Air Individual Permit State Permit

Transcription

1 Air Individual Permit State Permit Permittee: Facility name: FLEXcon Co Inc FLEXcon Co Inc 7165 Commerce Cir W Fridley, MN Anoka County Expiration date: Non-expiring State Permit Issuance date: December 27, 2018 Permit characteristics: State; Nonmajor for Part 70/True minor for NSR The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the submittals listed in the Permit Applications Table. This permit supersedes Air Emission Permit No and authorizes the Permittee to operate 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 are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Signature: for Carolina Espejel-Schutt This document has been electronically signed. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for the Minnesota Pollution Control Agency

2 Table of Contents 1. Permit applications table Where to send submittals Facility description Summary of subject items Limits and other requirements Submittal/action requirements Appendices Appendix A. Insignificant Activities and General Applicable Requirements Appendix B. Maximum Content of Materials and Process Rate of EQUI Page

3 Permit issued: December 27, Permit expires: Non-expiring permit Page 3 of Permit applications table Title description Application receipt date Action number State Permit 06/21/

4 Permit issued: December 27, Permit expires: Non-expiring permit Page 4 of Where to send submittals Send submittals that are required to be submitted to the EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by Minn. R 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 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 Send any application for a permit or permit amendment to: Fiscal Services 6 th Floor 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 Document Coordinator notices of: a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term Unless another person is identified in the applicable Table, send all other submittals to: AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Or a signed and scanned PDF copy to: submitstacktest.pca@state.mn.us (for submittals related to stack testing) AQRoutineReport.PCA@state.mn.us (for other compliance submittals) (See complete instructions in Routine Air Report Instructions Letter at

5 Permit issued: December 27, Permit expires: Non-expiring permit Page 5 of Facility description The FLEXcon Co Inc (Facility) is located at 7165 Commerce Circle West in Fridley, Anoka County, Minnesota. FLEXcon Company, Inc. manufactures pressure sensitive films. A coater/laminator is used to apply adhesives to a film stock followed by a drying oven. The facility also contains insignificant activities as allowed under Minn. R The main emissions are Volatile Organic Compounds (VOC) and Hazardous Air Pollutants (HAP) from the coater.

6 Permit issued: December 27, Permit expires: Non-expiring permit Page 6 of Summary of subject items SI ID: Description Relationshi p Type Related SI ID: Description TFAC 1: FLEXcon Co Inc ACTV 3: All IAs COMG 1: Coating Line has EQUI 1, EQUI 2 (oven and coater) members EQUI 1: Drying Oven sends to STRU 2: Drying oven EQUI 2: Coater/ Laminator sends to STRU 3: Coater/Lamina SI ID: Description STRU 1: FLEXcon is part of a larger building (rent space) STRU 2: Drying oven STRU 3: Coater/Laminator Relationshi p Type Related SI ID: Description tor

7 Permit Issued: December 27, Permit Expires: Non-expiring permit Page 7 of Limits and other requirements Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation TFAC FLEXcon Co Inc Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendices A & B. [Minn. R , subp. 2] 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. 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. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R (A)(2)] 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. [Minn. R ] Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R , subp. 16(J), Minn. R , subp. 2] Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance 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. [Minn. R , subp. 14, Minn. R , subp. 16(J)] 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.

8 Permit Issued: December 27, Permit Expires: Non-expiring permit Page 8 of 13 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation [Minn. R , subp. 4] 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 [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 enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R ] Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). [Minn. R , subp. 9(A)] The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. [Minn. R , subp. 16] Monitoring Equipment Calibration - The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration 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. [Minn. R , subp. 4(D)] Operation of Monitoring Equipment: Unless noted elsewhere in this permit, 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. [Minn. R , subp. 4(D)] Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, 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). [Minn. R , subp. 5(C)] 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. [Minn. R , subp. 5(B)]

9 Permit Issued: December 27, Permit Expires: Non-expiring permit Page 9 of 13 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R These records shall be kept for a period of five years from the date that the change was made. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. [Minn. R , subp. 4] 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. [Minn. R , subp. 3] 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. 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. [Minn. R , subp. 2] Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R , subp. 1] 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;

10 Permit Issued: December 27, Permit Expires: Non-expiring permit Page 10 of 13 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation 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. [Minn. R , subp. 1] 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. Upon adoption of a new or amended federal applicable requirement, and if there are 3 or more years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R , subp. 3. [Minn. R , subp. 3, Minn. R ] 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). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R , subp. 1(H). [Minn. R , subp. 1(H)] Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. Submit in a format specified by the Commissioner. [Minn. R ] Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R ] COMG 1 GP001 Coating Line (oven and coater) This Coating Line is an affected facility (per 40 CFR Section ) which has taken limits to avoid the emissions limits in 40 CFR Section (a). If the VOC input exceeds the limit in any 12- month period, the coating line is then subject to additional requirements in 40 CFR pt. 60, subp. RR, and the Permittee must obtain the appropriate permit amendment to add these requirements to the permit. [40 CFR (b), Minn. R ] The Permittee shall limit Volatile Organic Compounds <= 49.5 tons per year 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. This limit is on all solvent applied in the coating. This means all organic solvent contained in the adhesive, release, and precoat formulations that are metered into the coating applicator from the formulation area. The Total Facility Potential to Emit based on coating contents/fuels used is 3.8 tons per year for VOC. [40 CFR (b), Minn. R ]

11 Permit Issued: December 27, Permit Expires: Non-expiring permit Page 11 of 13 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Maximum Contents of Materials: The Permittee assumed certain worst-case contents of materials when determining the short-term potential to emit of EQUI 2. These assumptions are listed in Appendix B of this permit. Changing to a material that has a higher content of any of the given pollutants is considered a change in method of operation that must be evaluated under Minn. R , subp. 3 to determine if a permit amendment or notification is required under Minn. R [Minn. R , subp. 35a] Daily Recordkeeping: On each day of operation, the Permittee shall record and maintain the quantity of each coating applied at the Coating Line. This shall be based on usage logs or production records. [Minn. R , subps. 4-5] Monthly Recordkeeping -- VOC Applied in Coatings. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total gallons of each coating used in the previous month using the records and formulation specifications required by this permit; 2) The VOC applied in coatings for the previous month using the formulas specified in this permit; and 3) The 12-month rolling sum VOC applied in coatings for the previous 12-month period by summing the monthly VOC application data for the previous 12 months. [40 CFR (d), Minn. R , subps. 4-5, Minn. R ] Monthly Recordkeeping: The Permittee shall maintain a calendar month record of all coatings used at EQUI 2 and the results of the reference test methods specified in 40 CFR Section (a) or the manufacturer's formulation data used for determining the VOC content of those coatings. [40 CFR (a), Minn. R ] Monthly Calculations -- VOC Applied in Coatings. The Permittee shall calculate the VOC applied in coatings, in tons/month, by the 15th of the month for the previous month using the following method: VOC = ((W1 x V1) + (W2 x V2) + (W3 x V3) +...)/2000 where: V# = the total Volume, in gallons, of each coating (#) applied during the calendar month; and W# = the pounds of VOC in a gallon of coating V#. The value of W# shall be obtained from either a U.S. EPA Reference Method 24 test or manufacturer's formulation data. [40 CFR (a), (a), Minn. R , subps. 4-5, Minn. R ] Material Content: VOC contents in coating materials shall be determined by the Safety Data Sheet (SDS) or the Material Safety Data Sheet (MSDS) provided by the supplier for each material used. If a material content range is given on the SDS or the MSDS, the

12 Permit Issued: December 27, Permit Expires: Non-expiring permit Page 12 of 13 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation highest number in the range shall be used in all compliance calculations. If there is information provided in the Regulatory Section of the SDS, the highest number in the range of that section may be used. Other alternative methods approved by the MPCA may be used to determine the VOC contents. The Commissioner reserves the right to require the Permittee to determine the VOC contents according to EPA or ASTM reference methods. If an EPA or ASTM reference method is used for material content determination, the data obtained shall supersede the SDS or the MSDS. [Minn. R , subps. 4-5] 6. Submittal/action requirements This section lists most of the submittals required by this permit. Please note that some submittal requirements may appear in the Limits and Other Requirements section, or, if applicable, within a Compliance Schedule section. Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation TFAC FLEXcon Co Inc The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and July. 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. Submit this on form DRF-2 (Deviation Reporting Form). If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R , subp. 6(A)(2)] The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the previous calendar year). Submit this on form CR-04 (Annual Compliance Certification Report). This report covers all deviations experienced during the calendar year. If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R , subp. 6(C)] 7. Appendices Appendix A. Insignificant Activities and General Applicable Requirements The table below lists the insignificant activities that are currently at the Facility and their associated general applicable requirements.

13 Permit Issued: December 27, Permit Expires: Non-expiring permit Page 13 of 13 Minn. R. Rule description of the activity General applicable requirement Minn. R , subp. 3(A) Fuel Use: space heaters fueled by kerosene, natural gas, or propane, less than 420,000 Btu/hr. PM <= 0.4 lb/mmbtu Opacity <= 20% with exceptions (Minn. R ) Minn. R , subp. 3(I) FLEXcon has two natural gas space heaters with a total capacity of 30,000 Btu/hr. Individual units with potential emissions less than 2000 lb/year of certain pollutants. FLEXcon has one air make up unit with a capacity of 660,000 But/hr that qualifies under this subpart. PM <= 0.4 lb/mmbtu Opacity <= 20% with exceptions (Minn. R ) Appendix B. Maximum Content of Materials and Process Rate of EQUI 2 Contents listed are as applied. Maximum Capacity Maximum Weight Percent VOC (gal/hr)

14 Technical Support Document for Air Emission Permit No This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR 70.7(a)(5) and Minn. R , subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit. 1. General information 1.1 Applicant and stationary source location Table 1. Applicant and source address Applicant/Address FLEXcon Co Inc 1 FLEXcon Industrial Pk Spencer, Massachusetts Contact: James Tessier Phone: Stationary source/address (SIC Code: Unsupported Plastics Film and Sheet) FLEXcon Co Inc 7165 Commerce Cir W Fridley, MN Facility description FLEXcon Company, Inc. manufactures pressure sensitive films. A coater/laminator is used to apply adhesives to a film stock followed by a drying oven. The facility also contains insignificant activities as allowed under Minn. R The main emissions are Volatile Organic Compounds (VOC) and Hazardous Air Pollutants (HAP) from the coater. 1.3 Description of the activities allowed by this permit action This permit action is a State Permit. No changes are authorized by this permit. 1.4 Facility emissions Table 2. Total facility potential to emit (PTE) summary PM tpy PM10 tpy PM2.5 tpy SO2 tpy NOx tpy CO tpy CO2e tpy VOC tpy All HAPs tpy Total facility limited potential emissions Total facility actual emissions (2017) * * *Not reported in Minnesota emission inventory. Technical Support Document, Permit Number: Page 1 of 5

15 Table 3. Facility classification Classification Major Synthetic minor/area Minor/Area New Source Review Part 70 Part Changes to permit This permit action changes the type of permit issued to this facility from a Part 70 permit to a non-expiring individual state permit. The memorandum released by the EPA on January 25, 2018, reverses the Once In Always In policy, allowing facilities that were major sources at the time of a given major source standard s compliance date who have since become area sources to no longer be subject to the major source standard and in some cases obtain a state permit. FLEXcon has been permitted as an area source of HAPs since 2007 (permit number ). However, this was past the compliance date of 40 CFR pt. 63, subp. JJJJ, so the standard was included in their permit and that permit was a Part 70 permit. Now that this standard no longer applies, the facility does not need a Part 70 permit. As noted above, the PTE of the facility is below all permitting thresholds, but the facility still needs a state operating permit because 40 CFR pt. 60, subp. RR applies to the coating line (per Minn. R , subp. 2(A)). The MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R , the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action: The permit has been updated to reflect current MPCA templates and standard citation formatting; The data in Appendix B of the permit has been updated to reflect current materials; The requirements of 40 CFR pt. 63, subp. JJJJ have been removed because they no longer apply; and The direct heating rule from Minn. R. ch was incorrectly listed as applying to the coating line oven so it has been removed from the permit (the rule only applies if no other standard of performance applies and in this case 40 CFR pt. 60, subp. RR applies to the coating line oven so the Minnesota standard does not apply). 2. Regulatory and/or statutory basis 2.1 New source review (NSR) FLEXcon is a minor source under NSR-Prevention of Significant Deterioration (PSD), 40 CFR Part 70 permit program The facility is a nonmajor source under the Part 70 permit program. 2.3 New source performance standards (NSPS) The coating line is subject to the requirements of 40 CFR pt. 60, subp. RR (Pressure Sensitive Tape and Label Surface Coating Operations). VOC emissions are limited to 49.0 tpy to avoid applicability of control requirements from the NSPS. As long as VOC usage meets the rule requirements, no NSPS emission limits apply. Regardless, the facility PTE is less than 5 tpy of VOC. 2.4 National emission standards for hazardous air pollutants (NESHAP) The permittee has stated that no area source NESHAPs apply to the operations at this facility. X X X Technical Support Document, Permit Number: Page 2 of 5

16 2.5 Regulatory Overview Table 4. Regulatory overview of facility Subject item* Applicable regulations Rationale COMG 1 Coating Line 40 CFR pt. 60, subp. RR NSPS for Pressure Sensitive Tape and Label Surface Coating Operations. Limits to keep VOC usage less than threshold in the rule so that no NSPS emissions limits apply. *Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.). 3. Technical information 3.1 Calculations of potential to emit (PTE) Attachment 1 to this TSD contains detailed spreadsheets and supporting information created by the permittee and then modified by the MPCA. The coating emissions are calculated on a mass balance basis (content x capacity) and combustion emissions are based on equipment capacity, allowable fuels, and EPA emissions factors. 3.2 Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considered the following: the likelihood of the facility violating the applicable requirements; whether add-on controls are necessary to meet the emission limits; the variability of emissions over time; the type of monitoring, process, maintenance, or control equipment data already available for the emission unit; the technical and economic feasibility of possible periodic monitoring methods; and the kind of monitoring found on similar units elsewhere. Table 5 summarizes the monitoring requirements. Table 5. Monitoring Subject Item* COMG 1 Coating Line Requirement (basis) Volatile Organic Compounds <= 49.5 tons per year 12-month rolling (40 CFR (b), Minn. R ) What is the monitoring? Recordkeeping: Daily records of coating applied, monthly calculation of coating used at each line *Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.). Why is this monitoring adequate? Monitoring required by the NSPS is adequate to demonstrate compliance with the requirements. The PTE of the coating line is less than 5 tons per year. 3.1 Insignificant activities FLEXcon Co Inc has several operations that are classified as insignificant activities under the MPCA s permitting rules. These are listed in Appendix A to the permit. Technical Support Document, Permit Number: Page 3 of 5

17 The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities. See Attachment 1 of this TSD for PTE information for the insignificant activities. Table 6. Insignificant activities Insignificant activity Fuel Use: space heaters fueled by kerosene, natural gas, or propane, less than 420,000 Btu/hr Individual units with potential emissions less than 2000 lb/year of certain pollutants General applicable emission limit PM <= 0.4 lb/mmbtu, depending on year constructed Opacity <= 20% with exceptions (Minn. R ) PM <= 0.4 lb/mmbtu, depending on year constructed Opacity <= 20% with exceptions (Minn. R ) Discussion There are two natural gas space heaters listed under this item. For these units, based on the fuels used and EPA published emissions factors, it is highly unlikely that it could violate the applicable requirement (PTE of lb/mmbtu compared to rule limit of 0.4 lb/mmbtu). In addition, these units are operated and vented inside a building, so testing for PM or opacity is not feasible. The direct heating equipment rule might seem to apply to the space heaters, since the combustion gases are vented directly into the building. However, these units are not used for processing a material, the other criteria necessary to be direct heating equipment (e.g., process oven or dryer). Since the intent of the indirect heating rule is to limit emissions from combustion, this rule applies. One air make up unit is listed under this item. Based on the fuels used and EPA published emissions factors, it is highly unlikely that it could violate the applicable requirement (PTE of lb/mmbtu compared to rule limit of 0.4 lb/mmbtu). In addition, the unit is operated and vented inside a building, so testing for PM or opacity is not feasible. The direct heating equipment rule might seem to apply to the air make up unit, since the combustion gases are vented directly into the building. However, as with the space heaters, the unit is not used for processing a material. Since the intent of the indirect heating rule is to limit emissions from combustion, this rule applies. 3.2 Permit organization This permit meets the MPCA Tempo Guidance for ordering and grouping of requirements as well as the use of permit appendices. 3.3 Comments received No comments were received from the public during the public notice period. Public Notice Period: 11/21/18 12/20/18 4. Permit fee assessment The permittee submitted an application for a Part 70 reissuance. Due to the EPA s reversal of the Once in Always In policy previously discussed in this TSD, the MPCA made the decision to allow facilities with an open permit Technical Support Document, Permit Number: Page 4 of 5

18 action to request their Part 70 permits be converted to a state individual permit, without additional applications or fees. Therefore, no application fees apply under Minn. R , subp. 1 and this MPCA decision. 5. Conclusion Based on the information provided by FLEXcon Co Inc the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Peggy Bartz (permit engineer) Kirsten Baker (peer reviewer) Timothy Schwarz (enforcement) Beckie Olson (permit writing assistant, data entry) Laurie O Brien (administrative support) TEMPO360 Activities: State Permit (IND ) Attachments: 1. PTE summary and calculation spreadsheets 2. Subject item inventory and facility requirements Technical Support Document, Permit Number: Page 5 of 5

19 Coating Stock # Density (Lbs/Gal) FLEXcon Company, Inc. - Fridley, MN Potential to Emit Calculations - VOCs December 2017 % VOC VOC Content (Lb/Gal) Max Process Rate (gals / hr) Max Emission Rate (lbs/hr) Max Hours (for PTE) Max VOC Emissions (lbs/yr) Max VOC Emissions (tons/yr) A 7466NIBC % ,760 2, B 7674MN % ,760 7, C 551MN % ,760 4, Notes: Red font denotes coating with highest VOC emission rate Coating Stock # Density (Lb/Gal) HAPs FLEXcon Company, Inc. - Fridley, MN Potential to Emit Calculations - HAPs % of each HAP December 2017 HAP Content (lbs/gal) Max Process Rate (gals/hr) Max PTE HAPs (lbs/hr) Max Hours (for PTE) PTE HAPs (lbs/yr) PTE HAPs (tons/yr) A 7466NIBC 8.6 NONE 0.000% , B 7674MN 8.58 Vinyl Acetate 0.260% ,760 3, Methyl Methacryla % te C 551MN 8.59 Acrylic Acid % , Vinyl Acetate 0.33% , TOTAL HAPs 0.339% , Notes: Red font denotes coating with highest HAP emission rate IPER does not apply to the coater because the unit is an affected facility under 40 CFR pt.60, subp. RR. TSD Attachment 1

20 800, Potential Air Emissions from Coater Drying Oven Natural Gas Btu = British thermal unit Enter Btu/hr maximum heat input scf = standard cubic foot = ft 3 heat value of natural gas is 1050 Btu/scf ft 3 /hr Btu/hr X 1 ft 3 /1050 Btu ft 3 /year ft 3 /hr X 8760 hr/yr Potential to Emit - Natural Gas Fired Drying Oven ft 3 burned/yr SO2 NO X VOC CO PM PM 10 PM2.5 Lead natural gas sulfur dioxide nitrogen oxides volatile organic carbon monoxide particulate matter particulate matter particulate matter compunds < 10 microns <2.5 microns ton/yr ton/yr ton/yr ton/yr ton/yr ton/yr ton/yr ton/year ft3 X / 2000 ft3 X.0001 / 2000 ft3x / 2000 ft3 X /2000 ft3 X /2000 ft3 X /2000 ft3 X /2000 ft3 X /2000 6,674, Total PTE (tons / year) Total PTE lbs / year Total PTE lbs / hour MPCA Calculations/Adjustments GHG and total and individual HAP calculations from combustion are also required for all emissions units. These are also completed using EPA's AP 42 emissions factors Pollutant Fuel Usage Emission Factor Potential Emissions MMcu.ft./yr lb/mmcu.ft. lbs/hr tpy CO E E E+02 N2O E E E 03 Size in MMBtu/hr CH E E E CO2e NA NA 1.01E E+02 Benzene E E E 06 Arsenic E E E 07 Beryllium E E E 08 Cadmium E E E 06 Cobalt E E E 07 Chromium E E E 06 Dichlorobenzene E E E 06 Formaldehyde E E E 04 Hexane E E E 03 Lead E E E 06 Naphthalene E E E 06 Mercury E E E 07 Toluene E E E 05 Manganese E E E 06 Nickel E E E 06 POM E E E 07 Selenium E E E 08 Total HAPs E E E 03 Calculations: AP42, Chapter 1.4, Natural Gas Combustion, 7/98. The direct heating rule does not apply to the dryer because the unit is an affected facility under 40 CFR pt.60, subp. RR. TSD Attachment 1

21 Summary of IA PTEs Summary of PTE of Insignificant Activities Listed in the Permit Application The Facility has the following insignificant activities under Minn. R (per the April 2012 application): Rule Activity Pollutants subp. 3(A) 2 space heaters combustion pollutants subp. 3(I) air make up unit combustion pollutants The PTE of the listed IAs should be evaluated if they could affect the applicability of regulations. PTE estimates were included in the reissuance application and are summarized here. MPCA staff completed the calculations for HAPs and GHGs. Pollutant PTE tpy PM/PM10/PM SO NOx VOC CO CO2e 383 Benzene Arsenic Beryllium Cadmium Cobalt Chromium Dichlorobenzene Formaldehyde Hexane Lead Naphthalene Mercury Toluene Manganese Nickel POM Selenium Total HAPs Based on the PTE of the IAs and the PTE of the otherwise permitted units, it is clear that the IAs do not affect the applicability of regulations to the Facility. TSD Attachment 1

22 Potential Air Emissions from Space Heaters Natural Gas Btu = British thermal unit scf = standard cubic foot = ft 3 Enter Btu/hr maximum heat input 30, Total capacity for both Space Heaters combined heat value of natural gas is 1050 Btu/scf ft 3 /hr Btu/hr X 1 ft 3 /1050 Btu ft 3 /year ft 3 /hr X 8760 hr/yr Potential to Emit - Natural Gas Fired Space Heaters ft 3 burned/yr SO2 NO X VOC CO PM PM 10 PM2.5 Lead natural gas sulfur dioxide nitrogen oxides volatile organic carbon monoxide particulate matter particulate matter particulate matter compounds < 10 microns < 2.5 microns ton/yr ton/yr ton/yr ton/yr ton/yr ton/yr ton/yr ton/year ft3 X / 2000 ft3 X.0001 / 2000 ft3 X / 2000 ft3 X /2000 ft3 X /2000 ft3 X /2000 ft3 X /2000 ft3 X / , Total PTE (tons / year) Total PTE lbs / year Total PTE lbs / hour MPCA Calculations/Adjustments GHG and total and individual HAP calculations from combustion are also required for all emissions units. These are also completed using EPA's AP 42 emissions factors. Pollutant Fuel Usage Emission Factor Potential Emissions MMcu.ft./yr lb/mmcu.ft. lbs/hr tpy CO E E E+01 N2O E E E 04 Size in MMBtu/hr CH E E E CO2e NA NA 3.80E E+01 Benzene E E E 07 Arsenic E E E 08 Beryllium E E E 09 Cadmium E E E 07 Cobalt E E E 08 Chromium E E E 07 Dichlorobenzene E E E 07 Formaldehyde E E E 05 Hexane E E E 04 Lead E E E 08 Naphthalene E E E 08 Mercury E E E 08 Toluene E E E 07 Manganese E E E 08 Nickel E E E 07 POM E E E 08 Selenium E E E 09 Total HAPs E E E 04 Calculations: AP42, Chapter 1.4, Natural Gas Combustion, 7/98. TSD Attachment 1

23 660, Potential Air Emissions from Make-Up Air Unit Natural Gas Btu = British thermal unit Enter Btu/hr maximum heat input scf = standard cubic foot = ft 3 heat value of natural gas is 1050 Btu/scf ft 3 /hr Btu/hr X 1 ft 3 /1050 Btu ft 3 /year ft 3 /hr X 8760 hr/yr Potential to Emit - Natural Gas Fired Make-up Air Unit ft 3 burned/yr SO2 NO X VOC CO PM PM 10 Lead natural gas sulfur dioxide nitrogen oxides volatile organic carbon monoxide particulate matter particulate matter compounds < 10 microns ton/yr ton/yr ton/yr ton/yr ton/yr ton/yr ton/year ft3 X / 2000 ft3 X.0001 / 2000 ft3 X / 2000 ft3 X /2000 ft3 X /2000 ft3 X /2000 ft3 X /2000 5,506, Total PTE (tons / year) Total PTE lbs / year Total PTE lbs / hour MPCA Calculations/Adjustments GHG and total and individual HAP calculations from combustion are also required for all emissions units. These are also completed using EPA's AP 42 emissions factors. PM2.5 is also assumed to be equivalent to PM10. Pollutant Fuel Usage Emission Factor Potential Emissions MMcu.ft./yr lb/mmcu.ft. lbs/hr tpy CO E E E+02 N2O E E E 03 Size in MMBtu/hr CH E E E CO2e NA NA 8.37E E+02 Benzene E E E 06 Arsenic E E E 07 Beryllium E E E 08 Cadmium E E E 06 Cobalt E E E 07 Chromium E E E 06 Dichlorobenzene E E E 06 Formaldehyde E E E 04 Hexane E E E 03 Lead E E E 06 Naphthalene E E E 06 Mercury E E E 07 Toluene E E E 05 Manganese E E E 06 Nickel E E E 06 POM E E E 07 Selenium E E E 08 Total HAPs E E E 03 Calculations: AP42, Chapter 1.4, Natural Gas Combustion, 7/98. TSD Attachment 1

24 Both the space heaters and air make up units are considered indirect heating equipment (as discussed in the body of the TSD for this permit). We compare the calculated PTE from natural gas combustion to the applicable limit from the rule. Applicable rule limits PM 0.4 lb/mmbtu In order to compare with rule limit (in lb/mmbtu), calculate PM PTE based on AP 42 (EF/heat value of fuel) Natural Gas PM lb/mmbtu TSD Attachment 1

25 Attachment 2 Subject item inventory and facility requirements

26 ListofSIs AgencyInterest:FLEXconCoInc AgencyInterestID:675 Activity:IND (StatePermit) Detailsfor: SICategory:None SIType:Al AgencyInterestName SubjectItem ID SubjectItem Designation SubjectItem Description FLEXconCoInc ACTV3 Nul AlIAs AISI675 Nul Nul COMG1 GP001 CoatingLine(ovenand coater) EQUI1 EU001 DryingOven EQUI2 EU002 Coater/Laminator STRU1 BG001 FLEXconispartofalarger building(rentspace) STRU2 SV001 Dryingoven STRU3 SV002 Coater/Laminator TFAC FLEXconCoInc

27 Insignificantairemissionsactivity AgencyInterest:FLEXconCoInc AgencyInterestID:675 Activity:IND (StatePermit) Detailsfor: SICategory:Activity SIType:InsignificantAirEmissionsActivity AgencyInterestNa. ActivityID SubjectIte. SubjectItem TypeDescription SubjectItem ID SubjectIte. SubjectIte. StatusDesc.SubAttributeDescription FLEXconCoInc IND Activity InsignificantAirEmissionsActivity ACTV3 Nul AlIAs Active/ Existing Minn.R ,subp.3(A) Minn.R ,subp.3(I)

28 ComponentGroup(Members) AgencyInterest:FLEXconCoInc AgencyInterestID:675 Activity:None(StatePermit) Detailsfor: SICategory:ComponentGroup SIType:AirComponentGroup AgencyInterestName SubjectItem ID SubjectItem DesignationSubjectItem Description GroupMemberID(padded) FLEXconCoInc COMG1 GP001 CoatingLine(ovenand coater) EQUI1 EQUI2

29 SubjectItem CategoryDescription SubjectItem Type Description SubjectItem ID SubjectItem Designation SubjectItem Description Polutant Potential(lbs/hr) UnrestrictedPotential (tons/yr) PotentialLimited (tons/yr) Equipment Dryer/Oven,unknown firingmethod EQUI1 EU001 DryingOven 1,4-Dichlorobenzene(par. Arseniccompounds Benzene Berylium Cadmium compounds CarbonDioxide CarbonDioxideEquivalent CarbonMonoxide Chromium compounds Cobaltcompounds Formaldehyde HAPs-Total Hexane Lead Manganesecompounds Mercury Methane Naphthalene Nickelcompounds NitrogenOxides NitrousOxide ParticulateMatter PM <2.5micron PM <10micron Polycyclicorganicmatter Selenium compounds SulfurDioxide Toluene VolatileOrganicCompoun. SprayBooth/Coating Line EQUI2 EU002 Coater/Laminator Acrylicacid HAPs-Total Hexane Methylethylketone(MEK) Methylmethacrylate Styrene Toluene Vinylacetate(Aceticacid) VolatileOrganicCompoun. Xylenes,Total e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e PTEbysubjectitem AgencyInterest:None AgencyInterestID:675 Activity:None(StatePermit) Detailsfor: SICategory:Equipment SIType:Al

30 PTEbysubjectitem AgencyInterest:None AgencyInterestID:675 Activity:None(StatePermit) Detailsfor: SICategory:Equipment SIType:Al SubjectItem SubjectItem Type CategoryDescription Description Equipment Dryer/Oven,unknown firingmethod SprayBooth/Coating Line SubjectItem ID SubjectItem Designation SubjectItem Description Polutant EQUI1 EU001 DryingOven 1,4-Dichlorobenzene(par. 6 Arseniccompounds Benzene Berylium Cadmium compounds CarbonDioxide CarbonDioxideEquivalent 4 CarbonMonoxide Chromium compounds Cobaltcompounds Formaldehyde HAPs-Total Hexane Lead Manganesecompounds 6 Mercury Methane Naphthalene Nickelcompounds NitrogenOxides NitrousOxide ParticulateMatter PM <2.5micron PM <10micron Polycyclicorganicmatter 7 Selenium compounds SulfurDioxide Toluene EQUI2 EU002 Coater/Laminator Acrylicacid VolatileOrganicCompoun. 8 HAPs-Total Hexane Methylethylketone(MEK) 0 Methylmethacrylate Styrene Toluene Vinylacetate(Aceticacid) 9 VolatileOrganicCompoun. 9 Xylenes,Total ActualEmissions (tons/yr)

31 SI-SIrelationships AgencyInterest:None AgencyInterestID:675 Activity:None(StatePermit) Detailsfor: SICategory:Equipment SIType:Al SubjectItem Category Description Equipment SubjectItem Type Description SubjectItem ID SubjectItem SubjectItem Designation Description RelatedSubject Relationship Item ID % Flow RelatedSubjectItem TypeDescription StartDate(Related EndDate(Related SubjectItem) SubjectItem) Dryer/Oven, EQUI1 unknownfiringm. EU001 DryingOven sendsto STRU2 100 Stack/Vent 4/17/2002 Nul Spray Coater/ Booth/CoatingLi. EQUI2 EU002 Laminator sendsto STRU3 100 Stack/Vent 4/17/2002 Nul

32 EmissionUnits1 AgencyInterest:None AgencyInterestID:675 Activity:None(StatePermit) Detailsfor: SICategory:None SIType:SprayBooth/CoatingLine SubjectItem Type Description SubjectItem ID SubjectItem SubjectItem Designation Description Manufacturer Model MaxDesign Capacity MaxDesign Capacity Units (numerator) MaxDesign CapacityUnits (denominator) Material Construction Operation StartDate StartDate Modification Date SprayBooth/ Coater/ CoatingLine EQUI2 EU002 Laminator FLEXcon NA 16 galons hours Coating 10/15/ /15/1985 Nul

33 EmissionUnits2 AgencyInterest:None AgencyInterestID:675 Activity:None(StatePermit) Detailsfor: SICategory:Equipment SIType:Dryer/Oven,unknownfiringmethod SubjectItem Type Description Dryer/Oven,unknown firingmethod SubjectItem ID SubjectItem SubjectItem Designation Description Manufacturer Model EQUI1 EU001 DryingOven HarknessEngineering # MaxDesign Capacity MaxDesign CapacityUnits (numerator) milionbritish thermalunits MaxDesign CapacityUnits (denominator) Material Construction Operation StartDate StartDate hours Heat 10/15/ /15/1985 Nul Modification Date