exceedances of process or control system parameters shall include all the information required in 63.10(c)(5) (c)(13), in 40 CFR Section 63.8(c)(7) and 63.8(c)(8), and in the relevant standard, and they shall contain the name, title, and signature of the responsible official who is certifying the accuracy of the report. When no excess emissions or exceedances of a parameter have occurred, or a CMS has not been inoperative, out of control, repaired, or adjusted, such information shall be stated in the report. Summary report. One summary report shall be submitted for the hazardous air pollutants monitored at each affected source (unless the relevant standard specifies that more than one summary report is required. The summary report shall be entitled Summary Report Gaseous and Opacity Excess Emission and Continuous Monitoring System Performance and shall contain the information specified in 40 CFR Section 63.10(e)(3)(vi). If the total duration of excess emissions or process or control system parameter exceedances for the reporting period is 1 percent or greater of the total operating time for the reporting period, or the total CMS downtime for the reporting period is 5 percent or greater of the total operating time for the reporting period, both the summary report and the excess emissions and continuous monitoring system performance report shall be submitted. Page 33 Part 70 Manufacturing General Permit 2014, Permit Appendix B

246 Permit Appendix C: 40 CFR pt. 63, subp. T supplementary information Table T1: Performance, Monitoring, Recordkeeping and Requirement for Control Devices Control Device Freeboard refrigeration device Reduced room draft Performance Requirement The chilled air blanket temperature measured at the center of the air blanket, shall not be greater than 30% of the solvent s boiling point. 1. Ensure the flow or movement of air across the top of the freeboard area of the solvent cleaning machine or within the solvent cleaning machine enclosure does not exceed 50 ft/min at any time, either by controlling room parameters or using an enclosure. 2. Establish and maintain the operating conditions under which the wind speed was demonstrated to be 50 ft/min. or less. Exceedance (*) Monitoring and Recording Requirements A The Permittee shall use thermocouple or thermometer to monitor the temperature at the center of the air blanket during the idling mode and record the results on a weekly basis. A B Controlling room parameters The Permittee shall conduct an initial monitoring test of the windspeed and of room parameters (i.e. redirecting fans, closing doors and windows, etc.), using the following procedure: a. The windspeed shall be measured within 6 inches above the top of the freeboard area of the solvent cleaning machine. b. The direction of the wind current by slowly rotating a velometer or similar device until the maximum speed is located. c. Orient a velometer in the direction of the wind current at each of the 4 corners of the machine. d. Record the reading for each corner and average the values obtained at each corner and record the average wind speed. Using the above procedure, the Permittee shall monitor and record the windspeed on a quarterly basis, and monitor and record the room parameters established during the initial monitoring test on a weekly basis. Partial or total enclosure The Permittee shall conduct an initial monitoring rest, thereafter monthly monitoring tests of the windspeed as follows: determine the direction of the wind current in the enclosure by slowly rotating a velometer inside the entrance to the enclosure until the maximum speed is located and record the maximum wind speed. On a monthly basis the Permittee shall also record the results of the visual inspection to ensure the enclosure is free of cracks, holes and other defects. Page 1 Part 70 Manufacturing General Permit 2014, Permit Appendix C

247 Control Device Working mode cover Idling mode cover Dwell Performance Requirement 1. Ensure that the cover opens only for part entrance and removal and completely covers the cleaning machine opening when closed. 2. Ensure that the cover is maintained free of cracks, holes, and other defects. 1. Ensure that the cover is in place whenever parts are in the machine and completely covers the cleaning machine openings when in place. 2. Ensure that the cover is maintained free of cracks, holes, and other defects. 1. The Permittee shall determine the dwell time for each part or parts basket, or determine the maximum dwell time using the most complex part type or parts basket, using the following procedure: 1) determine the amount of time for the part or parts basket to cease dripping once placed in the vapor zone. The part or parts basket shall be at room temperature before being placed in the vapor zone. 2) The proper dwell time for parts to remain in the free board area above the vapor zone is no less than 35% of the time determined in 1). The Permittee shall record the dwell time for each part or parts basket. Exceedance (*) Monitoring and Recording Requirements B The Permittee shall conduct a visual inspection to determine if the cover is opening and closing properly, completely covers the cleaning machine openings when closed, and is free of cracks, holes, and other defects. The Permittee shall record the results on a monthly basis. A B A B The Permittee shall conduct a visual inspection to determine if the cover is opening and closing properly, completely covers the cleaning machine openings when closed, and is free of cracks, holes, and other defects. The Permittee shall record the results on a monthly basis. Page 2 Part 70 Manufacturing General Permit 2014, Permit Appendix C

248 Control Device Superheated vapor system Carbon adsorber Performance Requirement 2. Ensure that, after cleaning, each part is held in the machine freeboard area above the vapor zone for the dwell time determined as above. 1. The solvent vapor at the center of the superheated vapor zone is at least 10 F above the solvent s boiling point. 2. Ensure that the manufacturer s specifications for determining the minimum proper dwell time within the superheated vapor system is followed. 3. Ensure that parts remain within the superheated vapor for at least the minimum proper dwell time. 1. The concentration of HAP shall not exceed 100 ppm. 2. The cleaning machine shall be used at all times with its associated carbon adsorber. 3. The lip exhaust is located above the solvent cleaning machine cover so that the cover closes below the lip exhaust level. Exceedance (*) Monitoring and Recording Requirements B On a monthly basis, the Permittee shall monitor and record the actual dwell time by measuring the period of time that parts are held within the freeboard area of the solvent cleaning machine after cleaning. A B B A B B The Permittee shall use a thermometer or thermocouple to monitor the temperature at the center of the superheated solvent vapor zone while the solvent cleaning machine is in the idling mode and record the results on a weekly basis. The Permittee shall measure and record the concentration of HAP solvent in the exhaust of the carbon adsorber weekly with a calorimetric detector tube. The measurement shall be conducted while the solvent cleaning machine is in the working mode and is venting to the carbon adsorber using the following procedures: 1) Use a calorimetric detector tube designed to measure a concentration of 100 ppmv of solvent in air to an accuracy of plus or minus 25 ppmv. 2) Use the tube in accordance with the manufacturer s instruction. 3) A sampling port shall meet the minimum requirement for EPA method 1 of the 40 CFR part 60, Appendix A. Page 3 Part 70 Manufacturing General Permit 2014, Permit Appendix C

249 Footnotes to Table T1 (*)Exceedances A: 1. Out of compliance with requirement and are not corrected within 15 days of detection. 2. Adjustments or repairs shall be made to the solvent cleaning system or control device to reestablish required levels. 3. The parameter must be remeasured immediately upon adjustment or repair and demonstrated to be within required limits. (*)Exceedances B: Out of compliance with requirement. Page 4 Part 70 Manufacturing General Permit 2014, Permit Appendix C

250 Table T2: Control Combination for Batch Vapor Solvent Cleaning Machines Table T2a: A Solvent/Air Interface Area of 1.21 Square Meters (13 Square Feet) or less Options Control Combinations 1 Working mode cover, Freeboard ratio of 1.0, Superheated vapor 2 Freeboard refrigeration device Superheated vapor 3 Working mode cover, Freeboard refrigeration device 4 Reduced room draft, Freeboard ratio of 1.0, Superheated vapor 5 Reduced room draft, Freeboard refrigeration device 6 Freeboard refrigeration device, Freeboard ratio of Freeboard refrigeration device, Dwell 8 Reduced room draft, Dwell, Freeboard ratio of Freeboard refrigeration device, Carbon adsorber 10 Freeboard ratio of 1.0, Superheated vapor, Carbon adsorber Table T2b: A Solvent/Air Interface Area of More than 1.21 Square Meters (13 Square Feet) Options Control Combinations 1 Freeboard refrigeration device, Freeboard ratio of 1.0, Superheated vapor 2 Reduced room draft, Dwell, Freeboard refrigeration device 3 Working mode cover, Freeboard refrigeration device, Superheated vapor 4 Freeboard ratio of 1.0, Reduced room draft, Superheated vapor 5 Freeboard refrigeration device, Reduced room draft, Superheated vapor 6 Freeboard refrigeration device, Reduced room draft, Freeboard ratio of Freeboard refrigeration device, Superheated vapor, Carbon adsorber Page 5 Part 70 Manufacturing General Permit 2014, Permit Appendix C

251 Table T3: Control Combinations for Inline Solvent Cleaning Machines Table T3a: Existing Inline Machines Options Control Combinations 1 Freeboard ratio of 1.0, Superheated vapor 2 Freeboard ratio of 1.0,Freeboard refrigeration device 3 Dwell, Freeboard refrigeration device 4 Dwell, Carbon adsorber Table T3b: New Inline Machines Options Control Combinations 1 Freeboard refrigeration device, Superheated vapor 2 Freeboard refrigeration device, Carbon adsorber 3 Superheated vapor, Carbon adsorber Table T4 Facility wide Emission Limits for Facilities With Solvent Cleaning Machines (b)(2) Solvents emitted Facility wide annual emission limits in kg (lbs) for general population degreasing machines PCE only a 4,800 (10,560) 8,000 (17,600) TCE only 14,100 (31,020) 23,500 (51,700) Facility wide annual emission limit in kg (lbs) for military depot maintenance facilities MC only 60,000 (132,000) 100,000 (220,000) Multiple solvents Calculate the MC weighted emissions using Equation T1 60,000 (132,000) 100,000 (220,000) Note: In the equation, the facility emissions of PCE and TCE are weighted according to their carcinogenic potency relative to that of MC. The value of A is The value for B is Equation T1: WE PCE A TCE B MC Where: WE = Weighted 12 month rolling total emissions in kg (lbs). PCE = 12 month rolling total PCE emissions from all solvent cleaning machines at the facility in kg (lbs). TCE = 12 month rolling total TCE emission from all solvent cleaning machines at the facility in kg (lbs). MC = 12 month rolling total MC emissions from all solvent cleaning machines at the facility in kg (lbs). Page 6 Part 70 Manufacturing General Permit 2014, Permit Appendix C

252 Monthly Calculations (c) The Permittee shall determine solvent emissions (E unit ) from each solvent cleaning machine using the records of all solvent additions and deletions for the previous month and using Equation T2 below Equation T2: E SA LSR SSR Where: E unit = the total halogenated HAP solvent emissions from the solvent cleaning machine during the most recent month i, (kilograms of solvent per month). SA i = the total amount of halogenated HAP liquid solvent added to the solvent cleaning machine during the most recent month i, (kilograms of solvent per month). LSR i = the total amount of halogenated HAP liquid solvent removed from the solvent cleaning machine during the most recent month i, (kilograms of solvent per month). SSR i = the total amount of halogenated HAP solvent removed from the solvent cleaning machine in solid waste, obtained as described in paragraph (c)(3) of this section, during the most recent month i, (kilograms of solvent per month). [Equation T3 reserved] After 12 months of emissions data are available, the Permittee shall determine the 12 month rolling total emissions for each solvent cleaning machine (ET unit ) for the 12 month period ending with the most recent month using Equation T4 below. Equation T4: ET Where: E ET unit = the total halogenated HAP solvent emissions over the preceding 12 months, (kilograms of solvent emissions per 12 month period). E unit = halogenated HAP solvent emissions for each month (j) for the most recent 12 months (kilograms of solvent per month). After 12 months of emissions data are available, the Permittee shall determine the 12 month rolling total emissions for all cleaning machines at the facility (ET facility ) for the 12 month period ending with the most recent month using Equation T5 below. Page 7 Part 70 Manufacturing General Permit 2014, Permit Appendix C

253 Equation T5: ET Where: ET ET facility = the total halogenated HAP solvent emissions over the preceding 12 months for all cleaning machines at the facility, (kilograms of solvent emissions per 12 month period). ET unit = the total halogenated HAP solvent emissions over the preceding 12 months for each unit j, where i equals the total number of units at the facility (kilograms of solvent emissions per 12 month period). Page 8 Part 70 Manufacturing General Permit 2014, Permit Appendix C

254 Permit Appendix D for 40 CFR pt. 63, subp. MMMM Contents of this appendix: Emission limits new and existing sources o Alternative 1: predominant activity o Alternative 2: facility specific emissions limit Equation M1: facility specific emissions limit Compliant material option requirements o Volume fraction calculation Equation MC1: volume fraction of coating solids o Organic HAP content calculation Equation MC2: organic HAP content of a coating Emission rate without add on controls option requirements o Volume fraction calculation Equation MC1: volume fraction of coating solids o Organic HAP emissions Equation ME1: monthly total mass of organic HAP emissions Equation ME1a: total mass of organic HAP in coatings used during the month Equation ME1b: total mass of organic HAP in thinners/additives used during the month Equation ME1c: total mass of organic HAP in cleaning materials used during the month Organic HAP in waste materials used in Equation ME1 o Total volume used Equation ME2: monthly total volume coating solids used o Organic HAP emission rate Equation ME3: average organic HAP emission rate for the compliance period Mass fraction determination for solvent blends o Tables 1 and 2: [not used in this appendix] o Table 3: Default organic HAP mass fraction for solvents and solvent blends o Table 4: Default organic HAP mass fraction for petroleum solvent groups Emission limits new and existing sources Emission limit alternatives Alternative 1: Facilities with surface coating operations that are predominantly either general use or magnet wire (c)(1); Minn. R If the general use or magnet wire surface coating operations subject to only one of the emission limits specified in 40 CFR sections (a)(1), (3), (b)(1), or (3) account for 90 percent or more of the surface coating activity at the facility (i.e., it is the predominant activity at the facility), then compliance with that one emission limitation for all surface coating operations constitutes compliance with the other applicable emission limits. The determination of predominant activity shall accurately reflect current and projected coating operations and shall be verifiable through appropriate documentation. The Permittee shall use gallons (gal) of solids used as a measure of relative surface coating activity over a representative period of operation. The Permittee may estimate the relative volume of coating solids used from parameters other than coating consumption and volume solids content (e.g., design specifications for the parts or products coated and the Page 1 Part 70 Manufacturing General Permit 2014, Permit Appendix D

255 number of items produced). The use of parameters other than coating consumption and volume solids content must be approved by the Administrator. The Permittee may use data for any reasonable time period of at least 1 year in determining the relative amount of coating activity, as long as these data represent the way the source will continue to operate in the future and are approved by the Administrator. Alternative 2: Facility specific emissions unit (c)(2); Minn. R If the Permittee elects to comply with the applicable subcategory emissions limits described in 40 CFR paragraphs (a)(1) (5) and (b)(1) (5) using the facility specific emission limit alternative, then compliance with the facility specific emission limit and the emission limitations in 40 CFR pt. 63, subp. MMMM constitutes compliance with this and all other applicable surface coating NESHAP. In calculating a facility specific emission limit, the Permittee shall include all coating activities at the facility that meet the applicability criteria of the other subcategories and constitute more than 1 percent of total coating activities. The Permittee shall include in the compliance calculation all coating activities that meet the applicability criteria of other surface coating NESHAP but comprise less than 1 percent of coating activities, but may exclude these activities from the determination of predominant activity. The Permittee shall calculate the facility specific emission limit for each 12 month compliance period using Equation M1. Equation M1: Facility Specific Emission Limit n i 1 Limit i Solids i n i 1 Solids i Where: Facility Specific Emission Limit = Facility specific emission limit for each 12 month compliance period. (lb organic HAP per lb coating solids used) Limit i = The new source or existing source emission limit applicable to coating operation, i, included in the facility specific emission limit, converted to lb organic HAP per lb coating solids used, if the emission limit is not already in those units. All emission limits included in the facilityspecific emission limit must be in the same units. (lb organic HAP per lb coating solids used) Solids i = The volume of solids used in coating operation, i, in the 12 month compliance period that is subject to emission limit, i. The Permittee may estimate the volume of coating solids used from parameters other than coating consumption and volume solids content (e.g., design specifications for the parts or products coated and the number of items produced). The use of parameters other than coating consumption and volume solids content must be approved by the Administrator. (gal) n = The number of different coating operations included in the facility specific emission limit. To convert an emission limit in another surface coating NESHAP from lb organic HAP per lb coating solids used to lb organic HAP per gallon coating solids used, the Permittee shall use the default solids density of 10.5 lb solids per gal solids (1.26 kg solids per liter solids). Page 2 Part 70 Manufacturing General Permit 2014, Permit Appendix D

256 Compliant material option requirements Compliance Equations Volume Fraction calculation (b)(4); Minn. R Calculation of volume fraction of coating solids. The Permittee may determine the volume fraction of coating solids by using the following equation (Equation MC1): Equation MC1: Where: V s 1 = Volume fraction of coating solids, gallon coating solids per gallon coating. m vol = Total volatile matter content of the coating, including HAP, VOCs, water, and exempt compounds, determined according to Method 24 in appendix A of 40 CFR part 60, lb mass volatile matter per gallon coating. D avg = Average density of volatile matter in the coating, lb mass volatile matter per gallon volatile matter, determined from test results using ASTM Method D , "Standard Test Method for Density of Liquid Coatings, Inks, and Related Products" (incorporated by reference, see 63.14), information from the supplier or manufacturer of the material, or reference sources providing density or specific gravity data for pure materials. Organic HAP Content calculation (d); Minn. R Organic HAP Content: The Permittee shall calculate the organic HAP content, pounds of organic HAP emitted per gallon coating solids used, of each coating used during the compliance period using the following equation (Equation MC2): Equation MC2: Where: H c D c W c V s = Organic HAP content of the coating, lb mass organic HAP emitted per gallon coating solids used. = Density of coating, lb mass coating per gallon coating, determined according to the Density requirement above. = Mass fraction of organic HAP in the coating, lb mass organic HAP per lb mass coating, determined according to the Mass Fraction requirement in the NESHAP subp. MMMM: Compliant Material Option Requirements section of this permit. = Volume fraction of coating solids, gallon coating solids per gallon coating, determined according to the Volume Fraction requirement (Equation MC1) above. Emission rate without add on controls option requirements Compliance Equations Volume Fraction calculation (b)(4); Minn. R Calculation of volume fraction of coating solids. The Permittee may determine the volume fraction of coating solids by using the following equation (Equation MC1): Page 3 Part 70 Manufacturing General Permit 2014, Permit Appendix D

257 Equation MC1: Where: V s 1 = Volume fraction of coating solids, gallon coating solids per gallon coating. m vol = Total volatile matter content of the coating, including HAP, VOCs, water, and exempt compounds, determined according to Method 24 in appendix A of 40 CFR part 60, lb mass volatile matter per gallon coating. D avg = Average density of volatile matter in the coating, lb mass volatile matter per gallon volatile matter, determined from test results using ASTM Method D , "Standard Test Method for Density of Liquid Coatings, Inks, and Related Products" (incorporated by reference, see 63.14), information from the supplier or manufacturer of the material, or reference sources providing density or specific gravity data for pure materials. Organic HAP Emissions (e); Minn. R Organic HAP Emissions: The mass of organic HAP emissions is the combined mass of organic HAP contained in all coatings, thinners and/or other additives, and cleaning materials used during each month minus the organic HAP in certain waste materials. The Permittee shall calculate the mass of organic HAP emissions, using the following equation (Equation ME1): Equation ME1: Where: H e A B C R w A B C = Total mass of organic HAP emissions during the month, lb mass = Total mass of organic HAP in the coatings used during the month, lb mass, as calculated in Equation ME1a in this appendix = Total mass of organic HAP in the thinners and/or other additives used during the month, lbmass, as calculated in Equation ME1b in this appendix = Total mass of organic HAP in the cleaning materials used during the month, lb mass, as calculated in Equation ME1c in this appendix = Total mass of organic HAP in the waste materials sent or designated for shipment to a hazardous waste TSDF for treatment or disposal used during the month, lb mass, determined according to Organic HAP in Waste Materials below. (The Permittee shall assign a value of zero to R w if not using this allowance.) Organic HAP in Coatings (e)(1); Minn. R Total mass of organic HAP in coatings: The Permittee shall calculate the mass of organic HAP in the coatings used during the month using the following equation (Equation ME1a): Equation ME1a: A 1,,, Where: A = Total mass of organic HAP in the coatings used during the month, lb mass Vol c,i = Total volume of coating, i, used during the month, gallons D c,i = Density of coating, i, used during the month, lb mass per gallon coating Page 4 Part 70 Manufacturing General Permit 2014, Permit Appendix D

258 W c,i = Mass fraction of organic HAP in coating, i, lb mass organic HAP per lb mass coating. For reactive adhesives as defined in , the Permittee shall use the mass fraction of organic Hap that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP m = Number of different coatings used during the month Organic HAP in Thinners/Additives (e)(2); Minn. R Total mass of organic HAP in thinners and/or other additives: The Permittee shall calculate the mass of organic HAP in the thinners and/or other additives used during the month using the following equation (Equation ME1b): Equation ME1b: B 1,,, Where: A = Total mass of organic HAP in the thinners and/or other additives used during the month, lb mass Vol t,j = Total volume of thinner and/or other additive, j, used during the month, gallons D t,j = Density of thinner and/or other additive, j, used during the month, lb mass per gallon coating W t,j = Mass fraction of organic HAP in thinner and/or other additive, j, lb mass organic HAP per lb mass thinner and/or other additive. For reactive adhesives as defined in , the Permittee shall use the mass fraction of organic Hap that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP n = Number of different thinners and/or other additives used during the month Organic HAP in Cleaning Materials (e)(3); Minn. R Total mass of organic HAP in cleaning materials: The Permittee shall calculate the mass of organic HAP in the cleaning materials used during the month using the following equation (Equation ME1c): Equation ME1c: C 1,,, Where: C = Total mass of organic HAP in the cleaning materials used during the month, lb mass Vol s,k = Total volume of cleaning material, k, used during the month, gallons D s,k = Density of cleaning material, k, used during the month, lb mass per gallon coating W s,k = Mass fraction of organic HAP in cleaning material, k, lb mass organic HAP per lbmass coating. For reactive adhesives as defined in , the Permittee shall use the mass fraction of organic Hap that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP p = Number of different cleaning materials used during the month Page 5 Part 70 Manufacturing General Permit 2014, Permit Appendix D

259 Organic HAP in Waste Materials (e)(4); Minn. R If the Permittee elects to account for the mass of organic HAP contained in waste materials sent or designated for shipment to a hazardous waste TSDF in Equation ME1 in this appendix, then the Permittee shall determine the mass according to the following requirements: R w = Total mass of organic HAP in the waste materials sent or designated for shipment to a hazardous waste TSDF for treatment or disposal used during the month, lb mass. (The Permittee shall assign a value of zero to R w if not using this allowance.) i) The Permittee shall include in the determination only waste materials that: Are generated by coating operations in the affected source for which Equation ME1 in this appendix is used; and That will be treated or disposed of by a facility that is regulated as a TSDF under 40 CFR part 262,264, 265, or 266. The TSDF may be either off site or on site. The Permittee shall not include organic HAP contained in wastewater. ii) iii) iv) The Permittee shall determine either the amount of the waste materials sent to a TSDF during the month or the amount collected and stored during the month and designated for future transport to a TSDF. The Permittee shall not include in the determination any waste materials sent to a TSDF during a month if these materials have already been included in the amount collected and stored during that month or a previous month. The Permittee shall determine the total mass of organic HAP contained in the waste materials specified above in paragraph (ii). The Permittee shall document the methodology used to determine the amount of waste materials and the total mass of organic HAP they contain, as required in (h). If waste manifests include this information, the Permittee may use them as part of the documentation of the amount of waste materials and mass of organic HAP contained in them. Total Volume Used (f); Minn. R Total Volume Used: The Permittee shall determine the total volume of coating solids used, gallons, which is the combined volume of coating solids for all the coatings used during each month, using the following equation (Equation ME2): Equation ME2: 1,, Where: V st = Total volume of coating solids used during the month, gallons Vol c,i = Total volume of coating, i, used during the month, gallons V s,i = Volume fraction of coating solids for coating, i, gallon solids per gallon coating, determined according to Volume Fraction calculation above m = Number of different coatings used during the month Page 6 Part 70 Manufacturing General Permit 2014, Permit Appendix D

260 Organic HAP Emission Rate (g); Minn. R Organic HAP Emission Rate: The Permittee shall calculate the organic HAP emission rate for the compliance period, lb mass organic HAP emitted per gallon coating solids used, using the following equation (Equation ME3): Equation ME3: 1 Where: H yr H e V st y n 1 = Average organic HAP emission rate for the compliance period, in lb mass organic HAP emitted per gallon coating solids used = Total mass of organic HAP emissions from all materials used during the month, y, in lb mass, as calculated by Equation ME1 in this appendix = Total volume of coating solids used during month, y, in gallons, as calculated by Equation ME2 in this appendix = Identifier for months = Number of full or partial months in the compliance period (for the initial compliance period, n equals 12 if the compliance date falls on the first day of a month; otherwise n equals 13; for all following compliance periods, n equals 12) Mass fraction determination for solvent blends Tables 3 and 4 of 40 CFR pt. 63, subp. MMMM; s (a)(5) and (a); Minn. R Solvent blends may be listed as single components for some materials in data provided by manufacturers or suppliers. Solvent blends may contain organic HAP which must be counted toward the total organic HAP mass fraction of the materials. When test data and manufacturer's data for solvent blends are not available, the Permittee may use the default values for the mass fraction of organic HAP in these solvent blends listed in Table 3 or 4 below. If the tables are used, the Permittee shall use the values in Table 3 for all solvent blends that match the Table 3 entries according to the instructions for Table 3, and Table 4 may be used only if the solvent blends in the materials used do not match any of the solvent blends in Table 3 and it is known only whether the blend is aliphatic or aromatic. However, if the results of a Method 311 (appendix A to 40 CFR pt. 63) test indicate higher values than those listed in Tables 3 or 4, the Method 311 results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct. Page 7 Part 70 Manufacturing General Permit 2014, Permit Appendix D

261 Table 3: Default Organic HAP Mass Fraction for Solvents and Solvent Blends The Permittee may use the mass fraction values in the following table for solvent blends for which the Permittee does not have test data or manufacturer s formulation data and which match either the solvent blend name or the chemical abstract series (CAS) number. If a solvent blend matches both the name and the CAS number for an entry, the Permittee shall use that entry s organic HAP mass fraction for that solvent blend. Otherwise, the Permittee shall use the organic HAP mass fraction for the entry matching either the solvent blend name or CAS number; Or the Permittee shall use the organic HAP mass fraction from Table 4 below if neither the name nor CAS number match. Solvent/solvent blend CAS No. Average organic HAP mass fraction Typical organic HAP, percent by mass Toluene Toluene Xylene(s) Xylenes, ethylbenzene Hexane n hexane n Hexane n hexane Ethylbenzene Ethylbenzene Aliphatic None Aromatic % xylene, 1% cumene Aromatic Naphthalene Aromatic naphtha % xylene, 1% cumene Aromatic solvent Naphthalene Exempt mineral spirits None Ligroines (VM & P) None Lactol spirits Toluene Low aromatic white spirit None Mineral spirit Xylenes Hydrotreated naphtha None Hydrotreated light distillate Toluene Stoddard solvent Xylenes Super high flash naphtha Xylenes Varsol solvent % xylenes, 0.5% ethylbenzene VM & P naphtha % toluene, 3% xylene Petroleum distillate mixture % naphthalene, 4% biphenyl Page 8 Part 70 Manufacturing General Permit 2014, Permit Appendix D

262 Table 4: Default Organic HAP Mass Fraction for Petroleum Solvent Groups The Permittee may use the mass fraction values in the following table for solvent blends for which the Permittee does not have test data or manufacturer s formulation data. The Permittee shall use this table only if the solvent blend does not match any of the solvent blends in Table 3 above by either solvent blend name or CAS number and the Permittee knows only whether the blend is aliphatic or aromatic. Solvent type Average organic HAP mass fraction Typical organic HAP, percent by mass Aliphatic* % Xylene, 1% Toluene, and 1% Ethylbenzene Aromatic** % Xylene, 1% Toluene, and 1% Ethylbenzene * Mineral Spirits 135, Mineral Spirits 130 EC, Naphtha, Mixed Hydrocarbon, Aliphatic Hydrocarbon, Aliphatic Naphtha, Naphthol Spirits, Petroleum Spirits, Petroleum Oil, Petroleum Naphtha, Solvent Naphtha, Solvent Blend. ** Medium flash Naphtha, High flash Naphtha, Aromatic Naphtha, Light Aromatic Naphtha, Light Aromatic Hydrocarbons, Aromatic Hydrocarbons, Light Aromatic Solvent. Page 9 Part 70 Manufacturing General Permit 2014, Permit Appendix D

263 Permit Appendix E for 40 CFR pt. 63, subp. PPPP Contents of this appendix: Emission limits new and existing sources o Alternative 1: predominant activity o Alternative 2: facility specific emissions limit Equation P1: facility specific emissions limit Compliant material option requirements o Organic HAP content calculation Equation PC1: organic HAP content of a coating Emission rate without add on controls option requirements o Organic HAP emissions Equation PE1: monthly total mass of organic HAP emissions Equation PE1a: total mass of organic HAP in coatings used during the month Equation PE1b: total mass of organic HAP in thinners/additives used during the month Equation PE1c: total mass of organic HAP in cleaning materials used during the month Organic HAP in waste materials used in Equation PE1 o Total mass of coating solids Equation PE2: monthly total mass coating solids used o Organic HAP emission rate Equation PE3: average organic HAP emission rate for the compliance period Mass fraction determination for solvent blends o Tables 1 and 2: [not used in this appendix] o Table 3: Default organic HAP mass fraction for solvents and solvent blends o Table 4: Default organic HAP mass fraction for petroleum solvent groups Emission limits new and existing sources Emission limit alternatives Alternative 1: Facilities with surface coating operations that are predominantly either general use or TPO (c)(1); Minn. R If the general use or TPO surface coating operations subject to only one of the emission limits specified in 40 CFR paragraphs (a)(1), (b)(3), (b)(1), or (b)(3) account for 90 percent or more of the surface coating activity at the facility then compliance with that emission limitation for all surface coating operations constitutes compliance with the other applicable emission limits. The determination of predominant activity shall accurately reflect current and projected coating operations and shall be verifiable through appropriate documentation. The Permittee shall use pounds (lb) of solids used as a measure of relative surface coating activity over a representative period of operation. The Permittee may estimate the relative mass of coating solids used from parameters other than coating consumption and mass solids content (e.g., design specifications for the parts or products coated and the number of items produced). The use of parameters other than coating consumption and mass solids content must be approved by the Administrator. Page 1 Part 70 Manufacturing General Permit 2014, Permit Appendix E

264 The Permittee may use data for any reasonable time period of at least 1 year in determining the relative amount of coating activity, as long as these data represent the way the source will continue to operate in the future and are approved by the Administrator. Alternative 2: Facility specific emissions unit (c)(2); Minn. R If the Permittee elects to comply with the applicable subcategory emissions limits described in 40 CFR paragraphs (a)(1) (4) and (b)(1) (4) using the facility specific emission limit alternative, then compliance with the facility specific emission limit and the emission limitations in 40 CFR pt. 63, subp. PPPP constitutes compliance with this and all other applicable surface coating NESHAP. In calculating a facility specific emission limit, the Permittee shall include all coating activities at the facility that meet the applicability criteria of the other subcategories and constitute more than 1 percent of total coating activities. The Permittee shall include in the compliance calculation all coating activities that meet the applicability criteria of other surface coating NESHAP but comprise less than 1 percent of coating activities, but may exclude these activities from the determination of predominant activity. The Permittee shall calculate the facility specific emission limit for each 12 month compliance period using Equation P1. Equation P1: Facility Specific Emission Limit n i 1 Limit i Solids i n i 1 Solids i Where: Facility Specific Emission Limit = Facility specific emission limit for each 12 month compliance period. (lb organic HAP per lb coating solids used) Limit i = The new source or existing source emission limit applicable to coating operation, i, included in the facility specific emission limit, converted to lb organic HAP per lb coating solids used, if the emission limit is not already in those units. All emission limits included in the facilityspecific emission limit must be in the same units. (lb organic HAP per lb coating solids used) Solids i = The volume of solids used in coating operation, i, in the 12 month compliance period that is subject to emission limit, i. The Permittee may estimate the mass of coating solids used from parameters other than coating consumption and mass solids content (e.g., design specifications for the parts or products coated and the number of items produced). The use of parameters other than coating consumption and mass solids content must be approved by the Administrator. (lb) n = The number of different coating operations included in the facility specific emission limit. To convert an emission limit in another surface coating NESHAP from lb organic HAP per gal coating solids used to lb organic HAP per lb coating solids used, the Permittee shall use the default solids density of 12.5 lb solids per gal solids (1.50 kg solids per liter solids). Page 2 Part 70 Manufacturing General Permit 2014, Permit Appendix E

265 Compliant material option requirements Compliance Equations Organic HAP Content calculation (c); Minn. R Organic HAP Content: The Permittee shall calculate the organic HAP content, pounds of organic HAP emitted per pound coating solids used, of each coating used during the compliance period using the following equation (Equation PC1): Equation PC1: Where: H c W c S c = Organic HAP content of the coating, lb organic HAP emitted per lb coating solids used. = Mass fraction of organic HAP in the coating, lb organic HAP per lb coating, determined according to the Mass Fraction of Organic HAP requirement in the NESHAP subp. PPPP: Compliant Material Option Requirements section of this permit. = Mass fraction of coating solids, lb coating solids per lb coating, determined according to the Mass Fraction of Coating Solids requirement in the NESHAP subp. PPPP: Compliant Material Option Requirements section of this permit. Emission rate without add on controls option requirements Compliance Equations Organic HAP Emissions (e); Minn. R Organic HAP Emissions: The mass of organic HAP emissions is the combined mass of organic HAP contained in all coatings, thinners and/or other additives, and cleaning materials used during each month minus the organic HAP in certain waste materials. The Permittee shall calculate the mass of organic HAP emissions, using the following equation (Equation PE1): Equation PE1: Where: H e A B C R w A B C = Total mass of organic HAP emissions during the month, lb mass = Total mass of organic HAP in the coatings used during the month, lb mass, as calculated in Equation PE1a in this appendix = Total mass of organic HAP in the thinners and/or other additives used during the month, lbmass, as calculated in Equation PE1b in this appendix = Total mass of organic HAP in the cleaning materials used during the month, lb mass, as calculated in Equation PE1c in this appendix = Total mass of organic HAP in the waste materials sent or designated for shipment to a hazardous waste TSDF for treatment or disposal used during the month, lb mass, determined according to Organic HAP in Waste Materials below. (The Permittee shall assign a value of zero to R w if not using this allowance.) Page 3 Organic HAP in Coatings (e)(1); Minn. R Part 70 Manufacturing General Permit 2014, Permit Appendix E

266 Total mass of organic HAP in coatings: The Permittee shall calculate the mass of organic HAP in the coatings used during the month using the following equation (Equation PE1a): Equation PE1a: A 1,,, Where: A = Total mass of organic HAP in the coatings used during the month, lb mass Vol c,i = Total volume of coating, i, used during the month, gallons D c,i = Density of coating, i, used during the month, lb mass per gallon coating W c,i = Mass fraction of organic HAP in coating, i, lb mass organic HAP per lb mass coating. For reactive adhesives as defined in , the Permittee shall use the mass fraction of organic Hap that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP m = Number of different coatings used during the month Organic HAP in Thinners/Additives (e)(2); Minn. R Total mass of organic HAP in thinners and/or other additives: The Permittee shall calculate the mass of organic HAP in the thinners and/or other additives used during the month using the following equation (Equation PE1b): Equation PE1b: B 1,,, Where: A = Total mass of organic HAP in the thinners and/or other additives used during the month, lb mass Vol t,j = Total volume of thinner and/or other additive, j, used during the month, gallons D t,j = Density of thinner and/or other additive, j, used during the month, lb mass per gallon coating W t,j = Mass fraction of organic HAP in thinner and/or other additive, j, lb mass organic HAP per lb mass thinner and/or other additive. For reactive adhesives as defined in , the Permittee shall use the mass fraction of organic Hap that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP n = Number of different thinners and/or other additives used during the month Organic HAP in Cleaning Materials (e)(3); Minn. R Total mass of organic HAP in cleaning materials: The Permittee shall calculate the mass of organic HAP in the cleaning materials used during the month using the following equation (Equation PE1c): Equation PE1c: C 1,,, Where: C = Total mass of organic HAP in the cleaning materials used during the month, lb mass Vol s,k = Total volume of cleaning material, k, used during the month, gallons Page 4 D s,k = Density of cleaning material, k, used during the month, lb mass per gallon coating Part 70 Manufacturing General Permit 2014, Permit Appendix E

267 W s,k = Mass fraction of organic HAP in cleaning material, k, lb mass organic HAP per lbmass coating. For reactive adhesives as defined in , the Permittee shall use the mass fraction of organic Hap that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP p = Number of different cleaning materials used during the month Organic HAP in Waste Materials (e)(4); Minn. R If the Permittee elects to account for the mass of organic HAP contained in waste materials sent or designated for shipment to a hazardous waste TSDF in Equation PE1 in this appendix, then the Permittee shall determine the mass according to the following requirements: R w = Total mass of organic HAP in the waste materials sent or designated for shipment to a hazardous waste TSDF for treatment or disposal used during the month, lb mass. (The Permittee shall assign a value of zero to R w if not using this allowance.) v) The Permittee shall include in the determination only waste materials that: Are generated by coating operations in the affected source for which Equation PE1 in this appendix is used; and That will be treated or disposed of by a facility that is regulated as a TSDF under 40 CFR part 262,264, 265, or 266. The TSDF may be either off site or on site. The Permittee shall not include organic HAP contained in wastewater. vi) The Permittee shall determine either the amount of the waste materials sent to a TSDF during the month or the amount collected and stored during the month and designated for future transport to a TSDF. The Permittee shall not include in the determination any waste materials sent to a TSDF during a month if these materials have already been included in the amount collected and stored during that month or a previous month. vii) The Permittee shall determine the total mass of organic HAP contained in the waste materials specified above in paragraph (ii). viii) The Permittee shall document the methodology used to determine the amount of waste materials and the total mass of organic HAP they contain, as required in (h). If waste manifests include this information, the Permittee may use them as part of the documentation of the amount of waste materials and mass of organic HAP contained in them. Total Mass of Coating Solids (f); Minn. R Total Mass of Coating Solids: The Permittee shall determine the total mass of coating solids used, lb mass, which is the combined mass of coating solids for all the coatings used during each month, using the following equation (Equation PE2): Equation PE2: 1,,, Where: M st = Total mass of coating solids used during the month, lb mass Vol c,i = Total volume of coating, i, used during the month, gallons Page 5 Part 70 Manufacturing General Permit 2014, Permit Appendix E

268 D c,i = Density of coating, i, lb per gallon coating, determined according to the Density of Each Material requirement in the NESHAP subp. PPPP: Compliant Material Option Requirements section of this permit. M s,i = Mass fraction of coating solids for coating, i, lb solids per lb coating, determined according to the Mass Fraction of Coating Solids requirement in the NESHAP subp. PPPP: Compliant Material Option Requirements section of this permit. m = Number of different coatings used during the month Organic HAP Emission Rate (g); Minn. R Organic HAP Emission Rate: The Permittee shall calculate the organic HAP emission rate for the compliance period, lb organic HAP emitted per lb coating solids used, using the following equation (Equation PE3): Equation PE3: 1 Where: H yr H e M st y n 1 = Average organic HAP emission rate for the compliance period, in lb organic HAP emitted per lb coating solids used = Total mass of organic HAP emissions from all materials used during the month, y, in lb mass, as calculated by Equation PE1 in this appendix = Total mass of coating solids used during month, y, in lb mass, as calculated by Equation PE2 in this appendix = Identifier for months = Number of full or partial months in the compliance period (for the initial compliance period, n equals 12 if the compliance date falls on the first day of a month; otherwise n equals 13; for all following compliance periods, n equals 12) Mass fraction determination for solvent blends Tables 3 and 4 of 40 CFR pt. 63, subp. PPPP; s (a)(5) and (a); Minn. R Solvent blends may be listed as single components for some materials in data provided by manufacturers or suppliers. Solvent blends may contain organic HAP which must be counted toward the total organic HAP mass fraction of the materials. When test data and manufacturer's data for solvent blends are not available, he Permittee may use the default values for the mass fraction of organic HAP in these solvent blends listed in Table 3 or 4 below. If the tables are used, the Permittee shall use the values in Table 3 for all solvent blends that match the Table 3 entries according to the instructions for Table 3, and Table 4 may be used only if the solvent blends in the materials used do not match any of the solvent blends in Table 3 and it is known only whether the blend is aliphatic or aromatic. However, if the results of a Method 311 (appendix A to 40 CFR pt. 63) test indicate higher values than those listed in Tables 3 or 4, the Method 311 results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct. Page 6 Part 70 Manufacturing General Permit 2014, Permit Appendix E

269 Table 3: Default Organic HAP Mass Fraction for Solvents and Solvent Blends The Permittee may use the mass fraction values in the following table for solvent blends for which the Permittee does not have test data or manufacturer s formulation data and which match either the solvent blend name or the chemical abstract series (CAS) number. If a solvent blend matches both the name and the CAS number for an entry, the Permittee shall use that entry s organic HAP mass fraction for that solvent blend. Otherwise, the Permittee shall use the organic HAP mass fraction for the entry matching either the solvent blend name or CAS number; Or the Permittee shall use the organic HAP mass fraction from Table 4 below if neither the name nor CAS number match. Solvent/solvent blend CAS No. Average organic HAP mass fraction Typical organic HAP, percent by mass Toluene Toluene Xylene(s) Xylenes, ethylbenzene Hexane n hexane n Hexane n hexane Ethylbenzene Ethylbenzene Aliphatic None Aromatic % xylene, 1% cumene Aromatic Naphthalene Aromatic naphtha % xylene, 1% cumene Aromatic solvent Naphthalene Exempt mineral spirits None Ligroines (VM & P) None Lactol spirits Toluene Low aromatic white spirit None Mineral spirit Xylenes Hydrotreated naphtha None Hydrotreated light distillate Toluene Stoddard solvent Xylenes Super high flash naphtha Xylenes Varsol solvent % xylenes, 0.5% ethylbenzene VM & P naphtha % toluene, 3% xylene Petroleum distillate mixture % naphthalene, 4% biphenyl Page 7 Part 70 Manufacturing General Permit 2014, Permit Appendix E

270 Table 4: Default Organic HAP Mass Fraction for Petroleum Solvent Groups The Permittee may use the mass fraction values in the following table for solvent blends for which the Permittee does not have test data or manufacturer s formulation data. The Permittee shall use this table only if the solvent blend does not match any of the solvent blends in Table 3 above by either solvent blend name or CAS number and the Permittee knows only whether the blend is aliphatic or aromatic. Solvent type Average organic HAP mass fraction Typical organic HAP, percent by mass Aliphatic* % Xylene, 1% Toluene, and 1% Ethylbenzene Aromatic** % Xylene, 1% Toluene, and 1% Ethylbenzene * Mineral Spirits 135, Mineral Spirits 130 EC, Naphtha, Mixed Hydrocarbon, Aliphatic Hydrocarbon, Aliphatic Naphtha, Naphthol Spirits, Petroleum Spirits, Petroleum Oil, Petroleum Naphtha, Solvent Naphtha, Solvent Blend. ** Medium flash Naphtha, High flash Naphtha, Aromatic Naphtha, Light Aromatic Naphtha, Light Aromatic Hydrocarbons, Aromatic Hydrocarbons, Light Aromatic Solvent. Page 8 Part 70 Manufacturing General Permit 2014, Permit Appendix E

271 Permit Appendix F: 40 CFR pt. 63, subp. WWWW supplementary information Table W1 of Subpart WWWW: Equations to Calculate Organic HAP Emissions Factors for Specific Open Molding and Centrifugal Casting Process Streams 1 The Permittee shall use the equations in the following table to calculate organic HAP emissions factors for specific open molding and centrifugal casting process streams: If your operation type is new or existing.. 1. Open molding operation And you use.. With. Use the organic HAP Emission Factor (EF) Equation for materials with less than 33 percent organic HAP (19% organic HAP for nonatomized gel coat) 2,3,4 a. Manual resin application i. nonvapor suppressed resin. ii. vapor suppressed resin iii. vacuum bagging/closed mold curing with roll out iv. vacuum bagging/closed mold curing without roll out EF = x % HAP x EF = x % HAP x 2000 x (1 (0.5 x VSE factor)). EF = x % HAP x 2000 x EF = x % HAP x 2000 x 0.5 Use the organic HAP Emission Factor (EF) Equation for materials with 33 percent or more organic HAP (19% organic HAP for nonatomized gel coat) 2,3,4 EF = ((0.286 x %HAP) ) x EF = ((0.286 x %HAP) ) x 2000 x (1 (0.5 x VSE factor)). EF = ((0.286 x %HAP) ) x 2000 x 0.8. EF = ((0.286 x %HAP) ) x 2000 x 0.5 b. atomized mechanical resin application i. nonvapor suppressed resin. ii. vapor suppressed resin iii. vacuum bagging/closed mold curing with roll out iv. vacuum bagging/closed mold curing without roll out EF = x % HAP x EF = x % HAP x 2000 x (1 (0.45 x VSE factor)). EF = x % HAP x 2000 x EF = x % HAP x 2000 x 0.55 EF = ((0.714 x %HAP) 0.18) x EF = ((0.714 x %HAP) 0.18) x 2000 x (1 (0.45 x VSE factor)). EF = ((0.714 x %HAP) 0.18) x 2000 x EF = ((0.714 x %HAP) 0.18) x 2000 x 0.55 c. nonatomized mechanical resin i. nonvapor suppressed resin. EF = x % HAP x 2000 EF = ((0.157 x %HAP) ) x Page 1 Part 70 Manufacturing General Permit 2014, Permit Appendix F

272 If your operation type is new or existing.. And you use.. With. Use the organic HAP Emission Factor (EF) Equation for materials with less than 33 percent organic HAP (19% organic HAP for nonatomized gel coat) 2,3,4 application ii. vapor suppressed resin iii. vacuum bagging/closed mold curing with roll out iv. vacuum bagging/closed mold curing without roll out.. EF = x % HAP x 2000 x (1 (0.45 x VSE factor)). EF = x % HAP x 2000 x EF = x % HAP x 2000 x 0.55 Use the organic HAP Emission Factor (EF) Equation for materials with 33 percent or more organic HAP (19% organic HAP for nonatomized gel coat) 2,3,4 EF = ((0.157 x %HAP) ) x 2000 x (1 (0.45 x VSE factor)). EF = ((0.157 x %HAP) ) x 2000 x EF = ((0.157 x %HAP) ) x 2000 x 0.55 d. atomized mechanical resin application with robotic or automated spray control 5 e. filament application 6 i. nonvapor suppressed resin. ii. vapor suppressed resin nonvapor suppressed resin EF = x % HAP x 2000 x 0.77 EF = 0.77 x ((0.714 x %HAP) 0.18) x 2000 EF = x % HAP x EF = 0.12 x % HAP x 2000 EF = (( x %HAP) ) x 2000 EF = (( x %HAP) ) x 2000 x Centrifugal casting operations 7,8 f. atomized spray gel coat application g. nonatomized spray gel coat application h. atomized spray gel coat application using robotic or automated spray a. heated air blown through molds b. vented molds, but air vented through the molds is not heated. nonvapor suppressed gel coat nonvapor suppressed gel coat nonvapor suppressed gel coat nonvapor suppressed gel coat nonvapor suppressed gel coat EF = x % HAP x 2000 EF = (( x %HAP) 0.195) x 2000 EF = x % HAP x 2000 EF = (( x %HAP) ) x 2000 EF = x % HAP x 2000 x 0.73 EF = (( x %HAP) 0.195) x 2000 x 0.73 EF = x % HAP x 2000 EF = x % HAP x 2000 EF = x % HAP x 2000 EF = x % HAP x 2000 Page 2 Part 70 Manufacturing General Permit 2014, Permit Appendix F

273 Footnotes to Table W1 1 The equations are intended for use in calculating emission factors to demonstrate compliance with the emission limits in Subpart WWWW. These equations may not be most appropriate method to calculate emission estimates for other purposes. However, this does not preclude a facility from using the equations to calculate emissions factors for purposes then rule compliance if these equations are the most accurate available. 2 To obtain the organic HAP emissions factor value for an operation with an add on control device multiply the EF above by the add on control factor calculated using Equation 1 of Sec The organic HAP emissions factors have units of lbs of organic HAP per ton of resin or gel coat applied. 3 Percent HAP means total weight percent of organic HAP (styrene, methyl methacrylate, and any other organic HAP) in the resin or gel coat prior to the addition of fillers, catalyst, and promoters. Input the percent HAP as a decimal, i.e. 33 percent HAP should be input as 0.33, not The VSE factor means the percent reduction in organic HAP emissions expressed as a decimal measured by the VSE test method of appendix A to 40 CFR pt. 63, subp. WWWW. 5 This equation is based on an organic HAP emissions factor equation developed for mechanical atomized controlled spray. It may only be used for automated or robotic spray systems with atomized spray. All spray operations using hand held spray guns must use the appropriate mechanical atomized or mechanical nonatomized organic HAP emissions factor equation. Automated or robotic spray systems using nonatomized spray should use the appropriate nonatomized mechanical resin application equation. 6 Applies only to filament application using an open resin bath. If resin is applied manually or with a spray gun, use the appropriate manual or mechanical application organic HAP emissions factor equation. 7 These equations are for centrifugal casting operations where the mold is vented during spinning. Centrifugal casting operations where the mold is completely sealed after resin injection are considered to be closed molding operations. 8 If a centrifugal casting operation uses mechanical or manual resin application techniques to apply resin to an open centrifugal casting mold, use the appropriate open molding equation with covered cure and no rollout to determine an emission factor for operations prior to the closing of the centrifugal casting mold. If the closed centrifugal casting mold is vented during spinning, use the appropriate centrifugal casting equation to calculate an emission factor for the portion of the process where spinning and cure occur. If a centrifugal casting operation uses mechanical or manual resin application techniques to apply resin to an open centrifugal casting mold, and the mold is then closed and is not vented, treat the entire operation as open molding with covered cure and no rollout to determine emission factors. Page 3 Part 70 Manufacturing General Permit 2014, Permit Appendix F

274 Equation W1 ( (b)(1)) Demonstrate that, on average, each combination of operation type and resin application method or gel coat type meets the applicable HAP Emission Limits. The Permittee shall demonstrate that, on average, each unique combination of operation type and resin application method or gel coat type listed above in the HAP Emission Limits section meets the applicable HAP Emission Limits using the following procedures: (1) (i) Group the process streams by operation type and resin application method or gel coat type listed in the HAP Emission Limit section above and then calculate a weighted average emission factor based on the amounts of each individual resin or gel coat used for the last 12 months, using Equation W1 below. To do this, sum the product of each individual organic HAP emissions factor calculated in paragraph (1) in the Demonstrate that an individual resin or gel coat, as applied, meets the applicable HAP Emission Limit requirement and the amount of neat resin plus and neat gel coat plus usage that corresponds to the individual factors and divide the numerator by the total amount of neat resin plus and neat gel coat plus used in that operation type: Equation W1:, Where: EF avg = average organic HAP emissions factor EF act,i = actual organic HAP emissions factor for process stream i, lbs/ton. This is the individual organic HAP emissions factor calculated in paragraph (1) in the Demonstrate that an individual resin or gel coat, as applied, meets the applicable HAP Emission Limit requirement (40 CFR section (a)(1)). Material i = neat resin plus or neat gel coat plus used during the last 12 calendar months for process stream i, tons n = number of process streams for which an organic HAP emissions factor is calculated Equation W2 ( (c)(1)) Demonstrate compliance with a weighted average emission limit. (4) Each month the Permittee shall calculate the weighted average organic HAP emissions limit for all open molding operations and the weighted average organic HAP emissions limit for all centrifugal casting operations at the facility for the last 12 month period to determine the organic HAP emissions limit that the Permittee shall meet, using Equation W2 below. To do this, the Permittee shall multiply the individual HAP Emission Limit for each open molding (centrifugal casting) operation type by the amount of neat resin plus or neat gel coat plus used in the last 12 months for each open molding (centrifugal casting) operation type, sum the results, and then divide this sum by the total amount of neat resin plus and neat gel coat plus used in open molding (centrifugal casting) over the last 12 months : Page 4 Part 70 Manufacturing General Permit 2014, Permit Appendix F

275 Equation W2: Where: EL avg = weighted average emission limit EL i = organic HAP emissions factor for operation type i, lbs/ton. This is the individual organic HAP emissions limit from the HAP Emissions Limits section in the NESHAP subp. WWWW section of this permit. Material i = neat resin plus or neat gel coat plus used during the last 12 calendar months for operation type i, tons n = number of operations Equation W3 ( (c)(2)) (5) Each month the Permittee shall calculate the weighted average organic HAP emissions factor for open molding and centrifugal casting, using Equation W3 below. To do this, the Permittee shall multiply the actual open molding (centrifugal casting) operation organic HAP emission factors calculated in paragraph (1) of the Demonstrate that, on average, each combination of operation type and resin application method or gel coat type meets the applicable HAP Emission Limits requirement and the amount of neat resin plus and neat gel coat plus used in each open molding (centrifugal casting) operation type, sum the results, and then divide this sum by the total amount of neat resin plus and neat gel coat plus used in open molding (centrifugal casting) operations: Equation W3:, Where: EF AWA = actual weighted average organic HAP emissions factor EF op,i = actual organic HAP emissions factor for operation type i, lbs/ton. This is the organic HAP emissions factor calculated in paragraph (1) in the Demonstrate that, on average, each combination of operation type and resin application method or gel coat type meets the applicable HAP Emission Limits requirement (40 CFR section (b)(1)). Material i = neat resin plus or neat gel coat plus used during the last 12 calendar months for operation type i, tons n = number of operations Page 5 Part 70 Manufacturing General Permit 2014, Permit Appendix F

276 Equation W4 ( (a)) (d) Compliant line option: use Equation W4 below to calculate an organic HAP emission factor in lbs/ton. Equation W4: Where: E = HAP emissions factor in lbs/ton of resin and gel coat WAE = uncontrolled wet out area organic HAP emissions, lbs/year O = uncontrolled oven organic HAP emissions, lbs/year R = total usage of neat resin plus, tpy G = total usage of neat gel coat plus, tpy Equation W5 ( (b)) (e) Averaging option: use Equation W5 below to demonstrate compliance. Equation W5: Where: E = HAP emissions factor in lbs/ton of resin and gel coat WAE = uncontrolled wet out area organic HAP emissions from wet out area i, lbs/year O = uncontrolled oven organic HAP emissions from oven j, lbs/year m = number of wet out areas n = number of ovens R = total usage of neat resin plus, tpy G = total usage of neat gel coat plus, tpy Page 6 Part 70 Manufacturing General Permit 2014, Permit Appendix F

277 Table W2: Emission Factors for Open Molding of Composites Table W2a: Emission Rate in Pounds of Styrene Emitted per Ton of Resin or Gelcoat Processed Application Process Manual Manual w/ Vapor Suppressed Resin VSR (3) Mechanical Atomized Mechanical Atomized with VSR (3) Mechanical Non Atomized Mechanical Non Atomized with VSR (3) Filament application Filament application with VSR (4) Gelcoat Application Styrene content in resin/gelcoat, % (1) <33 (2) >50 (2) x %styrene x x %styrene x Manual emission factor [listed above] x (1 (0.50 x specific VSR reduction factor for each resin/suppressant formulation)) ((0.286 x %styrene) ) x 2000 ((0.714 x %styrene) 0.18) x 2000 Mechanical Atomized emission factor [listed above] x (1 (0.45 x specific VSR reduction factor for each resin/suppressant formulation)) x %styrene x ((0.157 x %styrene) ) x 2000 Mechanical Non Atomized emission factor [listed above] x (1 (0.45 x specific VSR reduction factor for each resin/suppressant formulation)) x %styrene x x %styrene x x %styrene x (( x %styrene) ) x x (( x %styrene) ) x 2000 (( x %styrene) 0.195) x 2000 Page 7 Part 70 Manufacturing General Permit 2014, Permit Appendix F

278 Application Process Covered Cure after Roll Out Covered Cure without Roll Out Styrene content in resin/gelcoat, % (1) <33 (2) >50 (2) Non VSR process emission factor [listed above] x ( 0.80 for Manual <or> 0.85 for Mechanical) Non VSR process emission factor [listed above] x ( 0.50 for Manual <or> 0.55 for Mechanical) Table W2b: Emission Rate in Pounds of Methyl Methacrylate Emitted per Ton of Gelcoat Processed MMA content in gelcoat, % (5) Application >20 Process Gel coat application (6) x %MMA x 2000 Footnotes to Table W2 This table is based on the CFA Unified Emissions Factors document, dated April 7, Including styrene monomer content as supplied, plus any extra styrene monomer added by the molder, but before addition of other additives such as powders, fillers, glass,...etc. 2. Formulas for materials with styrene content < 33% are based on the emission rate at 33% (constant emission factor expressed as percent of available styrene), and for styrene content > 50% on the emission rate based on the extrapolated factor equations; these are not based on test data but are believed to be conservative estimates. The value for "% styrene" in the formulas should be input as a fraction. For example, use the input value 0.30 for a resin with 30% styrene content by weight. 3. The VSR reduction factor is determined by testing each resin/suppressant formulation according to the procedures detailed in the CFA Vapor Suppressant Effectiveness Test. 4. The effect of vapor suppressants on emissions from filament winding operations is based on the Dow Filament Winding Emissions Study. 5. Including MMA monomer content as supplied, plus any extra MMA monomer added by the molder, but before addition of other additives such as powders, fillers, glass,...etc. 6. Based on gelcoat data from NMMA Emission Study. These factors shall be used or EPA approved factor supersedes emission factors used herein. Page 8 Part 70 Manufacturing General Permit 2014, Permit Appendix F

279 TECHNICAL SUPPORT DOCUMENT FOR AIR EMISSION GENERAL PERMIT: PART 70 MANUFACTURING GENERAL PERMIT October 2014

280 TABLE OF CONTENTS Section Page 1.0 INTRODUCTION PERMITTING APPROACH General Permits versus Individual Permits MPCA Overall Permit Approach for Cleaning, Painting/Coating, Cutting, Grinding, Blasting, and Fossil Fuel Combustion Stationary Sources; With or Without Pollution Control Equipment QUALIFICATION REQUIREMENTS Qualifications Pertaining to Stationary Source Type, Processes, Materials, Emissions Units and Emission Control Stationary Source Description Process Operations and Emission Units Materials Processed Emission Control Qualifications Pertaining to Minn. R and Restriction on Potential To Emit Compliance With Applicable Requirements Operating Flexibility Specific Requirements to be Met Based on "Applicable Requirements" National Emission Standards for Hazardous Air Pollutants New Source Review Ambient Air Quality Standards State and Federal Standards of Performance Acid Rain Program Stratospheric Ozone Protection Compliance Assurance Monitoring (CAM) Periodic Monitoring Solid Waste Combustion Federal Ozone Measures for the Control of Emissions From Certain Sources Tank Vessel Standards Environmental Review Other Applicable Minnesota Requirements CONTENT OF GENERAL PERMIT Permit Organization CONTENTS OF APPLICATION POTENTIAL TO EMIT Overview Fuel Combustion Limiting Particulates Emissions Limiting VOC Emissions Limiting GHG Emissions Limiting HAP Emissions Fugitive Emissions COMMENTS RECEIVED CONCLUSION

281 1.0 INTRODUCTION Technical Support Document Section 1 Page 1 It is a goal of the Minnesota Pollution Control Agency (MPCA) to efficiently implement its air emission permitting program and to continuously improve the permitting process. One objective to meeting this goal is the development of general permits for specific industrial categories. This document presents the MPCA s overall approach for the efficient permitting of cleaning, painting/coating, cutting, grinding, blasting, fossil fuel combustion, and general fiberglass stationary sources; with or without pollution control equipment. This document presents the technical support information for the development and reissuance of a general permit for these sources. This general permit is a Part 70 permit for cleaning, painting/coating, cutting, grinding, blasting, fossil fuel combustion, and general fiberglass stationary sources; with or without pollution control equipment; with potential to emit (PTE) limited to less than 100,000 tons per year carbon dioxide equivalent (CO 2 e) of greenhouse gases (GHGs), less than 250 tons per year of total volatile organic compounds (VOC), less than 100 tons per year for all other criteria pollutants, and less than 100 tons per year of hazardous air pollutants (HAP). The various gases that make up GHGs include carbon dioxide (CO 2 ), methane (CH 4 ), nitrous oxide (N 2 O), hydroflourocarbons (HFCs), perflourocarbons (PFCs), and sulfur hexafluoride (SF 6 ). The criteria pollutants are particulate matter less than 10 microns in aerodynamic diameter (PM 10 ), particulate matter less than 2.5 microns in aerodynamic diameter (PM 2.5 ), carbon monoxide (CO), nitrogen oxides (NO x ), sulfur dioxide (SO 2 ), lead (Pb), and ozone (VOC volatile organic compounds). The stationary sources may not be any of the source categories listed in 40 CFR 52.21(b)(1)(iii), the prevention of significant deterioration (PSD) of air quality rule. In order to support the general permit and application, the technical support information needs to meet the following general objectives: The information must describe how the sources eligible for this general permit are similar. The information should also describe the similar regulatory requirements for these sources (Minn. R , subp. 1). The information must identify which permit application requirements of Minn. R do not apply to stationary sources qualifying for the general permit in order to support development of a simplified application (Minn R , subp. 5), and For Part 70 permits, the information must set forth the legal and factual basis of the permit conditions, including reference to the applicable statutory or regulatory provisions (Minn. R , subp. 1). The remainder of this technical support document includes: a summary of the permitting approach in Section 2; a discussion of the qualifications and requirements for this general permit in Section 3; a summary of the general permit contents in Section 4; a summary of the general permit application contents in Section 5; and a discussion of the procedures for limiting PTE in Section 6. The legal and factual basis for the permit conditions is described in this document and in the permit. The permit contains the general conditions listed in Minn. R , subp. 16.

282 2.0 PERMITTING APPROACH Technical Support Document Section 2 Page 1 This section discusses the general concepts for individual versus general permits. It presents the overall permitting approaches being considered by the MPCA for cleaning, painting/coating, cutting, grinding, blasting, fossil fuel combustion, and general fiberglass stationary sources; with or without pollution control equipment. 2.1 General Permits versus Individual Permits Minn. R. ch requires air emission sources to obtain permits from the MPCA. These Rules also provide the overall specifications for the MPCA's air emission permits program. These specifications require the submittal of complete permit applications to the MPCA by the owner or operator of the emission source. The MPCA reviews the applications and, when the applications are determined complete, prepares a draft permit for public notice. Public notice requirements provide for a 30 day public comment period and in some cases review by neighboring states or provinces. Concurrent with and following the 30 day public comment period, the permit is not issued until after the U.S. Environmental Protection Agency (EPA) is provided a 45 day review period to review the operating portions of the permit. After the 45 day EPA review the permit may be issued. Typically, permitting involves preparing a draft permit for each individual source based on source specific considerations. The complete permitting process described above is then carried through for each individual permit. This approach is generally time consuming for all parties involved. As an alternative, Minn. R provides for the issuance of a "general permit" which covers numerous sources that are similar to each other and are subject to the same or substantially similar regulatory requirements. This approach provides for greater efficiency than the individual permit approach. The process of issuing a general permit includes: development of a simplified application based on requirements which would potentially be applicable to the types of sources for which the permit would be issued; development of a single permit for the source group which provides for compliance with applicable requirements by standard approaches identified in the permit; a one time public notice and EPA review prior to issuance of the final general permit; issuance of the general permit to any qualifying individual source without repeating the public notice for each source; and availability of a list from the MPCA upon request which identifies the stationary sources for which a general permit application has been received. The primary benefit of a general permit is the efficiency provided to the MPCA and to qualifying stationary sources through a simplified permitting process. At the same time, the opportunity for public participation is preserved in the public notice of the general permit. The MPCA will also make available to the public a list of sources from whom applications have been received. General permits also provide for equitable treatment of sources through the receipt of uniform permit applications and uniform permits. However, when requesting the general permit, the stationary source is accepting the terms and conditions of the general permit and must comply with them. When submitting the general permit application, the stationary source may not request special conditions for operation of its stationary source. If special conditions are necessary for an individual source, that source must apply for an individual permit.

283 Technical Support Document Section 2 Page MPCA Overall Permitting Approach For Cleaning, Painting/Coating, Cutting, Grinding, Blasting, Fossil Fuel Combustion, and General Fiberglass Stationary Sources; With or Without Pollution Control Equipment The overall permitting approach for cleaning, painting/coating, cutting, grinding, blasting, fossil fuel combustion, and general fiberglass stationary sources; with or without pollution control equipment includes the issuance of individual and general permits. This general permit is for new and existing cleaning, painting/coating, cutting, grinding, blasting, fossil fuel combustion, and general fiberglass stationary sources; with or without pollution control equipment; with PTE limited to less than 100,000 tpy CO 2 e of GHGs, less than 250 tpy of VOC, and less than 100 tpy for each other criteria pollutant, and less than 100 tpy of total HAP, after accounting for the effects of all pollution control equipment from all processes with pollution control equipment for all appropriate criteria pollutants. This general permit category is allowed by the MPCA based on Minn. R , subp. 1, which requires that the same or substantially similar requirements apply to the category of sources. This permit may be issued to stationary sources throughout the State of Minnesota. This general permit will be issued for stationary sources that can meet the emission limits established in this general permit when accounting for the effects of all pollution control equipment from all processes with pollution control equipment for all appropriate criteria pollutants. The permit allows operating flexibility by authorizing the installation, replacement and removal of equipment without significant regulatory burden to the permit holder, so long as the permit holder remains in compliance with the general permit. PSD requirements apply to stationary sources with the PTE of 250 tpy or more of any criteria pollutant, or 100,000 tpy CO 2 e or more of GHGs if the 250 tpy criteria pollutant threshold were also exceeded. Because this general permit will be issued only to stationary sources willing to limit PTE to less than 250 tpy of each criteria pollutant and less than 100,000 tpy of GHGs, PSD requirements will not apply to stationary sources eligible for this general permit. For stationary sources with the PTE 100 tpy or more of any criteria pollutant, 40 CFR pt. 70 requirements apply. Because this general permit allows stationary sources to emit more than 100 tpy of VOC, these stationary sources are required to obtain a Part 70 permit. This general permit will contain all necessary requirements of a Part 70 permit.

284 3.0 QUALIFICATION REQUIREMENTS Technical Support Document Section 3 Page 1 To meet requirements of Minn. R , subps. 1 and 5, the following four general criteria must be met for this general permit: The permit must be for a group of emission sources or stationary sources of like kind or substantially similar in nature; The same or substantially similar requirements of Minn. R CONTENT OF PERMIT APPLICATION and Minn. R PERMIT CONTENT need to apply to the emission sources or stationary sources covered by the permit; The same or substantially similar applicable requirements of Minn. R , subp. 7, apply to the emission sources or stationary sources; and The approaches for meeting the requirements of the second criteria and methods for meeting the applicable requirements identified by the third criteria need to be applied consistently. Development of the general permit and simplified application also requires that a number of assumptions be made to identify applicable requirements and establish how compliance with the applicable requirements will be achieved. These assumptions become qualification requirements for the general permit and need to be compatible with the design and operation practices at a number of cleaning, painting/coating, cutting, grinding, blasting, welding, brazing, soldering, fossil fuel combustion, and general fiberglass stationary sources with or without pollution control equipment for the permit to be useful. A number of qualifications were required to be established for the development of this general permit. These qualifications are presented as numerical steps in the Qualifications Review List supplied with the application package for this general permit (Form MG 00). The basis for the qualifications is presented in the remainder of this section. 3.1 Qualifications Pertaining to Stationary Source Type, Processes, Materials, Emissions Units and Emission Control Stationary Source Description This general permit applies to cleaning, painting/coating, cutting, grinding, blasting, fossil fuel combustion, and general fiberglass stationary sources; with or without pollution control equipment. The stationary source cannot be one of the 28 source categories listed in 40 CFR 52.21(b)(1)(iii), prevention of significant deterioration of air quality Process Operations and Emission Units Process operations and emission units typically present at stationary sources covered by this general permit include: Abrasive blasting, adhesive, bag houses, boilers, brazing, burn off ovens, casting, catalytic or thermal afterburners, cleaning (including acid cleaning, degreasers, general cleanup with solvents), dip tanks, fabric filters, fuel storage, furnaces, injection molding, internal combustion engines (generators), lamination, mixing, molding, ovens, resin and gel coating, sanding, screen printing, soldering, space heaters, spraying and coating activities, stenciling, storage tanks, wall/panel filters, water wash paint booths, and welding. If a stationary source has process operations or emission units that are not listed above and that are not insignificant activities (listed in Minn. R or conditionally insignificant activities listed in Minn. R. 7008), the stationary source does not qualify for the general permit. The insignificant activities listed in Minn. R , subps. 3 and 4, and in Minn.

285 Technical Support Document Section 3 Page 2 R and , are required to be listed in a permit application and calculation of emissions from these activities shall be provided upon request in the application for this general permit. Any stationary source with an emission unit(s) subject to any New Source Performance Standards other than for volatile organic liquid storage vessels (subpart Kb) and stationary compression ignition internal combustion sources (subpart IIII) in 40 CFR pt. 60, does not qualify this general permit. Any stationary source with an emission unit(s) subject to a National Emission Standards for Hazardous Air Pollutants (NESHAP) other than the NESHAPs for halogenated solvent cleaning machines (subpart T); miscellaneous metal parts and products for surface coating operations (subpart MMMM); surface coating of plastic parts and products (subpart PPPP); reinforced plastic composites production (subpart WWWW); stationary reciprocating internal combustion engines (subpart ZZZZ); and industrial/commercial/institutional boilers and process heaters (subpart DDDDD) in 40 CFR pt. 63, does not qualify for this general permit. A stationary source that is subject to a case by case maximum achievable control technology standards (MACT) determination under section 112(g) of the Clean Air Act does not qualify for this general permit Materials Processed Stationary sources that use painting or coating materials that contain lead do not qualify for this general permit Emission Control This permit requires particulate emission control for all booths for abrasive blasting, sanding, and non fiberglass spraying/coating operations by installing some type of particulate control device with a minimum overall control efficiency of 85 percent. The control device must be listed under Minn. R and the general permit requires the Permittee to comply with the operating condition requirements of Minn. R This general permit requires fugitive particulate emission control by the application of water on exposed surfaces. The stationary source is allowed to consider the effects of all VOC pollution control equipment when calculating emissions. The general permit emphasizes the necessity of capture efficiency and destruction efficiency determination for surface coating operations. The Permittee must comply with the control equipment rule operating condition requirements of Minn. R Qualifications Pertaining to Minn. R and Restriction on Potential to Emit As described in Section 2.2, this general permit is for stationary sources with PTE limited to less than 250 tpy of VOC and less than 100 tpy of both PM 10 and PM 2.5 after control, and less than 100 tpy for other criteria pollutants. Furthermore, the permit is for stationary sources with PTE limited to less than 100,000 tpy CO 2 e of GHGs, and less than 100 tpy of organic HAP. The basis for these PTE restrictions is so that stationary sources are able to make design and operational changes without being subject to PSD requirements. However, Part 70 permit and permit application requirements need to be fulfilled in this general permit. Fugitive emissions by definition cannot be collected and are released to the atmosphere at the point of generation. Fugitive emissions at sources eligible for this general permit may be generated by unpaved

286 Technical Support Document Section 3 Page 3 roads, blasting outdoors and other related miscellaneous activities outdoors. VOC emissions from cleaning solvents and adhesives are not considered fugitive emissions. The approach developed to restrict the PTE for the operations at stationary sources covered by this general permit are presented in Section 6.0. This approach involves the following concepts: the PTE limits are based on emissions not including fugitive emissions; restricting the type of fuel consumed limits the PTE of criteria pollutants, especially SO 2 ; and potential emissions of PM 10 and PM 2.5 are restricted to less than 100 tpy by requiring the company to use particulate controls on particulate emission generating booths for abrasive blasting, sanding, and spraying/coating operations. The caps on the PTE for NO x and CO emissions are based on 12 month rolling sum emissions limits. Compliance also limits the Permittee to certain fuel types (natural gas, distillate oil, biodiesel, liquefied petroleum gas and gasoline) to limit the NO x and CO PTE from all fuel combustion sources. Monitoring and recordkeeping provisions to track compliance with these permit conditions are also included. Combustion of the allowable fuel types emits SO 2 at a significantly lower rate than NO x or CO, so Permittees complying with the NO x and CO limits will by default also keep SO 2 emissions well below the PSD major source threshold. For this reason, the permit does not need to include a Title I limit on SO 2 to avoid PSD applicability. The cap on the PTE for PM/PM 2.5 /PM 10 from these sources is based on a 12 month rolling sum emissions limit. Compliance also requires the Permittee to use particulate control devices with an overall control efficiency of 85% or greater to control particulate matter emissions from the activities that emit the most particulate matter. Monitoring and recordkeeping provisions to track compliance with these permit conditions are also included. Given that the accepted capture efficiency of certified hoods is 80%, and no credit is given for capture efficiency from noncertified hoods, to meet this overall control efficiency limit, the Permittee must use a total enclosure on booths for abrasive blasting, sanding, and non fiberglass spraying/coating operations. Using a certified hood instead of a total enclosure will not result in a high enough overall control efficiency. The cap on the PTE for VOC from these sources is based on a 12 month rolling sum emissions limit. Monitoring and recordkeeping provisions to track compliance with these permit conditions are also included. There is no cap on PTE for Lead because permit restrictions on lead containing materials mean that lead emissions for facilities with this permit will be negligible. Compliance requires the Permittee to eliminate painting and coating materials that contain lead, and to use fuel types with negligible lead contents. The cap on PTE for HAP from these sources is based on a 12 month rolling sum emissions limit. Monitoring and recordkeeping provisions to track compliance with these permit conditions are also included. The cap on PTE for GHG from these sources is based on a 12 month rolling sum emissions limit. Monitoring and recordkeeping provisions to track compliance with these permit conditions are also included.

287 3.2.2 Compliance With Applicable Requirements Technical Support Document Section 3 Page 4 Minn. R , subp. 2, requires that permit applications include a compliance plan, including a schedule of compliance when applicable requirements are not met. This general permit specifies the compliance plan. To qualify for this general permit, stationary sources must be in compliance with all applicable requirements. The exception is that if the only reason the stationary source is not in compliance is because it does not have a permit and the issuance of a general permit will bring it into compliance. In addition, stationary sources subject to NSPS that have not conducted the performance testing and reporting requirements required by 40 CFR pt. 60, subps. Kb and IIII may be able to receive a general permit if they can commit to the compliance schedule in the general permit for completing the testing. In addition, stationary sources subject to NESHAP that have not submitted their initial notification requirement required by 40 CFR pt. 63, subps. T, MMMM, PPPP, WWWW, ZZZZ, and DDDDD may be able to receive a general permit if the owner or operator can commit to the compliance schedule in the permit for submitting the notification. The applicable requirements to be considered are identified in the permit Operating Flexibility This general permit includes a number of conditions that allow sources to have operating flexibility. These conditions must be met by the stationary source to qualify for this general permit. The conditions include: allowing only certain types of processing equipment and fuel combustion equipment at the stationary source; requiring all equipment to be labeled with a serial number or other identification number; requiring records to be maintained on site to identify the actual operating configuration of the stationary source; requiring records of calculations for the operating configuration of the stationary source showing that the actual emissions do not exceed 225 tpy for VOCs, 90,000 tpy for GHGs, 90 tpy for all other criteria pollutants, and 90 tpy for HAP; requiring all NSPS requirements to be met for new equipment, if applicable. requiring NSPS testing notification for new equipment that have not had NSPS testing or certification for new equipment that have had NSPS testing and passed, requiring all NESHAPS requirements to be met for new and existing equipment, requiring the operation of particulate control equipment for particulate emission generating booths for abrasive blasting, sanding, and spraying/coating operations. Once a company has a general permit, the Permittee may make modifications at the site as long as all permit conditions and limitations are met. If the stationary source will no longer be able to meet the general permit conditions and limitations after a proposed modification, the Permittee must apply for and receive an individual permit prior to the modification taking place. 3.3 Specific Requirements to be Met Based on Applicable Requirements National Emission Standards for HAPs

288 Technical Support Document Section 3 Page 5 National Emission Standards for Hazardous Air Pollutants (NESHAPs) for sources categories for major sources apply to stationary sources having the PTE of more than 10 tpy of any single HAP or 25 tpy of combined HAPs as provided in 40 CFR pt. 63. If stationary sources trigger these thresholds, they may be subject to these requirements. The EPA has identified a list of emission stationary sources known to emit HAPs that will be subject to maximum achievable control technology standards (MACT) in 40 CFR pt. 63. The identified source categories that affect this general permit are halogenated solvent cleaning machines (subp. T); surface coating for miscellaneous metal parts and products (subp. MMMM); surface coating of plastic parts and products (subp. PPPP); reinforced plastic composites facilities and reinforced plastic composites production (subp. WWWW); reciprocating internal combustion engines (subp. ZZZZ); and industrial, commercial and institutional boilers and process heaters (subp. DDDDD). The requirements for these NESHAPs are incorporated in this general permit. On December 27, 1996, the Clean Air Act Section 112(g) rule was finalized. If a major HAP source undergoes a modification AND a modification of a process production unit (as defined in the 112(g) rule, 40 CFR through 63.44) which by itself has a potential to emit of 10 or 25 tons per year and is not subject to a promulgated standard under 40 CFR pt. 63, the stationary source must apply for a permit including a case by case MACT determination. In this case this general permit cannot be used; instead, the stationary source would have to apply for an individual Part 70 permit. Other NESHAPS requirements are provided in 40 CFR pt. 61 and in Minn. R through Stationary sources with processes and equipment subject to these requirements will not be eligible for this general permit. Therefore, these standards are not contained in this general permit. The prevention of accidental releases program requirements are provided in 40 CFR pt. 68 and Section 112(r) of the Clean Air Act. The EPA promulgated the list of regulated substances and threshold quantities in the Federal Register on January 31, 1994, and the proposed risk management plan regulation on October 20, Cleaning, painting/coating, cutting, grinding, blasting, fossil fuel combustion, and general fiberglass stationary sources; with or without pollution control equipment may produce, process, handle, store, or use the listed substances in the quantities listed; therefore, these requirements may apply and if these rules do apply, the stationary source must register and submit a risk management plan according to the rules after promulgation of the final rule New Source Review (NSR) NSR requirements are in two programs: the nonattainment area review program (NAAR) and the PSD program. In this general permit, stationary sources in nonattainment areas will be restricted to under 100 tpy for all criteria pollutants except ozone. The 100 tpy restriction for ozone (VOC) does not apply because there are no ozone nonattainment areas in Minnesota. Therefore, the NAAR requirements do not apply because there are currently no nonattainment areas in Minnesota. NSR requirements of the PSD program apply to any stationary sources which have the PTE more than 250 tpy of any regulated pollutant as provided in 40 CFR pts. 51 and 52. The stationary sources eligible for this general permit cannot be one of the 28 sources listed that triggers the 100 tpy threshold for PSD. Restrictions will be placed in the general permit as federally enforceable limitations on VOC to keep the stationary sources eligible for this general permit below 250 tpy and the PTE for all other criteria pollutants will also be limited to less than 100 tpy; furthermore, this permit contains federally enforceable restrictions to limit GHG emissions to less than 100,000 tpy of CO 2 e.* Therefore, this permit does not contain PSD major source requirements because the stationary sources eligible for this general permit cannot be a major stationary source subject to PSD requirements.

289 Technical Support Document Section 3 Page 6 *Note: the June 23, 2014 Supreme Court ruling said that GHG emissions alone are not enough to trigger PSD applicability. See further discussion below, in section 7.0 Comments Received. Stationary sources constructed after August 7, 1980, that have the PTE more than 250 tpy may be subject to PSD review. If potential emissions and actual emissions of any pollutant have exceeded 250 tpy for a stationary source constructed after August 7, 1980, then the stationary source is not eligible for this general permit. The stationary source may also need to perform a PSD review as part of its individual Part 70 application to address the modification previously made. If actual emissions of VOC have not exceeded 250 tpy from the stationary source constructed after August 7, 1980, and the stationary source is willing to accept the federally enforceable limits in this general permit to remain below a PTE of 250 tpy, then the stationary source is eligible for this general permit, unless the source is required to achieve BACT equivalent emission reductions (BACT is Best Available Control Technology) Ambient Air Quality Standards National Ambient Air Quality Standards (NAAQS) and increment and visibility requirements are provided in the Clean Air Act, Section 109 and (B). Minnesota Ambient Air Quality Standards are provided in Minn. R Minnesota standards do not allow anyone to emit any pollutants in such a manner that ambient levels of the pollutant are higher than the maximum allowed level State and Federal Standards of Performance State standards of performance and federal New Source Performance Standards (NSPS) requirements apply to certain new and existing sources as provided in 40 CFR pt. 60 and Minn. R Standards that apply to cleaning, painting/coating, cutting, grinding, blasting, fossil fuel combustion, and general fiberglass stationary sources; with or without pollution control equipment are listed in Table 3.1:

290 Technical Support Document Section 3 Page 7 Table 3.1 Standards of Performance 40 CFR pt. 60 Minn. R. Emission Standards for Visible Air Contaminants Control of Fugitive Particulate Matter Indirect Heating Fossil Fuel Burning Equipment Direct Heating Fossil Fuel Burning Equipment Industrial Process Equipment Liquid Petroleum and Volatile Organic Liquid (VOL) Storage Vessels Stationary Internal Combustion Engines Compression Ignition Internal Combustion Engines Air Pollution Control Equipment subp. Kb subp. IIII The permit incorporates the provisions of these standards. The standards are summarized below: Emission Standards for Visible Air Contaminants The requirements set forth in Minn. R include an opacity limit that allows no greater than 20 percent, except that a maximum opacity of 33 percent may occur for one six minute period in any 60 minute period for existing stationary sources constructed before 1969, and for stationary sources constructed after 1969, an opacity limit that allows opacity at no greater than 20 percent. If performance tests are required, Method 9 for visual determination of opacity must be used. Control of Fugitive Particulate Matter The requirements set forth in Minn. R include minimizing airborne particulate emissions such that avoidable amounts of PM are not emitted from handling, use, transport, or storage of any material and that all reasonable control is applied. Indirect Heating Fossil Fuel Burning Equipment The requirements set forth in Minn. R include PM and sulfur dioxide emission limits based on location, rated heat input of all direct and indirect heating equipment at the stationary source, and the type of fuel used for new and existing equipment. These requirements for indirect heating fossil fuel burning equipment also include an opacity limit that allows opacity no greater than 20 percent, except for one six minute period per hour of not more than 60 percent opacity or whenever any one hour period contains two or more six minute periods during

291 Technical Support Document Section 3 Page 8 which the average opacity exceeds 20 percent or whenever any one hour period contains one or more six minute periods during which the average opacity for existing Stationary Sources. For Stationary Sources with new equipment of greater than 250 million Btu/hr rated heat input, an opacity limit that allows opacity no greater than 20 percent, except for one six minute period per hour of not more than 27 percent opacity or whenever any one hour period contains two or more six minute periods during which the average opacity exceeds 20 percent or whenever any one hour period contains one or more six minute periods during which the average opacity exceeds 27 percent. For Stationary sources with existing equipment of 250 million Btu/hr or less rated heat input, an opacity limit that allows opacity no greater than 20 percent, except whenever any one hour period contains two or more six minute periods during which the average opacity exceeds 20 percent or whenever any one hour period contains one or more six minute periods during which the average opacity exceeds 60 percent. Direct Heating Fossil Fuel Burning Equipment The requirements set forth in Minn. R include particulate emissions limitations such that the gases discharged to the atmosphere may not contain PM in excess of the limits allowed by the Industrial Process Equipment Standard of Performance (Minn. R ) and allows opacity no greater than 20 percent, except that a maximum opacity of 60 percent may occur for six minutes in any 60 minute period. These state requirements for direct heating fossil fuel burning equipment also include a sulfur dioxide emission limit for stationary sources within the Minneapolis St. Paul Air Quality Control Region, such that the gases discharged to the atmosphere do not contain sulfur dioxide in excess of 1.6 pounds per million Btu heat input if a liquid fuel is burned if the total rated heat input of all indirect and direct heating equipment of the owner or operator at that particular location exceeds 250 million Btu/hr. The emission limit is two pounds per million Btu heat input if a liquid fuel is burned if the total rated heat input of all indirect and direct heating equipment of the owner or operator at that particular location is equal to or less than 250 million Btu/hr. Industrial Processing Equipment The requirements set forth in Minn. R include standards for industrial equipment for which a specific Minnesota standard of performance does not apply. These standards are separated for industrial equipment put in operation before July 9, 1969, (pre 1969 requirements), and industrial equipment put in operation on or after July 9, 1969, (post 1969 requirements). The standard for PM, which is the same for equipment manufactured before and after 1969, is a pound per hour (lb/hr) limit based on the process weight rate. After reviewing the potential emission calculations (Section 6 of this document), operations at stationary sources covered by this general permit are expected not to exceed these standards. The post 1969 standard includes an opacity limit of 20 percent. The pre 1969 standard includes an opacity limit of 20 percent, but allows a maximum opacity of 60 percent for six minutes in a 60 minute period. If performance tests are required, Method 9 for visual determination of opacity should be used. Liquid Petroleum and VOL Organic Liquid Storage Vessels The requirements set forth in Minn. R and 40 CFR pt. 60, subp. Kb, apply to VOL organic liquid storage vessels constructed after July 23, 1984, with a capacity less than to 151 cubic meters storing a liquid with a maximum true vapor pressure less than 15.0 kilopascal. The requirements include tank design specifications, inspections, measurements, reporting and record keeping, and monitoring of operations.

292 Technical Support Document Section 3 Page 9 Stationary Internal Combustion Engines The requirements in Minn. R include an opacity limit such that engines are allowed a maximum opacity of 20 percent once operating temperatures are reached. The standard also includes a limit of 0.50 pounds SO 2 emissions per million Btu actual heat input. The actual heat input and rated heat input of the internal combustion engine should be determined using Minn. R The requirements set forth in 40 CFR pt. 60, subp. IIII, (incorporated by reference in Minn. R ), apply to stationary compression ignition internal combustion engines (CI ICE) meeting the applicability criteria listed in 40 CFR section The requirements from this standard that are included in this general permit apply to stationary CI ICE that commenced construction after July 11, 2005, where the stationary CI ICE were manufactured after January 1, For the purposes of 40 CFR pt. 60, subp. IIII, the date that construction commences is the date the engine is ordered by the Permittee. The requirements include emission and operation limitations, fuel specifications, engine installation/configuration requirements, reporting and recordkeeping, and monitoring of operations. Air Pollution Control Equipment The requirements set forth in Minn. R include the listed control equipment and the control equipment efficiencies, the control equipment general requirements, monitoring and record keeping for the listed control equipment. Compliance with these requirements is necessary to qualify for this general permit, so these rules apply to stationary sources that are issued this general permit under Minn. R , subp. 1(A) Acid Rain Program Acid rain program requirements are provided in the 1990 CAAA, Sections These requirements are for power utilities with a generating capacity of more than 25 megawatts and are not applicable to stationary sources covered by this general permit. Therefore, these requirements are not included in the permit application or permit Stratospheric Ozone Protection The Stratospheric Ozone Protection requirement in the permit pertains to a federal program that the state does not enforce. Stratospheric ozone protection requirements are for phasing out ozonedepleting chemicals as provided in the 1990 CAAA, Sections These requirements are for manufacturing, selling, distributing, or using ozone depleting halogenated chemicals. These requirements may apply to stationary sources eligible for this general permit and stationary sources who are subject to these requirements must comply with these rules Compliance Assurance Monitoring (CAM) The CAM rule (40 CFR pt. 64) applies at facilities that operate emission control devices subject to federally enforceable regulations promulgated prior to It requires enhanced monitoring for units with pre control PTE of >100tpy that are subject to an emission limit and depending on control equipment to meet the limit. There are exceptions for limits imposed by post 1990 federal regulations. This enhanced monitoring may apply to stationary sources eligible for this general permit as required under 40 CFR pt. 64.

293 Technical Support Document Section 3 Page 10 CAM plans were established for this general permit. The general permit includes the provisions that require the Permittee to comply with CAM requirements. If the Permittee objects to any of the CAM plans in the permit application, the Permittee must obtain an individual Part 70 permit Periodic Monitoring 40 CFR section 70.6(a)(3) of the Title V regulations specifies the standard monitoring and related recordkeeping and reporting requirements that each Title V permit must contain. One important element of the monitoring, recordkeeping, and reporting requirement of Title V is that each permit must contain periodic monitoring sufficient to yield reliable data from relevant time period that is representative of the facility s compliance with the permit. This provision is commonly referred to as a gap filling provision. Under Minn. R , subp. 4, the MPCA will require the Permittee of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. To achieve this objective, the MPCA staff considered all the relevant factors approved by EPA on periodic monitoring requirements for permitted sources. In evaluating the monitoring included in the permit, the MPCA considered the following: 1. The likelihood of violating the applicable requirements; 2. Whether add on controls are necessary to meet the emission limit; 3. The variability of emissions over time; 4. The type of monitoring, process, maintenance, or control equipment data already available; 5. The technical and economic considerations associated with the range of possible monitoring methods; and 6. The type of monitoring found on similar emission units. The MPCA staff considered all the relevant factors and incorporated all requirements into the general permit Solid Waste Combustion Solid waste combustion requirements are provided in the 1990 CAAA, Section 129. These requirements are for municipal solid waste incinerators and incinerators of hospital, medical and infectious waste and are not applicable to cleaning, painting/coating, cutting, grinding, blasting, fossil fuel combustion, and general fiberglass stationary sources; with or without pollution control equipment. Therefore, these requirements are not included in the permit application or permit Federal Ozone Measures for the Control of Emissions From Certain Sources Federal ozone measures for the control of emissions from certain sources requirements are provided in the 1990 CAAA, Section 183(e). As of December 2000, rules have not been promulgated under this section of the CAA. These requirements are for manufacturing, processing, distributing, or importing consumer or commercial products that emit VOCs and are not applicable to cleaning, painting/coating, cutting, grinding, blasting, fossil fuel combustion, and general fiberglass stationary sources; with or without pollution control equipment. Therefore, these requirements are not included in the permit application or permit.

294 Technical Support Document Section 3 Page Environmental Review On October 30, 2006, the Minnesota Environmental Review Rules (Minn. R. ch. 4410) were revised to include the new provisions for air pollution of a stationary source facility that constructs or increases by 250 tons or more per year of any single air pollutant after pollution control. An environmental review is required for a new source or a modification to an existing source with potential emissions increase by greater than or equal to 250 tpy of any single criteria pollutant. Since the recent changes to the Environmental Assessment Worksheet threshold from 100 tpy to 250 tpy for individual criteria pollutants won t eliminate the need for an Air Emission Risk Analysis (AERA), the Permittee should still plan to complete an AERA if their stationary source is the subject of significant public interest, or the identification of a new stationary source or existing stationary source expansion indicate a need for further analysis prior to issuance. If a company does an AERA and it results in a need for source specific permit conditions, then the stationary source is not eligible for this general permit Other Applicable Minnesota Requirements In addition to the Minnesota requirements described above, the Minnesota rules listed in Table 3.2 apply to stationary sources qualifying for this permit.

295 Technical Support Document Section 3 Page 12 Table 3.2 TITLE OF THE RULE MINNESOTA RULES (Chapter or Part) WHAT THE CONTENT OF THE RULE IS: Air Quality Emission Fees 7002 Requires stationary sources to pay emission fees every year within 60 days of MPCA billing. Air Pollution Episodes Requires stationary sources to comply with episode control directives issued by the commissioner. Performance Tests Outlines requirements for emissions performance testing. Emission Inventory et seq. Requires stationary sources to submit an emission inventory report by April 1st every year. Circumvention No one may conceal or dilute emissions that would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Notifications Requires stationary sources to notify MPCA of shutdowns and breakdowns. Monitoring Equipment , subp. 4(D) Requires the Permittee to install or make needed repairs to monitoring equipment. Monitoring Equipment Calibration Operation and Maintenance Plan Reporting of Deviations Endangering Human Health and the Environment , subp. 16(J) Requires the Permittee to calibrate annually all monitoring equipment other than continuous emission monitors , subp. 16(J) Requires the Permittee to retain at the stationary source an operation and maintenance plan for all air pollution control equipment , subp. 6(A) Requires the Permittee to report any deviation from the permit conditions that could endanger human health or the environment.

296 TITLE OF THE RULE MINNESOTA RULES (Chapter or Part) Technical Support Document Section 3 Page 13 WHAT THE CONTENT OF THE RULE IS: Inspections , subp. 9 Allow the MPCA, or an authorized representative or agent of the MPCA, to enter the Permittee s premises, to have access to and copy any records required by this permit, to inspect at reasonable times (which include any time the source is operating) any stationary sources, equipment, practices or operations, and to sample or monitor any substances or parameters at any location. Minnesota and National Ambient Air Quality Standard No one is allowed to emit any of the listed pollutants in such a manner that ambient levels of the pollutant are higher than the maximum level. Noise Pollution Control Sets noise standards in decibels that cannot be exceeded.

297 Technical Support Document Section 4 Page CONTENT OF GENERAL PERMIT A permit template has been developed for this general permit and was based on the MPCA individual permit template. The difference between the MPCA individual permit template and the general permit template is that parts that are not applicable were removed as explained in Section Permit Organization In general, this permit meets the MPCA Delta Guidance for ordering of requirements. One area where this permit deviates slightly from Delta guidance is in grouping of requirements: due to the general nature of this permit, the MPCA does not have the list of equipment identification numbers prior to permit issuance, and so cannot associate specific items with the groups. Also, the requirements of a group may apply to members of the group individually. Again, this was done because without prior access to the list of specific units at a given facility, it would not be possible to write the permit with requirements separated out for the individual units. Instead, the requirements were written for groups of a given type of emission unit. Another area that deviates from the guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be electronically tracked (e.g., limits, submittals, etc.), should be in Table A or B of the permit. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these. However, due to the constraints of the Delta database and the structure and complexity of this general permit, the entire permit is a word processing section and is not part of the electronic tracking system. The use of appendices for this permit does not further reduce the MPCA s electronic tracking ability for requirements in this permit.

298 Technical Support Document Section 6 Page CONTENTS OF APPLICATION 5. Application Content A tailored permit application has been developed, as provided by Minn. R , subp. 5, for the purpose of this general permit. The following Table is a summary of how the standard application forms adapted for the general permit application. Table 5.1 FORM COMMENTS SCP 01 Submittal Cover Page Retained. Applicants use the same form as used for a standard application. Total Facility Application Instructions Retained with significant modifications to fit this general permit. Form name was changed to Handbook and Application Instructions, Form number was changed to GPHGBK3. CR 02 Hood Certification Retained. Form number was changed to MGCR 02. HE 01 Hood Evaluation Retained. Form number was changed to MGHE 01. CK 01 Operating Permit Application Requirements IA 01 Insignificant Activities GI 01 Facility Information Retained with significant modifications to fit this general permit. Form name was changed to Application Forms Master List. Form number was changed to MGmaster. Retained with those not required and those required to be listed indicated on a single form with space available for the applicant to list those required to be listed. Form number was changed to MGIA 01. Retained with certain answers pre filled. Form number was changed to MG 01. Retained. Form number was changed to MG 02. GI 02 Process Flow Diagram GI 03 Facility and Stack/Vent Diagram Retained. Form number was changed to MG 03. GI 04 Stack/Vent Information Retained. Form number was changed to MG 04. GI 05A Pollution Control Equipment Information GI 05B Emission Unit Information GI 05C Tank Information GI 05D Fugitive Emission Source Information GI 07 Facility Emissions Summary GI 09 Requirements Forms (including GI 09A through GI 09I) CD 01 Compliance Plan CD 02 Compliance Certification Retained with certain answers pre filled, and with form separated by control equipment type. Form number was changed to MG 05A1 through MG 05A4. Retained with certain answers pre filled, and with form separated by emission unit type. Form number was changed to MG 05B1 through MG 05B9. Retained with certain answers pre filled. Form number was changed to MG 05C. Retained with certain answers pre filled. Form number was changed to MG 05D. Retained. Form number was changed to MG 07. Retained with modifications to fit this general permit and with certain answers pre filled. Form numbers were changed to MG 09 (including MG 09A through MG 09I). Removed because required information is included in the general permit Retained with modifications to fit this general permit. The form number was changed to MG 06.

299 Technical Support Document Section 6 Page 2 FORM COMMENTS CD 03 Compliance Schedule Removed because required information is included in the general permit CD 05 Compliance Plan for Control Retained with modifications to fit this general permit. The form number Equipment was changed to MGCD 05. EC Series Emission Calculations Forms Not required. As with the standard application, applicants must provide an editable spreadsheet with all necessary calculations. They may use the EC series forms to assist them in preparing the spreadsheet, but are not required to submit the EC series forms. ME 01 Continuous Monitoring System Removed as not applicable to this general permit. Information MI 01 Building and Structure Removed as not applicable to this general permit. Information EMS 00 EMS Permit Qualification Retained with significant modifications to fit this general permit. The form number was changed to MG 00. CH 17 Individual Permit Administrativ Retained with modifications to fit this general permit. The form number Changes was changed to GP 01. CR 04 Annual Compliance CertificationRetained with modifications to fit this general permit. The form number Report. was changed to MGCR 04. TF Series Halogenated Solvent Retained. Applicants use the same forms as used for a standard Cleaners Forms; application, as needed. 4W 01, 4M 01, 4P 01, 4Z 01 Initial Notification forms for NESHAPs DRF 1 Excess Emissions Reporting Form; DRF 2 Deviations Identified by Periodi Monitoring Systems; CS 01 Compliance Schedule Progress Report; AQRF Air Quality Reporting Form Checklist for Routine Submittals [N/A] Form MG EIL Annual Equipment Inventory List was created for this general permit and has no standard application parallel. [N/A] Form MG CMP Compliance Management Plan was created for this general permit and has no standard application parallel.

300 6.0 POTENTIAL TO EMIT (PTE) Technical Support Document Section 6 Page Overview Criteria pollutants emitted from processes at cleaning, painting/coating, cutting, grinding, blasting, fossil fuel combustion, and general fiberglass stationary sources; with or without pollution control equipment are summarized in Table 6.1. Table 6.1 Criteria pollutants emitted by allowed activities Sources PM/PM 10 /PM 2.5 SO 2 NO x VOC CO Pb HAP GHG Cleaning X X Spray and coating booths (painting/coating) X X X Mixing X X X Molding, casting, lamination X X X Resin and gel coaters X X X Abrasive blasting X Cutting, grinding, sanding X Fuel combustion (natural gas, distillate oil, LPG, biodiesel, X X X X X Neg. X X gasoline) Storage tanks X X Without restrictions, PTE of VOC may exceed 250 tpy, PTE of other criteria pollutants may exceed 100 tpy, and PTE of GHGs may exceed 100,000 tpy CO 2 e. To keep VOC emissions below 250 tpy, other criteria pollutant emissions levels below 100 tpy, and GHG emissions below 100,000 tpy CO 2 e, the stationary source must have a permit with federally enforceable limits. Because fuel combustion is the only source of SO 2, NO x, CO, and GHGs, limiting emission levels of SO 2, NO x and CO to a potential of less than 100 tpy and GHGs to a potential of less than 100,000 tpy is accomplished by applying fuel type limitations. Limiting emission levels of VOC to a potential of less than 250 tpy is accomplished by requiring record keeping of the amount of VOC materials used. Limiting emission levels of each PM, PM 10, and PM 2.5 to a potential of less than 100 tpy is accomplished by requiring the use particulate matter control equipment on particulate emissions generating booths for abrasive blasting, sanding, and spraying/coating operations. With these requirements and limitations, the total particulate matter emissions from cleaning, painting/coating, cutting, grinding, blasting, fossil fuel combustion, and general fiberglass stationary sources; with or without pollution control equipment will not exceed 100 tpy. The emission limitations are described below. 6.2 Fuel Combustion Some stationary sources covered by this general permit will have fossil fuel combustion processes. This general permit allows these stationary sources to use a variety of fuels including natural gas, distillate oil

301 Technical Support Document Section 6 Page 2 (diesel) and liquefied petroleum gas (LPG) for indirect heating sources, and distillate oil (diesel), biodiesel for internal combustion engines. These processes may have potential emissions greater than 100 tpy for SO 2, NO x and CO; these processes may also have potential emissions greater than 100,000 tpy CO 2 e of GHGs. Therefore, the general permit will include enforceable restrictions on fuel type to maintain emissions below 100 tpy for each of these criteria pollutants. Based on the expected annual fuel usage of stationary sources likely to use this general permit, the actual quantities of pollutants expected to be emitted to the atmosphere with the limitations of this permit can be estimated to be less than the 100 tpy emission thresholds. While actual emissions cannot be equated to PTE for a stationary source without an operating history, the fact that actual emissions are expected to be much less than the estimated PTE indicates that these stationary sources could be permitted more efficiently using imposed restrictions on the type of fuel combusted and the amount of emissions on a monthly basis. These imposed restrictions would then be placed in the general permit as federally enforceable limitations on PTE. The restrictions would be established such that the stationary source would not be subject to NSR requirements. Emissions from combustion sources are determined directly by the type and quantity of fuel consumed. Thus, the permit allows for fuel usage (and hence pollutants emitted) to be determined by use of a fuel flow meter(s) or by use of purchase and inventory records. The general permit also makes a provision to allow the combustion of any combination of natural gas, distillate oil (diesel) and LPG for indirect heating sources and distillate oil (diesel) and biodiesel for external combustion engines. Procedures to estimate and limit PTE from fuel combustion are described in Appendix A to the permit, Section 2. Combustion Sources. To allow for the combustion of natural gas, LPG and distillate oil (diesel) in indirect heating sources and for the combustion of distillate oil and biodiesel in internal combustion engines under this general permit, the limiting pollutant for each fuel type must be determined. For each fuel there is a maximum emission factor that defines the amount of that fuel that could be combusted and still emit less than emission thresholds of the corresponding pollutant. From these emission factors, it can be seen that for indirect heating sources, CO 2 e is the limiting pollutant for natural gas and NO x is the limiting pollutant for LPG. The limiting pollutant for distillate fuel is dependent upon the sulfur content: NO x is the limiting pollutant when the sulfur content is less than 0.14% by mass. For indirect heating sources, CO 2 e is the limiting pollutant for distillate oil. For reciprocating internal combustion engines NO x is the limiting pollutant for biodiesel and distillate oil. Stationary sources with indirect heating sources and internal combustion engines may choose to install a fuel flow measuring device on such units or use purchasing records to use in calculating emissions from fuel combustion. 6.3 Limiting Particulate Emissions Limiting emission levels of PM/PM 10 /PM 2.5 to a potential of less than 100 tpy is accomplished by requiring control equipment on particulate emissions generating booths for abrasive blasting, sanding, and spraying/coating operations. Particulate emissions from welding, brazing, grinding, cutting and soldering are considered insignificant activities under Minn. R , subp. 3. and Minn. R Particulate emissions from insignificant activities under Minn. R , subp. 4, must be counted towards potential to emit. The Permittee must keep records of PM/PM 10 /PM 2.5 emissions to account for the actual emissions and submit an annual emission inventory to the MPCA. The recordkeeping

302 Technical Support Document Section 6 Page 3 provisions and methods of calculation are addressed in the application and permit package. Procedures to estimate and limit PTE from booths are described in Appendix A to the permit, Section 3. The limitation for PM/PM 10 /PM 2.5 is based on a 12 month rolling sum. 6.4 Limiting VOC Emissions Limiting emissions levels of VOC to a potential of less than 250 tpy based on a 12 month rolling sum by is accomplished by requiring tracking VOC contents and use of VOC containing materials. The Permittee is required to perform calculations each month for the VOC emissions from the previous month and for the 12 month rolling sum through the previous month. Procedures to estimate and limit PTE from VOC emitting operations are described in Appendix A to the permit, Section 4. The limitation for VOC is based on a 12 month rolling sum. 6.5 Limiting GHG Emissions Limiting emission levels of CO2e to a potential of less than 100,000 tpy based on a 12 month rolling sum is accomplished by restricting the fuel type, as discussed above in section 6.2 Combustion Emissions. Procedures to estimate and limit CO 2 e PTE from fuel combustion are described in Appendix A to the permit, Section 5. The limitation for CO 2 equivalent Emissions is based on a 12 month rolling sum. 6.6 Limiting HAP Emissions Limiting emissions levels of HAP to a potential of less than 100 tpy based on a 12 month rolling sum using emission factors from 40 CFR pt. 63, subp. WWWW. The Permittee can use any organic HAP emission factors most recently approved by US EPA, such as factors from AP 42 or site specific organic HAP emission factors if they are approved by the MPCA. Procedures to estimate and limit PTE from HAP emitting operations are described in Appendix A to the permit, Section 6. The limitation for HAP is based on a 12 month rolling sum. 6.7 Fugitive Emissions Stationary sources covered by this general permit will not be required to submit fugitive emission calculations because they are not one of the 28 source categories listed that triggers the 100 tpy threshold for PSD. Fugitive emission sources must be identified in the application; however, to comply with Part 70 requirements.

303 7.0 COMMENTS RECEIVED Technical Support Document Section 7 Page 1 Public Notice Period: August 5, 2014 September 3, 2014 EPA 45 day Review Period: August 5, 2014 September 19, 2014 Comments were received from the public during the public notice period. The comments received did include adverse comments on some applicable requirements of the permit. Changes to the permit were made as a result of the comments. Below is a summary of the comments and changes. The comments and MPCA responses are included as Attachment 2 to this TSD. Table 7.1 Summary of comments received and associated permit changes Comment # Date received Commenter Comment summary Change/response summary 1 9/3/2014 Jessica Karras Bailey of RTP Environmental Associates, Inc. 2 9/3/2014 Brent Pavelko, of AGCO Corporation 3 9/3/2014 Sneha Raghavan, of Industrial Protection Corporation Remove 90,000 tpy GHG limit because non applicable citation Due to recent court decision, GHG is no longer enough to trigger PSD applicability so the 90,000 tpy GHG limit should be removed from the permit Remove 90,000 tpy GHG limit because non applicable citation Due to recent court decision, GHG is no longer enough to trigger PSD applicability so the 90,000 tpy GHG limit should be removed from the permit Add NESHAP VVVV for expanded access 40 CFR pt. 63, subp. VVVV should be added to the permit to expand eligibility. Kept 90,000 tpy GHG limit, updated citation MPCA removed the Title Title I Condition: To avoid classification as a major source under and Minn. R citation from the GHG limit and associated recordkeeping. MPCA is retaining the 90,000 tpy GHG limit and the citation To qualify for this general permit under Minn. R NESHAP VVVV unnecessary: did not add Subp. VVVV is unnecessary for the facilities for which this general permit was designed, and incorporating this NESHAP so late in the permitting process would create unacceptable delays in issuing this permit. The MPCA will not be adding subp. VVVV to this general permit. These revisions were discussed with the EPA as part of the EPA review. The EPA agreed that these changes were not significant enough to warrant restarting the 45 day EPA review. Comments were not received from EPA during their review period.

304 8.0 CONCLUSION Technical Support Document Section 8 Page 1 Based on the eligibility criteria for facilities applying for this general permit, the MPCA has reasonable assurance that the proposed operation of the emission facilities that receive this permit, as described in the 2014 Part 70 Manufacturing General Permit and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Kira Gillette (permit engineer and project manager) Cassandra Meyer (permit engineer) Bonnie Nelson (permit engineer) Cindy Schafer (permit engineer) Toni Volkmeier (permit engineer and project supervisor) Amrill Okonkwo (peer reviewer) Brent Rohne (compliance, enforcement, and performance testing) Beckie Olson (permit writing assistant) Laurie O Brien (administrative support) Attachments: 1. CAM Plans (from Form MG 09H) 2. Public Notice comments and responses

305 Attachment 1 CAM Plans (from Form MG 09H) Technical Support Document Attachment 1 Page 1

306 CAM Plans Technical Support Document Attachment 1 Page 2 The next section contains CAM Plans for those units to which CAM may apply under the Part 70 Manufacturing General Permit. The Permittee indicates which CAM Plan(s) apply(applies) to units at the facility in application form MG-09H. If the Permittee has units which are subject to CAM that are not covered by any of the attached CAM plans, then the Permittee does not qualify for this general permit. Attached CAM Plans: CAM Plan for HEPA and Other Wall Filters Controlling PM and PM10 from Spray Booths [Other PSEU] CAM Plan for Fabric Filters/Baghouses controlling PM and PM10 from Spray Booths [Other PSEU] CAM Plan for Fabric Filters/Baghouses controlling PM and PM10 from Abrasive Blasting [Other PSEU] CAM Plan for Catalytic Oxidizers Controlling VOC from Spray Booths, Molding, Casting, Lamination, Mixing or Cleaning [Large PSEU] CAM Plan for Thermal Oxidizers Controlling VOC from Spray Booths Molding, Casting, Lamination, Mixing or Cleaning & Burn-off Ovens [Large PSEU] CAM Plan for Catalytic Oxidizer controlling VOC from Spray Booth, Molding, Casting, Lamination, Mixing or Cleaning [Other PSEU] CAM Plan for Thermal Oxidizer controlling VOC from Spray Booths, Molding, Casting, Lamination, Mixing or Cleaning & Burn-off Oven [Other PSEU]

307 Technical Support Document Attachment 1 Page 3 CAM Plan for Wall Filters Controlling PM and PM 10 from Spray Booths [Other PSEU] 1. Applicability 1.1. Process/Emission Unit: Spray Booth [Other PSEU] 1.2. Control Technology: HEPA and other Wall Filters 1.3. Pollutant: Particulate Matter (PM, PM 10 ) 2. Monitoring Approach Description Indicators Monitored Rationale for Monitoring Approach Monitoring Methods Location Analytical Devices Required Data Acquisition and Measurement System Operation Data Requirements QA/QC Procedures Visually inspect the condition of the filters. If there are any holes, saturation, tears or alignment in the filter, these indicate there is little or no particulate removal. Adhere to the Operation and Maintenance Plan for the filters and take corrective action as soon as possible (within 24 hours of discovery) to eliminate any problem associated with the filters. Train staff on the operation and monitoring of the filters and troubleshooting. Also, train and require staff to respond to indications of malfunctioning equipment and, including indicators of abnormal operation. Frequency of Measurement: Once each operating day, visually inspect the condition of each filter with respect to alignment, saturation, tears, holes, and any other matter that may affect the filter s performance. Reporting units: daily check of the condition of the filter. Recording process: Records are maintained of all inspections and maintenance activities performed. Operators record activities maintenance log sheets, initial and date. The baseline is determined by the facility s historical records of the condition of the filter with respect to alignment, saturation, tears, holes, and any other matter that may affect the filter s performance. Operate and maintain each filter in accordance with the Operation and Maintenance Plan and while taking into account the manufacturer s specifications. 3. Justification Compliance testing is not necessary for the owner or operator to establish operating ranges so that excursion from the operating ranges can be addressed prior to potential emission exceedance. Monitoring based on the Minnesota Standards of Performance for Control Equipment is adequate to have a reasonable assurance of compliance (daily and periodic inspections, corrective actions, O & M, and hood design records) and to ensure that control equipment continues to operate properly and achieve the desired PM control efficiency.

308 Technical Support Document Attachment 1 Page 4 CAM Plan for Fabric Filters/Baghouses Controlling PM and PM 10 from Spray Booths [Other PSEU] 1. Applicability 1.1. Process/Emission Unit: Spray Booth [Other PSEU] 1.2. Control Technology: Fabric Filters 1.3. Pollutant: Particulate Matter (PM, PM 10 ) 2. Monitoring Approach Description Indicators Monitored Rationale for Monitoring Approach Monitoring Methods Location Analytical Devices Required Data Acquisition and Measurement System Operation Data Requirements QA/QC Procedures Pressure Drop and Visible Emissions (VE) Decrease in pressure drop indicative of bag failure; Increase in pressure drop indicative of fabric blinding or decreased permeability; A change in VE observations indicates process change, changes in fabric filter s efficiency, or leaks. Measure across the inlet and outlet of each compartment of the fabric filter. RM 22 (VE) requirements. Pressure transducers, differential pressure gauges, manometers, other methods and/or alternative instrumentation as appropriate. Trained observer using visible/no visible emissions observation techniques (RM 22-like) Frequency of Measurement: Record pressure drop once every 24 hours when in operation, or recorded continuously on strip chart and daily VE checks as weather permits. Reporting units: Inches of water column (in w.c). and visible/no visible emissions. Recording process: Record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified. If the pressure drop is outside the required operating range and VE emission are observed, the owner or operator will follow the Operation and Maintenance plan for the fabric filter and take corrective action within 24 hours of discovery. Keep a record of the type and date of any corrective action taken for each filter. The facility s historical records on pressure drop measurements determine the baseline. No data are needed for visible emissions. Calibrate, maintain and operate instrumentation using the procedures that take into account the manufacturer s recommendations and initial training of observer per RM Justification Compliance testing is not necessary for the owner or operator to establish operating ranges so that excursion from the operating ranges can be addressed prior to potential emission exceedance. Monitoring based on the Minnesota Standards of Performance for Control Equipment is adequate to have a reasonable assurance of compliance (daily and periodic inspections, corrective actions, O & M, and hood design records) and to ensure that control equipment continues to operate properly and achieve the desired PM control efficiency.

309 Technical Support Document Attachment 1 Page 5 CAM Plan for Fabric Filters/Baghouses Controlling PM and PM 10 from Abrasive Blasting [Other PSEU] 1. Applicability 1.1. Process/Emission Unit: Abrasive Blasting Booth 1.2. Control Technology: Fabric Filters 1.3. Pollutant: Particulate Matter (PM, PM 10 ) 2. Monitoring Approach Description Indicators Monitored Rationale for Monitoring Approach Monitoring Methods Location Analytical Devices Required Data Acquisition and Measurement System Operation Data Requirements QA/QC Procedures Pressure Drop and Visible Emissions (VE) Decrease in pressure drop indicative of bag failure; Increase in pressure drop indicative of fabric blinding or decreased permeability; A change in VE observations indicates process change, changes in fabric filter s efficiency, or leaks. Measure across the inlet and outlet of each compartment of the fabric filter. RM 22 (VE) requirements. Pressure transducers, differential pressure gauges, manometers, other methods and/or alternative instrumentation as appropriate. Trained observer using visible/no visible emissions observation techniques (RM 22-like) Frequency of Measurement: Record pressure drop once every 24 hours when in operation, or recorded continuously on strip chart and daily VE checks as weather permits. Reporting units: Inches of water column (in w.c). and visible/no visible emissions. Recording process: Record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified. If the pressure drop is outside the required operating range and VE emission are observed, the owner or operator will follow the Operation and Maintenance plan for the fabric filter and take corrective action within 24 hours of discovery. Keep a record of the type and date of any corrective action taken for each filter. The facility s historical records on pressure drop measurements determine the baseline. No data are needed for visible emissions. Calibrate, maintain and operate instrumentation using the procedures that take into account the manufacturer s recommendations and initial training of observer per RM Justification Compliance testing is not necessary for the owner or operator to establish operating ranges so that excursion from the operating ranges can be addressed prior to potential emission exceedance. Monitoring based on the Minnesota Standards of Performance for Control Equipment is adequate to have a reasonable assurance of compliance (daily and periodic inspections, corrective actions, O & M, and hood design records) and to ensure that control equipment continues to operate properly and achieve the desired PM control efficiency.

310 Technical Support Document Attachment 1 Page 6 CAM Plan for Catalytic Oxidizers Controlling VOC from Spray Booths Molding, Casting, Lamination, Mixing or Cleaning [Large PSEU] 1. Applicability 1.1 Process/Emission Unit: Spray Booth, Molding, Casting, Lamination, Mixing or Cleaning 1.2 Control Technology: Catalytic Oxidizer 1.3 Pollutant: Volatile Organic Compounds (VOCs) 2. Monitoring Approach Description Indicators Monitored Rationale for Monitoring Approach Monitoring Methods Location Analytical Devices Required Data Acquisition and Measurement System Operation Data Requirements QA/QC Procedures Catalyst bed inlet temperature and catalyst activity. Catalyst bed inlet temperature: Indicates whether the gas flowing into catalyst bed is of sufficient temperature to initiate oxidation. Catalyst activity: Determines conversion efficiency of catalyst; indicates that catalyst is not poisoned or masked beyond operational range. Catalyst bed inlet and outlet temperature: Preheat chamber outlet and catalyst bed inlet. Catalyst activity: Sample of catalyst. Temperature: Thermocouples, or alternative methods/instrumentation as appropriate for specific gas stream. Catalyst activity: Qualified laboratory (e.g. catalyst manufactures) for determining activity of catalyst sample. Frequency of Measurement: Once every 15 minutes or recorded continuously on strip chart or data acquisition system. Reporting Units: Degrees Fahrenheit (º F) Recording process: Operators log data manually, or recorded automatically on strip chart or data acquisition system. Catalyst activity: Annual analyses of catalyst sample. The facility s historical records on catalyst bed inlet and outlet temperature measurements. Catalyst activity: Laboratory results of conversion efficiency. Calibrate, maintain and operate instrumentation using the procedures that take into account the manufacturer s recommendations and specifications. 3. Justification Compliance testing is not necessary for the owner or operator to establish operating ranges so that excursion from the operating ranges can be addressed prior to potential emission exceedance. Monitoring based on the Minnesota Standards of Performance for Control Equipment is adequate to have a reasonable assurance of compliance (daily and periodic inspections, corrective actions, O & M, and hood design records) and to ensure that control equipment continues to operate properly and achieve the desired VOC control efficiency.

311 Technical Support Document Attachment 1 Page 7 CAM Plan for Thermal Oxidizers Controlling VOC from Spray Booths Molding, Casting, Lamination, Mixing or Cleaning & Burn-off Ovens [Large PSEU] 1. Applicability 1.4 Process/Emission Unit: Spray Booth, Spray Booths, Molding, Casting, Lamination, Mixing or Cleaning, and Burn-off Oven 1.5 Control Technology: Thermal Oxidizer 1.6 Pollutant: Volatile Organic Compounds (VOCs) 2. Monitoring Approach Description Indicators Monitored Rationale for Monitoring Approach Monitoring Methods Location Analytical Devices Required Data Acquisition and Measurement System Operation Data Requirements QA/QC Procedures Combustion chamber temperature and annual burner inspections. Combustion chamber temperature: Proper temperature range is related to good performance. Annual burner inspection: Maintain proper operation and efficiency. Combustion chamber temperature: Outlet of combustion chamber. Annual burner inspection: At the burner. Combustion chamber temperature: Thermocouples or alternative methods/instrumentation as appropriate for specific gas stream. Annual burner inspection: None Frequency of Measurement: Combustion chamber temperature: Once every 15 minutes or recorded continuously on strip chart or data acquisition system. Annual burner inspection: Annually Reporting Units: Combustion chamber temperature: Degrees Fahrenheit (º F) Annual burner inspection: None Recording process: Combustion chamber temperature: Operators log data manually, or recorded automatically on strip chart or data acquisition system. Annual burner inspection: Operators log data manually. The facility s historical records on combustion chamber temperature measurements and burner inspection. Calibrate, maintain and operate instrumentation using the procedures that take into account the manufacturer s recommendations and specifications. 3. Justification Compliance testing is not necessary for the owner or operator to establish operating ranges so that excursion from the operating ranges can be addressed prior to potential emission exceedance. Monitoring based on the Minnesota Standards of Performance for Control Equipment is adequate to have a reasonable assurance of compliance (daily and periodic inspections, corrective actions, O & M, and hood design records) and to ensure that control equipment continues to operate properly and achieve the desired VOC control efficiency.

312 Technical Support Document Attachment 1 Page 8 CAM Plan for Catalytic Oxidizers Controlling VOC from Spray Booths Molding, Casting, Lamination, Mixing or Cleaning [Other PSEU] 1. Applicability 2.1 Process/Emission Unit: Spray Booths, Molding, Casting, Lamination, Mixing or Cleaning 2.2 Control Technology: Catalytic Oxidizer 2.3 Pollutant: Volatile Organic Compounds (VOCs) 2. Monitoring Approach Description Indicators Monitored Rationale for Monitoring Approach Monitoring Methods Location Analytical Devices Required Data Acquisition and Measurement System Operation Data Requirements QA/QC Procedures Catalyst bed inlet temperature and catalyst activity. Catalyst bed inlet temperature: Indicates whether the gas flowing into catalyst bed is of sufficient temperature to initiate oxidation. Catalyst activity: Determines conversion efficiency of catalyst; indicates that catalyst is not poisoned or masked beyond operational range. Catalyst bed inlet and outlet temperature: Preheat chamber outlet and catalyst bed inlet. Catalyst activity: Sample of catalyst. Temperature: Thermocouples, or alternative methods/instrumentation as appropriate for specific gas stream. Catalyst activity: Qualified laboratory (e.g. catalyst manufactures) for determining activity of catalyst sample. Frequency of Measurement: Once every 24 hours when in operation, or recorded continuously on strip chart or data acquisition system. Reporting Units: Degrees Fahrenheit (º F) Recording process: Operators log data manually, or recorded automatically on strip chart or data acquisition system. Catalyst activity: Annual analyses of catalyst sample. The facility s historical records on catalyst bed inlet and outlet temperature measurements. Catalyst activity: Laboratory results of conversion efficiency. Calibrate, maintain and operate instrumentation using the procedures that take into account the manufacturer s recommendations and specifications. 3. Justification Compliance testing is not necessary for the owner or operator to establish operating ranges so that excursion from the operating ranges can be addressed prior to potential emission exceedance. Monitoring based on the Minnesota Standards of Performance for Control Equipment is adequate to have a reasonable assurance of compliance (daily and periodic inspections, corrective actions, O & M, and hood design records) and to ensure that control equipment continues to operate properly and achieve the desired VOC control efficiency.

313 Technical Support Document Attachment 1 Page 9 CAM Plan for Thermal Oxidizers Controlling VOC from Spray Booths, Molding, Casting, Lamination, Mixing or Cleaning & Burn-off Ovens [Other PSEU] 1. Applicability 2.4 Process/Emission Unit: Spray Booths, Molding, Casting, Lamination, Mixing or Cleaning, and Burn-off Ovens 2.5 Control Technology: Thermal Oxidizer 2.6 Pollutant: Volatile Organic Compounds (VOCs) 3. Monitoring Approach Description Indicators Monitored Rationale for Monitoring Approach Monitoring Methods Location Analytical Devices Required Data Acquisition and Measurement System Operation Data Requirements QA/QC Procedures Combustion chamber temperature and annual burner inspections. Combustion chamber temperature: Proper temperature range is related to good performance. Annual burner inspection: Maintain proper operation and efficiency. Combustion chamber temperature: Outlet of combustion chamber. Annual burner inspection: At the burner. Combustion chamber temperature: Thermocouples or alternative methods/instrumentation as appropriate for specific gas stream. Annual burner inspection: None Frequency of Measurement: Combustion chamber temperature: Once every 24 hours when in operation, or recorded continuously on strip chart or data acquisition system. Annual burner inspection: Annually Reporting Units: Combustion chamber temperature: Degrees Fahrenheit (º F) Annual burner inspection: None Recording process: Combustion chamber temperature: Operators log data manually, or recorded automatically on strip chart or data acquisition system. Annual burner inspection: Operators log data manually. The facility s historical records on combustion chamber temperature measurements and burner inspection. Calibrate, maintain and operate instrumentation using the procedures that take into account the manufacturer s recommendations and specifications. 3. Justification Compliance testing is not necessary for the owner or operator to establish operating ranges so that excursion from the operating ranges can be addressed prior to potential emission exceedance. Monitoring based on the Minnesota Standards of Performance for Control Equipment is adequate to have a reasonable assurance of compliance (daily and periodic inspections, corrective actions, O & M, and hood design records) and to ensure that control equipment continues to operate properly and achieve the desired VOC control efficiency.

314 Technical Support Document Attachment 2 Page 1 Attachment 2 Public Notice comments and responses (from Form MG 09H) Table 7.1 Summary of comments received and associated permit changes Comment # Date received Commenter Comment summary Change/response summary 1 9/3/2014 Jessica Karras Bailey of RTP Environmental Associates, Inc. 2 9/3/2014 Brent Pavelko, of AGCO Corporation 3 9/3/2014 Sneha Raghavan, of Industrial Protection Corporation Remove 90,000 tpy GHG limit Due to recent court decision, GHG is no longer enough to trigger PSD applicability so the 90,000 tpy GHG limit should be removed from the permit Remove 90,000 tpy GHG limit Due to recent court decision, GHG is no longer enough to trigger PSD applicability so the 90,000 tpy GHG limit should be removed from the permit Add NESHAP VVVV 40 CFR pt. 63, subp. VVVV should be added to the permit to expand eligibility. Kept 90,000 tpy GHG limit, updated citation MPCA removed the Title Title I Condition: To avoid classification as a major source under 40 CFR Section and Minn. R citation from the GHG limit and associated recordkeeping. MPCA is retaining the 90,000 tpy GHG limit and the citation To qualify for this general permit under Minn. R Did not add NESHAP VVVV Subp. VVVV is unnecessary for the facilities for which this general permit was designed, and incorporating this NESHAP so late in the permitting process would create unacceptable delays in issuing this permit. The MPCA will not be adding subp. VVVV to this general permit.

315 Comment #1 Technical Support Document Attachment 2 Page 2 From: Jessica Karras-Bailey [mailto:bailey@rtpenv.com] Sent: Wednesday, September 03, :05 PM To: Gillette, Kira (MPCA) Cc: Jessica Buckley Subject: Public Comment on Gen Permit Kira, Attached please find a letter regarding the MPCA Draft Part 70 Manufacturing General Air Emission Permit currently on public notice. We have prepared this letter to describe our comments for your review and consideration. Of course, if you should have any questions or require more information please let me know. Thank you, Jessica Bailey Jessica A. Karras-Bailey Principal RTP Environmental Associates, Inc. 400 Post Avenue, Suite 405 Westbury, NY Ph: (516) Fax: (516) Cell: (516)

316 Technical Support Document Attachment 2 Page 3 VIA ELECTRONIC MAIL September 3, 2014 Ms. Kira Gillette Air Permit Engineer Air Quality Permits Section, Industrial Division Minnesota Pollution Control Agency 520 Lafayette Rd. St. Paul, Minnesota Re: Comments on the DRAFT Part 70 Manufacturing General Air Emission Permit Dear Ms. Gillette: RTP Environmental Associates, Inc. (RTP) is providing comments on the DRAFT/PROPOSED Part 70 Manufacturing General Air Emission Permit (herein referred to as the Draft Permit) published by the Minnesota Pollution Control Agency (MPCA) on Tuesday, August 5, RTP provides environmental consulting services to Minnesota manufacturing facilities. As such, we have an interest in the conditions and language associated with the Part 70 Manufacturing General Air Emission Permit. Based on our review of the Draft Permit, there is one main area of concern that requires MPCA s attention and removal from permitting requirements as not to impose unnecessarily stringent requirements on the permittee(s). The requirement in question is the restriction on Greenhouse Gas (GHG) emissions to 90,000 tons per year (tpy). On June 23, 2014, the U.S Supreme Court issued a decision addressing the application of stationary source permitting requirements to GHGs. In its decision, the Supreme Court indicated that the EPA exceeded its statutory authority when it interpreted the Clean Air Act to require PSD and Title V permitting for stationary sources based on GHG emissions, known as the Tailoring Rule. In summary, the Supreme Court said that the EPA may not treat greenhouse gases as an air pollutant for purposes of determining whether a source is a major source required to obtain a Prevention of Significant Deterioration (PSD) or

317 Technical Support Document Attachment 2 Page 4 Ms. Kira Gillette September 3, 2014 Page 2 of 2 Title V permit. In a memorandum issued by the EPA on July 24, 2014 from Ms. Janet McCabe and Ms. Cynthia Giles, EPA has stated that the plan is to act consistent with its understanding of the Supreme Court's decision and the EPA will no longer require PSD or title V permits for Step 2 sources (attached). Since there are no longer federally enforceable restrictions to limit GHG emissions, the 90,000 tpy limit for GHG emissions (as carbon dioxide equivalent) and all conditions associated with this limit should be removed from the Draft Permit. Thank you for your consideration. Of course, if you have any questions or would like to discuss the contents of this memo further, please do not hesitate to call me at or me at bailey@rtpenv.com. Sincerely, RTP ENVIRONMENTAL ASSOCIATES, INC. Jessica A. Karras-Bailey Principal

318 Technical Support Document Attachment 2 Page 5 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C OFFICE OF AIR.\ND RADIATION MEMORA NDUM SUBJ l;:ct: Nex t Steps and Prel iminary Views on the Appl ication of Clean A i r /\ct Permitti ng Programs to Greenhouse Gases Fol lowing the Supreme Court's Decision in Utility Air Regu/a101 J ' Group 1. Environmental Protection Agency FROM : Janet G. McCabe. Acting Assistant Ad mi nistrator _)G{-.::: Office of Air and Radiation Cynthia G i les, Assistant Admi nistrato Office or En lorccmcnt and Complianc TO: Regional Ad mi nistrators. Regions On.l u ne the U ni ted tates Supreme Cou rt i ssued a decision addressing the application or stationary source permi tt ing requirements to green house gases (GHG). Utility Air Regula101y Group ( UARC) v. Enl'ironmenta! Pro1ectio11 Agency (EPA) (1 o ). The EPA actions at issue i n the case incl uded those generall y known as the..tailoring Rule.. and the..timin g Decision: In very brief sum mary, the Supreme Court said that the EPA may not treat greenhouse gases as an air pollutant for purposes of determi ning whether a source is a major source required to obtain a Prevention of Si gni!icant Deterioration (PSD) or t i tl e V permi t. The Supreme Court also said that the EPA could contin ue to req ui re that PSD permits, otherwise req u ired based on emissions of conventional pollutant s, contai n limitations on GHG emissions based on the application of Best Avai lable Control Technology (BACT). The EPA is cont i n uing to examine the i m pl icat ions of the Supreme Cou11 s decision. includ i ng how the EPA wi ll need tu revise its permitting regulat ions and related impacts to state programs. There wi ll be further federal court action to apply the decision, but we knovv that you, as \;veil as our part ner agencies i n state. local and tri bal governments. have questions regard i ng how the decision affects PSD and tilie V permi tt ing requi rements in the meanti me. Some of these questions have near term im pl ications, i n particular t hose related to pend ing PSD and title V penn i tt ing act ions. The EPA intend s to act ive l y engage wi t h stakeholders on t ime-sensit ive act ions, such as permi t appl ications, state program submissions, and sta tionary source construclion that may no longer need to meet certain permilli ng req uirements. The EPA is likely to take other steps in the longer term and to respond to further court action in t his case as needed.

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320 Technical Support Document Attachment 2 Page 7 Pend ing fu11her EPA engagement i n the ongoi11g jud icial process before the District of Columbia Circuit Court of A ppeals (0.C. Circuit). the EPA plans to act consistent with i ts undcrstand.ing of the Supreme Court's decision. This memorand um has two pa rts. f-irst. i t expla ins how the EPA intends to proceed al this poi nt with respect lo permit applications for Tailoring Rule ''Step 2" sources and PSD mod ifications that were previousl y cl assified as major based sol ely on GI-JG emissions (th us req uiring that the sources get permits). Second. thi s memorandum provides prel i minary guidance i n respon se to several quest ions regard ing ongoing permi tti ng requi rements for any'vvay sources and some addi t ional issues pert aining to permi ttu1g req uirements for step 2" sources. We believe that the status of pendi ng permi t applications and whether certa in projects need to apply for PSD and title V permi ts in J ight of the Supreme Court decision may be the most im mediate questions. 1. Permit Applica tions for Sou rc es and Modifications Previouslv Cla ssi fied as "Ma jor" Based Solely on G reen house Gas Emissions ("Step 2" Sources) I n order to act consistent with its understanding of the Supreme Court's decision pending jud icial action to effectuate the final decision, t he EPA will no longer require PSD or title V permi ts for Step 2 sources. More speci fically. the EPA will no longer apply or en force federal regulatory provisions or the EPAappro ed PSD State I m plemen tation Plan (SIP) provisions that requi re a stati onary source to obtain n PSD permit i f green house gases are the only pollutant (i ) that the source em i ts or has the potential to emit above the major source thresholds, or (ii) for wh ich there is a significa nt emissions increase and a signi Iicant net emissions i ncrease from a modificati cm (e.g., 40 CFR (b)(49)(v)). Nor does the EPA i ntend to continue applyi ng regulations that woul d require that states incl ude in thei r SIP a req ui rement that such sources obtain PSD pem1its. Sim ilarl y, the EPA will no longer apply or enforce federal regulatory provisions or provisions of the EPA-approved title V programs that requi re a stationary source to obtain a t i tl e V permit solely because the source emits or has the potential to emit greenhouse gases above the major source thresholds (e.g.. the regulatory provision relating to GHG under the definition of --subjecl to regula t ion in 40 CFR 7 1.2). The EPA also does not i ntend to continue applying regulations that would requ i re t it le V program s su bmi tted for approva l by the EPA to require that such sources obtain title V permi ts. Thus, the EPA does not intend to continue processing PSD or Title V permi t appiications for Step 2 sou rces or require new appl ications for such permi ts in cases where the EP/\ i s t he permitt ing authority. In summary, in order to act consistentl y with its understanding of the Supreme Coun s decision pending jud icial action to effectuate the final decision, the EPA \\'ill not apply or enforce the following regulatory requi rements: Federal regulation s or the EPA-approv ed PSD SIP provisions that require a stationary source to obtain a PSD permit if GHG are the on l y pollutant (i) that the source em i ts or has the potential to emit above the major source thresholds, or (ii) for which there is a significant emissions i ncrease and a significant net emissions increase from a modi fication (e.g.. 40 CFR (b)(49)(y)). Federal regulations or provisions in the EPA-approved title V programs that require a stationary source to obtain a title V permi t solely because the source emits or has the potential to emit GHG above the major source tlu esholds.

321 .., -' Technical Support Document Attachment 2 Page 8 As discussed further below, we recommend that Regional Offices confer with state, local and tri bal permitti ng authorities and permit applicants to discuss how to handle permit applications pendi ng with those agencies. 2. Preliminarv EPA Views Regarding Other Questions Raised by Supreme Court Decision The remai nder of this memorandum is intended simply to provide a clear statement of the EPA's present understand ing of the im plications of the Supreme Court's decision on additional subjects regarding permi tti ng requi remen ts. The fol lowing is not intended to represent a definitive or final statement by the agency on these issues. E n fact, the EPA expects that some changes or refinements to the following guidance may result as the EPA examines these matters further in the course of jud icial proceedings, discussions with stakeholders, and forthcoming action with respect to pem1it applications, issued permits, and approval of state programs. 1 Next Steps in the Legal Process Following the Supreme Court's Decision Additional steps have yet to occur in the U.S. Courts to implement the Supreme Cou11decision. Since no party requested reconsideration of the Supreme Court decision by the applicable deadline under Supreme Court rules, the EPA expects that the Supreme Comt's decision \vill become final shortly. This will be the case as soon as the Supreme Court sends its decision down to the D.C. Circuit for further proceed ings. After this occurs, we expect that the D.C. Circuit will issue an order that leads to a process that identifies particular parts of the regulations adopted in the Tailoring Rule and earlier EPA regulat ions that the EPA must revise (remanding the regulations) or that are struck down (vacating the regulat ions). The EPA and the Department of Justice expect to soon begi n a process of consulting with the parties to the litigation regardi ng this step of the court process. PSD Construction Permi t Requirements Sources Triggering PSD Based on Pollutants Other Than GHG The Supreme Court upheld application of the BACT requirement to greenhouse gas emissions from new and modified sources that trigger PSD permitting obligations on the basis of their emissions of air poll utants other than GHG (also known as "Step 1" or 'anyway sources"). In the EPA's current view, Step I sources remain subject to the PSD BACT requirement for GHG, as well as other pollutants, if they emit those poll utants at or above certain thresholds. With respect to new "anyway sources," the EPA intends to continue applying the PSD BACT requirement to GHG emissions if the source emits or has the potential to emit 75,000 tons per year (tpy) or more of GHG on a carbon dioxide equivalent (C02e) basis. With respect to mod ified "anyway sources," the EPA intends to continue applying the PSD BACT req uirements to GHG if both of the following circumstances are present: (1) the mod ification is otherwise subject to PSD for a pollutant other than GHG; (2) the modification resul ts in a GHG emissions increase and a net GHG emissions increase equal to or greater than 75,000 tpy C02e and greater than zero on a mass basis. 1 Since it provides genera l gu idance on these issues, the remainder of this memorandum does not itsel f create any rights or impose any new obl igations or prohib itions, and is not intended to be a basis for enforcement actions. The guidance that fol lows from this point may not be appropriate for all situations. and EPA retains the discretion to approach issues differently t han recom mended here in specific situations that may arise.

322 Technical Support Document Attachment 2 Page 9 The part of the Supreme Court opinion that affirmed application of BACT t o greenhouse gases at "anyway sources" also noted that the EPA may limit application of BACT to greenhouse gases to those situations where a permit applicant's source has the potential to emit GHG above a specified threshold (or de minimis) level. The Supreme Court explained that the EPA wou ld need to justify its de minimis threshold on proper grounds. In the meantime, to ensure compliance with the Clean A ir Act at present, the EPA intends to conti nue applying BACT to GHG at "anyway sources" and processing PSD permi t applications for "anyway sources" using a 75,000 tpy C02e threshold to determi ne whether a permit must include a BACT limitation for greenhouse gases, pending further developments. Such further developments may include action by the D.C. Circuit. input received by the EPA from stakeholders in connection with the court process, experience applying this approach in ind ividual permi tti ng actions, and further EPA action to consider whether to promulgate a de minimis level and what level would be appropriate. Thus, for now, the EPA believes the best course of action with respect to "anyway sources" is to continue applying existing regulations. Sources Triggering PSD Solely Based on GHCi Emissions Subject to the considerations discussed below, headquarters recommends that Regional Offices confer with state, local, and tr ibal permitting authorities and permi t applicants to explore their plans to respond to the Supreme Court s decision. These conversations should examine whether. in light of the Supreme Court decision. there is flexibility under state, local and tri bal laws to determine that Step 2 sources no longer are req uired to obtain PSD permits prior to the completion of any actions to repeal or revise such regulations to in light of the Supreme Court decision. The EPA understands that some states have provisions in their laws that may automaticall y modify state-law permitting requirements based on the Supreme Court's decision. To the extent such provisions were approved by the EPA as part of a Sf P, Regional Offices should encourage such states to contact the EPA to discuss implementation of those provisions. We do not read the Supreme Court decision to preclude st.ates from retaini ng permitting requi rements for sources of GHG emissions that apply independently under state law even where those requirements are no longer req uired under federal law. Regional Offices should be mi ndful that even if the EPA is not requiring Step 2 sources to obtain a PSD permit under federal law, such sources l ikely have a continuing obligation to obtain minor source construction permits under the applicable SIP as a result of their emissions of non-ghg polluta nts. Thus. we recommend discussing with state, local, and tribal permitti ng authorities and permit applicants, the feasibili ty of converting pending permit applications into minor source permi t applications and proceeding on that basis where appropriate. We plan to provide additional views in the future with respect to Step 2 sources t hat have already obtained a PSD permit, but our general thinking at this time is that it may be appropriate to ultimately remove OHO BACT limitations from such permits and to convert such permi ts into mi nor source permits where this is feasible and minor source req uirements remain applicable. We encourage Regional Offices to contact states to discuss their ability to proceed consistent with the outcome of the Supreme Court decision on individual permi tt ing matters.

323 Technical Support Document Attachment 2 Page 10 Title V Operating Permits While the EPA will no longer apply or enforce the requirement that a source obtain a ti t le V pennit solely because it emits OT has the potential to emit greenhouse gases above major source thresholds, the agency docs not read the Supreme Court decision to affect other grounds on which a title V perm it may be required or the appl icable req uirements that m ust be addressed in tit le V permits. For example, the EPA currentl y bel ieves i t is still appropriate for a t i tle V permit to incorporate and assure compliance with greenhouse gas BACT l im its that remai n applicable requi rements under a PSD permit issued to a Step 1 "an yway source.'" We recommend that Regional Offices confer with state, local, and tribal permitti ng authorities and perm it applicants regarding their plans to respond to the Supreme Court's decision. These conversations should examine whether, in l ight of the Supreme Court decision, there is flexibility under state, local, and tri bal laws to determine that Step 2 sources are no longer req uired to obtain title V permits prior to the completion of any actions to repeal or revise such regulations in light of the Supreme Court decision. To the extent that any approved state, local or tribal title V programs have prov isions in their laws that may automatical ly modify state, local or tribal-law permitting requirements based on the Supreme Court's decision, Regional Offices should encourage such permitting authorities to contact the EPA to discuss implementation of those provisions. Similar to state-law construction permitting requ irements, the Supreme Court decision does not preclude states from continuing to require that certain types of sources obtain operating perm its meeti ng requirements that apply independently under state law. Thus, we recommend that Regional Offices advise sources to consult with their individual permi tting authorities regardi ng operating permi t requirements after the Supreme Court's decision. With respect to title V permits that have already been issued to Step 2 sources, we recommend that such sources consu l t wi th their title V permitting authori ty to determine the appropriate next steps based on the source's specific permi tting situation. Federal PSD and Title V Rules, SIP and State Title V Programs The Office of Air and Radiation (OAR) anticipates a need for the EPA to revise federal PSD and title V rules 2 in light of the Supreme Court opinion. In addition, OAR anticipates that many SIPs and approved title V programs will be revised to effectuate the Supreme Court's decision. The timing and content of the EPA's actions with respect to the EPA regulations and state program approvals are expected to be informed by the forthcoming legal process before the D.C. Circuit. The EPA plans to consu lt with permi tting authorities to determine the most efficient and least burdensome ways to accomplish any such revisions to state or tri bal programs. GHG 5-Year Studv In the Tailoring Rule, the EPA described next steps to include a study by April 201 5, referred to as the ''5-year study,'' and a possible further regulatory action, referred to as "Step 4." OAR bel ieves the resul ts of the Supreme Court decision eliminate the need for the 5-year study. Thus, at this time, OAR is no longer working on the study, and we intend to inform states collecting data requested by the EPA for 2 The EPA is st ill eva l uating the im pl ications of the Supreme Court's decision, i f any. on GHG Plantwide Appl icability Limitations wh ich were finalized under Step 3 of the Tailoring Ru le. that study that this data collection is no longer necessary. In addition. the EPA does not intend to take

324 Technical Support Document Attachment 2 Page 11 further action on Step 4. The EPA is) however, continuing to evaluate GHG permitti ng data as appropriate with regard to the possible development and justification of an appropriate GHG significance (or ' de minimis") level for determining the application of PSD BACT requi remen ts to GHG in permitting of "anyway sources.'' We expect that the information that states have submitted for the 5- year study will be use ful in that effort. Assessment of Biogenic Carbon Dioxide CC02) Emissions The Supreme Court's decision did not directly address the application of PSD and ti tle V permitt ing requirements to biogenic C02 emissions. On July 12, 2013, the D.C. Circuit issued a decision (the Deferral decision) overturning the EPA regulation that deferred application of these permitting programs to biogenic C02 emissions (the Deferral Rule). Centerfor Biological Diversity v. EPA, 722 F.3d 421 (D.C. Cir. 2013). However, the Deferral decision has not yet taken effect because some paities have been waiting for the Supreme Court decision to determi ne whether to ask the D.C. Circuit to reconsider i ts ru ling on the Deferral Rule. Furthermore, court actions against the Tai loring Rule remai n pend ing by parties that contend that the Tailoring Ruic caused PSD and title V programs to apply to biogcnic greenhouse gas emissions. Notwi thstandi ng these matters sti ll pending in the courts, the Deferral Rule itself expired on its own terms on July 21, The EPA s work regardi ng the biogenic C0 2 assessment framework remai ns ongoing and is not directly impacted by the Supreme Court's decision. Nonetheless, the EPA's current view is that the Supreme Court's decision effecti vely narrows the scope of the biogenic C02 permitting issues that remain for the EPA to address. This is because, as described above, the EPA will no longer apply or enforce regulatory provisions requiri ng PSD or ti tle V permits for sources solely on the basis of their GHG emissions. Continuing our cujtent approach, OAR recommends that Regional Offices consult with sources and permitting authorities on biomass related permitting questions as they arise. Conclusion We trust this information will be helpful as the EPA pursues next steps and await further developments before the U.S. Courts. Should you have questions generall y concerning this memorandu m, plea.se contact J uan Santiago, Associate Division Director of the Air Qua lity Policy Div ision, Office of Air Quality Planning and Standards at santiago.juan@epa.gov or Should you have questions generally concerning the enforcement specific aspects of this memorandum, please contact Apple Chapman, Associate Division Director, Air Enforcement Division, Office of Civii Enforcement at chapman.apple@epa.gov or

325 Response #1 Technical Support Document Attachment 2 Page 12 Jessica A. Karras Bailey RTP Environmental Associates, Inc. 400 Post Avenue, Suite 405 Westbury, NY RE: Comments on the DRAFT Part 70 Manufacturing General Air Emission Permit Dear Ms. Karras Bailey: The Minnesota Pollution Control Agency (MPCA) received your comments during the 2014 public notice period on the Part 70 Manufacturing General Permit. This letter is in response to your comments. RTP expressed concern that the restriction on Greenhouse Gas (GHG) emissions to 90,000 tons per year (tpy) may impose unnecessarily stringent requirements on the permittee(s), and requested removal of this limit. The reason provided for why this limit may be unnecessarily stringent was that the June 23, 2014, U.S. Supreme Court ruling and the subsequent July 24, 2014, EPA memorandum indicated that the EPA may not use GHG emissions to determine whether a source is a major source for Prevention of Significant Deterioration (PSD) and that the EPA will no longer require PSD or Title V permits for Step 2 sources. The MPCA agrees that avoiding classification as a major source under PSD is no longer a reason to include the 90,000 tpy restriction on GHG. However, avoiding PSD was not the only reason this limit was included in the permit. The public noticed permit also cited To qualify for this general permit under Minn. R as basis for this restriction. A review of the facilities currently holding the previous version of this general permit showed that expected GHG emissions for these facilities is well below the 90,000 tpy limit. Since the facilities for which this general permit was designed should have no trouble meeting this limit, the limit will be retained in the final permit. Per the court decision and EPA memorandum, the Title I Condition: To avoid classification as a major source under and Minn. R citation has been removed from the GHG emission limit and associated recordkeeping requirement. Portions of the Technical Support Document (TSD) that discuss PSD applicability and/or justification for the pollutant emission limits have been updated to demonstrate the appropriate reasoning for this limit. Thank you for taking the time to comment on the DRAFT Part 70 Manufacturing General Air Emission Permit. Your comments are an important part of the public participation process for issuing Part 70 air permits, and helped us to correct an inaccurate citation. Sincerely, Kira Gillette Air Permit Engineer Minnesota Pollution Control Agency 520 Lafayette Road St. Paul, MN Our mission is to protect and improve the environment and enhance human health. Join us!

326 Comment #2 Technical Support Document Attachment 2 Page 13 From: Pavelko, Brent M. [mailto:brent.pavelko@agcocorp.com] Sent: Wednesday, September 03, :38 PM To: Gillette, Kira (MPCA) Subject: DRFT Part 70 Manuf Gen Air Emission Permit - Public Comment As you know, the public comment period ends today on the MPCA Draft Part 70 Manufacturing General Air Emission Permit. Please see attached comment letter. Thank you for the opportunity to provide comments. Regards Brent Pavelko Environmental, Health and Safety Manager AGCO Corporation Tel: Fax: Cell: Industrial Park Jackson, MN brent.pavelko@agcocorp.com blog.agcocorp.com facebook.com/agcocorp twitter.com/agcocorp youtube.com/agcocorp AGCO CORPORATION Jackson Operations 202 Industrial Park Jackson, MN USA AGCO

327 VIA ELECTRONIC MAIL Technical Support Document Attachment 2 Page 14 September 3, 2014 Ms. Kira Gillette Air Permit Engineer Air Quality Permits Section, Industrial Division Minnesota Pollution Control Agency 520 Lafayette Rd. St. Paul, Minnesota Re: DRAFT Part 70 Manufacturing General Air Emission Permit Dear Ms. Gillette: As you know, the public comment period ends today on the MPCA Draft Part 70 Manufacturing General Air Emission Permit. AGCO Corporation owns and operates one of our manufacturing facilities in Jackson, Minnesota. The AGCO-Jackson facility has been covered by the Manufacturing General Permit and expects to request authorization again. Therefore, we have reviewed the Draft permit and have one comment for your consideration related to the Greenhouse Gas (GHG) emissions limit of 90,000 tons per year (tpy). It is our understanding that with the US Supreme Court decision in June 2014, the EPA was criticized for exceeding their statutory authority with regard to the promulgation of the "Tailoring Rule". In essence, the Court determined that EPA may not consider GHG emissions alone with regard to PSD and Title V requirements. Since the Draft Title V permit clearly includes limit to maintain sources at levels below major source levels with regard to PSD, we believe that the GHG conditions in the Draft permit should be removed as they are no longer appropriate in light of the Court's decision. Thank you for the opp01iunity to provide comments. Sincerely, AGCO Corporation Jackson Operations Brent M. Pavel 1 ;co --- Environmental Health and Safety Manager CHALLENGER FENDT" MASSEY FERGUSON VALTRA

328 Response #2 Technical Support Document Attachment 2 Page 15 Brent M. Pavelko AGCO Corporation 202 Industrial Park Jackson, MN RE: DRAFT Part 70 Manufacturing General Air Emission Permit Public Comment Dear Mr. Pavelko: The Minnesota Pollution Control Agency (MPCA) received your comments during the 2014 public notice period on the Part 70 Manufacturing General Permit. This letter is in response to your comments. AGCO requested that the restriction on Greenhouse Gas (GHG) emissions to 90,000 tons per year (tpy) be removed. The reason provided for why this limit should be removed was that the June 23, 2014, U.S. Supreme Court ruling indicated that the EPA may not use GHG emissions to determine whether a source is a major source for Prevention of Significant Deterioration (PSD). The MPCA agrees that avoiding classification as a major source under PSD is no longer a reason to include the 90,000 tpy restriction on GHG. However, avoiding PSD was not the only reason this limit was included in the permit. The public noticed permit also cited To qualify for this general permit under Minn. R as basis for this restriction. A review of the facilities currently holding the previous version of this general permit showed that expected GHG emissions for these facilities is well below the 90,000 tpy limit. Since the facilities for which this general permit was designed should have no trouble meeting this limit, the limit will be retained in the final permit. Per the court decision, the Title I Condition: To avoid classification as a major source under 40 CFR Section and Minn. R citation has been removed from the GHG emission limit and associated recordkeeping requirement. Portions of the Technical Support Document (TSD) that discuss PSD applicability and/or justification for the pollutant emission limits have been updated to demonstrate the appropriate reasoning for this limit. Thank you for taking the time to comment on the DRAFT Part 70 Manufacturing General Air Emission Permit. Your comments are an important part of the public participation process for issuing Part 70 air permits, and helped us to correct an inaccurate citation. Sincerely, Kira Gillette Air Permit Engineer Minnesota Pollution Control Agency 520 Lafayette Road St. Paul, MN Our mission is to protect and improve the environment and enhance human health. Join us!

329 Technical Support Document Attachment 2 Page 16 Comment #3 From: Sneha Raghavan [mailto:snehar@industrialprotectioncorp.com] Sent: Wednesday, September 03, :58 PM To: Gillette, Kira (MPCA) Subject: Public Comment on Part 70 General Permit Hello Kira, Thank you for the opportunity to comment on the proposed Part 70 General Permit. Find attached copy of my comment for your perusal. Regards,

330 Industrial Protection Corporation 5605 W. 36 th Street, Suite 204 St. Louis Park, MN To Kira Gillette Air Permit Engineer Air Quality Permits Section, Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North, St. Paul, Minnesota RE: Public Comment Part 70 Manufacturing General Permit. Dear Kira Gillette, My name is Sneha Raghavan and I am submitting this comment on behalf of small scale fiberglass boat manufacturing facilities. Thank you for spearheading the Part 70 Manufacturing General Permit option. It is a great cost effective option for many small scale facilities with general fiberglass stationary sources whose Potential-to- Emit is below the thresholds listed in the permit. This comment focuses specifically on the eligibility criteria for part 70 manufacturing general permit. The concern is as follows: It is observed that 40 CFR pt. 63 NESHAP VVVV is excluded from the list of NESHAP included in the general permit (i.e. 40 CFR pt. 63 NESHAP MMMM, PPPP, WWWW, ZZZZ, and DDDDDD). Many fiberglass manufacturing industries are also involved in operations such as building molds to make fiberglass hulls or decks, manufacturing hulls or decks of boats from fiberglass. These operations meet the definition of boat manufacturer provided in NESHAP VVVV. This will disqualify them from the NESHAP eligibility criteria of the Part 70 general permit even though they meet the Potential-to-emit thresholds. Small scale fiberglass manufacturing facilities who also manufacture fiberglass boat molds will be forced to obtain the Federal Individual Part 70 Permit which is an expensive affair. These facilities are extremely small and often use one booth for both boat mold manufacturing and fiberglass product manufacturing.

331 Industrial Protection Corporation 5605 W. 36 th Street, Suite 204 St. Louis Park, MN As an environmental consultant in Minnesota, I feel it is beneficial to such facilities if the NESHAP VVVV is included in the eligibility list. Thank you again for the opportunity to comment on this proposed permit option. Sincerely, Sneha Raghavan EHS Compliance Specialist Industrial Protection Corporation