AIR EMISSION PERMIT NO IS ISSUED TO. SUNRISE FIBERGLASS CORPORATION th St Wyoming, Chisago County, MN 55092

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1 AIR EMISSION PERMIT NO IS ISSUED TO SUNRISE FIBERGLASS CORPORATION th St Wyoming, Chisago County, MN The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type: Part 70 Application Date: February 11, 2000 This permit authorizes the permittee to operate and construct the stationary source at the address listed above unless otherwise noted in Table A. 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 as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: Federal; Part 70 Issue Date: April 14, 2000 Expiration Date: April 14, 2005 Richard J. Sandberg, Manager Major Facilities Section Metro District For Karen A. Studders, Commissioner 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 No Page 2 TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals

3 Permit No Page 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 (651) Outside Metro Area TTY (651) 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 the specific provision of the applicable requirement identified in the permit as the basis of each condition. Certain requirements which have been determined not to apply are listed in Table A of this permit. FACILITY DESCRIPTION: The Permittee, Sunrise Fiberglass Corporation, operates an existing fiberglass manufacturing facility consisting of one gelcoat booth, one paint booth, and six fiberglass layup stations. This permit authorizes relocation, expansion, and operation of the existing operation. The new facility to which this permit applies will be configured identically to the existing facility, except that four new fiberglass lay-up stations will be added, bringing the total to ten stations.

4 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/14/00 Facility Name: Sunrise Fiberglass Corp Permit Number: Table A contains limits and other requirements with which your facility must comply. The 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 (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C. Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as specified by Minn. R following formal review of a subsequent performance test on the same unit. Monitoring Equipment: 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: Annually calibrate all required monitoring equipment (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. Circumvention: Do 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. Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to 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. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Breakdown Notifications: 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 any 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. Why to do it Minn. R , subp. 14 and Minn. R , subp. 16(J) Minn. R. ch Minn. R Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R Minn. R , subp. 3 Minn. R , subp. 2 At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation 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. 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. Minn. R , subp. 1 Minn. R , subp. 4 A-1

5 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/14/00 Facility Name: Sunrise Fiberglass Corp Permit Number: Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Fugitive Emissions: Do 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. Comply with all other requirements listed in Minn. R Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R subp. 2), including records of the emissions resulting from those changes. Record keeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). 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 enforceable by the EPA Administrator or citizens under the Clean Air Act. The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. Inspections: Upon presentation of credentials and other documents as may be required by law, allow the Agency, or its representative, 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 facilities, equipment, practices or operations, and to sample or monitor any substances or parameters at any location. Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R Minn. R through Minn. R Minn. R , subp. 1(H) Minn. R , subp. 5(B) Minn. R , subp. 5(C) Minn. R Minn. R , subp. 16 Minn. R , subp. 9(A) Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R through Minn. R Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot for exhaust gases unless required to further reduce emissions to comply with the less stringent of Minn. R or Minn. R Opacity: less than or equal to 20 percent. Volatile Organic Compounds: less than or equal to 60.0 tons/year using 12-month Rolling Sum calculation basis. Mass of VOC emitted shall be determined using Equation 1. Equation 1: VOC = [(Prs)(EFrs) + (Pgc)(EFgc) + (Pps)(Cps) + (Pm)(Cm)] x Minn. R , subp. 1(A) Minn. R , subp. 1(B) permit action under 40 CFR Section 52.21; Minn. R , subp. 4(C); permit action under 40 CFR Section 52.21; Minn. R , subp. 4(C); where: VOC is total facility VOC emissions in tons; Prs is the pounds of resin purchased; EFrs is the Unified Emission Factor (UEF) release rate for resin; Pgc is the pounds of gel coat purchased; EFgc is the Unified Emission Factor (UEF) release rate for gel coat; Pps is the pounds of paint purchased; Cps is the VOC percent composition of paint; Pm is the pounds of other VOC-containing materials purchased; Cm is the VOC percent composition of other VOC-containing materials; and is a conversion factor to convert pounds to tons Volatile Organic Compounds (VOC) Record Keeping By the 15th of each month, the Permittee shall: 1) Record the total mass of each VOC-containing material from purchase records in the previous month and the VOC content of of each material as determined by the Material Content requirement in this permit. 2) Calculate the VOC emissions for the previous month. 3) Calcluate the VOC emissions for the previous 12 months (12-month Rollling Sum). Title I Condition: Record Keeping to avoid classification as a major permit action under 40 CFR Section 52.21; Minn. R , subp. 4(C); 40 CFR Section 63.43(g) A-2

6 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/14/00 Facility Name: Sunrise Fiberglass Corp Permit Number: Total Particulate Matter: less than or equal to 95.0 tons/year using 12-month Rolling Sum calculation basis. Mass of Total Particulate Matter emitted shall be determined using Equation 2 and shall take into account a filter efficiency of 92 percent. Equation 2: PM = [(Prs)(Crs)(1 - TErs) + (Pgc)(Cgc)(1 - TEgc) + (Pps)(Cps)(TEps)] x (1 - CO) x (1 - CA) x Title I Condition: Limit to avoid classification as a major permit action under 40 CFR Section 52.21; Minn. R , subp. 4(C) permit action under 40 CFR Section 52.21; Minn. R , subp. 4(C) where: PM is total facility PM emissions in tons; Prs is the pounds of resin purchased; Crs is the PM percent composition of resin; TErs is the resin transfer efficiency, 75% Pgc is the pounds of gel coat purchased; Cgc is the PM percent composition of gel coat; TEgc is the gel coat transfer efficiency, 75% Pps is the pounds of paint purchased; Cps is the PM percent composition of paint; TEps is the paint spray transfer efficiency, 75%; CO is the required control efficiency, 92%; CA is the capture efficiency, 74%; and is a conversion factor to convert pounds to tons Particulate Matter < 10 micron: less than or equal to 95.0 tons/year using 12-month Rolling Sum calculation basis. Mass of Particulate Matter < 10 micron emitted shall be determined using Equation 3 and shall take into account a filter efficiency of 92 percent. Equation 3: PM10 = [(Prs)(Crs)(1 - TErs) + (Pgc)(Cgc)(1 - TEgc) + (Pps)(Cps)(TEps)] x (1 - CO) x (1 - CA) x where: PM is total facility PM10 emissions in tons; Prs is the pounds of resin purchased; Crs is the PM10 percent composition of resin; TErs is the resin transfer efficiency, 75% Pgc is the pounds of gel coat purchased; Cgc is the PM10 percent composition of gel coat; TEgc is the gel coat transfer efficiency, 75% Pps is the pounds of paint purchased; Cps is the PM10 percent composition of paint; TEps is the paint spray transfer efficiency, 75%; CO is the required control efficiency, 92%; CA is the capture efficiency, 74%; and is a conversion factor to convert pounds to tons Total Particulate Matter and Particulate Matter < 10 micron Record Keeping By the 15th of each month, the Permittee shall: 1) Record the total mass of each solids containing material from purchase records in the previous month and the solid content of of each material as determined by the Material Content requirement in this permit. 2) Calculate the PM/PM10 emissions for the previous month. 3) Calcluate the PM/PM10 emissions for the previous 12 months (12-month Rollling Sum). Material Content: VOC and Solids (PM and PM<10 microns) contents shall be determined by the Material Safety Data Sheet (MSDS) provided by the supplier for each material used. If a material content range is given on the MSDS, the highest number in the range shall be used in all compliance calculations. When using the MSDS as the basis of calculating particulate emissions, the conservative assumption is made that PM consists entirely of PM less than 10 microns. Other alternative methods approved by the MPCA may be used to determine the VOC and solids contents. The Division Manager reserves the right to require the Permittee to determine the VOC and solids contents of any material, according to EPA reference methods. If an EPA reference method is used for material content determination, the data obtained shall supersede the MSDS. Styrene: less than or equal to 40.0 tons/year using 12-month Rolling Sum. Mass of styrene emissions shall be determined based on the total amount of styrene-containing materials purchased multiplied by the most recent Unified Emission Factor (UEF) data from the Composite Fabricator's Association (CFA). permit action under 40 CFR Section 52.21; Minn. R , subp. 4(C) permit action under 40 CFR Section 52.21; Minn. R , subp. 4(C) Title I Condition: Record Keeping to avoid classification as a major permit action under 40 CFR Section 52.21; Minn. R , subp. 4(C) Title I Condition: Limit to avoid classification as major permit action under 40 CFR Section A-3

7 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/14/00 Facility Name: Sunrise Fiberglass Corp Permit Number: Styrene Record Keeping By the 15th of each month, the Permittee shall: 1) Record the total mass of styrene-containing material from purchase records in the previous month. 2) Calculate the styrene emissions for the previous month. 3) Calcluate the styrene emissions for the previous 12 months (12-month Rollling Sum). HAPs - Total: less than or equal to 50.0 tons/year using 12-month Rolling Sum. Mass of total HAPs emitted shall be determined using Equation 4, with the exception of dimethylphthalate, which shall be determined using the calculations described in "Emission Factors for Liquid Organic Peroxide Catalysts used in the Open Molding of Composites" (R.A. Haberlain, 1999). HAP composition shall be determined from Material Safety Data Sheets (MSDS) for each HAP-containing material purchased. Equation 4: HAP = [(Prs)(Crs) + (Pgc)(Cgc) + (Pps)(Cps) + (Pm)(Cm)] x where: HAP is total facility HAP emissions in tons; Prs is the pounds of resin purchased; Crs is the HAP percent composition of resin; Pgc is the pounds of gel coat purchased; Cgc is the HAP percent composition of gel coat; Pps is the pounds of paint purchased; Cps is the HAP percent composition of paint; Pm is the pounds of other HAP-containing materials purchased; Cm is the HAP percent composition of other HAP-containing materials; and is a conversion factor to convert pounds to tons Unified Emission Factor release rates shall be used in place of HAP percent composition for styrene (Crs and Cgc) and methyl methacrylate (Cgc). HAPs - Total: less than or equal to 90 lbs/ton of unfilled polyester resin purchased on a monthly average basis. This limit shall be achieved through the use of non-atomized spray equipment and low-styrene resins for EU 001 through EU 010 and high-volume/low pressure (HVLP) guns or equivalent for EU 011 and EU 012. HAP Record Keeping By the 15th of each month, the Permittee shall: 1) Record the total mass of HAP-containing material from purchase records in the previous month. 2) Calculate the total HAP emissions for the previous month. 3) Calcluate the total HAP emissions for the previous 12 months (12-month Rollling Sum). 4.) Calculate the monthly mass of HAP emitted per ton of unfilled polyester resin purchased. The Permittee shall provide training for employees on a minimum biannual basis regarding techniques associated with gel coating and composite spray lay-up applications. Records of each training event shall be maintained. The Permittee may be allowed to use alternative styrene and/or total HAP emission reduction techniques, provided that prior written approval is obtained from the Division Manager. The Permittee shall cover or close all hazardous material containers, open troughs, basins, and tanks at all times when they are not in use. The Permittee shall allow all composite products to cure for a minimum of three hours prior to transferring outside the manufacturing building. The permittee shall apply for a new Title V air emission permit within twelve months from the time that a National Emission Standard for Hazardous Air Pollutants (NESHAP) for the Reinforced Plastics Composites and Boat Manufacturing industry is promulgated under Sections 112(d), 112(h), or 112(j) of the Clean Air Act, provided that the controls in this permit are deemed less stringent that the Maximum Achievable Control Technology (MACT) specified in the promulgated NESHAP. A-4

8 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/14/00 Facility Name: Sunrise Fiberglass Corp Permit Number: Subject Item: Associated Items: GP 001 Control Equipment CE 001 Mat or Panel Filter CE 002 Mat or Panel Filter CE 003 Mat or Panel Filter CE 004 Mat or Panel Filter CE 005 Mat or Panel Filter CE 006 Mat or Panel Filter What to do Operate and maintain control equipment to achieve a control efficiency for PM/PM10: greater than or equal to 92 percent. HEPA and other wall filters in GP 001 listed as CE 001, CE 002, CE 004, CE 005 must meet the total enclosure definition contained in Minn R , subp. 5. HEPA and other wall filters in GP 001 listed as CE 003 and CE 006 must maintain a capture efficiency of 80 percent. Control Equipment Monitoring: The Permittee shall monitor the condition of all HEPA and other wall filters, including, at a minimum, the alignment, saturation, and occurence of tears and holes at least once during each 24 hour period while in operation. Any other indicators of performance shall also be monitored. Control Equipment Record Keeping: The Permittee shall record the condition of all HEPA and other wall filters once each 24 hour period if in operation. Control Equipment Maintenance: The Permittee shall: 1) maintain an inventory of spare parts that are subject to frequent replacement, 2) train staff on the operation and maintenance of all control equipment, 3) train and require staff to respond to indicators of malfunctioning equipment, 4) replace torn or plugged filters immediately, and 5) maintain a record of parts replaced, repaired, or modified. Why to do it Title I Condition: Limit to avoid classification as a major permit action under 40 CFR Section 52.21; Minn. R , subp. 1 permit action under 40 CFR Section 52.21, Minn. R , subp. 1 permit action under 40 CFR Section 52.21, Minn. R , subp. 2, 4, & 14 permit action under 40 CFR Section 52.21, Minn. R , subp 2, 5, & 14 Minn. R , subp 2, 5, & 14 A-5

9 TABLE B: SUBMITTALS Facility Name: Sunrise Fiberglass Corp Permit Number: /14/00 Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements. Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts to must be certified by a responsible official, defined in Minn. R , subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. Send any application for a permit or permit amendment to: Permit Technical Advisor Permit Section Air Quality Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term. Unless another person is identified in the applicable Table, send all other submittals to: Supervisor Compliance Determination Unit Air Quality Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Send submittals that are required to be submitted to the U.S. EPA regional office to: Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Send submittals that are required by the Acid Rain Program to: U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C B-1

10 TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: Sunrise Fiberglass Corp 04/14/00 Permit Number: What to send When to send Portion of Facility Affected Application for Permit Reissuance due 180 days before expiration of Existing Total Facility Permit Notification of the Actual Date of Initial Startup due 15 days after Initial Startup Total Facility B-2

11 TABLE B: RECURRENT SUBMITTALS Facility Name: Sunrise Fiberglass Corp 04/14/00 Permit Number: What to send When to send Portion of Facility Affected Semiannual Deviations Report due 30 days after end of each calendar Total Facility half-year following Initial Startup. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations occur, the Permittee shall submit the report stating no deviations. Compliance Certification due 31 days after end of each calendar year Total Facility following Initial Startup (for the previous calendar year). To be submitted on a form approved by the Commissioner <, both to the Commissioner, and to the U.S. EPA regional office in Chicago>. This report covers all deviations experienced during the calendar year. < The EPA copy shall be sent to: Mr. George Czerniak, Chief, Air Enforcement and Compliance Assurance Branch, Air and Radiation Division, EPA Region V, 77 West Jackson Boulevard, Chicago, Illinois 60604> Emissions Inventory Report due 91 days after end of each calendar year following Permit Issuance (April 1). To be submitted on a form approved by the Commissioner. Total Facility B-3

12 TECHNICAL SUPPORT DOCUMENT for DRAFT AIR EMISSION PERMIT This technical support document is for all the interested parties of the draft permit. The purpose of this document is to set forth the legal and factual basis for the draft permit conditions, including references to the applicable statutory or regulatory provisions. 1. General Information 1.1. Applicant and Stationary Source Location: Owner/Operator Address Sunrise Fiberglass Corporation th Street Wyoming, Minnesota Facility Address and Telephone Number (SIC Code: 3089) Sunrise Fiberglass Corporation th Street Wyoming, Minnesota (651) Description of the Facility The Permittee, Sunrise Fiberglass Corporation (Sunrise Fiberglass) operates an existing fiberglass manufacturing facility consisting of one gelcoat booth, one paint booth, and six fiberglass layup stations. The new facility to which this permit applies will be configured identically to the existing facility, except that four new fiberglass lay-up stations will be added, bringing the total to ten stations Description of Activities Allowed by this Permit Action Sunrise Fiberglass has requested an air emission permit for construction and operation of a new fiberglass manufacturing facility. Equipment from an existing facility will be moved to the new location, and four fiberglass lay-up stations will be added to the existing inventory of equipment. Particulate emissions from all of the emission units at the facility will be controlled by wall filters. The facility will be covered by emission limits of 95.0 tons per year for both total particulate matter (PM) and particulate matter < 10 microns (PM10). Volatile organic compound (VOC) emissions will be limited to 60.0 tons per year. Styrene and Total Hazardous Air Pollutants (Total HAPs) emissions will be limited to 40.0 and 50.0 tons per year, respectively. Compliance with these emission limits will be determined on a 12-month rolling sum basis.

13 Pollutant 1.4. Facility Emissions: Potential to emit from the modification Table 1. Emissions Associated with the Modification Potential to emit from the modification *Emission increases authorized with this permit action (TPY) *Emission decreases authorized with this permit action (TPY) *Other contemporaneous emission increases/ decreases (TPY) Net emission change NSR/ 112(g) threshold level (lb/hr) (TPY) (TPY) (TPY) PM NA NA NA NA 25 No PM NA NA NA NA 15 No SO2 NA NA NA NA NA NA 40 No NOx NA NA NA NA NA NA 40 No VOC NA NA NA NA 40 No CO NA NA NA NA NA NA 100 No Lead NA NA NA NA NA NA 0.6 No NSR/ MACT review required (Yes or No) **Total NA NA NA NA NA Yes HAPs *Emission increases allowed with the permit action include additions and subtractions associated with netting. If netting is done, this will be different from the potential to emit from the modification. **Potential emissions for each specific Hazardous Air Pollutant (HAP) are shown in the permit application on form GI-07 **Other emission changes during the contemporaneous period as defined by 40 CFR 52.21, 40 CFR or 40 CFR 51 EU # SV # Emission Unit Description 001 through through 010 Table 2. Uncontrolled/Unlimited Potential to Emit Summary Fiberglass Layup Stations PM PM-10 SO2 NOx CO VOC Pb Total HAP NA NA NA NA Gel Coat Booth NA NA NA 95.7 NA Paint Booth NA NA NA NA Preparation, Mixing, NA NA NA NA NA 6.13 NA 0.9 Gluing, and Cleaning Station Total Facility Actual Emissions* NA NA NA NA * Total Facility Actual Emissions as indicated are from 1997 MPCA emissions inventory database. 2

14 Table 3. Permit Action Classification Classification Major/Affected Source *Synthetic Minor *Minor PSD X NAAR Part 70 Permit Program X * Refers to potential emissions that are less than those specified as major by 40 CFR 52.21, 40 CFR pt. 51 Appendix S, and 40 CFR pt Regulatory and/or Statutory Basis of Emission Limits Table 4. Regulatory Overview* Emission Unit Total Facility Applicable Regulations Part 70 of the Clean Air Act Comments The proposed new facility is subject to the general requirements in the Delta help file for Part 70 major facilities Total Facility 40 CFR Section The proposed new facility will be subject to emission limits of 95.0 tons per year of PM and PM10 to avoid classification as a major permit action under the Prevention of Significant Deterioration (PSD) portion of New Source Review (NSR) Total Facility Because the uncontrolled/unlimited HAP emissions are above major source thresholds, the facility is subject to 112(g) preconstruction review and a case-by-case Maximum Achievable Control Technology (MACT) determination. Many of the permit requirements are a result of the MACT determination. GP 001 Minn. R , Minn. R The PM/PM10 control devices (wall filters) are subject to monitoring and record keeping requirements, and must maintain a minimum control efficiency of 92 percent. * Please refer to the permit for a complete citation of regulatory requirements. 3. Technical Information Potential emissions of VOC, PM, PM10, individual HAPs, and total HAPs were calculated based on worst case composition of raw materials. Concentration of each pollutant in the liquid raw materials was multiplied by density and maximum usage rate to determine annual and hourly potential emissions. Unified Emission Factors for Open Molding of Composites (Composites Fabricators Association) were used to calculate styrene and methyl methacrylate potential emissions. Because individual HAP and total HAP potential emissions are above major source thresholds (10 and 25 tons per year, respectively), the facility is subject to 112(g) preconstruction review and a case-by-case MACT determination. 3

15 The Permittee submitted a MACT proposal as part of the air emission permit application. The MACT proposal summarizes previous MACT determinations made for similar manufacturing facilities in three other states (Indiana, Florida, and Texas). The progression of MACT for this industry was tracked relative to time, and the latest, most stringent controls were proposed and approved by the Minnesota Pollution Control Agency for the Sunrise Fiberglass facility. MPCA s approval of the proposed MACT standards for Sunrise Fiberglass is inherent in the public noticing of the draft air emissions permit. In addition, an economic analysis of various control technologies using CO$T-AIR cost estimating software was presented. In summary, the proposed MACT requirements approved by MPCA for the Sunrise Fiberglass facility are as follows: 1. Emission limit of 40.0 tons per year and record keeping for styrene; 2. Emission limit of 50.0 tons per year and record keeping for total HAPs; 3. Use of non-atomized spray equipment, low-styrene resins, and high volume/low pressure (HVLP) guns to achieve a maximum usage rate of 90 pounds per ton of unfilled polyester resin purchased; 4. Biannual employee training and recordkeeping requirements; 5. Requirements to cover all hazardous material containers, troughs, basins, and tanks when not in use; and 6. Requirements to allow all composite products to cure for a minimum of three hours prior to moving outside the manufacturing area. These limits and other requirements have been determined to be at least as stringent as the most recently approved case-by-case MACT determination made for a similar facility nationwide. In order of MACT determination approval date, the other facilities considered in this case-by-case MACT determination were Monaco Coach Corporation (Indiana Permit Number CP ), Leisure Bay Manufacturing (Florida Permit Number AV), and Hydro- Action, Inc. (Texas Permit Number 39565). Example calculations and supporting information for the Sunrise Fiberglass MACT determination and other general components of the air emission permit can be found in the permit application and follow-up correspondence attached to this Technical Support Document. 4. Conclusion Based on information provided by Sunrise Fiberglass Corporation, MPCA has reasonable assurance that the proposed operation of the emission facility, as described in Air Emission Permit No and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota rules. Staff Members on Permit Team: Mary Jean Fenske Rhonda Land Jim Robin 4