Draft Air Individual Permit Part 70 Reissuance County Road 25 Saint Louis Park, MN55416 Hennepin County

Transcription

1 Draft Air Individual Permit Part 70 Reissuance Permittee: Facility name: Northland Aluminum Products Inc Northland Aluminum Products Inc 5005 County Road 25 Saint Louis Park, MN55416 Hennepin County Expiration date: [five years from issuance] * All Title I Conditions do not expire Part 70 Reissuance: [Amendment Issue Date] Permit characteristics: Federal; Part 70/ Limits to avoid NSR; Limits to avoid NSR The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the Permit Applications Table. This permit reissuance supersedes Air Emission Permit No and authorizes the Permittee to operate and modify the stationary source at the address listed above unless otherwise noted in the permit. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR and as such are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Signature: [ ] for 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. Stack Parameters Used in NAAQS Modeling for PM Appendix C. Stack Parameters Used in NAAQS Modeling for PM Appendix D. Maximum Material Content, Maximum Capacity, and Minimum Transfer Efficiency Appendix E. Part 63 Subpart MMMM Compliance Equations Page

3 Permit issued: [month day, year] Permit expires: [month day, year] Page 3 of Permit applications table Subsequent permit applications: Title description Application receipt date Action number Part 70 Reissuance 06/18/ Supplemental Application Material 03/05/ Supplemental Application Material (Modeling) 11/30/ Minor Amendment 08/31/

4 Permit issued: [month day, year] Permit expires: [month day, year] 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: [month day, year] Permit expires: [month day, year] Page 5 of Facility description The Northland Aluminum Products Inc (Facility) is located at 5005 County Road 25 in Saint Louis Park, Hennepin County, Minnesota. Northland Aluminum Products, Inc. (NAP) manufactures metal and plastic cookware/bakeware and conducts some custom parts surface coating. Air emission sources at the facility include plastics compression molding, combustion, thermal spraying and coating. The plastics compression molding operation consists of twelve molders (EQUI 43 - EQUI 54). The site's combustion equipment includes boilers (EQUI 16 and EQUI 19), emergency generators (EQUI 17 and EQUI 40), process heaters (EQUI 41 and EQUI 42) and curing ovens (EQUI 28 - EQUI 37) fueled by natural gas. The facility's thermal spraying operations (EQUI 12) are controlled by a fabric filter (TREA 2). Spray guns are cleaned in a former paint booth (EQUI 25). Coating line operations at the spray booths (EQUI 1 - EQUI 11, EQUI 18, EQUI 20 and EQUI 22 - EQUI 24) include spray application of liquid and powder coatings. All of the facility's coating lines have panel filters (TREA 1, TREA 3 - TREA 13, TREA 15 - TREA 17, and TREA 19) for particulate control. The facility has taken measures to make the portions of the two buildings that contain the coating lines total enclosures, so that it is assumed that the pollution control devices achieve 100% capture efficiency. The Facility is a major source under the Part 70 permitting program, a synthetic minor source under the Prevention of Significant Deterioration (PSD) program and a major source under the National Emission Standards for Hazardous Air Pollutants program.

6 Permit issued: [month day, year] Permit expires: [month day, year] Page 6 of Summary of subject items SI ID: Description TFAC 1: Northland Aluminum Products Inc ACTV 3: All IA'a COMG 1: New Direct Heating Equipment COMG 4: Indirect Heating Equipment COMG 5: VOC and PM Sources COMG 6: Panel Filters COMG 7: Surface Coating Operations (NESHAP MMMM) Relationshi p Type has members has members has members has members has members Related SI ID: Description EQUI 28, EQUI 29, EQUI 31, EQUI 33, EQUI 34, EQUI 35, EQUI 36, EQUI 37 EQUI 30, EQUI 32 EQUI 1, EQUI 2, EQUI 3, EQUI 4, EQUI 5, EQUI 6, EQUI 7, EQUI 8, EQUI 9, EQUI 10, EQUI 11, EQUI 12, EQUI 18, EQUI 20, EQUI 22, EQUI 23, EQUI 24, EQUI 25, EQUI 43, EQUI 44, EQUI 45, EQUI 46, EQUI 47, EQUI 48, EQUI 49, EQUI 50, EQUI 51, EQUI 52, EQUI 53, EQUI 54 TREA 1, TREA 3, TREA 4, TREA 5, TREA 6, TREA 7, TREA 8, TREA 9, TREA 10, TREA 11, TREA 12, TREA 13, TREA 15, TREA 16, TREA 17, TREA 19 EQUI 1, EQUI 2, EQUI 3, EQUI 4, EQUI 5, EQUI 6, EQUI 7, EQUI 8, EQUI 9, SI ID: Description Relationshi p Type COMG 8: Molding Room has members COMG 11: Building 1 Automated Booth Limit COMG 12: Building 2 Automated Booth Limit EQUI 1: Line A Primer Paint Booth EQUI 1: Line A Primer Paint Booth EQUI 2: Line A Finish Paint Booth EQUI 2: Line A Finish Paint Booth EQUI 3: Line B Primer Paint Booth EQUI 3: Line B Primer Paint Booth EQUI 4: Line B Finish Paint Booth EQUI 4: Line B Finish Paint Booth EQUI 5: Line C Primer Paint Booth has members has members sends to is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to Related SI ID: Description EQUI 10, EQUI 11, EQUI 12, EQUI 18, EQUI 20, EQUI 22, EQUI 23, EQUI 24 EQUI 43, EQUI 44, EQUI 45, EQUI 46, EQUI 47, EQUI 48, EQUI 49, EQUI 50, EQUI 51, EQUI 52, EQUI 53, EQUI 54 EQUI 1, EQUI 2, EQUI 9, EQUI 10, EQUI 11, EQUI 18 EQUI 3, EQUI 4, EQUI 5, EQUI 6, EQUI 7, EQUI 8 STRU 12: Line A Primer Paint Booth TREA 19: Mat or Panel Filter STRU 13: Line A Finish Paint Booth TREA 3: Mat or Panel Filter STRU 14: Line B Primer Paint Booth TREA 4: Mat or Panel Filter STRU 15: Line B Finish Paint Booth TREA 5: Mat or Panel Filter STRU 16: Line C Primer Paint

7 Permit Expires: [month day, year] Page 7 of 83 SI ID: Description EQUI 5: Line C Primer Paint Booth EQUI 6: Line C Finish Paint Booth EQUI 6: Line C Finish Paint Booth EQUI 7: Line D Primer Paint Booth EQUI 7: Line D Primer Paint Booth EQUI 8: Line D Finish Paint Booth EQUI 8: Line D Finish Paint Booth EQUI 9: Line E Paint Booth EQUI 9: Line E Paint Booth EQUI 10: Line F Primer Paint Booth EQUI 10: Line F Primer Paint Booth EQUI 11: Line F Finish Paint Booth EQUI 11: Line F Finish Paint Booth EQUI 12: Line D Thermal Spray Booth EQUI 12: Line D Thermal Spray Booth EQUI 16: Crown Boiler Relationshi p Type is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to is controlled by Related SI ID: Description Booth TREA 6: Mat or Panel Filter STRU 17: Line C Finish Paint Booth TREA 7: Mat or Panel Filter STRU 18: Line D Primer Paint Booth TREA 8: Mat or Panel Filter STRU 19: Line D Finish Paint Booth TREA 9: Mat or Panel Filter STRU 20: Line E Primer Paint Booth TREA 10: Mat or Panel Filter STRU 21: Line F Primer Paint Booth TREA 11: Mat or Panel Filter STRU 22: Line F Finish Paint Booth TREA 12: Mat or Panel Filter sends to STRU 29: Thermal Spray Booth is controlled by TREA 2: Fabric Filter - Low Temperature, i.e., T<180 Degrees F sends to STRU 10: Emergency SI ID: Description EQUI 17: Emergency Generator Engine EQUI 18: Line E Ferro Prime Booth EQUI 18: Line E Ferro Prime Booth Relationshi p Type Related SI ID: Description Generator/Cro wn Boiler sends to STRU 10: Emergency Generator/Cro wn Boiler sends to STRU 11: Ferro Prime Booth is controlled by TREA 1: Mat or Panel Filter EQUI 19: Pennant Boiler sends to STRU 6: Pennant Boiler EQUI 20: Line G Spray Booth sends to STRU 23: Line G Spray Booth EQUI 20: Line G Spray Booth is controlled TREA 13: Mat or Panel Filter by EQUI 22: Line J1 Paint sends to STRU 25: Line Booth EQUI 22: Line J1 Paint Booth EQUI 23: Line J2 Paint Booth EQUI 23: Line J2 Paint Booth EQUI 24: Line J3 Paint Booth EQUI 24: Line J3 Paint Booth EQUI 25: Line H2 Paint Booth EQUI 25: Line H2 Paint Booth is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to J1 Paint Booth TREA 15: Mat or Panel Filter STRU 26: Line J2 Paint Booth TREA 16: Mat or Panel Filter STRU 27: Line J3 Paint Booth TREA 17: Mat or Panel Filter STRU 28: Line H2 Paint Booth TREA 18: Mat or Panel Filter EQUI 28: Line A Curing Oven STRU 33: Line A Curing Oven EQUI 29: Line B Curing sends to STRU 34: Line Oven B Curing Oven EQUI 30: Line C Curing sends to STRU 35: Line Oven C Curing Oven EQUI 31: Line D Curing sends to STRU 36: Line Oven D Curing Oven EQUI 32: Line E Curing sends to STRU 37: Line Oven E Curing Oven EQUI 33: Line F Curing sends to STRU 38: Line

8 Permit Expires: [month day, year] Page 8 of 83 SI ID: Description Oven EQUI 34: Line G Curing Oven EQUI 35: Line H1 Curing Oven EQUI 36: Line J2 Curing Oven EQUI 37: Line J3 Curing Oven EQUI 40: 70 kw Emergency Generator EQUI 41: Parts Washer 1 Burner EQUI 42: Parts Washer 2 Burner EQUI 43: Compression molder #4 using BMC polyester (styrene) EQUI 43: Compression molder #4 using BMC polyester (styrene) EQUI 44: Compression molder #344 using BMC polyester (styrene) EQUI 44: Compression molder #344 using BMC polyester (styrene) EQUI 45: Compression molder #350 using BMC polyester (styrene) EQUI 45: Compression molder #350 using BMC polyester (styrene) EQUI 46: Compression molder #82 using BMC polyester (styrene) EQUI 46: Compression molder #82 using BMC polyester (styrene) EQUI 47: Compression molder #83 using BMC polyester (styrene) Relationshi Related SI ID: p Type Description F Curing Oven sends to STRU 39: Line G Curing Oven sends to STRU 40: Line H1 Curing Oven sends to STRU 41: Line J2 Curing Oven sends to STRU 42: Line J3 Curing Oven sends to STRU 10: Emergency Generator/Cro wn Boiler sends to STRU 43: Stack/Vent for Parts Washer 1 Burner sends to STRU 44: Stack/Vent for Parts Washer 2 Burner sends to STRU 30: Molding Room Exhaust sends to STRU 31: New Molders Exhaust sends to STRU 30: Molding Room Exhaust sends to STRU 31: New Molders Exhaust sends to STRU 30: Molding Room Exhaust sends to STRU 31: New Molders Exhaust sends to STRU 30: Molding Room Exhaust sends to STRU 31: New Molders Exhaust sends to STRU 30: Molding Room Exhaust EQUI 47: Compression sends to STRU 31: New SI ID: Description molder #83 using BMC polyester (styrene) EQUI 48: Compression molder #84 using BMC polyester (styrene) EQUI 48: Compression molder #84 using BMC polyester (styrene) EQUI 49: Compression molder #85 using BMC polyester (styrene) EQUI 49: Compression molder #85 using BMC polyester (styrene) EQUI 50: Compression molder #351 using BMC polyester (styrene) or phenolic plastic EQUI 50: Compression molder #351 using BMC polyester (styrene) or phenolic plastic EQUI 51: Compression molder #352 using BMC polyester (styrene) or phenolic plastic EQUI 51: Compression molder #352 using BMC polyester (styrene) or phenolic plastic EQUI 52: Compression molder #353 using phenolic plastic EQUI 52: Compression molder #353 using phenolic plastic EQUI 53: Compression molder #354 using phenolic plastic EQUI 53: Compression molder #354 using phenolic plastic EQUI 54: Compression molder #86 using BMC polyester (styrene) EQUI 54: Compression molder #86 using BMC polyester (styrene) STRU 1: Building 1 - Main Relationshi Related SI ID: p Type Description Molders Exhaust sends to STRU 30: Molding Room Exhaust sends to STRU 31: New Molders Exhaust sends to STRU 30: Molding Room Exhaust sends to STRU 31: New Molders Exhaust sends to STRU 30: Molding Room Exhaust sends to STRU 31: New Molders Exhaust sends to STRU 30: Molding Room Exhaust sends to STRU 31: New Molders Exhaust sends to STRU 30: Molding Room Exhaust sends to STRU 31: New Molders Exhaust sends to STRU 30: Molding Room sends to Exhaust STRU 31: New Molders Exhaust sends to STRU 30: Molding Room Exhaust sends to STRU 31: New Molders Exhaust

9 Permit Expires: [month day, year] Page 9 of 83 SI ID: Description STRU 2: Building 2 - Coatings STRU 3: Building 3 - Packaging STRU 4: Building 5 STRU 5: Building 6 STRU 6: Pennant Boiler STRU 10: Emergency Generator/Crown Boiler STRU 11: Ferro Prime Booth STRU 12: Line A Primer Paint Booth STRU 13: Line A Finish Paint Booth STRU 14: Line B Primer Paint Booth STRU 15: Line B Finish Paint Booth STRU 16: Line C Primer Paint Booth STRU 17: Line C Finish Paint Booth STRU 18: Line D Primer Paint Booth STRU 19: Line D Finish Paint Booth STRU 20: Line E Primer Paint Booth STRU 21: Line F Primer Paint Booth STRU 22: Line F Finish Paint Booth STRU 23: Line G Spray Booth STRU 25: Line J1 Paint Booth STRU 26: Line J2 Paint Booth STRU 27: Line J3 Paint Booth STRU 28: Line H2 Paint Booth STRU 29: Thermal Spray Booth STRU 30: Molding Room Exhaust STRU 31: New Molders Exhaust STRU 33: Line A Curing Relationshi p Type Related SI ID: Description SI ID: Description Oven STRU 34: Line B Curing Oven STRU 35: Line C Curing Oven STRU 36: Line D Curing Oven STRU 37: Line E Curing Oven STRU 38: Line F Curing Oven STRU 39: Line G Curing Oven STRU 40: Line H1 Curing Oven STRU 41: Line J2 Curing Oven STRU 42: Line J3 Curing Oven STRU 43: Stack/Vent for Parts Washer 1 Burner STRU 44: Stack/Vent for Parts Washer 2 Burner STRU 45: Warehouse STRU 46: Building 7: Shipping TREA 1: Mat or Panel Filter TREA 2: Fabric Filter - Low Temperature, i.e., T<180 Degrees F TREA 3: Mat or Panel Filter TREA 4: Mat or Panel Filter TREA 5: Mat or Panel Filter TREA 6: Mat or Panel Filter TREA 7: Mat or Panel Filter TREA 8: Mat or Panel Filter TREA 9: Mat or Panel Filter TREA 10: Mat or Panel Filter TREA 11: Mat or Panel Filter TREA 12: Mat or Panel Relationshi p Type Related SI ID: Description

10 Permit Expires: [month day, year] Page 10 of 83 SI ID: Description Filter TREA 13: Mat or Panel Filter TREA 15: Mat or Panel Filter TREA 16: Mat or Panel Relationshi p Type Related SI ID: Description SI ID: Description Filter TREA 17: Mat or Panel Filter TREA 19: Mat or Panel Filter Relationshi p Type Related SI ID: Description

11 Permit Expires: [month day, year] Page 11 of Limits and other requirements TFAC Northland Aluminum Products Inc 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)] The Permittee shall implement the following physical changes needed to model compliance with the PM2.5 NAAQS/MAAQS within 365 calendar days after Permit Issuance Date. The Permittee shall combine the primer and finish booth stacks for each line A - F. For each of the remaining stacks on lines A-F, the Permittee shall raise the stack height 12 feet and construct a hi-fume structure at the exhaust exit point. These stack include: STRU 12, STRU 15, STRU 16, STRU 18, STRU 20 and STRU 21. Stacks to be decommissioned include: STRU 11, STRU 13, STRU 14, STRU 17, STRU 19 and STRU 22. Stack parameters are listed in Appendix C. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] This permit establishes limits on the facility to keep it a minor source under New Source Review. The Permittee cannot make any change at the source that would make the source a major source under New Source Review until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Equipment Labeling: The Permittee shall permanently affix a unique number to each emissions unit for tracking purposes. The numbers shall correlate the unit to the appropriate Subject Item numbers used in this permit. The number can be affixed by placard, stencil, or other means. The number shall be maintained so that it is readable and visible at all times from a safe distance. If equipment is added, it shall be given a new unique number; numbers from replaced or removed equipment shall not be reused. [Minn. R.

12 Permit Expires: [month day, year] Page 12 of , subp. 2] Equipment Inventory: The Permittee shall maintain a written list of all emissions units and control equipment on site. The Permittee shall update the list to include any replaced, modified, or new equipment prior to making the change. The list shall correlate the units to the Subject Item numbers used in this permit and shall include the data on GI-04, GI-05A, GI-05B, and GI-05F. The date of construction shall be the date the change was made for replaced, modified, or new equipment. [Minn. R , subp. 2] 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: Insignificant Activities and General Applicable Requirement, D: Maximum Material Content, Maximum Capacity, and Minimum Transfer Efficiency, and E: Part 63 Subpart MMMM Compliance Equations. Modeling parameters in Appendices B: Stack Parameters Used in NAAQS Modeling for PM10 and C: Stack Parameters Used in NAAQS Modeling for PM2.5 are included for reference only as described elsewhere in this permit. [Minn. R , subp. 2] The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R to Compliance shall be demonstrated upon written request by the MPCA. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] 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)]

13 Permit Expires: [month day, year] Page 13 of Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R , subp. 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] Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in this permit. [Minn. R. ch. 7017] Performance Test Notifications and Submittals: Performance Test Notification and 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 The Notification, Test Plan, and Test Report must be submitted in a format specified by the commissioner. [Minn. R , Minn. R , subps. 1-4, Minn. R , subps. 1-2] 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. [Minn. R , subp. 3] 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

14 Permit Expires: [month day, year] Page 14 of 83 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)] Modeled Parameters for PM10 and PM2.5: The parameters used in PM10 modeling for permit number are listed in Appendix B of this permit. The parameters used in PM2.5 modeling for permit number are listed in Appendix C of this permit. The parameters describe the operation of the facility at maximum permitted capacity. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Equivalent or Better Dispersion (EBD) Modeling Triggers (Modeling Required) for PM2.5: Any changes that affect any modeled PM2.5 parameter or emission rate listed in Appendix C, or an addition to the information documented in Appendix C, trigger the EBD Remodeling Submittal requirement. This includes changes that do not require a permit amendment as well as changes that require any type of permit amendment. Changes made under the Administrative amendment process are excluded from this requirement. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] EBD Modeling Submittal for PM2.5: For changes meeting the criteria in the EBD Modeling Triggers (Modeling Required) requirement, the Permittee shall submit an EBD modeling submittal in accordance with the current version of the MPCA Air Dispersion Modeling Guidance and shall wait for written approval (for major amendments, in the form of an issued permit amendment; for moderate amendments, in the form of a construction authorization letter) before making such changes. For changes that do not require a moderate or major amendment, written approval of the EBD modeling may be given before permit issuance; however, this approval applies only to the EBD modeling and not to any other changes. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R.

15 Permit Expires: [month day, year] Page 15 of , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] EBD Modeling Submittal Content for PM2.5: The information submitted must include, for stack and vent sources, source emission rate, location, height, diameters, exit velocity, exit temperature, discharge direction, use of rain caps or rain hats, and, if applicable, locations and dimensions of nearby buildings. For non-stack/vent sources, this includes the source emission rate, location, size and shape, release height, and, if applicable, any emission rate scalars, and the initial lateral dimensions and initial vertical dimensions and adjacent building heights. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Outdated EBD Baseline Modeling for PM2.5: Prior to conducting the EBD analysis, the Permittee shall use the current version of the MPCA Air Dispersion Modeling Guidance to determine if the Baseline Modeling (the most recent refined modeling demonstration) is outdated. If the Baseline Modeling is outdated, the Permittee shall update the Baseline Modeling to be consistent with the current version of the MPCA Air Dispersion Modeling Guidance. The updated modeling will become the new Baseline Modeling. This requirement does not require the Permittee to complete a new refined modeling demonstration using the revisions made for the EBD demonstration. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] EBD Modeling Results for PM2.5: The dispersion characteristics due to the revisions of the information in Appendix C must be equivalent to or better than the dispersion characteristics modeled for the modeling report submitted on November 30, The Permittee shall demonstrate this equivalency in the proposal. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Computer Dispersion Modeling Triggers for PM2.5: The Permittee shall conduct a refined remodeling analysis in accordance with the Computer Dispersion Modeling requirements of this permit and the current version of the MPCA Air Dispersion Modeling Guidance if: (1) the results of the EBD modeling analysis do not demonstrate equivalent or better dispersion characteristics; (2) a conclusion cannot readily be made about the dispersion, or (3) the criteria in the EBD Modeling Triggers requirement are met and the Permittee has previously conducted three successive EBD analyses using the same Baseline Modeling. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. R ,

16 Permit Expires: [month day, year] Page 16 of 83 Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Computer Dispersion Modeling Protocol: due 180 days after receipt of written MPCA request for PM2.5 refined modeling. The Permittee shall submit a Computer Dispersion Modeling Protocol that is complete and approvable by MPCA by the deadline in this requirement. This protocol will describe the proposed modeling methodology and input data, in accordance with the current version of the MPCA Air Dispersion Modeling Guidance. The protocol must be based on projected operating conditions under the next permit term. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to the submitted protocol for PM2.5 modeling. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Computer Dispersion Modeling Results: due 180 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol for PM2.5. The Permittee shall submit a final Computer Dispersion Modeling Report that is complete and approvable by MPCA by the deadline in this requirement. The submittal shall adhere to the current version of the MPCA Air Dispersion Modeling Guidance and the approved Computer Dispersion Modeling Protocol. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] 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)] 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 expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. 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

17 Permit Expires: [month day, year] Page 17 of 83 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; 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

18 Permit Expires: [month day, year] Page 18 of 83 vary, depending on the type of amendment needed. 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. [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 GP003 Direct Heating Equipment Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R This limit applies to each unit individually. [Minn. R , subp. 1(A)(1)] Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. This limit applies to each unit individually. [Minn. R , subp. 1(A)(2)] The Permittee shall burn only natural gas in EQUI 28, EQUI 29, EQUI 31, EQUI 33, EQUI 34, EQUI 35, EQUI 36 and EQUI 37. [Minn. R , subp. 35a] The Permittee shall keep records of fuel type and usage on a monthly basis. [Minn. R , subp. 5] COMG 4 GP002 Indirect Heating Equipment Particulate Matter <= 0.4 pounds per million Btu heat input. This limit applies to each unit individually. The potential to emit from EQUI 30 is lb/mmbtu due to equipment design and allowable fuels. The potential to emit from EQUI 32 is lb/mmbtu due to equipment design and allowable fuels. [Minn. R , subp. 1] Opacity <= 20 percent opacity except for one six-minute period per

19 Permit Expires: [month day, year] Page 19 of 83 hour of not more than 60 percent opacity. This limit applies to each unit individually. [Minn. R , subp. 2] The Permittee shall burn only natural gas in EQUI 30 and EQUI 32. [Minn. R. ch , subp. 35a] The Permittee shall keep records of fuel type and usage on a monthly basis. [Minn. R , subp. 5] COMG 5 GP004 VOC and PM Sources Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R This limit applies to each unit individually. EQUI 9 is subject to Minn. R ; all other equipment in COMG 5 are subject to Minn. R [Minn. R , subp. 1(A), Minn. R , subp. 1(A)] Opacity <= 20 percent opacity. This limit applies to each unit individually. EQUI 9 is subject to Minn. R ; all other equipment in COMG 5 are subject to Minn. R [Minn. R , subp. 1(B), Minn. R , subp. 1(B)] The Permittee shall limit emissions of Volatile Organic Compounds <= 200 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 under the Volatile Organic Compounds: Monthly Recordkeeping requirement in COMG 5. All VOC-emitting equipment in COMG 5 is subject to this limit. If the Permittee replaces any existing non-combustion VOC-emitting equipment, adds new non-combustion VOC-emitting equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the requirements in COMG 5 and, if the equipment is a compression molder, COMG 8. 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 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. VOC contents for each VOC-containing material shall be determined as described under the Material Content requirement in COMG 5. The calculation of VOCs used may take into account recovered/recycled VOCs as described under the Waste Credit requirement in COMG 5. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall vent emissions from EQUI 1 - EQUI 11, EQUI 18, EQUI 20, EQUI 22 - EQUI 24 to control equipment meeting the

20 Permit Expires: [month day, year] Page 20 of 83 requirements of COMG 6 whenever any of the following operates: EQUI 1 - EQUI 11, EQUI 18, EQUI 20 and EQUI 22 - EQUI 24. The Permittee shall vent emissions from EQUI 12 to control equipment meeting the requirements of TREA 2 whenever EQUI 12 operates. The Permittee shall document periods of non-operation of the control equipment. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Total Enclosure Requirements: All painting and coating operations shall be conducted in a total enclosure (building or a portion of a building) meeting the following requirements: 1.) All air vented from the total enclosure shall be sent through air pollution control equipment meeting the requirements of COMG 6 or TREA 2. 2.) All windows and uncontrolled air vents leading to/from the total enclosure shall remain closed during operation of any of the paint booths. 3.) All other openings or doors leading to/from the total enclosure shall remain closed or equipped with overlapping strip doors or air curtains. [Minn. R , subp. 7(A), Minn. R , subp. 7(L), Minn. R , subp. 7(M), Minn. R , subp. 1, Minn. R , subp. 2, Minn. R , subp. 4, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Air Curtain Requirements: The air curtains shall be operated at all items that any of the paint booths are in operation. The air curtains shall be maintained and operated according to the manufacturers' specifications. [Minn. R , subp. 7(A), Minn. R , subp. 7(L), Minn. R , subp. 7(M), Minn. R , subp. 1, Minn. R , subp. 2, Minn. R , subp. 4, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Maximum Contents of Materials and Application Rate: The Permittee assumed certain worst-case contents of materials when determining the short term potential to emit of units in COMG 5. These assumptions are listed in Appendix D of this permit. Changing to a material that has a higher content of any of the given pollutants or increasing the application rate 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]

21 Permit Expires: [month day, year] Page 21 of Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the total quantity of all coatings and other VOC, solids, and HAP-containing materials used at the facility. This shall be based on written usage logs and/or flowmeters. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Volatile Organic Compounds: Monthly Recordkeeping -- VOC Emissions. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total usage of VOC-containing materials for the previous calendar month using the daily usage records. This record shall also include the VOC contents of each material as determined by the Material Content requirement of this permit; 2) The VOC emissions for the previous month using the formulas specified in this permit; and 3) The 12-month rolling sum VOC emissions for the previous 12- month period by summing the monthly VOC emissions data for the previous 12 months. [Minn. R , subps. 4-5] Volatile Organic Compounds: Monthly Calculation -- VOC Emissions. The Permittee shall calculate VOC emissions using the following equations: E(VOC) = sum (X(coatings/solvents) x U (coatings/solvents)) + sum(ef x U (molding)) sum(x (offsite recycling) x U (offsite recycling)) where: E = 12-month rolling sum emissions (tons/yr); X = VOC content by weight (lb VOC/lb material); U = Usage for the previous 12-month rolling period (tons/yr); EF = 0.03 lb VOC/lb material injected for reinforced plastics and g VOC/lb material injected for phenolic plastics. [Minn. R , subps. 4-5] Material Content. VOC and Solids (PM, PM<10 microns, and PM<2.5 microns) 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 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 and solids contents. The Commissioner reserves the right to require the Permittee to determine the VOC and solids contents of any material, 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]

22 Permit Expires: [month day, year] Page 22 of Waste Credit: If the Permittee elects to obtain credit for VOC shipped in waste materials, the Permittee shall either use item 1 or 2 to determine the VOC content for each credited shipment. 1) The Permittee shall analyze a composite sample of each waste shipment to determine the weight content of VOC, excluding water. 2) The Permittee may use supplier data for raw materials to determine the VOC contents of each waste shipment, using the same content data used to determine the content of raw materials. If the waste contains several materials, the content of mixed waste shall be assumed to be the lowest VOC content of any of the materials. [Minn. R , subps. 4-5] Signage and Inspection of Building Openings: The Permittee shall post signs on all doors and windows leading to the outside from Buildings 1 & 2 total enclosures, stating that the doors and windows must remain closed while the paint booths are in operation. The Permittee shall conduct inspections at least once each calendar week, while the paint booths are in use, to determine if the doors and windows are closed as required by this permit. The Permittee shall maintain a written record of the inspections and any corrective action taken. [Minn. R , subp. 1, Minn. R , subp. 7(M), Minn. Stat , subd. 4a, Minn. R , subp. 7(L), Minn. Stat , subd. 9, Minn. R , subp. 7(A), Minn. R , subp. 2, Minn. R , Minn. R , subp. 4] Signage and Inspection of Air Curtains: The Permittee shall post signs at each exit that has an air curtain that states that the air curtain must be operated at all times that any of the spray booths are in operation. The Permittee shall conduct inspections at least once each calendar week, while the paint booths are in use, to determine if the air curtains are in operation as required by this permit. The Permittee shall maintain a written record of the inspections and any corrective action taken. [Minn. R , subp. 7(A), Minn. R , subp. 7(L), Minn. R , subp. 7(M), Minn. R , subp. 1, Minn. R , subp. 2, Minn. R , subp. 4, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] COMG 6 GP005 Panel Filters The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Total Particulate Matter >= 97 percent control efficiency. This limit applies individually to each member of COMG 6. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall operate and maintain control equipment such