DRAFT. AIR EMISSION PERMIT NO Total Facility Operating Permit IS ISSUED TO. AmeriPride Services Inc

Transcription

1 DRAFT AIR EMISSION PERMIT NO Total Facility Operating Permit IS ISSUED TO AmeriPride Services Inc AMERIPRIDE SERVICES INC MINNEAPOLIS 700 Industrial Boulevard Northeast Minneapolis, Hennepin County, Minnesota 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 permit authorizes the Permittee to operate 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 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. Permit Type: State Permit; Limits to Avoid Part 70/Limits to Avoid NSR; Operating Permit Issue Date: <issue date> Expiration Date: Non Expiring All Title I Conditions do not expire. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for John Linc Stine 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 Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit October 30, TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Appendix A: Insignificant Activities and Applicable Requirements Appendix B: MPCA Approved Emission Factors

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 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.

4 FACILITY DESCRIPTION: AmeriPride Services Inc. (AmeriPride) owns and operates an industrial laundry facility in Minneapolis, Minnesota. At the facility, AmeriPride receives shop and print towels, garments, linens, aprons, uniforms and mats from customers, then cleans and returns the laundry to its customers. There is no dry cleaning conducted at the facility and no chlorinated cleaning chemicals or detergents are used in the cleaning process. Equipment at the facility includes industrial laundry machines and fuel combustion units. The combustion units are fired by natural gas only (no back up fuels). The shop and print towels received by AmeriPride may contain VOCs and HAPs from cleaning and/or processing materials used at the customer s facilities or businesses. The other types of industrial laundry cleaned are believed to contain no appreciable quantity of VOCs or HAPs.

5 Facility Name: AmeriPride Services Inc - Minneapolis Permit Number: A-1 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 SOURCE-SPECIFIC REQUIREMENTS Permit Appendixces: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices. 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 your facility. Read Sections and 40 CFR pt. 82 to determine all the requirements that apply to your facility. OPERATIONAL REQUIREMENTS 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. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. 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. 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: 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 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. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. PERFORMANCE TESTING Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, and B. hdr Why to do it Minn. R , subp CFR pt. 82 hdr Minn. R Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R , subps. 14 and 16(J) Minn. R , subp. 4 Minn. R Minn. R Minn. R , subp. 9(A) Minn. R , subp. 16 hdr Minn. R. ch. 7017

6 Facility Name: AmeriPride Services Inc - Minneapolis Permit Number: A-2 Performance Test Notifications and Submittals: Performance Tests are due as outlined in Table A of the permit. See Table B for additional testing requirements. Minn. R ; Minn. R , subps. 1-4, Minn. R , subps. 1-2 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 Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R , subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. MONITORING REQUIREMENTS Monitoring Equipment Calibration - The Permittee shall either: Minn. R , subp. 3 hdr Minn. R , subp. 4(D) 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. Operation of Monitoring Equipment: Unless otherwise noted in Tables A and B 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 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). 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. 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 For nonexpiring permits, 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. REPORTING/SUBMITTALS 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. 4(D) hdr Minn. R , subp. 5(C) Minn. R , subp. 5(B) Minn. R , subp. 4 hdr Minn. R , subp. 3

7 Facility Name: AmeriPride Services Inc - Minneapolis Permit Number: A-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. 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. 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. 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. Minn. R , subp. 2 Minn. R , subp. 1 Minn. R , subp. 1 Minn. R Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 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. Extension Requests: The Permittee may apply for an Administrative Amendment to Minn. R , subp. 1(H) 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). Emission Inventory Report: due on or before April 1 of each calendar year following Minn. R permit issuance, to be submitted on a form approved by the Commissioner. Emission Fees: due 30 days after receipt of an MPCA bill. Minn. R

8 Facility Name: Permit Number: AmeriPride Services Inc - Minneapolis Subject Item: GP 001 Injunctive Relief Limits A-4 Associated Items: EU 005 Dryer #1 - Dryer/Oven, direct fired EU 006 Dryer #2 - Dryer/Oven, direct fired EU 007 Dryer #3 - Dryer/Oven, direct fired EU 008 Dryer #4 - Dryer/Oven, direct fired EU 009 Dryer #5 - Dryer/Oven, direct fired EU 011 Clean Room Electric Dryer #1 - Thermal Unit EU 012 Clean Room Electric Dryer #2 - Thermal Unit EU 013 #1 Washer EU 014 #2 Washer EU 015 #3 Washer EU 016 #4 Washer EU 017 #5 Washer EU 018 #6 Washer EU 019 #7 Washer EU 020 #8 Washer EU 021 #9 Washer EU 022 #10 Washer EU 023 #11 Washer EU 024 #12 Washer EU 025 #13 Washer EU 026 #14 Washer EU 027 #15 Washer EU 030 #16 Washer EU 031 #17 Washer What to do Process Throughput: less than or equal to 650,000 lbs/year using 12-month Rolling Sum of soiled print towels washed and dried. All washers and dryers listed in GP001 are subject to this limit. Process Throughput: less than or equal to 860,000 lbs/year using 12-month Rolling Sum of soiled shop towels washed and dried. All washers and dryers listed in GP001 are subject to this limit. Good Work Practices: The Permittee shall employ good work practices to control VOC emissions from sorting and handling of soiled towels at the Facility. Examples of work practice standards include but are not limited to: 1. Minimizing the amount of time that soiled print and shop towels are open to the atmosphere by washing within the day or evening of arrival. 2. Employing proper maintenance and operation of the wastewater handling process. Daily Recordkeeping - Throughput limit: On each day of operation, the Permittee shall record the amount, in pounds, of soiled print towels washed and dried at the Facility each day. Why to do it Title I Condition: CAAA of 1990; Minn. R , subp. 2 Title I Condition: CAAA of 1990; Minn. R , subp. 2 Title I Condition: CAAA of 1990; Minn. R , subp. 2 Title I Condition: CAAA of 1990; Minn. R , subps. 4 & 5 On each day of operation, the Permittee shall record the amount, in pounds, of soiled shop towels washed and dried at the Facility each day.

9 Facility Name: AmeriPride Services Inc - Minneapolis Permit Number: A-5 Monthly Recordkeeping - Throughput limit: By the 15th day of each month, the Permittee shall calculate and record the following: Title I Condition: CAAA of 1990; Minn. R , subps. 4 & 5 1. The total amount, in pounds, of soiled print towels washed and dried at the Facility during the previous calendar month. 2. The 12-month rolling sum, in pounds, of soiled print towels washed and dried at the Facility during the previous 12-month period by summing the monthly soiled print towel throughput data for the previous 12 months. 3. The total amount, in pounds, of soiled shop towels washed and dried at the Facility during the previous calendar month. 4. The 12-month rolling sum, in pounds, of soiled shop towels washed and dried at the Facility during the previous 12-month period by summing the monthly soiled shop towel throughput data for the previous 12 months.

10 Facility Name: Permit Number: AmeriPride Services Inc - Minneapolis Subject Item: GP 002 Pre-Cap Limits: Washers and Dryers A-6 Associated Items: EU 005 Dryer #1 - Dryer/Oven, direct fired EU 006 Dryer #2 - Dryer/Oven, direct fired EU 007 Dryer #3 - Dryer/Oven, direct fired EU 008 Dryer #4 - Dryer/Oven, direct fired EU 009 Dryer #5 - Dryer/Oven, direct fired EU 011 Clean Room Electric Dryer #1 - Thermal Unit EU 012 Clean Room Electric Dryer #2 - Thermal Unit EU 013 #1 Washer EU 014 #2 Washer EU 015 #3 Washer EU 016 #4 Washer EU 017 #5 Washer EU 018 #6 Washer EU 019 #7 Washer EU 020 #8 Washer EU 021 #9 Washer EU 022 #10 Washer EU 023 #11 Washer EU 024 #12 Washer EU 025 #13 Washer EU 026 #14 Washer EU 027 #15 Washer EU 030 #16 Washer EU 031 #17 Washer What to do Process Throughput: less than or equal to 650,000 lbs/year using 12-month Rolling Sum of soiled print towels washed and dried. All washers and dryers at the Facility are subject to this limit. If the Permittee replaces any existing washer or dryer, adds new washers or dryers. or modifies existing washers or dryers, such equipment is subject to this permit limit. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee is not required to complete VOC and HAP calculations described in Minn. R , subp. 2. A permit amendment will still be needed regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to the limits or monitoring and recordkeeping in this permit. Process Throughput: less than or equal to 860,000 lbs/year using 12-month Rolling Sum of soiled shop towels washed and dried. All washers and dryers at the Facility are subject to this limit. If the Permittee replaces any existing washer or dryer, adds new washers or dryers. or modifies existing washers or dryers, such equipment is subject to this permit limit. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee is not required to complete VOC and HAP calculations described in Minn. R , subp. 2. A permit amendment will still be needed regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to the limits or monitoring and recordkeeping in this permit. Fuel Type: natural gas only, by design. This requirement applies to each GP002 unit individually. Why to do it Title I Condition: To avoid classification as major source or modification under 40 CFR Section & Minn. R ; To avoid major source classification under 40 CFR Section 70.2 & Minn. R ; To avoid major source classification under 40 CFR Section 63.2 Title I Condition: To avoid classification as major source or modification under 40 CFR Section & Minn. R ; To avoid major source classification under 40 CFR Section 70.2 & Minn. R ; To avoid major source classification under 40 CFR Section 63.2 Minn. R , subp. 35a

11 Facility Name: AmeriPride Services Inc - Minneapolis Permit Number: A-7 Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R This requirement applies to each dryer in GP002 individually. Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. This requirement applies to each dryer in GP002 individually. Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R This limit applies to each washer in GP002 individually. Opacity: less than or equal to 20 percent opacity This limit applies to each washer in GP002 individully. Daily Recordkeeping - Throughput limit: On each day of operation, the Permittee shall record the amount, in pounds, of soiled print towels washed and dried at the Facility each day. On each day of operation, the Permittee shall record the amount, in pounds, of soiled shop towels washed and dried at the Facility each day. Monthly Recordkeeping - Throughput limit: By the 15th day of each month, the Permittee shall calculate and record the following: 1. The total amount, in pounds, of soiled print towels washed and dried at the Facility during the previous calendar month. 2. The 12-month rolling sum, in pounds, of soiled print towels washed and dried at the Facility during the previous 12-month period by summing the monthly soiled print towel throughput data for the previous 12 months. 1. The total amount, in pounds, of soiled shop towels washed and dried at the Facility during the previous calendar month. 2. The 12-month rolling sum, in pounds, of soiled shop towels washed and dried at the Facility during the previous 12-month period by summing the monthly soiled shop towel throughput data for the previous 12 months. Monthly Recordkeeping - Fuel Type: The Permittee shall keep records of fuel type and usage on a monthly basis. Minn. R , subp. 1(A)(1) and Minn. R , subp. 1 Minn. R , subp. 1(A)(2) Minn. R , subp. 1(A) Minn. R , subp. 1(B) Title I Condition: To avoid classification as major source or modification under 40 CFR Section & Minn. R ; To avoid major source classification under 40 CFR Section 70.2 & Minn. R ; To avoid major source classification under 40 CFR Section 63.2; Minn. R , subps. 4 and 5 Title I Condition: To avoid classification as major source or modification under 40 CFR Section & Minn. R ; To avoid major source classification under 40 CFR Section 70.2 & Minn. R ; To avoid major source classification under 40 CFR Section 63.2; Minn. R , subps. 4 and 5 Minn. R , subp. 5

12 Facility Name: Permit Number: AmeriPride Services Inc - Minneapolis Subject Item: GP 003 Boilers and Hot Water Heaters A-8 Associated Items: EU 001 Boiler #1 - Boiler EU 002 Boiler #2 - Boiler EU 003 Hot Water Heater - Process Heater EU 010 Fulton Boiler - Boiler What to do Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input. The potential to emit from each unit in GP003 due to equipment design and allowable fuels is: EU001: lb/mmbtu EU002: lb/mmbtu EU003: lb/mmbtu EU010: lb/mmbtu Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. Fuel Type: Natural gas only, by design. This limit applies to each unit in GP003 individually. Monthly Recordkeeping - Fuel Type: The Permittee shall keep records of fuel type and usage on a monthly basis. Why to do it Minn. R , subp. 1 Minn. R , subp. 2 Minn. R , subp. 35a Minn. R , subp. 5

13 Facility Name: Permit Number: AmeriPride Services Inc - Minneapolis Subject Item: GP 004 Boilers subject to NSPS subp. Dc A-9 Associated Items: EU 001 Boiler #1 - Boiler EU 002 Boiler #2 - Boiler Fuel Type: Natural gas only, by design. What to do This limit applies to each unit in GP004 individually. Recordkeeping: By the last day of each calendar month, the Permittee shall record the amount of natural gas combusted in the boilers during the previous calendar month. These records shall consist of purchase records, receipts, or fuel meter readings. Why to do it 40 CFR Section 60.41c; Minn. R CFR Section 60.48c(g)(2); Minn. R This requirement applies to each unit in GP004 individually.

14 Facility Name: Permit Number: AmeriPride Services Inc - Minneapolis Subject Item: EU 004 Emergency Generator - Reciprocating IC Engine A-10 Associated Items: SV 004 Emergency Electrical Generator Exhaust What to do Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. Fuel type: Natural gas only, by design. Why to do it Minn. R , subp. 1 Minn. R , subp. 2 Minn. R , subp. 35a Hours of Operation: The Permittee shall maintain documentation on site that the Minn. R , subps. 4 & 5 unit is an emergency generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) for Emergency Generators" dated September 6, 1995, limiting operation to 500 hours per year. The Permittee shall keep records of fuel type and usage on a monthly basis. Minn. R , subp. 5 NESHAP SUBPART ZZZZ REQUIREMENTS - ENFORCEMENT NOT DELEGATED TO MPCA The Permittee shall comply with the applicable emission and operational limitations from 40 CFR pt. 63, subp. ZZZZ. 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 in order to extend the oil change requirement as described below. Inspect spark plugs 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 be in compliance with the emission limitations and operating limitations in this subpart that apply at all times. 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 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 shall 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. 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 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 three parameters: Total Acid Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Acid Number increases by more than 3.0 milligrams of potassium hydroxide (KOH) per gram from Total Acid 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 all of these condemning limits are not exceeded, the Permittee is not required to change the oil. (continued below) Minn. R , subp CFR Section (a)(1); Minn. R CFR Section (a); 40 CFR Section ; 40 CFR pt. 63, subp. ZZZZ, Table 2d; Minn. R CFR Section (a); 40 CFR Section ; 40 CFR pt. 63, subp. ZZZZ, Table 2d; Minn. R CFR Section (a); 40 CFR Section ; 40 CFR pt. 63, subp. ZZZZ, Table 2d; Minn. R CFR Section (a); Minn. R CFR Section (b); Minn. R CFR Section (e); Minn. R CFR Section (f); Minn. R CFR Section (h); Minn. R CFR Section (j); Minn. R

15 Facility Name: AmeriPride Services Inc - Minneapolis Permit Number: A-11 (continued from above) If any of the limits are exceeded, the engine owner or operator shall change the oil within 2 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 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. The Permittee shall operate and maintain the stationary RICE according to the manufacturer's emission related operation and maintenance instructions; or the Permittee shall develop and follow a maintenance plan which shall 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 report each instance in which the stationary RICE did not meet each applicable operating limitation. These instances are deviations from the emission and operating limitations. These deviations shall be reported with the deviations report required by Table A (listed at the Total Facility level) and Table B of this permit. These deviations shall be reported according to the requirements in 40 CFR Section The Permittee shall report each instance in which the applicable requirements of 40 CFR pt. 63, subp. ZZZZ, Table 8 were not meet. The Permittee shall operate the emergency stationary RICE according to the requirements in paragraphs 40 CFR Section (f)(1) through (4). 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 this subpart and will need to meet all requirements for non-emergency engines. 40 CFR Section (j); Minn. R CFR Section (a); 40 CFR pt. 63 subp. ZZZZ, Table 6 40 CFR Section (b); Minn. R CFR Section (e); Minn. R CFR Section (f); Minn. R (1) There is no time limit on the use of emergency stationary RICE in emergency situations. ON MAY 1, 2015, THE DISTRICT OF COLUMBIA CIRCUIT (DC CIRCUIT) COURT DECIDED TO VACATE THE PROVISIONS OF 40 CFR SECTION (F)(2) THAT ALLOW OPERATION OF A BACKUP GENERATOR WITHOUT EMISSIONS CONTROLS FOR UP TO 100 HOURS PER YEAR AS PART OF AN EMERGENCY DEMAND-RESPONSE PROGRAM. AS OF THE DATE OF ISSUANCE OF AIR EMISSION PERMIT NO , THE DC CIRCUIT COURT HAS NOT YET ISSUED THE MANDATE IMPLEMENTING ITS DECISION, SO THOSE PROVISIONS REMAIN IN EFFECT. AFTER THE DC CIRCUIT ISSUES THE MANDATE, THE 100 HOUR EXEMPTION WILL NO LONGER BE EFFECTIVE. (2) The Permittee may operate the emergency stationary RICE for any combination of the purposes specified in 40 CFR Section (f)(2)(i) through (iii) for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by 40 CFR Section (f)(3) and (4) counts as part of the 100 hours per calendar year allowed by this paragraph. ON MAY 1, 2015, THE DISTRICT OF COLUMBIA CIRCUIT (DC CIRCUIT) COURT DECIDED TO VACATE THE PROVISIONS OF 40 CFR SECTION (F)(2) THAT ALLOW OPERATION OF A BACKUP GENERATOR WITHOUT EMISSIONS CONTROLS FOR UP TO 100 HOURS PER YEAR AS PART OF AN EMERGENCY DEMAND-RESPONSE PROGRAM. AS OF THE DATE OF ISSUANCE OF AIR EMISSION PERMIT NO , THE DC CIRCUIT COURT HAS NOT YET ISSUED THE MANDATE IMPLEMENTING ITS DECISION, SO THOSE PROVISIONS REMAIN IN EFFECT. AFTER THE DC CIRCUIT ISSUES THE MANDATE, THE 100 HOUR EXEMPTION WILL NO LONGER BE EFFECTIVE. 40 CFR Section (f)(1) - (2); Minn. R CFR Section (f)(2)(i); Minn. R (i) The Permittee may operate EU004 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. (continued below)

16 Facility Name: AmeriPride Services Inc - Minneapolis Permit Number: A-12 (continued from above) 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 indicating that Federal, State, or local standards require maintenance and testing of emergency RICE beyond 100 hours per calendar year. ON MAY 1, 2015, THE DISTRICT OF COLUMBIA CIRCUIT (DC CIRCUIT) COURT DECIDED TO VACATE THE PROVISIONS OF 40 CFR SECTION (F)(2) THAT ALLOW OPERATION OF A BACKUP GENERATOR WITHOUT EMISSIONS CONTROLS FOR UP TO 100 HOURS PER YEAR AS PART OF AN EMERGENCY DEMAND-RESPONSE PROGRAM. AS OF THE DATE OF ISSUANCE OF AIR EMISSION PERMIT NO , THE DC CIRCUIT COURT HAS NOT YET ISSUED THE MANDATE IMPLEMENTING ITS DECISION, SO THOSE PROVISIONS REMAIN IN EFFECT. AFTER THE DC CIRCUIT ISSUES THE MANDATE, THE 100 HOUR EXEMPTION WILL NO LONGER BE EFFECTIVE. 40 CFR Section (f)(2)(i); Minn. R CFR Section (f)(2)(ii); Minn. R (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, 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 ON MAY 1, 2015, THE DISTRICT OF COLUMBIA CIRCUIT (DC CIRCUIT) COURT DECIDED TO VACATE THE PROVISIONS OF 40 CFR SECTION (F)(2) THAT ALLOW OPERATION OF A BACKUP GENERATOR WITHOUT EMISSIONS CONTROLS FOR UP TO 100 HOURS PER YEAR AS PART OF AN EMERGENCY DEMAND-RESPONSE PROGRAM. AS OF THE DATE OF ISSUANCE OF AIR EMISSION PERMIT NO , THE DC CIRCUIT COURT HAS NOT YET ISSUED THE MANDATE IMPLEMENTING ITS DECISION, SO THOSE PROVISIONS REMAIN IN EFFECT. AFTER THE DC CIRCUIT ISSUES THE MANDATE, THE 100 HOUR EXEMPTION WILL NO LONGER BE EFFECTIVE. (iii) 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. (4) The Permittee may operate the emergency stationary RICE up to 50 hours per 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). Except as provided in 40 CFR Section (f)(4)(i) and (ii), 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. 4(i) Prior to May 3, 2014, the 50 hours per year for non-emergency situations can be used for peak shaving or non-emergency demand response to generate income for a facility, or to otherwise supply power as part of a financial arrangement with another entity if the engine is operated as part of a peak shaving (load management program) with the local distribution system operator and the power is provided only to the facility itself or to support the local distribution system. 4(ii) The 50 hours per year for nonemergency 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 so as 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. (continued below) 40 CFR Section (f)(2)(iii); Minn. R CFR Section (f)(4); Minn. R CFR Section (f)(4)(i); Minn. R CFR Section (f)(4)(ii); Minn. R

17 Facility Name: AmeriPride Services Inc - Minneapolis Permit Number: A-13 (continued from above) 4(ii) (E) The owner or operator 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. The Permittee shall submit an annual report to the Administrator according to the requirements in 40 CFR Section (h)(2)-(3) if the Permittee operates or is contractually obligated to make the emergency stationary RICE available to operate for more than 15 hours per year for the purposes specificed in 40 CFR Section (f)(2)(ii) (Emergency Demand Response) and (iii) (voltage or frequency deviation) or that operate for the purposes specified in 40 CFR Section (f)(4)(ii) (financial arrangement). The report shall contain the information specified in 40 CFR Section (h)(1). The report shall cover the annual reproting period from January 1 through December31. The report shall be postmarked or delivered no later than January 31. The Permittee shall keep a copy of each report that was submitted in compliance with 40 CFR pt. 63, subp. ZZZZ. 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. The Permittee shall keep 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. The Permittee shall comply with the General Provisions in 40 CFR Section 63.1 through 63.15, as applicable. 40 CFR PT. 63, SUBP. A - GENERAL PROVISIONS hdr Prohibited activities. (1) No owner or operator subject to the provisions of 40 CFR pt. 63 shall operate any affected source in violation of the requirements of 40 CFR pt CFR Section (f)(4)(ii); Minn. R CFR Section (a)-(b); 40 CFR pt. 63, subp. ZZZZ, Table 7; Minn. R CFR Section (a); Minn. R CFR Section (e); Minn. R CFR Section (f); Minn. R CFR Section ; 40 CFR Section 63.10(b)(1); Minn. R CFR Section and Table 8 to Subpart ZZZZ of Part 63; 40 CFR Section ; Minn. R CFR Section 63.4(a); Minn. R (2) No owner or operator subject to the provisions of this part shall fail to keep records, notify, report, or revise reports as required under this part. Circumvention. No owner or operator subject to the provisions of this part shall 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- 40 CFR Section 63.4(b); Minn. R (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. Fragmentation. Fragmentation after November 15, 1990 which divides ownership of an operation, within the same facility among various owners where there is no real change in control, will not affect applicability. The owner and operator must not use fragmentation or phasing of reconstruction activities (i.e., intentionally dividing reconstruction into multiple parts for purposes of avoiding new source requirements) to avoid becoming subject to new source requirements. Recordkeeping: The Permittee shall maintain files of all information required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site. 40 CFR Section 63.4(c); Minn. R CFR Section 63.10(b)(1) ; Minn. R

18 Facility Name: AmeriPride Services Inc - Minneapolis Permit Number: A-14 The Permittee shall maintain, at a minimum, the following information in the files: i. the occurrence and duration of each startup, shutdown, or malfunction of operation; ii. The occurrence and duration of each malfunction of the air pollution control equipment; iii. All maintenance performed on the pollution control equipment; iv. Actions taken during periods of startup, shutdown, and malfunction when such actions are different from the procedures specified in the affected source's startup, shutdown, and malfunction plan (SSMP). Action taken during periods of malfunction when the actions taken are different from the procedures specified in the SSMP. v. All information necessary to demonstrate conformance with the affected source's SSMP and actions taken in accordance with SSMP; vi. Each period during which a continuous monitoring system (CMS) is malfunctioning or inoperative; (continued below) (continued from above) vii. All required measurements needed to demonstrate compliance with a relevant standard; viii. All results of performance test, CMS performance evaluations, and opacity and visible emission observations; ix. All measurements as may be necessary to determine the conditions of performance tests and performance evaluations; x. All CMS calibration checks; xi. All adjustments and maintenance performed on CMS; xii. Any information demonstrating whether a source is meeting the requirements for a waiver of recordkeeping or reporting requirements, if applicable; xiii. Not applicable xiv. All documentation supporting initial notifications and notifications of compliance status under 40 CFR Section CFR Section 63.10(b)(2) ; Minn. R CFR Section 63.10(b)(2) ; Minn. R (continued)

19 TABLE B: SUBMITTALS Facility Name: AmeriPride Services Inc - Minneapolis Permit Number: Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term. B-1 Send any application for a permit or permit amendment to: Fiscal Services Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 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 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 submittals that are required to be submitted to the U.S. EPA regional office to: Chief Air Enforcement 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 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.

20 TABLE B: RECURRENT SUBMITTALS Facility Name: AmeriPride Services Inc - Minneapolis Permit Number: B-2 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 Permit Issuance. 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 have occurred, the Permittee shall submit the report stating no deviations. Compliance Certification due 31 days after end of each calendar year following Permit Issuance (for the previous calendar year). The Permittee shall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. Total Facility