TECHNICAL SUPPORT DOCUMENT For DRAFT AIR EMISSION PERMIT NO

Transcription

1 TECHNICAL SUPPORT DOCUMENT For DRAFT AIR EMISSION PERMIT NO This technical support document (TSD) is intended for all parties interested in the draft permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR 70.7(a)(5) and Minn. R , subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft permit. 1. General Information 1.1 Applicant and Stationary Source Location Table 1. Applicant and Source Address Stationary Source/Address Applicant/Address (SIC Code: 3365, 3324) Jordan Carley Carley Foundry, Inc Coral Sea St NE 8301 Coral Sea St NE Blaine Blaine Ramsey County, Minnesota Ramsey County, Minnesota Contact: Randy Oehrlein Phone: Facility Description Carley Foundry is an aluminum and steel investment foundry. Carley primarily produces aluminum castings with over 60 Aluminum furnaces, but because there are two steel electric furnaces located at the facility as well, it is also considered a steel foundry. The facility also contains knockout, shakeout, burnout, abrasive blasting, core molding, and sand handling equipment; boilers, core ovens, heat treat ovens, quench tanks, emergency generators, and a variety of insignificant activities. The main pollutants of concern are particulate matter (PM), particulate matter less than 10 microns (PM 10 ), particulate matter less than 2.5 microns (PM 2.5 ), and volatile organic compounds (VOC). Carley Foundry is limiting their potential to emit (PTE) so that they can be classified as a non-major source under the Part 70 permit program. The facility controls all VOC-emitting core molding processes with a gas scrubber. There are 15 fabric filters and five panel filters controlling PM emissions from certain knockout, shakeout, abrasive blasting, and sand handling processes. The facility also controls PM and VOC emissions from its investment casting processes with four direct flame afterburners. As a result of these controls, Carley Foundry qualifies for an individual state operating permit. 1.3 Facility History Carley Foundry is a third generation family owned business that was established in By 1984, the business was running out of room in its original New Brighton facility so a new plant was built in Blaine, site of the current facility. Both plants were in operation until 1994 when the New Brighton facility was closed and relocated to an addition of the Blaine plant. This will be the first air permit issued to Carley Foundry. The Minnesota Pollution Control Agency (MPCA) issued an Administrative Penalty Order (APO) on August 29, 2014, to Carley Foundry for not having an air permit. According to the APO, Carley Foundry failed to obtain an air permit when it exceeded the state permitting threshold for PM 10 in 1999 Technical Support Document, Permit Action Number: Page 1 of 19

2 due to the addition of furnaces and molding machines. In , Carley Foundry failed again to obtain an air permit when potential VOC emissions exceeded federal permitting thresholds due to the addition of casting, semi-permanent mold hubs, ovens, and furnaces. The MPCA received a registration permit application from Carley Foundry on 09/17/2012. The permit application was returned on 11/29/2012 because the facility did not qualify for a registration permit due to being above emission thresholds, and subject to NSPS UUU. Carley Foundry submitted a permit application for an individual state operating permit on 01/13/2014. This application was returned on 02/11/2014 because it was deemed incomplete. The MPCA received a new state permit application from Carley Foundry on 06/25/2014. This new permit application requested to waive the statutory right to a completeness review in 30 days, and was later deemed incomplete, but the MPCA did not return the permit application. Based on the information the Permittee submitted to the MPCA, as of 10/07/2014, the Permittee has completed all the corrective actions contained in the APO. 1.4 Description of the Activities Allowed by this Permit Action This permit action is a State operating permit. 1.5 Facility Emissions PM tpy Table 3. Total Facility Potential to Emit Summary PM 10 tpy PM 2.5 tpy SO 2 tpy NO x tpy CO tpy CO 2 e tpy VOC tpy Single HAP tpy Total Facility Limited Potential Emissions , Total Facility Actual Emissions (2013) * 24.4 * *Not reported in MN emission inventory. Table 4. Facility Classification Classification Major Synthetic Minor/Area Minor/Area PSD X Part 70 Permit Program X Part 63 NESHAP X 2. Regulatory and/or Statutory Basis New Source Review The facility is a non-major source under New Source Review regulations. No changes are authorized by this permit. Part 70 Permit Program The facility is limiting emissions so that it is classified as a non-major source under the Part 70 permit program. All HAPs tpy Technical Support Document, Permit Action Number: Page 2 of 19

3 New Source Performance Standards (NSPS) The facility is subject to 40 CFR pt. 60, subp. UUU Standards of Performance for Calciners and Dryers in Mineral Industries. This standard does not specifically state that it applies to the foundry industry, only to the mineral processing industry. However, due to some applicability determinations made by the EPA early in the implementation of this standard, thermal reclaimers are considered to meet the broad Subpart UUU definition of calciners and dryers that process industrial sand. EPA Applicability Determination Index Control Number: , dated 01/05/2000, Titled NSPS Applicability to Sand Reclamation Facilities, states that furnaces used in sand reclamation facilities would be subject to Subpart UUU because industrial sand is a nonmetallic mineral and the rule does not specify a size or throughput cutoff. The applicability determination also states that Subpart UUU identifies a number of specific types of calciners and dryers that are exempt from opacity monitoring because their particulate emissions are known to be less than 11 tons per year. In several previous determinations the EPA has extended this exemption to other types of calciners and dryers that emit less than 11 tons of particulate per year. The thermal sand reclaimer (EU 134) at Carley Foundry has an unrestricted PTE for total PM of less than 3 tons per year, and as a result should be exempt from opacity monitoring. The EPA Applicability document and further details can be found in attachment 4 of this TSD. In regards to sand reclamation processes being subject to NSPS, 40 CFR pt. 60, subp. OOO, the EPA determination also states that the applicability of Subpart OOO depends upon whether the process is used to merely break up the organic binder that holds the molds together or whether the process also results in size reduction of the sand particles in the mold. The operations that take place at Carley Foundry are only done to break down the organic binder holding the sand together and as a result is not subject to Subpart OOO. The EPA Applicability document and further details can be found in attachment 4 of this TSD. The emergency diesel generator (EU 208) is required by NESHAP, 40 CFR pt. 63, subp. ZZZZ to meet the requirements of NSPS, 40 CFR pt. 60, subp. IIII. Pursuant to 40 CFR Section (a)(2), the provisions of NSPS Subpart IIII are applicable to owners and operators of stationary CI ICE that commence construction after July 11, EU 208 commenced construction in As a result, there are no applicable requirements for this unit. There are two natural gas emergency generators (EU 024 and EU 209) are required by NESHAP, 40 CFR pt. 63, subp. ZZZZ to meet the requirements of NSPS, 40 CFR pt. 60, subp. JJJJ. Pursuant to 40 CFR Section (a)(4)(iii), engines with a maximum power less than 500 HP must have been manufactured on or after July 1, 2008, and have commenced construction after June 12, EU 024 and EU 209 are both under 500 HP and were manufactured and constructed in As a result, both units are subject to the requirements of Subpart JJJJ. National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility is below the single and combined major thresholds of 10 and 25 tpy, and is considered an area source of HAPS. The following area source NESHAPs apply: Area Source Standards for Aluminum, Copper, and Other Nonferrous Foundries (40 CFR pt. 63, subp. ZZZZZZ) The facility is subject to this NESHAP because it is an aluminum foundry that has an annual Technical Support Document, Permit Action Number: Page 3 of 19

4 metal melt production or an annual metal melt capacity of at least 600 tpy. It applies to GP 001 which contains all natural gas and electric aluminum melting furnaces. NESHAP Iron and Steel Foundries Area Sources (40 CFR pt. 63, subp. ZZZZZ) The facility is subject to this NESHAP because it has two steel melt furnaces (EU033, EU041 contained in GP 002). The facility has an annual melting capacity is 10,000 tons or less, and is considered a small foundry. Notification of Compliance and Size Classification were signed and submitted to the EPA Administrator on 6/13/14. NESHAP for Stationary Reciprocating Internal Combustion Engines (40 CFR pt. 63, subp. ZZZZ) The facility has an emergency diesel generator (EU 023) that is subject to this NESHAP. The emergency engine was installed before June 12, 2006, is greater than 500hp, and is located at an area source of HAP emissions. There are three emergency engines (EU 024, EU 208, EU 209) that are classified as new because they were installed after June 12, Pursuant to 40 CFR Section (c)(1), new sources that are located at an area source must meet the requirements of NESHAP, 40 CFR pt. 63, subp. ZZZZ by meeting the requirements of 40 CFR pt. 60, subp. IIII, for compression ignition engines (EU 208) or 40 CFR pt. 60, subp. JJJJ, for spark ignition engines (EU 024, EU 209). No further requirements apply for such engines under this part. Compliance Assurance Monitoring (CAM) There are no emission units that are achieving compliance with a limitation or standard using an add-on control device. As a result, the facility is not subject to CAM. Minnesota State Rules Portions of the facility are subject to the following Minnesota Standards of Performance: Minn. R Standards of Performance for Stationary Internal Combustion Engines Minn. R Standards of Performance for New Indirect Heating Equipment Minn. R Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment Minn. R Standards of Performance for Post-1969 Industrial Process Equipment Minn. R Stationary Reciprocating Internal Combustion Engines Minn. R Standards of Performance for Listed Control Equipment Table 5. Regulatory Overview of Facility Subject Item* Applicable Regulations Rationale GP CFR pt. 63, subp. ZZZZZZ National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Aluminum, Copper, and Other Nonferrous Foundries GP CFR pt. 63, subp. ZZZZZ National Emission Standards for Hazardous Air Pollutants for Iron and Steel Foundries Area Sources GP 010, GP 011, GP 012, GP 013, GP 016, GP 017, GP 018, GP 020, GP 021, EU 138 GP 023, GP 024, GP 025, GP 027 Minn. R Minn. R Standards of Performance for Post-1969 Industrial Process Equipment Minnesota Standards of Performance for Fossil-Fuel- Burning Direct Heating Equipment Technical Support Document, Permit Action Number: Page 4 of 19

5 Subject Item* Applicable Regulations Rationale GP 015, GP 019, GP 022, GP 026 Minn. R Minnesota Standards of Performance for New Indirect Heating Equipment EU CFR pt. 63, subp. ZZZZ Minn. R National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Minn. R Standards of Performance for Stationary Internal Combustion Engines EU CFR pt. 60, subp. UUU Standards of Performance for Calciners and Dryers in Mineral Industries EU 024, EU CFR pt. 60, subp. JJJJ Minn. R Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Minn. R Standards of Performance for Stationary Internal Combustion Engines EU 208 Minn. R Standards of Performance for Stationary Internal Combustion Engines CE 003, CE 007, CE 008, CE 009, CE 010, CE 011, CE 012, CE 013, CE 014, CE 018, CE 019, CE 020, CE 021, CE 022, CE 023, CE 024, CE 026, CE 027, CE 028, CE 029, CE 030 CE 005, CE 016, CE 020 Title I condition to avoid 40 CFR 70.2 and Minn. R Minn. R Requirements to avoid Minn. R Standards of Performance for Listed Control Equipment and Control Equipment Efficiencies Title I condition to avoid 40 CFR 70.2 and Minn. R Requirements to avoid Minn. R Minn. R Minn. R Standards of Performance for Listed Control Equipment and Control Equipment Efficiencies; Requirements for Certified Hoods CE 015 Title I condition to avoid 40 CFR 70.2 and Minn. R Requirements to avoid Minn. R *Location of the requirement in the permit (e.g., EU, SV, GP, etc.). The language 'This is a state-only requirement and is not enforceable by the U.S. Environmental Protection Agency (EPA) Administrator and citizens under the Clean Air Act' refers to permit requirements that are established only under state law and are not established under or required by the federal Clean Air Act. The language is to clarify the distinction between permit conditions that are required by federal law and those that are required only under state law. State law-only requirements are not enforceable by the EPA or by citizens under the federal Clean Air Act, but are fully enforceable by the MPCA and citizens under provisions of state law. 3. Technical Information 3.1 Calculations of Potential to Emit Attachment 1 to this TSD contains Form GI-07, which summarizes the PTE of the Facility, as well as detailed spreadsheets and supporting information prepared by the MPCA and the Permittee. Technical Support Document, Permit Action Number: Page 5 of 19

6 Many of the foundry emission factors found in AP-42 and FIRE are out dated and not representative of Aluminum Foundries. As a result, Carley Foundry has researched more accurate and representative emission factors from other sources. These alternatives are discussed below: Emission Factors from a 2011 Air Emissions Inventory Summary Report were used because Carley is familiar with an aluminum foundry in Wisconsin (Mercury Marine) that uses similar types of equipment. Specifically these emission factors were used for aluminum melting, pouring, and casting operations (GP019, GP020); and PM/PM 10 for the Thermal Reclaimer (EU134). These factors are approved by WI- DNR Bureau of Air Management, and their origin is cited as the EPA. The report and further details can be found as Attachment 5 to the TSD. For electric induction furnaces (GP020), AP-42 states that CO, SO 2, NO x, and VOC emissions can be considered negligible or have no data (AP-42 Table ). These assumptions are made for Gray Iron Foundries, and hold true to Carley Foundry because of the more conservative nature of aluminum melting versus iron. PM emission factors for natural gas, process gas, and LPG have been revised by Roy Huntley of the EPA. The reason for this adjustment is that the EPA believes that the current AP-42 factors for condensable PM emissions are too high. These values can be found as Attachment 6 to the TSD. Since acquiring PM 2.5 emission factors for various operations is not readily available, a methodology from the South Coast Air Quality Management District document titled, Final-Methodology to Calculate Particulate Matter 2.5 was used along with the most appropriate multiplier fraction found in Appendix A of the referenced document that can be found as Attachment 7 to this TSD. Emission factors for Shakeout equipment (GP011) were obtained from Air Pollution Control requirements for Industrial Sand Mines, publication AM , written by the Wisconsin DNR. Handling from Screening emission factors were used as it is the most representative of how sand is handled during foundry shakeout operations. See Attachment 8 to the TSD for more details. VOC emission factor for the Thermal Reclaimer (EU 134) is from emission rate test data provided by the manufacturer (Thermfire) and can be found in Attachment 9 to the TSD. Investment casting operations (EU 027, EU 031, and EU 034) involves emitting paraffin wax fumes. Emission factors for these processes are not readily available so Carley Foundry used calculations for similar equipment found from a New Hampshire air permit for Wyman-Gordon Investment Castings, Inc. The New Hampshire Department of Environmental Services calculation sheet with further detail can be found as Attachment 10 to the TSD. HAP emission calculations for core molding operations (GP 015) used assumptions from a 2007 AFS (American Foundry Society) publication titled, Reporting of Binder Chemicals Used in Foundries. Further details on this can be found in Attachment 11 to the TSD. 3.2 Monitoring Technical Support Document, Permit Action Number: Page 6 of 19

7 In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considered the following: the likelihood of the facility violating the applicable requirements; whether add-on controls are necessary to meet the emission limits; the variability of emissions over time; the type of monitoring, process, maintenance, or control equipment data already available for the emission unit; the technical and economic feasibility of possible periodic monitoring methods; and the kind of monitoring found on similar units elsewhere. Table 6 summarizes the monitoring requirements Table 6. Monitoring Subject Item* Requirement (basis) Monitoring Discussion GP 001 (Units subject to NESHAP ZZZZZZ) Cover or enclose each melting furnace to the extent practicable GP 002 (Units subject to NESHAP ZZZZZ) Purchase only metal scrap that has been depleted of HAPs Prepare and operate pursuant to a written management practices plan (40 CFR ) Purchase and use of only metal ingots, pig iron, slitter, or other materials that do not include post-consumer automotive body scrap, post-consumer engine blocks, post-consumer oil filters, oily turnings, lead components, chlorinated plastics, or free liquids Use of only iron and steel scrap that has been depleted of organic and metal HAPs Must use a binder chemical formulation that does not use methanol as a specific ingredient of the catalyst formulation. This does not apply to the resin portion of the binder system. (40 CFR ) Required to document conformance with the management practice plan, and metal scrap purchase records The Permittee shall keep a copy of the material specifications and each scrap provider The standards and management practices required by this NESHAP are enough to establish reasonable assurance that the requirements will not be exceeded. The standards and management practices required by this NESHAP are enough to establish reasonable assurance that the requirements will not be exceeded. Technical Support Document, Permit Action Number: Page 7 of 19

8 Subject Item* Requirement (basis) Monitoring Discussion GP 010 None (Knockout) GP011 (Shakeout) GP 012 (Abrasive Blasting) GP 013 (Core Molding- Isocure/Cold Box) GP 015 (Core Molding-Shell Core) Total PM 0.30 grains/dscf Opacity 20% (Minn. R ) Total PM 0.30 grains/dscf Opacity 20% (Minn. R ) Total PM 0.30 grains/dscf Opacity 20% (Minn. R ) Total PM 0.30 grains/dscf Opacity 20% (Minn. R ) Total PM 0.30 grains/dscf Opacity 20% SO lbs/mmbtu heat input Fuel Type: Natural gas only (Minn. R ; Minn. R , subp. 35a) None None None None Knockout cabinets are fully enclosed operations, and the only exhaust assumed is when the doors are opened to remove castings. Due to the design of these operations, it is unlikely that these emissions limits will be exceeded. All shakeout operations are captured with a certified hood and controlled with a dust collector. Due to the design of these operations, it is unlikely that these emission limits will be exceeded. All blasting units are confined, and controlled with a dust collector. Due to the design of these operations it is unlikely that the emission limits will be exceeded. There are almost no PM emissions from these units, and based on the exit flow rate of the associated stack vent, the maximum PM concentration for an individual unit is 0.09 gr/dscf. This is well below the emission limit, and assures that none of the units will be in exceedance. PM emissions only occur during the sand handling process of this operation. The use of moist sand that has the tendency to fall to the floor results in PM emissions of almost 0. This provides adequate assurance that the limit will not be exceeded. GP 016 (7000 Series Molding Machines) GP 017 (Sand Handling-Silos) Total PM 0.30 grains/dscf Opacity 20% (Minn. R ) Total PM 0.30 grains/dscf Opacity 20% (Minn. R ) None None The potential to emit SO2 from the units is lb/mmbtu. Due to the low levels of sulfur in natural gas it is unlikely that the heat input limit will be exceeded. PM emissions only occur during the sand handling process of this operation. The use of moist sand that has the tendency to fall to the floor results in PM emissions of almost 0. This provides adequate assurance that the limits will not be exceeded. The sand is contained in silos with bin vent filters, and emits almost 0 PM. Based on the design of these units it is unlikely they will exceed the PM emissions. Technical Support Document, Permit Action Number: Page 8 of 19

9 Subject Item* Requirement (basis) Monitoring Discussion GP 018 (Sand Handling/Transf er-conveyors, Mullers, Elevators) Total PM 0.30 grains/dscf Opacity 20% (Minn. R ) None Due to the nature of sand having the tendency to fall to the floor rather than remain suspended in air, it is unlikely that these units will exceed the PM and opacity limits. GP 019 (Furnaces- Natural Gas Aluminum) GP 020 (Furnaces- Electric Aluminum) GP 021 (Furnaces- Electric Steel) GP 022 (Boilers) GP 023 (Core Bake-out Ovens) Total PM 0.30 grains/dscf Opacity 20% SO lbs/mmbtu heat input Fuel Type: Natural gas only (Minn. R ; Minn. R , subp. 35a) Total PM 0.30 grains/dscf Opacity 20% (Minn. R ) Total PM 0.30 grains/dscf Opacity 20% (Minn. R ) Total PM 0.40 lbs/million Btu heat input Opacity 20% SO lbs/mmbtu heat input Fuel Type: Natural gas only (Minn. R ; Minn. R , subp. 35a) Total PM 0.30 grains/dscf Opacity 20% SO lbs/mmbtu heat input Fuel Type: Natural gas only (Minn. R ; Minn. R , subp. 35a) No additional monitoring applies. No additional monitoring applies. No additional monitoring applies. None None The standards and management practices required by NESHAP ZZZZZZ are enough to establish reasonable assurance that these emission limits will not be exceeded. The potential to emit SO 2 from the units is lb/mmbtu. The potential to emit PM is lb/mmbtu. The standards and management practices required by NESHAP ZZZZZZ are enough to establish reasonable assurance that these emission limits will not be exceeded. The standards and management practices required by NESHAP ZZZZZ are enough to establish reasonable assurance that these emission limits will not be exceeded. The potential to emit PM from the unit is lb/mmbtu. It is unlikely that the PM and opacity limit will be exceeded due to the decreased particle formation from the low sulfur content of fuel used. The potential to emit SO 2 from the unit is lb/mmbtu. Due to the low levels of sulfur in natural gas it is unlikely that the heat input limit will be exceeded. It is unlikely that the PM and opacity limit will be exceeded due to the decreased particle formation from the low sulfur content of fuel used. The potential to emit SO 2 from the unit is lb/mmbtu. Due to the low levels of sulfur in natural gas it is unlikely that the heat input limit will be exceeded. Technical Support Document, Permit Action Number: Page 9 of 19

10 Subject Item* Requirement (basis) Monitoring Discussion EU 024 (Ladle None Preheaters) GP 025 (Heat Treat Ovens) GP 026 (Quench & Kolene Tanks) GP 027 (Investment Casting - Wax Burnout Ovens) Total PM 0.30 grains/dscf Opacity 20% SO lbs/mmbtu heat input Fuel Type: Natural gas only (Minn. R ; Minn. R , subp. 35a) Total PM 0.30 grains/dscf Opacity 20% SO lbs/mmbtu heat input Fuel Type: Natural gas only (Minn. R ; Minn. R , subp. 35a) Total PM 0.40 lbs/million Btu heat input Opacity 20% SO lbs/mmbtu heat input Fuel Type: Natural gas only (Minn. R ; Minn. R , subp. 35a) Total PM 0.30 grains/dscf Opacity 20% SO lbs/mmbtu heat input Fuel Type: Natural gas only (Minn. R ; Minn. R , subp. 35a) None None None It is unlikely that the PM and opacity limit will be exceeded due to the decreased particle formation from the low sulfur content of fuel used. The potential to emit SO 2 from the unit is lb/mmbtu. Due to the low levels of sulfur in natural gas it is unlikely that the heat input limit will be exceeded. It is unlikely that the PM and opacity limit will be exceeded due to the decreased particle formation from the low sulfur content of fuel used. The potential to emit SO 2 from the unit is lb/mmbtu. Due to the low levels of sulfur in natural gas it is unlikely that the heat input limit will be exceeded. The potential to emit PM from the unit is lb/mmbtu. It is unlikely that the PM and opacity limit will be exceeded due to the decreased particle formation from the low sulfur content of fuel used. The potential to emit SO 2 from the unit is lb/mmbtu. Due to the low levels of sulfur in natural gas it is unlikely that the heat input limit will be exceeded. It is unlikely that the PM and opacity limit will be exceeded due to the decreased particle formation from the low sulfur content of fuel used. The potential to emit SO 2 from the unit is lb/mmbtu. Due to the low levels of sulfur in natural gas it is unlikely that the heat input limit will be exceeded. Technical Support Document, Permit Action Number: Page 10 of 19

11 Subject Item* Requirement (basis) Monitoring Discussion EU 134 (Thermal Reclaimer) Total PM grains/dscf Opacity 10% (NSPS UUU Limits) Initial performance tests for PM and Opacity According to an EPA decision found in Attachment 4 to this TSD, calciners and dryers that emit less than 11 tons of PM should be exempt from opacity monitoring requirements. EU 134 has an unrestricted PTE of PM less than 3 tpy. Due to qualifying for this exemption and the low levels of particle formation from natural gas combustion it is unlikely the unit will exceed the emission limits. EU 138 (Kloster Cold Box Mixer) EU 023 (Emergency Diesel Generator) EU 024 (Emergency Natural gas Generator) Total PM 0.30 grains/dscf Opacity 20% (Minn. R ) Opacity 20% SO lbs/million Btu heat input (Minn. R ) Hours of Operation 500 hours per year Fuel Type: No. 2 fuel oil/diesel only (40 CFR pt. 63, subp. ZZZZ; Minn. R ; Minn. R , subp. 35a) Opacity 20% SO lbs/million Btu heat input Fuel Type: Natural gas only (Minn. R ; Minn. R , subp. 35a) NO x 10 grams/hp-hr CO 387 grams/hp-hr Maintenance and readiness tests 100 hrs/year Non-emergency situations 50 hrs/year (40 CFR pt. 60, subp. JJJJ; Minn. R ) None None Installation of a non-resettable hour meter, fuel use records Fuel use records Installation of a non-resettable hour meter. Engine Certification. An initial performance test for PM and Opacity is required by 40 CFR pt. 60, subp. UUU to ensure compliance with the emission limits. PM emissions only occur during the sand handling process of this operation. The use of moist sand that has the tendency to fall to the floor results in PM emissions of almost 0. This provides adequate assurance that the limits will not be exceeded. The potential to emit SO 2 from the unit is 0.40 lb/mmbtu. Due to equipment design, allowable fuel, and hours of operation it is unlikely that it will exceed the requirements. This unit is used only in emergency situations and for routine maintenance so it is unlikely to exceed the operational requirements. The potential to emit SO 2 from the unit is lb/mmbtu. Due to equipment design, allowable fuel, and hours of operation it is unlikely that it will exceed the requirements. Due to its size (25<HP<100), use of natural gas, and limited use as an emergency generator, it is unlikely that it will exceed the emission and hours of operation limits. The Permittee shall operate and maintain the certified engine according to the manufacturer s instructions to further ensure compliance. Technical Support Document, Permit Action Number: Page 11 of 19

12 Subject Item* Requirement (basis) Monitoring Discussion EU 208 (Emergency Diesel Generator) Fuel use records EU 209 (Emergency Natural Gas Generator) CE 003 (Fabric Filter low temperature, total enclosure) CE 005 (Fabric Filter low temperature, certified hood) CE007 (Fabric Filter low temperature, total enclosure) Opacity 20% SO lbs/million Btu heat input Fuel Type: No. 2 fuel oil/diesel only (Minn. R ; Minn. R , subp. 35a) Opacity 20% SO lbs/million Btu heat input Fuel Type: Natural gas only (Minn. R ; Minn. R , subp. 35a) NMHC+NOx 8.0 grams/kw-hr CO 610 grams/kw-hr Maintenance and readiness tests 100 hrs/year Non-emergency situations 50 hrs/year (40 CFR pt. 60, subp. JJJJ; Minn. R ) Total PM: Control Efficiency 99% PM 10 /PM 2.5 : Control Efficiency 93% 1.0 P 7.5 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Total PM: Control Efficiency 79% PM 10 /PM 2.5 : Control Efficiency 74% 0.40 P 4.5 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Total PM: Control Efficiency 99% PM 10 /PM 2.5 : Control Efficiency 93% 0.10 P 1.2 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Fuel use records Installation of a non-resettable hour meter. Visible emissions and pressure drop checks, daily recordkeeping, O&M, monitoring equipment, corrective actions Visible emissions and pressure drop checks, daily recordkeeping, O&M, monitoring equipment, corrective actions Visible emissions and pressure drop checks, daily recordkeeping, O&M, monitoring equipment, corrective actions The potential to emit SO2 from the unit is 0.29 lb/mmbtu. Due to equipment design, allowable fuel, and hours of operation it is unlikely that it will exceed the requirements. The potential to emit SO2 from the unit is lb/mmbtu. Due to equipment design, allowable fuel, and hours of operation it is unlikely that it will exceed the requirements. Due to its size ( 25 HP), use of natural gas, and limited use as an emergency generator, it is unlikely that it will exceed the emission and hours of operation limits. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Technical Support Document, Permit Action Number: Page 12 of 19

13 Subject Item* Requirement (basis) Monitoring Discussion CE 008 (Fabric Filter low temperature, total enclosure) CE 009 (Fabric Filter low temperature, total enclosure) CE 010 (Fabric Filter low temperature, total enclosure) CE 011 (Fabric Filter low temperature, total enclosure) CE 012 (Fabric Filter low temperature, total enclosure) Total PM: Control Efficiency 99% PM 10 /PM 2.5 : Control Efficiency 93% 0.50 P 3.5 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Total PM: Control Efficiency 99% PM 10 /PM 2.5 : Control Efficiency 93% 0.10 P 12.0 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Total PM: Control Efficiency 99% PM 10 /PM 2.5 : Control Efficiency 93% 0.10 P 2.0 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Total PM: Control Efficiency 99% PM 10 /PM 2.5 : Control Efficiency 93% 0.10 P 1.0 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Total PM: Control Efficiency 99% PM 10 /PM 2.5 : Control Efficiency 93% 0.20 P 1.5 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Visible emissions and pressure drop checks, daily recordkeeping, O&M, monitoring equipment, corrective actions Visible emissions and pressure drop checks, daily recordkeeping, O&M, monitoring equipment, corrective actions Visible emissions and pressure drop checks, daily recordkeeping, O&M, monitoring equipment, corrective actions Visible emissions and pressure drop checks, daily recordkeeping, O&M, monitoring equipment, corrective actions Visible emissions and pressure drop checks, daily recordkeeping, O&M, monitoring equipment, corrective actions Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Technical Support Document, Permit Action Number: Page 13 of 19

14 Subject Item* Requirement (basis) Monitoring Discussion CE 013 (Fabric Filter low temperature, total enclosure) CE 014 (Fabric Filter low temperature, total enclosure) CE 015 (Gas Scrubber, total enclosure) CE 016 (Fabric Filter low temperature, certified hood) CE 018 (Fabric Filter low temperature, total enclosure) Total PM: Control Efficiency 99% PM 10 /PM 2.5 : Control Efficiency 93% 0.10 P 5.0 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Total PM: Control Efficiency 99% PM 10 /PM 2.5 : Control Efficiency 93% 0.20 P 4.0 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) VOC: Control Efficiency 99% ph 4.5 (Title I condition to avoid 40 CFR 70.2 and Minn. R ) Total PM: Control Efficiency 79% PM 10 /PM 2.5 : Control Efficiency 74% 0.40 P 4.5 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Total PM: Control Efficiency 99% PM 10 /PM 2.5 : Control Efficiency 93% 0.20 P 4.5 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Visible emissions and pressure drop checks, daily recordkeeping, O&M, monitoring equipment, corrective actions Visible emissions and pressure drop checks, daily recordkeeping, O&M, monitoring equipment, corrective actions Daily ph recordkeeping, monitoring equipment, quarterly inspections, annual calibration, corrective actions, O&M Visible emissions and pressure drop checks, daily recordkeeping, O&M, monitoring equipment, corrective actions Visible emissions and pressure drop checks, daily recordkeeping, O&M, corrective actions Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. The ph of the scrubbing solution is continuously monitored for automatic indication that the scrubber solution is spent and needs replacement. This monitoring of ph to ensure proper chemical environment for capture of VOC emissions is adequate to have a reasonable assurance of compliance. Additional information on this gas scrubber can be found as Attachment 12 to the TSD. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Technical Support Document, Permit Action Number: Page 14 of 19

15 Subject Item* Requirement (basis) Monitoring Discussion CE 019 (Fabric Filter low temperature, total enclosure) CE 020 (Fabric Filter low temperature, certified hood) CE 021, CE 022, CE 023, CE 024 (Direct flame afterburner, total enclosure) CE 026, CE 027, CE 028, CE 029, CE 030 (Panel filter, total enclosure) Total PM: Control Efficiency 99% PM 10 /PM 2.5 : Control Efficiency 93% 0.40 P 12.0 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Total PM: Control Efficiency 99% PM 10 /PM 2.5 : Control Efficiency 93% 0.20 P 4.5 inches of water column (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) VOC: Control Efficiency 97% Total PM: Control Efficiency 62% PM 10 /PM 2.5 : Control Efficiency 62% Temperature 1500 F at the combustion chamber (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Total PM: Control Efficiency 85% PM 10 /PM 2.5 : Control Efficiency 85% (Title I condition to avoid 40 CFR 70.2 and Minn. R ; Minn. R. 0070; Minn. R. 0080) Visible emissions and pressure drop checks, daily recordkeeping, O&M, corrective actions Visible emissions and pressure drop checks, daily recordkeeping, O&M, corrective actions Continuous temperature readings, daily monitoring, monitoring equipment, thermocouple monitoring, quarterly inspections, annual calibration, O&M Daily pressure drop checks and recordkeeping, periodic inspections, corrective actions, O&M *Location of the requirement in the permit (e.g., EU, SV, GP, etc.). Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. Due to safety concerns of climbing silos in the winter, the usually required daily inspections have been replaced with daily pressure drop checks that will ensure compliance. 3.3 Insignificant Activities Carley Foundry, Inc. has several operations which are classified as insignificant activities under the MPCA s permitting rules. These are listed in Appendix B to the permit. Technical Support Document, Permit Action Number: Page 15 of 19

16 Insignificant Activity Equipment used exclusively for melting or application of wax Minn. R , subp. (3)(H)(5) Cleaning Operations: alkaline/phosphate cleaners, associated cleaners, and associated burners. Minn. R , subp. 3(H)(7) Individual units with potential emissions less than 2000 lb/year of certain pollutants Minn. R , subp. 3(I) Equipment venting PM/PM 10 inside a building, provided that emissions from the equipment are: a). filtered through an air cleaning system; and b). vented inside of the building 100% of the time Minn. R Table 7. Insignificant Activities General Applicable Emission limit Discussion PM, variable Carley Foundry has wax gating and shell molding depending on airflow processes that are a part of their investment Opacity 20% casting operations that are applicable to this subpart. Minn. R PM, variable depending on airflow Opacity 20% Minn. R PM, variable depending on airflow Opacity 20% (with exceptions) Minn. R and Minn. R PM, variable depending on airflow Opacity 20% Minn. R Carley Foundry has a RamCo Potassium Hydroxide tank as well as a Kolene unit (salt bath) that are applicable to this subpart. Carley Foundry has 22 natural gas fueled space heaters. Each individual heater has a PTE less than the thresholds listed in Minn. R , subp. 3(I). The largest of the heaters have a capacity of 0.40 MMBtu/hr which results in NOx having the single largest PTE of 343 lbs/yr. Carley Foundry has 20 water based refractory coating spray guns (1 per molding station) that each have a PTE less than the above thresholds. The largest pollutant for each spray gun is VOC with a PTE of 1,249 lbs/year. Carley Foundry has a pattern shop which contains 31 pieces of woodworking equipment that consists of saws, drills, mills, and sanders. All these units emit into a dust collector and are vented inside the building 100% of the time. Carley also has a cleaning room with 24 pieces of finishing equipment in the foundry. These consist of grinders, band saws, and cut off saws. All these are filtered and vented inside the building 100% of the time. 3.4 Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be electronically tracked (e.g., limits, submittals, etc.), should be in Table A or B of the permit. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these. Technical Support Document, Permit Action Number: Page 16 of 19

17 Another area that deviates from the guidance is in the use of groups where the requirements in the group apply to the members of the group individually. Due to the large amount of emission units at Carley Foundry, groups have been used to organize the facility by the various processes conducted. This was done in order to shorten the permit and where no testing or tracking specific to a unit is in the permit (thereby reducing the likelihood that there where will be further unit-specific requirements later). An area that needs to be noted is GP 001. This group is for 40 CFR pt. 63, subp. ZZZZZZ - Area Source Standards for Aluminum Foundries, and contains all aluminum melting units. These aluminum melting units are further grouped as either electric (GP 019) or natural gas (GP 020). This was done because having a separate group upfront for Subpart ZZZZZZ is consistent with the organization of other foundry permits, and because different standards will apply to aluminum melting units depending on if they are electric or natural gas fired so they cannot all be combined into a single group. 3.5 Comments Received Document the official start/end dates of EPA's review period if they are different than the default (i.e., start of the notice + 45 days) and explain why the EPA review period is different. Document whether or not EPA agreed that we could go ahead and issue the permit prior to the end of their official review period by stating how and when this was communicated (or by attaching s/letters). Public Notice Period: <start date> - <end date> EPA 45-day Review Period: <start date> - <end date> If comments were received during the public notice period from the public or if comments are received from EPA, they should be described briefly here, as well as any changes made to the permit as a result of the comments. Generally, the comment letters should also be provided as attachments to the TSD. Comments were <not> received from the public during the public notice period. <The comments received did <not> include adverse comments on any applicable requirements of the permit. Changes to the permit were <not> made as a result of the comments. Provide summary of changes. > <The revised permit was sent to EPA for their 45-day review on <date>.> Comments were <not> received from EPA during their review period. Changes to the permit were <not> made as a result of the comments. Provide summary of changes. > 4. Permit Fee Assessment This permit action is the issuance of an individual State operating permit based on an application received June 25, This action is not considered a reissuance of an individual State operating permit; therefore, the application fees apply under Minn. R Attachment 3 to this TSD contains the MPCA s assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R Conclusion Based on the information provided by Carley Foundry, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No Technical Support Document, Permit Action Number: Page 17 of 19

18 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Robert Little (permit engineer) Steve Palzkill (enforcement) Curtis Stock (compliance) Amrill Okonkwo (peer reviewer) Beckie Olson (permit writing assistant) Sandra Simbeck (administrative support) AQ File No. 4292; DQ 4842 Attachments: 1. Emission Calculation Spreadsheets 2. Facility Description and -01 Forms 3. Points Calculator 4. EPA Applicability for Subpart NSPS UUU State of Wisconsin Air Emissions Inventory Report 6. Revised PM Natural Gas Emission Factors 7. South Coast Air Quality PM 2.5 multipliers 8. Emission Factors for Industrial Sand Mines 9. Thermal Reclaimer VOC Emission Factor 10. Investment Casting Wax Burnout Emission Factors 11. Core Molding Binder Formula Technical Support Document, Permit Action Number: Page 18 of 19

19 Carley Foundry Attachment 1 Emission Calculation Spreadsheets Available electronically in the Central File of Delta Technical Support Document, Permit Action Number: Page 19 of 19

20 Carley Foundry Attachment 1 Emission Calculation Spreadsheets Available electronically in the Central File of Delta

21 Carley Foundry Attachment 2 Facility Description and -01 Forms

22 MINNESOTA POLLUTION CONTROL AGENCY 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) Show: Action: PER 001 AQD Facility ID: Facility Name: ID No. Active and Pending Records Emission Unit Status Added By (Action) Retired By (Action) Insignificant Activity Operator ID for Item Stack/ Vent ID No(s). Control Equip. ID No(s). Operator Description Manufacturer Model Number SIC Max. Design Capacity Materials Maximum Design Capacity Units n Units d 1 EU 023 Active PER SV 097 Emergency Diesel Generator - Cummins 1500DFMB Energy Gal Hr Reciprocating IC Engine 2 EU 024 Active PER SV 083 Emergency Natural Gas Kohler 60REZG Energy Gal Hr Generator - Reciprocating IC Engine 3 EU 026 Active PER SV 079 Kolene Unit Burner - Other Kolene X-AL Aluminum Lb Batch SV 080 Combustion 4 EU 027 Active PER SV 076 CE 021 Shell Firing Furnace - Wax Pacific Kiln PBF-112NG-HT Solid Lb Batch CE 022 Burnout Oven 5 EU 030 Active PER SV 074 Autoclave Boiler - Boiler Fulton FB-020-F Steam Lb Hr 6 EU 031 Active PER SV 073 CE 023 Shell Firing Furnace - Wax Johnson BURNOUT Solid Lb Batch Burnout Oven 7 EU 033 Active PER Steel Electric Melt Furnace - Inductotherm Metal Lb Batch Melting Equipment 8 EU 034 Active PER SV 072 CE 024 Shell Firing Furnace - Wax Recco Burn-out Solid Lb Batch Burnout Oven 9 EU 036 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 10 EU 037 Active PER Electric Melt Furnace - Melting Thermtronix CSF Aluminum Lb Hr Equipment 11 EU 038 Active PER CE 005 Knockout Cabinet - Casting Herschal Sand Lb Hr Equipment 12 EU 039 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Equipment 13 EU 040 Active PER Electric melt Furnace - Melting Thermtronix SF Aluminum Lb Equipment 14 EU 041 Active PER Rollover Furnace - Furnace Inductotherm R/O MECH Metal Lb 15 EU 042 Active PER CE 003 Blast Cabinet - Abrasive Empire EP Shot Lb Min Equipment 16 EU 043 Active PER CE 003 Blast Cabinet - Abrasive Empire EP Shot Lb Min Equipment 17 EU 044 Active PER CE 011 Wheelabrator Blast Cabinet - Wheelabrator Tumblast Shot Lb Min Abrasive Equipment 18 EU 045 Active PER CE 011 Blast Cabinet - Abrasive Ruemelin Shot Lb Shot Material Min Pounds Minutes Equipment 19 EU 046 Active PER SV 063 CE 007 Wheelabrator - Abrasive Wheelabrator Tumblast Shot Lb Shot Material Min Pounds Minutes blasting Max Fuel Input (mil Btu) Page 1 of 8 (a)

23 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) ID No. Emission Unit Status Added By (Action) Commence Const. Date Initial Startup Date Removal Date Firing Method Pct. Fuel/ Space Heat Bottleneck Elevator Type 1 EU 023 Active PER /30/ /01/ EU 024 Active PER /01/ /01/ EU 026 Active PER /01/ /01/ EU 027 Active PER /01/ /01/ EU 030 Active PER /01/ /01/ EU 031 Active PER /01/ /01/ EU 033 Active PER /01/ /01/ EU 034 Active PER /01/ /01/ EU 036 Active PER /01/ /01/ EU 037 Active PER /01/ /01/ EU 038 Active PER /01/ /01/ EU 039 Active PER /01/ /01/ EU 040 Active PER /01/ /01/ EU 041 Active PER /01/ /01/ EU 042 Active PER /01/ /01/ EU 043 Active PER /01/ /01/ EU 044 Active PER /01/ /01/ EU 045 Active PER /01/ /01/ EU 046 Active PER /01/ /01/1984 Page 1 of 8 (b)

24 MINNESOTA POLLUTION CONTROL AGENCY 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) Show: Action: PER 001 AQD Facility ID: Facility Name: ID No. Active and Pending Records Emission Unit Status Added By (Action) Retired By (Action) Insignificant Activity Operator ID for Item Stack/ Vent ID No(s). Control Equip. ID No(s). Operator Description Manufacturer Model Number SIC Max. Design Capacity Materials Maximum Design Capacity Units n Units d 20 EU 047 Active PER SV 063 CE 007 Jet Wheelblast - Abrasive Jet wheel blast PHS Shot Lb Min Equipment 21 EU 048 Active PER CE 008 Mesh Belt Blaster - Abrasive Wheelabrator DE Shot Lb Min Equipment 22 EU 049 Active PER CE 009 Blast Cabinet - Abrasive Empire JT48-SP Shot Lb Min Equipment 23 EU 050 Active PER CE 011 Blast Cabinet - Abrasive MBA P.P Shot Lb Min Equipment 24 EU 051 Active PER Knockout Cabinet - Casting Herschal Sand Lb Hr Equipment 25 EU 052 Active PER Knockout Cabinet - Casting Herschal Sand Lb Hr Equipment 26 EU 053 Active PER Knockout Cabinet - Casting Herschal Sand Lb Hr Equipment 27 EU 054 Active PER Knockout Cabinet - Casting Herschal Cabinet Sand Lb Hr Equipment 28 EU 055 Active PER CE 010 Blast Cabinet - Abrasive Empire pro finish Shot Lb Min Equipment 29 EU 056 Active PER CE 012 Blast Room - Abrasive Empire PEB Sand Lb Hr Equipment 30 EU 057 Active PER 001 Knockout Cabinet - Casting General Kinematics Sand Lb Hr Equipment 31 EU 058 Active PER 001 Knockout Cabinet - Casting Herschal Sand Lb Hr Equipment 32 EU 060 Active PER SV 062 Heat Treat Aging Oven - Despatch Age Aluminum Lb Batch Dryer/Oven, direct fired 33 EU 062 Active PER SV 066 Heat Treat Aging Oven - Despatch Age Aluminum Lb Batch Dryer/Oven, direct fired 34 EU 063 Active PER SV 050 Core Bake Out Oven - Despatch PSE3-18S-1G Sand Lb Batch Dryer/Oven, direct fired 35 EU 064 Active PER SV 044 SV 045 SV 046 SV 048 Heat Treat - Dryer/Oven, direct fired Despatch Drop bottom quench Aluminum Lb Batch 36 EU 065 Active PER SV 041 Furnace C Quench Tank with Despatch Rolling Quench Aluminum Lb Batch Heater - Other Combustion 37 EU 066 Active PER SV 060 Heat Treat Aging Oven - Despatch PSD G Aluminum Lb Batch Pounds Dryer/Oven, direct fired Max Fuel Input (mil Btu) Page 2 of 8 (a)

25 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) ID No. Emission Unit Status Added By (Action) Commence Const. Date Initial Startup Date Removal Date Firing Method Pct. Fuel/ Space Heat Bottleneck Elevator Type 20 EU 047 Active PER /01/ /01/ EU 048 Active PER /01/ /01/ EU 049 Active PER /01/ /01/ EU 050 Active PER /01/ /01/ EU 051 Active PER /01/ /01/ EU 052 Active PER EU 053 Active PER /01/ /01/ EU 054 Active PER /01/ /01/ EU 055 Active PER /01/ /01/ EU 056 Active PER /01/ /01/ EU 057 Active PER /01/ /01/ EU 058 Active PER /01/ /01/ EU 060 Active PER /01/ /01/ EU 062 Active PER /01/ /01/ EU 063 Active PER /01/ /01/ EU 064 Active PER /01/ /01/ EU 065 Active PER /01/ /01/ EU 066 Active PER /01/ /01/2005 Page 2 of 8 (b)

26 MINNESOTA POLLUTION CONTROL AGENCY 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) Show: Action: PER 001 AQD Facility ID: Facility Name: ID No. Active and Pending Records Emission Unit Status Added By (Action) Retired By (Action) Insignificant Activity Operator ID for Item Stack/ Vent ID No(s). Control Equip. ID No(s). Operator Description Manufacturer Model Number SIC Max. Design Capacity Materials Maximum Design Capacity Units n Units d 38 EU 068 Active PER SV 061 Heat Treat Aging Oven - Despatch PSD G Aluminum Lb Batch Dryer/Oven, direct fired 39 EU 070 Active PER SV 049 Core Bake out Oven - Wisconsin EWN G10/EP Aluminum Lb Batch Dryer/Oven, direct fired 40 EU 073 Active PER Core Bake out Oven - Despatch PSE Aluminum Lb Batch Dryer/Oven, direct fired 41 EU 074 Active PER Permanent Mold Preheating Carley Heat Btu Hr Torches - Other Combustion 42 EU 075 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 43 EU 076 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 44 EU 077 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 45 EU 078 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 46 EU 079 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 47 EU 080 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 48 EU 081 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 49 EU 082 Active PER CE 014 Empire Blast Cabinet (glass Empire PF Shot Lb Min bead) - Abrasive Equipment 50 EU 083 Active PER CE 013 Knockout Cabinet - Casting Herschal HP76D "KO" hammer Sand Lb Hr Equipment 51 EU 084 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 52 EU 085 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 53 EU 086 Active PER SV 023 Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 54 EU 087 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Pounds Equipment 55 EU 088 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Pounds Hours Equipment 56 EU 089 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Pounds Hours Equipment Max Fuel Input (mil Btu) Page 3 of 8 (a)

27 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) ID No. Emission Unit Status Added By (Action) Commence Const. Date Initial Startup Date Removal Date Firing Method Pct. Fuel/ Space Heat Bottleneck Elevator Type 38 EU 068 Active PER /01/ /01/ EU 070 Active PER /01/ /01/ EU 073 Active PER /01/ /01/ EU 074 Active PER EU 075 Active PER /01/ /01/ EU 076 Active PER /01/ /01/ EU 077 Active PER /01/ /01/ EU 078 Active PER /01/ /01/ EU 079 Active PER /01/ /01/ EU 080 Active PER /01/ /01/ EU 081 Active PER /01/ /01/ EU 082 Active PER /01/ /01/ EU 083 Active PER /01/ /01/ EU 084 Active PER /01/ /01/ EU 085 Active PER /01/ /01/ EU 086 Active PER /01/ /01/ EU 087 Active PER /01/ /01/ EU 088 Active PER /01/ /01/ EU 089 Active PER /01/ /01/1998 Page 3 of 8 (b)

28 MINNESOTA POLLUTION CONTROL AGENCY 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) Show: Action: PER 001 AQD Facility ID: Facility Name: ID No. Active and Pending Records Emission Unit Status Added By (Action) Retired By (Action) Insignificant Activity Operator ID for Item Stack/ Vent ID No(s). Control Equip. ID No(s). Operator Description Manufacturer Model Number SIC Max. Design Capacity Materials Maximum Design Capacity Units n Units d 57 EU 090 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 58 EU 091 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 59 EU 092 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 60 EU 093 Active PER SV 091 Natural Gas Melt Furnace - Themrtronix GT Aluminum Lb Hr Melting Equipment 61 EU 094 Active PER SV 087 Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 62 EU 095 Active PER SV 087 Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 63 EU 096 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 64 EU 097 Active PER CE 013 Blast Cabinet (alum oxide) - Empire PF Shot Lb Min Abrasive Equipment 65 EU 098 Active PER SV 069 Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 66 EU 099 Active PER SV 069 Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 67 EU 100 Active PER SV 069 Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 68 EU 101 Active PER SV 069 Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 69 EU 102 Active PER Knockout Cabinet - Casting Herschal Sand Lb Hr Equipment 70 EU 103 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Equipment 71 EU 104 Active PER Electric Melt Furnace - Melting Equipment Thermtronix SF Aluminum Lb 72 EU 105 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Equipment 73 EU 106 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Pounds Equipment 74 EU 107 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Pounds Equipment 75 EU 108 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Pounds Equipment Max Fuel Input (mil Btu) 2.5 Page 4 of 8 (a)

29 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) ID No. Emission Unit Status Added By (Action) Commence Const. Date Initial Startup Date Removal Date Firing Method Pct. Fuel/ Space Heat Bottleneck Elevator Type 57 EU 090 Active PER /01/ /01/ EU 091 Active PER /01/ /01/ EU 092 Active PER /01/ /01/ EU 093 Active PER /01/ /01/ EU 094 Active PER /01/ /01/ EU 095 Active PER /01/ /01/ EU 096 Active PER /01/ /01/ EU 097 Active PER /01/ /01/ EU 098 Active PER /01/ /01/ EU 099 Active PER /01/ /01/ EU 100 Active PER /01/ /01/ EU 101 Active PER /01/ /01/ EU 102 Active PER /01/ /01/ EU 103 Active PER /01/ /01/ EU 104 Active PER /01/ /01/ EU 105 Active PER /01/ /01/ EU 106 Active PER /01/ /01/ EU 107 Active PER /01/ /01/ EU 108 Active PER /01/ /01/2012 Page 4 of 8 (b)

30 MINNESOTA POLLUTION CONTROL AGENCY 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) Show: Action: PER 001 AQD Facility ID: Facility Name: ID No. Active and Pending Records Emission Unit Status Added By (Action) Retired By (Action) Insignificant Activity Operator ID for Item Stack/ Vent ID No(s). Control Equip. ID No(s). Operator Description Manufacturer 76 EU 109 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Equipment 77 EU 110 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Equipment 78 EU 111 Active PER Electric Melt Furnace - Melting Themrtronix SF Aluminum Lb Equipment 79 EU 112 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Equipment 80 EU 113 Active PER Electric Melt Furnace - Melting Carley Aluminum Lb Equipment 81 EU 114 Active PER Electric Melt Furnace - Melting Carley Aluminum Lb Equipment 82 EU 116 Active PER SV 092 CE 026 Sand Silo-silica - Silo/bin Sand Ton Yr 83 EU 117 Active PER SV 094 CE 027 Sand Silo-silica - Silo/bin Imperial Industrial Sand Ton Yr 84 EU 118 Active PER SV 094 CE 027 Sand Silo-silica - Silo/bin Imperial Industrial Sand Ton Yr 85 EU 119 Active PER SV 095 CE 028 Sand Silo-silica - Silo/bin Imperial Industrial Sand Ton Yr 86 EU 120 Active PER CE 014 Sand SIlo-silica - Silo/bin Imperial Industrial Sand Ton Yr 87 EU 121 Active PER SV 018 CE 015 Cold Box Machine - Casting CMI/Hayes Lemmerz CB Sand Lb Yr Equipment Model Number SIC Max. Design Capacity Materials Maximum Design Capacity Units n Units d 88 EU 122 Active PER SV 018 CE 015 Cold Box Machine - Casting CMI/Hayes Lemmerz CB-22 vertical Sand Lb Hr Equipment 89 EU 123 Active PER SV 018 CE 015 Cold Box Machine - Casting CMI/Hayes Lemmerz HCB Sand Lb Hr Equipment 90 EU 124 Active PER SV 018 CE 015 Laempe L2 Core Machine - Laempe LB-50, 63C Sand Lb Hr Casting Equipment 91 EU 125 Active PER SV 018 CE 015 Laempe L1 Core Machine - Laempe LB-50 6LBC Sand Lb Hr Casting Equipment 92 EU 126 Active PER Shell Core Machine - Casting Dependable SA Sand Lb Hr Equipment 93 EU 127 Active PER Shell Core Machine - Casting Redford HP Sand Lb Hr Pounds Hours Equipment 94 EU 128 Active PER Shell Core Machine - Casting CMI/Hayes Lemmerz HS-22 RA Sand Lb Hr Pounds Hours Equipment 95 EU 129 Active PER Shell Core Machine - Casting Dependable SA Sand Lb Hr Pounds Hours Equipment Max Fuel Input (mil Btu) Page 5 of 8 (a)

31 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) ID No. Emission Unit Status Added By (Action) Commence Const. Date Initial Startup Date Removal Date Firing Method Pct. Fuel/ Space Heat Bottleneck Elevator Type 76 EU 109 Active PER /01/ /01/ EU 110 Active PER /01/ /01/ EU 111 Active PER /01/ /01/ EU 112 Active PER /01/ /01/ EU 113 Active PER /01/ /01/ EU 114 Active PER /01/ /01/ EU 116 Active PER /01/ /01/ EU 117 Active PER /01/ /01/ EU 118 Active PER /01/ /01/ EU 119 Active PER /01/ /01/ EU 120 Active PER /01/ /01/ EU 121 Active PER /01/ /01/ EU 122 Active PER /01/ /01/ EU 123 Active PER /01/ /01/ EU 124 Active PER /01/ /01/ EU 125 Active PER /01/ /01/ EU 126 Active PER /01/ /01/ EU 127 Active PER /01/ /01/ EU 128 Active PER /01/ /01/ EU 129 Active PER /01/ /01/1994 Page 5 of 8 (b)

32 MINNESOTA POLLUTION CONTROL AGENCY 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) Show: Action: PER 001 AQD Facility ID: Facility Name: ID No. Active and Pending Records Emission Unit Status Added By (Action) Retired By (Action) Insignificant Activity Operator ID for Item Stack/ Vent ID No(s). Control Equip. ID No(s). Operator Description Manufacturer Model Number SIC Max. Design Capacity Materials Maximum Design Capacity Units n Units d 96 EU 130 Active PER Electric Melt Furnace - Melting Thermtronix TF Aluminum Lb Hr Equipment 97 EU 131 Active PER Electric Melt Furnace - Melting Thermtronix TF Aluminum Lb Hr Equipment 98 EU 132 Active PER SV 003 Electric Melt Furnace - Melting Thermtronix TF Aluminum Lb Hr Equipment 99 EU 133 Active PER Shakeout - Casting Equipment General Kinematics Shakeout Sand Lb Hr 100 EU 134 Active PER SV 093 CE 019 Thermal Reclaimer - Thermfire (Grudgeon B TF Sand Lb Hr Dryer/Oven, indirect fired 101 EU 135 Active PER Kloster Molding Unit (w\ Kloster Versa-mull # Sand Lb Hr binders) - Aggregate Handling Equipment 102 EU 136 Active PER CE 016 Vibro mill - Abrasive General Kinematics VM Sand Lb Hr Equipment 103 EU 137 Active PER Ladle Preheater - Other GFE INC/Maxon 400FS-FS-MOD-RS Heat Btu Hr Combustion 104 EU 138 Active PER CE 014 Kloster Cold Box Mixer - Mixing Kloster I-600# /min Sand Lb Min Equipment 105 EU 139 Active PER SV 018 CE 015 Laempe L3 Core Machine - Laempe LB Sand Lb Hr Casting Equipment 106 EU 140 Active PER Sand Mixer "special" - Mixing Kloster Type lll 75# Sand Lb Min Equipment 107 EU 141 Active PER CE 016 Shakeout - Casting Equipment General Kinematics SCRTV 18x Sand Lb Hr 108 EU 142 Active PER SV 006 Boiler for Kloster Heater/Cooler Raypak Raytherm-H Heat Btu Hr - NG 109 EU 143 Active PER SV 024 Boiler for Kloster Sand Raypak Raytherm H Heat Btu Hr Heater/cooler 110 EU 144 Active PER SV 018 CE 015 Core Blower - CB-10 - Casting Beardsley & Piper CB-10DH Sand Lb Hr Equipment 111 EU 145 Active PER Electric Melt Furnace - Melting Thermtronix TF Aluminum Lb Hr Equipment 112 EU 146 Active PER CE 018 Blast Cabinet - Abrasive Empire PF Shot Lb Min Pounds Equipment 113 EU 147 Active PER SV 018 CE 015 Core Blower - Gaylord GFE INC SATB Sand Lb Min Pounds Minutes SATB-15 - Casting Equipment 114 EU 148 Active PER SV 018 CE 015 Laempe L4 Core Machine - Laempe LB Sand Lb Min Pounds Minutes Casting Equipment Max Fuel Input (mil Btu) Page 6 of 8 (a)

33 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) ID No. Emission Unit Status Added By (Action) Commence Const. Date Initial Startup Date Removal Date Firing Method Pct. Fuel/ Space Heat Bottleneck Elevator Type 96 EU 130 Active PER /01/ /01/ EU 131 Active PER /01/ /01/ EU 132 Active PER /01/ /01/ EU 133 Active PER /01/ /01/ EU 134 Active PER /01/ /01/ EU 135 Active PER /01/ /01/ EU 136 Active PER /01/ /01/ EU 137 Active PER /01/ /01/ EU 138 Active PER /01/ /01/ EU 139 Active PER /01/ /01/ EU 140 Active PER /01/ /01/ EU 141 Active PER /01/ /01/ EU 142 Active PER /01/ /01/ EU 143 Active PER /01/ /01/ EU 144 Active PER /01/ /01/ EU 145 Active PER /01/ /01/ EU 146 Active PER /01/ /01/ EU 147 Active PER /01/ /01/ EU 148 Active PER /01/ /01/2013 Page 6 of 8 (b)

34 MINNESOTA POLLUTION CONTROL AGENCY 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) Show: Action: PER 001 AQD Facility ID: Facility Name: ID No. Active and Pending Records Emission Unit Status Added By (Action) Retired By (Action) Insignificant Activity Operator ID for Item Stack/ Vent ID No(s). Control Equip. ID No(s). Operator Description Manufacturer 115 EU 149 Active PER SV 096 CE 029 Sand Silo - Olivine - Silo/bin Sand Ton Yr 116 EU 150 Active PER SV 026 Natural Gas Melt Furnace - Thermtronix GS Aluminum Lb Hr Melting Equipment 117 EU 151 Active PER SV 026 Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 118 EU 152 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 119 EU 153 Active PER Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 120 EU 154 Active PER SV 028 Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 121 EU 155 Active PER SV 029 Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 122 EU 156 Active PER SV 029 Electric Melt Furnace - Melting Themrtronix SF Aluminum Lb Hr Equipment 123 EU 157 Active PER SV 030 Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 124 EU 158 Active PER Muller - Mixing Equipment Simpson 1-1/2 G Sand Ton Hr 125 EU 159 Active PER Molding Machine - Squeezing - BMM QJS Sand Lb Hr Molding Equipment 126 EU 160 Active PER Molding Machine - Squeezing - BMM QJS Sand Lb Hr Molding Equipment 127 EU 161 Active PER Molding Machine - Rotolifts - Osborn Sand Lb Hr Molding Equipment 128 EU 162 Active PER Molding Machine - Rotolifts - Osborn Sand Lb Hr Molding Equipment 129 EU 163 Active PER Molding Machine - Squeezer - Spo 2114-P Sand Lb Hr Molding Equipment 130 EU 164 Active PER Molding Machine - BMM - BMM QJS Sand Lb Hr Molding Equipment 131 EU 165 Active PER Molding Machine - BMM - BMM QJS Sand Lb Hr Molding Equipment Model Number SIC Max. Design Capacity Materials Maximum Design Capacity Units n Units d 132 EU 166 Active PER SV 032 CE 020 Bucket Elevator Muller - Mixing Summit Sand Lb Hr Pounds Hours Equipment 133 EU 167 Active PER SV 032 CE 020 Elevator Summit Sand Lb Hr Pounds Hours 134 EU 168 Active PER Sand Storage - Silo/bin Summit Sand Ton Hr English Tons Hours(200 Max Fuel Input (mil Btu) 1.5 Page 7 of 8 (a)

35 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) ID No. Emission Unit Status Added By (Action) Commence Const. Date Initial Startup Date Removal Date Firing Method Pct. Fuel/ Space Heat Bottleneck Elevator Type 115 EU 149 Active PER /01/ /01/ EU 150 Active PER /01/ /01/ EU 151 Active PER /01/ /01/ EU 152 Active PER /01/ /01/ EU 153 Active PER /01/ /01/ EU 154 Active PER /01/ /01/ EU 155 Active PER /01/ /01/ EU 156 Active PER /01/ /01/ EU 157 Active PER /01/ /01/ EU 158 Active PER /01/ /01/ EU 159 Active PER /01/ /01/ EU 160 Active PER /01/ /01/ EU 161 Active PER /01/ /01/ EU 162 Active PER /01/ /01/ EU 163 Active PER /01/ /01/ EU 164 Active PER /01/ /01/ EU 165 Active PER /01/ /01/ EU 166 Active PER /01/ /01/ EU 167 Active PER /01/ /01/ EU 168 Active PER /01/ /01/2007 Page 7 of 8 (b)

36 MINNESOTA POLLUTION CONTROL AGENCY 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) Show: Active and Pending Records Action: PER 001 AQD Facility ID: Facility Name: ID No. Emission Unit Status Added By (Action) Retired By (Action) Insignificant Activity Operator ID for Item Stack/ Vent ID No(s). Control Equip. ID No(s). Operator Description Manufacturer 135 EU 169 Active PER Shaker, vibratory - Abrasive Conveyor Dynamics S Sand Lb Hr Equipment 136 EU 170 Active PER CE 020 Shaker, vibratory - Abrasive Summit Sand Lb Hr Equipment 137 EU 202 Active PER SV 052 Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 138 EU 203 Active PER SV 052 Electric Melt Furnace - Melting Thermtronix SF Aluminum Lb Hr Equipment 139 EU 204 Active PER SV 053 Natural Gas Melt Furnace - Thermtronix GS Aluminum Lb Hr Melting Equipment 140 EU 205 Active PER Low Pressure Molding Machine Carley # Aluminum Lb Hr #1 - Molding Equipment 141 EU 206 Active PER Low Pressure Molding Machine Carley # Aluminum Lb Hr #3 - Molding Equipment 142 EU 207 Active PER Low Pressure Molding Machine Carley # Aluminum Lb Hr #2 - Molding Equipment 143 EU 208 Active PER Emergency Diesel Generator - Generac Energy Gal Hr Reciprocating IC Engine 144 EU 209 Active PER Emergency Natural Gas Kohler 12RES Energy Gal Hr Generator - Reciprocating IC Engine 145 EU 210 Active PER SV 053 Gas Dry Hearth - Melting Carley Aluminum Lb Hr Equipment Model Number SIC Max. Design Capacity Materials Maximum Design Capacity Units n Units d Max Fuel Input (mil Btu) Page 8 of 8 (a)

37 19 February, :14 FACILITY DESCRIPTION: EMISSION UNIT (EU) ID No. Emission Unit Status Added By (Action) Commence Const. Date Initial Startup Date Removal Date Firing Method Pct. Fuel/ Space Heat Bottleneck Elevator Type 135 EU 169 Active PER /01/ /01/ EU 170 Active PER /01/ /01/ EU 202 Active PER /01/ /01/ EU 203 Active PER /01/ /01/ EU 204 Active PER /01/ /01/ EU 205 Active PER /01/ /01/ EU 206 Active PER /01/ /01/ EU 207 Active PER /01/ /01/ EU 208 Active PER /01/ /01/ EU 209 Active PER /01/ /01/ EU 210 Active PER /01/ /01/2012 Page 8 of 8 (b)

38 MINNESOTA POLLUTION CONTROL AGENCY 19 February, :14 FACILITY DESCRIPTION: GROUPS (GP) Show: Action: AQD Facility ID: Facility Name: Active and Pending Records PER ID No. Group Status Added By (Action) Retired By (Action) Include in EI Operator ID for Item Group Description Group Items 1 GP 001 Active PER 001 Units subject to 40 CFR pt. 63, subp. ZZZZZZ - Area Source Standards for Aluminum Foundries 2 GP 002 Active PER 001 Units subject to 40 CFR pt. 63, subp. ZZZZZ - Area Source Standards for Steel Foundries EU 036, EU 037, EU 039, EU 040, EU 075, EU 076, EU 077, EU 078, EU 079, EU 080, EU 081, EU 084, EU 085, EU 086, EU 087, EU 088, EU 089, EU 090, EU 091, EU 092, EU 093, EU 094, EU 095, EU 096, EU 098, EU 099, EU 100, EU 101, EU 103, EU 104, EU 105, EU 106, EU 107, EU 108, EU 109, EU 110, EU 111, EU 112, EU 113, EU 114, EU 130, EU 131, EU 132, EU 145, EU 150, EU 151, EU 152, EU 153, EU 154, EU 155, EU 156, EU 157, EU 202, EU 203, EU 204, EU 205, EU 206, EU 207, EU 210 EU 033, EU GP 010 Active PER 001 Knockout CE 005, CE 013, EU 038, EU 051, EU 052, EU 053, EU 054, EU 057, EU 058, EU 083, EU GP 011 PER 001 Shakeout CE 016, CE 020, EU 133, EU 136, EU 141, EU 169, EU 170 Active 5 GP 012 Active PER 001 Abrasive Blasting CE 003, CE 007, CE 008, CE 009, CE 010, CE 011, CE 012, CE 013, CE 014, CE 018, EU 042, EU 043, EU 044, EU 045, EU 046, EU 047, EU 048, EU 049, EU 050, EU 055, EU 056, EU 082, EU 097, EU GP 013 Active PER 001 Core Molding - Isocure/Cold Box CE 015, EU 121, EU 122, EU 123, EU 124, EU 125, EU 139, EU 144, EU 147, EU GP 015 PER 001 Core Molding - Shell Core EU 126, EU 127, EU 128, EU 129 Active 8 GP 016 PER Series Molding Machines EU 159, EU 160, EU 161, EU 162, EU 163, EU 164, EU 165 Active 9 GP 017 Active PER 001 Sand Handling - Silos (New Sand) CE 014, CE 026, CE 027, CE 028, CE 029, EU 116, EU 117, EU 118, EU 119, EU 120, EU GP 018 PER 001 Sand Handling/Transfer - Conveyors, Mullers, Elevators CE 020, EU 135, EU 140, EU 158, EU 166, EU 167, EU 168 Active 11 GP 019 PER 001 Furnaces - Natural Gas (Aluminum) EU 093, EU 150, EU 204, EU 210 Active 12 GP 020 Active PER 001 Furnaces - Electric (Aluminum) EU 036, EU 037, EU 039, EU 040, EU 075, EU 076, EU 077, EU 078, EU 079, EU 080, EU 081, EU 084, EU 085, EU 086, EU 087, EU 088, EU 089, EU 090, EU 091, EU 092, EU 094, EU 095, EU 096, EU 098, EU 099, EU 100, EU 101, EU 103, EU 104, EU 105, EU 106, EU 107, EU 108, EU 109, EU 110, EU 111, EU 112, EU 113, EU 114, EU 130, EU 131, EU 132, EU 145, EU 151, EU 152, EU 153, EU 154, EU 155, EU 156, EU 157, EU 202, EU 203, EU 205, EU 206, EU GP 021 PER 001 Furnaces - Electric (Steel) EU 033, EU 041 Active 14 GP 022 PER 001 Boilers EU 030, EU 142, EU 143 Active 15 GP 023 PER 001 Core Bake-Out Ovens EU 063, EU 070, EU 073 Active 16 GP 024 PER 001 Ladle Preheaters EU 074, EU 137 Active 17 GP 025 PER 001 Heat Treat Ovens EU 060, EU 062, EU 064, EU 066, EU 068 Active 18 GP 026 PER 001 Quench & Kolene Tanks EU 026, EU 065 Active 19 GP 027 PER 001 Investment Casting - Wax Burnout Ovens CE 021, CE 022, CE 023, CE 024, EU 027, EU 031, EU 034 Active Page 1 of 1

39 MINNESOTA POLLUTION CONTROL AGENCY 19 February, :15 FACILITY DESCRIPTION: CONTROL EQUIPMENT (CE) Show: Active and Pending Records Action: PER 001 AQD Facility ID: Facility Name: ID No. Control Equip. Status Added By (Action) Retired By (Action) Operator ID for Item Control Equip. Type Control Equipment Description Manufacturer Model Pollutants Controlled Capture Efficiency (%) Destruction/ Collection Efficiency (%) Afterburner Combustion Parameters 1 CE 003 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Empire EM 2-2 PM10 PM CE 005 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Torit DFT 2-24 PM10 PM CE 007 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Torit DFT 2-12 PM10 PM CE 008 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Torit DFT 2-12 PM10 PM CE 009 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Empire EM 2-4 PM10 PM CE 010 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Torit TD 650 PM10 PM CE 011 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Torit DFT 2-8 PM10 PM CE 012 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Torit DFT 3-12 PM10 PM CE 013 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Torit DFT 2-4 PM10 PM CE 014 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Torit SDF-7=6 PM10 PM CE 015 Active PER Gas Scrubber (General, Not Classified) Dakota DES-724 PM VOC CE 016 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Torit DFT 3-18 PM10 PM CE 018 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Torit DFO 3-3 PM10 PM CE 019 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Torit 81MBT10 PM10 PM CE 020 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Torit DFT 3-24 PM10 PM CE 021 Active PER _ Direct Flame Afterburner Pacific Kiln CAT III PM10 PM VOC F/0.52S 17 CE 022 Active PER _ Direct Flame Afterburner Pacific Kiln CAT III PM10 PM VOC F/0.52S 18 CE 023 Active PER Direct Flame Afterburner Johnston PM10 PM VOC F/0.52S Page 1 of 2

40 MINNESOTA POLLUTION CONTROL AGENCY 19 February, :15 FACILITY DESCRIPTION: CONTROL EQUIPMENT (CE) Show: Active and Pending Records Action: PER 001 AQD Facility ID: Facility Name: ID No. Control Equip. Status Added By (Action) Retired By (Action) Operator ID for Item Control Equip. Type Control Equipment Description Manufacturer Model Pollutants Controlled Capture Efficiency (%) Destruction/ Collection Efficiency (%) Afterburner Combustion Parameters 19 CE 024 Active PER Direct Flame Afterburner Recco PM10 PM VOC F/0.52S 20 CE 026 Active PER Mat or Panel Filter unknown unknown PM10 PM CE 027 Active PER Mat or Panel Filter unkown unknown PM10 PM CE 028 Active PER Mat or Panel Filter unkown unkown PM10 PM CE 029 Active PER Mat or Panel Filter unkown unknown PM10 PM Page 2 of 2

41 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 1 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Total Facility NC/ CA Type Citation Requirement hdr SOURCE-SPECIFIC REQUIREMENTS 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 the appendices. Minn. R (C)(2) Permit Shield: 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. hdr OPERATIONAL REQUIREMENTS Minn. Stat. Section , subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps. 1, 2 & 4; Minn. R Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R , subps. 14 and 16(J) 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. 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. Minn. R , subp. 4 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 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 , subp. 9(A) Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). Minn. R , subp. 16 The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. hdr PERFORMANCE TESTING Minn. R. ch Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A and B. Minn. R ; Minn. R , subps. 1-4, Minn. R , subps. 1-2 Performance Test Notifications and Submittals: Performance Tests are due as outlined in Table A of the permit. See Table B for additional testing requirements. 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

42 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 2 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 3 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. hdr MONITORING REQUIREMENTS Minn. R , subp. 4(D) Monitoring Equipment Calibration - The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. Minn. R , subp. 4(D) Operation of Monitoring Equipment: Unless 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. hdr RECORDKEEPING Minn. R , subp. 5(C) 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(B) 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. 4 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 electronic or paper format. hdr REPORTING/SUBMITTALS Minn. R , subp. 3 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.

43 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 3 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 2 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. 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. S/A Minn. R , subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar 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. Minn. R Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. S/A Minn. R , subp. 2 Application for Permit Reissuance: due 180 days before expiration of Existing Permit Minn. R , subp. 1(H) 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). S/A Minn. R , subp. 6(B) Report: due 30 days before end of each calendar half-year following Permit Issuance. The Compliance Schedule Progress Report shall contain the information specified in MInn. R , subp. 6(B) and shall be submitted on a form approved by the Commissioner in accordance with the Compliance Schedule contained in Table C. Progress Reports will not be needed upon completion of all activities contained in the Compliance Schedule. S/A Minn. R , subp. 6(C) 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. Minn. R Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance, to be submitted on a form approved by the Commissioner. Minn. R Emission Fees: due 30 days after receipt of an MPCA bill.

44 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 4 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 001 Units subject to 40 CFR pt. 63, subp. ZZZZZZ - Area Source Standards for Aluminum Foundries EU 036 Electric Melt Furnace - Melting Equipment EU 037 Electric Melt Furnace - Melting Equipment EU 039 Electric Melt Furnace - Melting Equipment EU 040 Electric melt Furnace - Melting Equipment EU 075 Electric Melt Furnace - Melting Equipment EU 076 Electric Melt Furnace - Melting Equipment EU 077 Electric Melt Furnace - Melting Equipment EU 078 Electric Melt Furnace - Melting Equipment EU 079 Electric Melt Furnace - Melting Equipment EU 080 Electric Melt Furnace - Melting Equipment EU 081 Electric Melt Furnace - Melting Equipment EU 084 Electric Melt Furnace - Melting Equipment EU 085 Electric Melt Furnace - Melting Equipment EU 086 Electric Melt Furnace - Melting Equipment EU 087 Electric Melt Furnace - Melting Equipment EU 088 Electric Melt Furnace - Melting Equipment EU 089 Electric Melt Furnace - Melting Equipment EU 090 Electric Melt Furnace - Melting Equipment EU 091 Electric Melt Furnace - Melting Equipment EU 092 Electric Melt Furnace - Melting Equipment EU 093 Natural Gas Melt Furnace - Melting Equipment EU 094 Electric Melt Furnace - Melting Equipment EU 095 Electric Melt Furnace - Melting Equipment EU 096 Electric Melt Furnace - Melting Equipment EU 098 Electric Melt Furnace - Melting Equipment EU 099 Electric Melt Furnace - Melting Equipment EU 100 Electric Melt Furnace - Melting Equipment EU 101 Electric Melt Furnace - Melting Equipment EU 103 Electric Melt Furnace - Melting Equipment EU 104 Electric Melt Furnace - Melting Equipment EU 105 Electric Melt Furnace - Melting Equipment EU 106 Electric Melt Furnace - Melting Equipment EU 107 Electric Melt Furnace - Melting Equipment EU 108 Electric Melt Furnace - Melting Equipment EU 109 Electric Melt Furnace - Melting Equipment EU 110 Electric Melt Furnace - Melting Equipment EU 111 Electric Melt Furnace - Melting Equipment EU 112 Electric Melt Furnace - Melting Equipment EU 113 Electric Melt Furnace - Melting Equipment EU 114 Electric Melt Furnace - Melting Equipment EU 130 Electric Melt Furnace - Melting Equipment EU 131 Electric Melt Furnace - Melting Equipment EU 132 Electric Melt Furnace - Melting Equipment

45 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 5 of Feb, :07 COMPLIANCE PLAN -01 Associated Items: EU 145 Electric Melt Furnace - Melting Equipment EU 150 Natural Gas Melt Furnace - Melting Equipment EU 151 Electric Melt Furnace - Melting Equipment EU 152 Electric Melt Furnace - Melting Equipment EU 153 Electric Melt Furnace - Melting Equipment EU 154 Electric Melt Furnace - Melting Equipment EU 155 Electric Melt Furnace - Melting Equipment EU 156 Electric Melt Furnace - Melting Equipment EU 157 Electric Melt Furnace - Melting Equipment EU 202 Electric Melt Furnace - Melting Equipment EU 203 Electric Melt Furnace - Melting Equipment EU 204 Natural Gas Melt Furnace - Melting Equipment EU 205 Low Pressure Molding Machine #1 - Molding Equipment EU 206 Low Pressure Molding Machine #3 - Molding Equipment EU 207 Low Pressure Molding Machine #2 - Molding Equipment EU 210 Gas Dry Hearth - Melting Equipment NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. hdr NESHAP SUBPART ZZZZZZ REQUIREMENTS - Enforcement Not Delegated to MPCA hdr STANDARDS AND MANAGEMENT PRACTICES 40 CFR Section (a)(1) Cover or enclose each melting furnace that is equipped with a cover or enclosure during the melting operation to the extent practicable (e.g., except when access is needed; including, but not limited to charging, alloy addition, and tapping). 40 CFR Section (a)(2) Purchase only metal scrap that has been depleted (to the extent practicable) of aluminum foundry HAP, copper foundry HAP, or other nonferrous foundry HAP (as applicable) in the materials charged to the melting furnace, except metal scrap that is purchased specifically for its HAP metal content for use in alloying or to meet specifications for the casting. This requirement does not apply to material that is not scrap (e.g., ingots, alloys, sows) or to materials that are not purchased (e.g., internal scrap, customer returns). 40 CFR Section (a)(3) Prepare and operate pursuant to a written management practices plan. The management practices plan must include the required management practices in paragraphs (a)(1) and (2) of this section and may include any other management practices that are implemented at the facility to minimize emissions from melting furnaces. The Permittee must inform the appropriate employees of the management practices that they must follow. The Permittee may use standard operating procedures as the management practices plan provided the standard operating procedures include the required management practices in paragraphs (a)(1) and (2) of this section. hdr MONITORING REQUIREMENTS 40 CFR Section (a) The Permittee shall record the information specified in 40 CFR Section (c)(2) to document conformance with the management practices plan required in 40 CFR Section (a). hdr REPORTING, AND RECORDKEEPING REQUIREMENTS

46 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 6 of Feb, :07 COMPLIANCE PLAN CFR Section (c) The Permittee shall keep the records specified below: (1) As required in Section 63.10(b)(2)(xiv), the Permittee shall keep a copy of each notification that is submitted to comply with this subpart and all documentation supporting any Initial Notification or Notification of Compliance Status that is submitted. (2) The Permittee shall keep records to document conformance with the management practices plan required by Section as specified in paragraphs (c)(2)(i) and (ii) of this section CFR Section (c) continued (i) For melting furnaces equipped with a cover or enclosure, records must identify each melting furnace equipped with a cover or enclosure and document that the procedures in the management practices plan were followed during the monthly inspections. These records may be in the form of a checklist. (ii) Records documenting that the Permittee purchased only metal scrap that has been depleted of HAP metals (to the extent practicable) charged to the melting furnace. If the Permittee purchases scrap metal specifically for the HAP metal content for use in alloying or to meet specifications for the casting, the Permittee must keep records to document that the HAP metal is included in the material specifications for the cast metal product. 40 CFR Section (d) The records must be in a form suitable and readily available for expeditious review, according to Section 63.10(b)(1). As specified in Section 63.10(b)(1), the Permittee shall keep each record for 5 years following the date of each recorded action. For records of annual metal melt production, the Permittee shall keep the records for 5 years from the end of the calendar year. The Permittee shall keep each record onsite for at least 2 years after the date of each recorded action according to Section 63.10(b)(1). The Permittee may keep the records offsite for the remaining 3 years. 40 CFR Section (e) If a deviation occurs during a semiannual reporting period, the Permittee shall submit a compliance report to the permitting authority according to the requirements in paragraphs (e)(1) and (2) of this section. (1) The first reporting period covers the period beginning on the compliance date specified in Section and ending on June 30 or December 31, whichever date comes first after the compliance date. Each subsequent reporting period covers the semiannual period from January 1 through June 30 or from July 1 through December 31. The compliance report must be postmarked or delivered no later than July 31 or January 31, whichever date comes first after the end of the semiannual reporting period. (2) A compliance report must include the information in paragraphs (e)(2)(i) through (iv) of this section. (i) Company name and address CFR Section (e) continued (ii) Statement by a responsible official, with the official's name, title, and signature, certifying the truth, accuracy and completeness of the content of the report. (iii) Date of the report and beginning and ending dates of the reporting period hdr GENERAL PROVISIONS 40 CFR Section 63.4(b); Minn. R CFR Section 63.5(b)(4); Minn. R (iv) Identification of the affected source, the pollutant being monitored, applicable requirement, description of deviation, and corrective action taken. Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, but is not limited to: 1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere or 2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions. The Permittee must submit notification according to 40 CFR Section 63.9(b) if the Permittee constructs or reconstructs a source such that the source becomes an affected source subject to a standard.

47 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 7 of Feb, :07 COMPLIANCE PLAN CFR Section 63.5(b)(6); Minn. R CFR Section 63.6(e)(1)(i); Minn. R CFR Section 63.6(e)(1)(ii); Minn. R CFR Section 63.6(e)(3)(i); Minn. R CFR Section 63.6(e)(3)(iii) ; Minn. R CFR Section 63.6(e)(3)(iv) ; Minn. R CFR Section 63.6(e)(3)(v); Minn. R CFR Section 63.6(e)(3)(vi ); Minn. R CFR Section 63.6(e)(3)(vii) ; Minn. R After the effective date of any relevant standard promulgated under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source. Proper Operation and Maintenance. At all times, including periods of startup, shutdown, and malfunction, the Permittee shall operate and maintain the emission unit subject to the MACT standard and any associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by any relevant standard and as detailed in 40 CFR Section 63.6(e)(1)(i)-(iii). Malfunctions shall be corrected as soon as practicable after their occurrence. Startup, shutdown, and malfunction plan (SSMP). The Permittee shall prepare and implement a written SSMP within 120 days of permit issuance that describes, in detail, procedures for operating and maintaining the source during periods of startup, shutdown, and malfunction; and a program of corrective action for malfunctioning process, air pollution control, and monitoring equipment used to comply with the relevant standard. The plan requirements are further described in 40 CFR Section 63.6(e)(3)(i). When actions taken by Permittee during a startup or shutdown (and the startup or shutdown causes the source to exceed any applicable emission limitation), or malfunction (including actions taken to correct a malfunction) are consistent with the procedures specified in the affected source's SSMP, the Permittee must keep records which demonstrate that the procedures specified in the SSMP were followed and describes the actions taken for that event. If an action taken by the Permittee during a startup, shutdown, or malfunction (including an action taken to correct a malfunction) is not consistent with the procedures specified in the affected source's SSMP, and the source exceeds any applicable emission limitation in the relevant emission standard, then the Permittee must record the actions taken for that event and must report such actions as specified in 40 CFR Section 63.10(d)(5). The Permittee must maintain at the affected source a current SSMP and must make the plan available upon request for inspection and copying by the Commissioner and the Administrator. In addition, if the SSMP is subsequently revised, the Permittee must maintain at the affected source each previous (i.e., superseded) version of the SSMP, and must make each such previous version available for inspection and copying for a period of 5 years after revision of the SSMP. To satisfy the requirements of this section to develop a SSMP, the Permittee may use a standard operating procedures (SOP) manual, or other plan, provided the alternative plans meet all the requirements and are made available for inspection or submission. The Commissioner or the Administrator may require that a Permittee make changes to the SSMP. Revisions to the SSMP will be required if the plan: 1) Does not address a startup, shutdown, or malfunction event that has occurred; 2) Fails to provide for the operation of the source (including associated air pollution control and monitoring equipment) during a startup, shutdown, or malfunction event in a manner consistent with the general duty to minimize emissions established by 40 CFR Section 63.6(e)(3)(iii)-63.6(e)(3)(ix) (e)(1)(i); 3) Does not provide adequate procedures for correcting malfunctioning process and/or air pollution control and monitoring equipment as quickly as practicable; or 4) Includes an event that does not meet the definition of startup, shutdown, or malfunction CFR Section 63.6(e)(3)(viii); Minn. R The Permittee may periodically revise the SSMP as necessary to reflect changes in equipment or procedures at the affected source. Each such revision to a SSMP must be reported in the semiannual report required by 40 CFR Section 63.10(d)(5). If the SSMP fails to address or inadequately addresses an event that meets the characteristics of a malfunction but was not included in the SSMP, the Permittee shall revise the SSMP within 45 days after the event in accordance with 40 CFR Section 63.6(e)(3)(viii) CFR Section 63.6(e)(3)(ix); Minn. R Any revisions made to the SSMP shall not be deemed to constitute permit revisions under 40 CFR pt. 70 or pt. 71.

48 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 8 of Feb, :07 COMPLIANCE PLAN CFR Section 63.6(f)(2); Minn. R CFR Section 63.6(f)(3); Minn. R Methods for determining compliance will be, in part, based on the results of performance tests, conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 40 CFR Section 63.6(f)(2). The Permittee many use the results of performance testing conducted previously if it meets the requirements of 40 CFR Section 63.6(f)(iii). Finding of compliance. The Commissioner or the Administrator will make a finding concerning an affected source's compliance with a non-opacity emission standard upon obtaining all the compliance information required by the relevant standard. hdr GENERAL MONITORING REQUIREMENTS 40 CFR Section 63.8(b)(1); Minn. R CFR Section 63.8(f); Minn. R hdr NOTIFICATION REQUIREMENTS Conduct of monitoring. Monitoring shall be conducted as set forth in 40 CFR Section 63.8(a)(b)(1). Use of an alternative monitoring method. Until permission to use an alternative monitoring procedure has been granted by the Administrator under 40 CFR Sections 63.8(f)(1)-(6), as appropriate, the Permittee remains subject to the requirements of 40 CFR Section 63.8 and the relevant standard. 63.9(h); Minn. R Notification of compliance status. Each time a notification of compliance status is required under 40 CFR pt. 63, subp. A, the Permittee shall submit to the Commissioner a notification of compliance status containing the information required by 40 CFR Section 63.9(h), signed by the responsible official who shall certify its accuracy, attesting to whether the source has complied with the relevant standard. The notification must be sent by the 60th day following the completion of the relevant compliance demonstration activity specified in the relevant standard. If no performance test is required but opacity or visible emission observations are required, the notification of compliance status shall be sent by the 30th day following the completion of opacity or visible emission observations. Notifications may be combined as long as the due date requirement for each notification is met. 40 CFR Section 63.9(j); Minn. R Notification. Any change in the information already provided under 40 CFR Section 63.9 shall be provided to the Commissioner and the Administrator in writing within 15 calendar days after the change. hdr RECORDKEEPING AND REPORTING REQUIREMENTS 40 CFR Section 63.10(a); Minn. R CFR Section 63.10(b)(1); Minn. R , subp. 2(B) 40 CFR Section 63.10(b)(2); Minn. R , subp. 2(B) The Permittee shall submit reports to the Commissioner and shall send a copy of each report to the Administrator. Recordkeeping. The Permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent 2 years of data must be retained on site. The Permittee shall maintain, at a minimum, the following information in the files: 1) the occurrence and duration of each startup, shutdown, or malfunction of operation; 2) the occurrence and duration of each malfunction of the air pollution control equipment; 3) all maintenance performed on the pollution control equipment; 4) 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). In this case, the Permittee shall report this action within 2 days of occurrence and follow by a written notification within 7 days of occurrence. 5) all information necessary to demonstrate conformance with the affected source's SSMP and actions taken in accordance with SSMP; 6) all required measurements needed to demonstrate compliance with a relevant standard; (Continued below)

49 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 9 of Feb, :07 COMPLIANCE PLAN CFR Section 63.10(b)(2); Minn. R , subp. 2(B) 40 CFR Section 63.10(d)(1); Minn. R CFR Section 63.10(d)(4); Minn. R CFR Section 63.10(d)(5)(i); Minn. R (Continued from above) 7) all measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 8) any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 9) all documents supporting initial notifications and notifications of compliance status. Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), the Permittee shall submit reports to the Commissioner and the Administrator in accordance with the reporting requirements in the relevant standard. Progress reports. The Permittee who is required to submit progress reports as a condition of receiving an extension of compliance under 40 CFR Section 63.6(i) shall submit such reports to the Commissioner and the Administrator by the dates specified in the written extension of compliance. Periodic startup, shutdown, and malfunction reports. If actions taken by a Permittee during a startup or shutdown (and the startup or shutdown causes the source to exceed any applicable emission limitation in the relevant emission standards), or malfunction of an affected source (including actions taken to correct a malfunction) are consistent with the procedures specified in the source's startup, shutdown, and malfunction plan, the Permittee shall state such information in a startup, shutdown, and malfunction report. (Continued below) CFR Section 63.10(d)(5)(i); Minn. R (Continued from above) Actions taken to minimize emissions during such startups, shutdowns, and malfunctions shall be summarized in the report and may be done in checklist form. Such a report shall also include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. Reports shall only be required if a startup or shutdown caused the source to exceed any applicable emission limitation, or if a malfunction occurred during the reporting period. The startup, shutdown, and malfunction report shall consist of a letter, containing the name, title, and signature of the Permittee who is certifying its accuracy, that shall be submitted to the Commissioner and the Administrator semiannually or on a more frequent basis if specified otherwise in a relevant standard or as established otherwise in the title V permit CFR Section 63.10(d)(5)(ii); Minn. R , subp. 2(B) Immediate startup, shutdown, and malfunction reports. Notwithstanding the allowance to reduce the frequency of reporting for periodic startup, shutdown, and malfunction reports, any time an action taken by a Permittee during a startup or shutdown that caused the source to exceed any applicable emission limitation in the relevant emission standards, or malfunction is not consistent with the procedures specified in the affected source's SSMP, the Permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan followed by a letter within 7 working days after the end of the event CFR Section 63.10(d)(5)(ii); Minn. R , subp. 2(B) 40 CFR Section 63.10(f); Minn. R (Continued below) (Continued from above) The immediate report required under this paragraph (d)(5)(ii) shall consist of a telephone call (or facsimile (FAX) transmission) to the Commissioner and the Administrator within 2 working days after commencing actions inconsistent with the plan, and it shall be followed by a letter, delivered or postmarked within 7 working days after the end of the event. The report shall contain the information specified in 40 CFR Section 63.10(d)(5)(ii). Waiver of recordkeeping or reporting requirements. No requirements required.

50 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 10 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 002 Units subject to 40 CFR pt. 63, subp. ZZZZZ - Area Source Standards for Steel Foundries EU 033 Steel Electric Melt Furnace - Melting Equipment EU 041 Rollover Furnace - Furnace NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. hdr NESHAP SUBPART ZZZZZ REQUIREMENTS - Enforcement Not Delegated to MPCA hdr MANAGEMENT PRACTICES FOR METALLIC SCRAP 40 CFR Section (a) For each segregated metallic scrap storage area, bin or pile, the Permittee shall comply with the following materials acquisition requirements. The Permittee shall keep a copy of the material specifications onsite and readily available to all personnel with material acquisition duties, and provide a copy to each scrap provider. 40 CFR Section (a)(1) Restricted metallic scrap. The Permittee shall prepare and operate at all times according to written material specifications for the purchase and use of only metal ingots, pig iron, slitter, or other materials that do not include post-consumer automotive body scrap, post-consumer engine blocks, post-consumer oil filters, oily turnings, lead components, chlorinated plastics, or free liquids. "Free liquids" is defined as material that fails the paint filter test by EPA Method 9095B, "Paint Filter Liquids Test" (revision 2), November 2004 (incorporated by reference-see 40 CFR Section 63.14). The requirements for no free liquids do not apply if the Permittee can demonstrate that the free liquid is water that resulted from scrap exposure to rain. 40 CFR Section (a)(2) The Permittee shall prepare and operate at all times according to written material for the purchase and use of only iron and steel scrap that has been depleted (to the extent practicable) of organics and HAP metals in the charge materials in the charge materials used by the iron and steel foundry. The materials specifications must include at a minimum the information specified in paragraph (a)(2)(i) or (ii) of this section. 40 CFR Section (a)(2)(i) Except as provided in paragraph (a)(2)(ii) of this section, specifications for metallic scrap materials charged to a scrap preheater or metal melting furnace to be depleted (to the extent practicable) of the presence of used oil filters, chlorinated plastic parts, accessible lead-containing components (such as batteries and wheel weights), and a program to ensure the scrap materials are drained of free liquids. 40 CFR Section (b)(4) Mercury Requirements for Non-Motor Vehicle Scrap: For scrap that does not contain motor vehicle scrap, the Permittee must certify in the notification of compliance status and maintain records of documentation that the scrap does not contain motor vehicle scrap, for each scrap provider, contract, or shipment. hdr MANAGEMENT PRACTICES FOR BINDER FORMULATIONS 40 CFR Section For each furfuryl alcohol warm box mold or core making line at a new or existing iron and steel foundry, the Permittee must use a binder chemical formulation that does not use methanol as a specific ingredient of the catalyst formulation. This requirement does not apply to the resin portion of the binder system. hdr RECORDKEEPING AND REPORTING 40 CFR Section (d) The Permittee shall maintain files of all information (including all reports and notifications) for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent 2 years of data shall be retained on site. The remaining 3 years of data may be retained off site. Such files may be maintained on microfilm, on a computer, on computer floppy disks, on magnetic tape disks, or on microfiche.

51 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 11 of Feb, :07 COMPLIANCE PLAN CFR Section (e)(1)-(2) (e) You must maintain records of the information specified in paragraphs (e)(1), (e)(2), and (e)(5) through (e)(7) of this section according to the requirements in 63.10(b)(1). (1) Records supporting your initial notification of applicability and your notification of compliance status according to 63.10(b)(2)(xiv). (2) Records of your written materials specifications according to (a) and records that demonstrate compliance with the requirements for restricted metallic scrap in (a)(1) and/or for the use of general scrap in (a)(2) and for mercury in (b)(1) through (3), as applicable. You must keep records documenting compliance with (b)(4) for scrap that does not contain motor vehicle scrap CFR Section (e)(5)-(7) (5) Records to document use of binder chemical formulation that does not contain methanol as a specific ingredient of the catalyst formulation for each furfuryl alcohol warm box mold or core making line as required by These records must be the Material Safety Data Sheet (provided that it contains appropriate information), a certified product data sheet, or a manufacturer's hazardous air pollutant data sheet. (6) Records of the annual quantity and composition of each HAP-containing chemical binder or coating material used to make molds and cores. These records must be copies of purchasing records, Material Safety Data Sheets, or other documentation that provides information on the binder or coating materials used (7) Records of metal melt production for each calendar year. 40 CFR Section (f) The Permittee shall submit semiannual compliance reports to the Administrator according to the requirements in 63.10(e). The report must clearly identify any deviation from the pollution prevention management practices in or and the corrective action taken. 40 CFR Section (g) The Permittee shall submit a written notification to the Administrator of the initial classification of your facility as a small foundry as required in (f) and (g), as applicable, and for any subsequent reclassification as required in (d)(1) or (e), as applicable 40 CFR Section (h) Following the initial determination for an existing affected source as a small foundry, if the annual metal melt production exceeds 20,000 tons during the preceding year, you must comply with the requirements for large foundries by the applicable dates in (d)(1)(i) or (d)(1)(ii). Following the initial determination for a new affected source as a small foundry, if you increase the annual metal melt capacity to exceed 10,000 tons, you must comply with the requirements for a large foundry by the applicable dates in (e)(1). hdr GENERAL PROVISIONS 40 CFR Section (i) The Permittee shall comply with the following requirements of the General Provisions (40 CFR part 63, subpart A): 63.1 through 63.5; 63.6(a), (b), (c), and (e)(1); 63.9; 63.10(a), (b)(1), (b)(2)(xiv), (b)(3), (d)(1), (d)(4), and (f); and through Requirements of the General Provisions not cited in the preceding sentence do not apply to the owner or operator of a new or existing affected source that is classified as a small foundry. 40 CFR Section 63.4(b); Minn. R CFR Section 63.5(b)(4); Minn. R CFR Section 63.5(b)(6); Minn. R Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, but is not limited to: 1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere or 2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions. The Permittee must submit notification according to 40 CFR Section 63.9(b) if the Permittee constructs or reconstructs a source such that the source becomes an affected source subject to a standard. After the effective date of any relevant standard promulgated under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source.

52 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 12 of Feb, :07 COMPLIANCE PLAN CFR Section 63.6(e)(1)(i); Minn. R CFR Section 63.6(e)(1)(ii); Minn. R CFR Section 63.9(b)(2); Minn. R CFR Section 63.9(b)(4); Minn. R CFR Section 63.9(j); Minn. R Proper Operation and Maintenance. At all times, including periods of startup, shutdown, and malfunction, the Permittee shall operate and maintain the emission unit subject to the MACT standard and any associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by any relevant standard and as detailed in 40 CFR Section 63.6(e)(1)(i)-(iii). Malfunctions shall be corrected as soon as practicable after their occurrence. Initial notification due within 120 calendar days after the source becomes subject to the relevant standard. The initial notification shall include the information specified in 40 CFR Section 63.9(b)(2). The Permittee shall submit the notification both to the Commissioner and to the US EPA regional office in Chicago. The Permittee of a new or reconstructed major affected source for which an application for approval of construction or reconstruction is required under 40 CFR Section 63.5(d) must provide the following information in writing to the the Commissioner and the Administrator: 1) A notification of intention to construct a new major-emitting affected source, reconstruct a major-emitting affected source, or reconstruct a major source such that the source becomes a major-emitting affected source; and 2) A notification of the actual date of startup of the source, delivered or postmarked within 15 calendar days after that date. Notification. Any change in the information already provided under 40 CFR Section 63.9 shall be provided to the Commissioner and the Administrator in writing within 15 calendar days after the change. hdr RECORDKEEPING AND REPORTING REQUIREMENTS 40 CFR Section 63.10(a); Minn. R CFR Section 63.10(b)(1); Minn. R , subp. 2(B) 40 CFR Section 63.10(d)(1); Minn. R CFR Section 63.10(d)(4); Minn. R The Permittee shall submit reports to the Commissioner and shall send a copy of each report to the Administrator. Recordkeeping. The Permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent 2 years of data must be retained on site. Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), the Permittee shall submit reports to the Commissioner and the Administrator in accordance with the reporting requirements in the relevant standard. Progress reports. The Permittee who is required to submit progress reports as a condition of receiving an extension of compliance under 40 CFR Section 63.6(i) shall submit such reports to the Commissioner and the Administrator by the dates specified in the written extension of compliance.

53 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 13 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 010 Knockout CE 005 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 013 Fabric Filter - Low Temperature, i.e., T<180 Degrees F EU 038 Knockout Cabinet - Casting Equipment EU 051 Knockout Cabinet - Casting Equipment EU 052 Knockout Cabinet - Casting Equipment EU 053 Knockout Cabinet - Casting Equipment EU 054 Knockout Cabinet - Casting Equipment EU 057 Knockout Cabinet - Casting Equipment EU 058 Knockout Cabinet - Casting Equipment EU 083 Knockout Cabinet - Casting Equipment EU 102 Knockout Cabinet - Casting Equipment NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A) 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 LIMIT Minn. R , subp. 1(B) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. Minn. R , subps. 2 and 14 Maintain air pollution control equipment in proper operating condition and utilize the air pollution control systems as designed. See CE 005, and CE 013 for fabric filter requirements.

54 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 14 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: GP 011 Shakeout Associated Items: CE 016 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 020 Fabric Filter - Low Temperature, i.e., T<180 Degrees F EU 133 Shakeout - Casting Equipment EU 136 Vibro mill - Abrasive Equipment EU 141 Shakeout - Casting Equipment EU 169 Shaker, vibratory - Abrasive Equipment EU 170 Shaker, vibratory - Abrasive Equipment NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A) 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 LIMIT Minn. R , subp. 1(B) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. Minn. R , subps. 2 and 14 Maintain air pollution control equipment in proper operating condition and utilize the air pollution control systems as designed. See CE 016, and CE 020 for fabric filter requirements.

55 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 15 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 012 Abrasive Blasting CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 007 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 009 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 010 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 011 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 012 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 013 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 014 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F EU 042 Blast Cabinet - Abrasive Equipment EU 043 Blast Cabinet - Abrasive Equipment EU 044 Wheelabrator Blast Cabinet - Abrasive Equipment EU 045 Blast Cabinet - Abrasive Equipment EU 046 Wheelabrator - Abrasive blasting EU 047 Jet Wheelblast - Abrasive Equipment EU 048 Mesh Belt Blaster - Abrasive Equipment EU 049 Blast Cabinet - Abrasive Equipment EU 050 Blast Cabinet - Abrasive Equipment EU 055 Blast Cabinet - Abrasive Equipment EU 056 Blast Room - Abrasive Equipment EU 082 Empire Blast Cabinet (glass bead) - Abrasive Equipment EU 097 Blast Cabinet (alum oxide) - Abrasive Equipment EU 146 Blast Cabinet - Abrasive Equipment NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A) 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 LIMIT Minn. R , subp. 1(B) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. Minn. R , subps. 2 and 14 Maintain air pollution control equipment in proper operating condition and utilize the air pollution control systems as designed. See CE 003, CE 007, CE 008, CE 009, CE 010, CE 011, CE 012, CE 013, CE 014, and CE 018 for fabric filter requirements.

56 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 16 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 013 Core Molding - Isocure/Cold Box CE 015 Gas Scrubber (General, Not Classified) EU 121 Cold Box Machine - Casting Equipment EU 122 Cold Box Machine - Casting Equipment EU 123 Cold Box Machine - Casting Equipment EU 124 Laempe L2 Core Machine - Casting Equipment EU 125 Laempe L1 Core Machine - Casting Equipment EU 139 Laempe L3 Core Machine - Casting Equipment EU 144 Core Blower - CB-10 - Casting Equipment EU 147 Core Blower - Gaylord SATB-15 - Casting Equipment EU 148 Laempe L4 Core Machine - Casting Equipment NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A) 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 LIMIT Minn. R , subp. 1(B) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. Minn. R , subps. 2 and 14 Maintain air pollution control equipment in proper operating condition and utilize the air pollution control systems as designed. See CE 015 for gas scrubber requirements.

57 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 17 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 015 Core Molding - Shell Core EU 126 Shell Core Machine - Casting Equipment EU 127 Shell Core Machine - Casting Equipment EU 128 Shell Core Machine - Casting Equipment EU 129 Shell Core Machine - Casting Equipment NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1 Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. LIMIT Minn. R , subp. 2 Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. LIMIT Minn. R , subp. 1 Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. Minn. R , subp. 35a Fuel type: Natural gas only, by design.

58 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 18 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP Series Molding Machines EU 159 Molding Machine - Squeezing - Molding Equipment EU 160 Molding Machine - Squeezing - Molding Equipment EU 161 Molding Machine - Rotolifts - Molding Equipment EU 162 Molding Machine - Rotolifts - Molding Equipment EU 163 Molding Machine - Squeezer - Molding Equipment EU 164 Molding Machine - BMM - Molding Equipment EU 165 Molding Machine - BMM - Molding Equipment NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A) 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 LIMIT Minn. R , subp. 1(B) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity.

59 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 19 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 017 Sand Handling - Silos (New Sand) CE 014 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 026 Mat or Panel Filter CE 027 Mat or Panel Filter CE 028 Mat or Panel Filter CE 029 Mat or Panel Filter EU 116 Sand Silo-silica - Silo/bin EU 117 Sand Silo-silica - Silo/bin EU 118 Sand Silo-silica - Silo/bin EU 119 Sand Silo-silica - Silo/bin EU 120 Sand SIlo-silica - Silo/bin EU 149 Sand Silo - Olivine - Silo/bin NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A) 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 LIMIT Minn. R , subp. 1(B) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. Minn. R , subps. 2 and 14 Maintain air pollution control equipment in proper operating condition and utilize the air pollution control systems as designed. See CE 014, CE 026, CE 027, CE 028, and CE 029 for fabric filter, and panel filter requirements.

60 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 20 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 018 Sand Handling/Transfer - Conveyors, Mullers, Elevators CE 020 Fabric Filter - Low Temperature, i.e., T<180 Degrees F EU 135 Kloster Molding Unit (w\ binders) - Aggregate Handling Equipment EU 140 Sand Mixer "special" - Mixing Equipment EU 158 Muller - Mixing Equipment EU 166 Bucket Elevator Muller - Mixing Equipment EU 167 Elevator EU 168 Sand Storage - Silo/bin NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A) 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 LIMIT Minn. R , subp. 1(B) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. Minn. R , subps. 2 and 14 Maintain air pollution control equipment in proper operating condition and utilize the air pollution control systems as designed. See CE 020 for fabric filter requirements.

61 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 21 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 019 Furnaces - Natural Gas (Aluminum) EU 093 Natural Gas Melt Furnace - Melting Equipment EU 150 Natural Gas Melt Furnace - Melting Equipment EU 204 Natural Gas Melt Furnace - Melting Equipment EU 210 Gas Dry Hearth - Melting Equipment NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1 Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. LIMIT Minn. R , subp. 2 Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. LIMIT Minn. R , subp. 1 Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. Minn. R , subp. 35a Fuel Type: Natural gas only, by design.

62 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 22 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 020 Furnaces - Electric (Aluminum) EU 036 Electric Melt Furnace - Melting Equipment EU 037 Electric Melt Furnace - Melting Equipment EU 039 Electric Melt Furnace - Melting Equipment EU 040 Electric melt Furnace - Melting Equipment EU 075 Electric Melt Furnace - Melting Equipment EU 076 Electric Melt Furnace - Melting Equipment EU 077 Electric Melt Furnace - Melting Equipment EU 078 Electric Melt Furnace - Melting Equipment EU 079 Electric Melt Furnace - Melting Equipment EU 080 Electric Melt Furnace - Melting Equipment EU 081 Electric Melt Furnace - Melting Equipment EU 084 Electric Melt Furnace - Melting Equipment EU 085 Electric Melt Furnace - Melting Equipment EU 086 Electric Melt Furnace - Melting Equipment EU 087 Electric Melt Furnace - Melting Equipment EU 088 Electric Melt Furnace - Melting Equipment EU 089 Electric Melt Furnace - Melting Equipment EU 090 Electric Melt Furnace - Melting Equipment EU 091 Electric Melt Furnace - Melting Equipment EU 092 Electric Melt Furnace - Melting Equipment EU 094 Electric Melt Furnace - Melting Equipment EU 095 Electric Melt Furnace - Melting Equipment EU 096 Electric Melt Furnace - Melting Equipment EU 098 Electric Melt Furnace - Melting Equipment EU 099 Electric Melt Furnace - Melting Equipment EU 100 Electric Melt Furnace - Melting Equipment EU 101 Electric Melt Furnace - Melting Equipment EU 103 Electric Melt Furnace - Melting Equipment EU 104 Electric Melt Furnace - Melting Equipment EU 105 Electric Melt Furnace - Melting Equipment EU 106 Electric Melt Furnace - Melting Equipment EU 107 Electric Melt Furnace - Melting Equipment EU 108 Electric Melt Furnace - Melting Equipment EU 109 Electric Melt Furnace - Melting Equipment EU 110 Electric Melt Furnace - Melting Equipment EU 111 Electric Melt Furnace - Melting Equipment EU 112 Electric Melt Furnace - Melting Equipment EU 113 Electric Melt Furnace - Melting Equipment EU 114 Electric Melt Furnace - Melting Equipment EU 130 Electric Melt Furnace - Melting Equipment EU 131 Electric Melt Furnace - Melting Equipment EU 132 Electric Melt Furnace - Melting Equipment EU 145 Electric Melt Furnace - Melting Equipment

63 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 23 of Feb, :07 COMPLIANCE PLAN -01 Associated Items: EU 151 Electric Melt Furnace - Melting Equipment EU 152 Electric Melt Furnace - Melting Equipment EU 153 Electric Melt Furnace - Melting Equipment EU 154 Electric Melt Furnace - Melting Equipment EU 155 Electric Melt Furnace - Melting Equipment EU 156 Electric Melt Furnace - Melting Equipment EU 157 Electric Melt Furnace - Melting Equipment EU 202 Electric Melt Furnace - Melting Equipment EU 203 Electric Melt Furnace - Melting Equipment EU 205 Low Pressure Molding Machine #1 - Molding Equipment EU 206 Low Pressure Molding Machine #3 - Molding Equipment EU 207 Low Pressure Molding Machine #2 - Molding Equipment NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A) 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 LIMIT Minn. R , subp. 1(B) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity.

64 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 24 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 021 Furnaces - Electric (Steel) EU 033 Steel Electric Melt Furnace - Melting Equipment EU 041 Rollover Furnace - Furnace NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A) 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 LIMIT Minn. R , subp. 1(B) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity.

65 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 25 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 022 Boilers EU 030 Autoclave Boiler - Boiler EU 142 Boiler for Kloster Heater/Cooler - NG EU 143 Boiler for Kloster Sand Heater/cooler NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1 Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. LIMIT Minn. R , subp. 2 Opacity: less than 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity LIMIT Minn. R , subp. 1 Sulfur Dioxide: less than or equal to 2.00 lbs/million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. Minn. R , subp. 35a Fuel Type: Natural gas only, by design.

66 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 26 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 023 Core Bake-Out Ovens EU 063 Core Bake Out Oven - Dryer/Oven, direct fired EU 070 Core Bake out Oven - Dryer/Oven, direct fired EU 073 Core Bake out Oven - Dryer/Oven, direct fired NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A)(1) 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 LIMIT Minn. R , subp. 1(A)(2) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. LIMIT Minn. R , subp. 2(A)(2) Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. Minn. R , subp. 35a Fuel Type: Natural gas only, by design.

67 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 27 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 024 Ladle Preheaters EU 074 Permanent Mold Preheating Torches - Other Combustion EU 137 Ladle Preheater - Other Combustion NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A)(1) 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 LIMIT Minn. R , subp. 1(A)(2) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. LIMIT Minn. R , subp. 2(A)(2) Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. Minn. R , subp. 35a Fuel Type: Natural gas only, by design.

68 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 28 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 025 Heat Treat Ovens EU 060 Heat Treat Aging Oven - Dryer/Oven, direct fired EU 062 Heat Treat Aging Oven - Dryer/Oven, direct fired EU 064 Heat Treat - Dryer/Oven, direct fired EU 066 Heat Treat Aging Oven - Dryer/Oven, direct fired EU 068 Heat Treat Aging Oven - Dryer/Oven, direct fired NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A)(1) 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 LIMIT Minn. R , subp. 1(A)(2) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. LIMIT Minn. R , subp. 2(A)(2) Sulfur Dioxide: less than or equal to 3.0 lbs/million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. Minn. R , subp. 35a Fuel Type: Natural gas only, by design.

69 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 29 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 026 Quench & Kolene Tanks EU 026 Kolene Unit Burner - Other Combustion EU 065 Furnace C Quench Tank with Heater - Other Combustion NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1 Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. LIMIT Minn. R , subp. 2 Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. LIMIT Minn. R , subp. 1 Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. Minn. R , subp. 35a Fuel type: Natural gas only, by design.

70 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 30 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: Associated Items: GP 027 Investment Casting - Wax Burnout Ovens CE 021 Direct Flame Afterburner CE 022 Direct Flame Afterburner CE 023 Direct Flame Afterburner CE 024 Direct Flame Afterburner EU 027 Shell Firing Furnace - Wax Burnout Oven EU 031 Shell Firing Furnace - Wax Burnout Oven EU 034 Shell Firing Furnace - Wax Burnout Oven NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A)(1) 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 LIMIT Minn. R , subp. 1(A)(2) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. LIMIT Minn. R , subp. 2(A)(2) Minn. R , subp. 35a Fuel Type: Natural gas only, by design. Minn. R , subps. 2 and 14 Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input. The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. Maintain air pollution control equipment in proper operating condition and utilize the air pollution control systems as designed. See CE 021, CE 022, CE 023, and CE 024 for after burner requirements.

71 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 31 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: EU 023 Emergency Diesel Generator - Reciprocating IC Engine Associated Items: SV 097 Dust Collector EQ ID NC/ CA Type Citation Requirement hdr EMISSION LIMITS LIMIT Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. LIMIT Minn. R , subp. 2 Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input. The potential to emit from the unit is 0.40 lb/mmbtu due to equipment design and allowable fuels. Minn. R , subp. 35a Fuel type: No. 2 fuel oil/diesel fuel meeting the requirements of 40 CFR Section (c) only by design. hdr RECORDKEEPING REQUIREMENTS Minn. R , subps. 4 & 5 Hours of Operation: The Permittee shall maintain documentation on site that the 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. Minn. R , subp. 5 The Permittee shall keep records of fuel type and usage on a monthly basis. hdr NESHAP, 40 CFR pt. 63, subp. ZZZZ REQUIREMENTS - Enforcement Not Delegated to MPCA 40 CFR Section ; 40 CFR Section ; 40 CFR pt. 63, subp. ZZZZ, Table 2d; Minn. R CFR Section ; 40 CFR Section ; 40 CFR pt. 63, subp. ZZZZ, Table 2d; Minn. R CFR Section ; 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 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 in 40 CFR Section (i). Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. The Permittee shall be in compliance with the emission limitations, operating limitations, and other requirements 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.

72 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 32 of Feb, :07 COMPLIANCE PLAN CFR Section (i); Minn. R CFR Section (i); Minn. R CFR Section (a); 40 CFR pt. 63, subp. ZZZZ, Table 6 The Permittee has the option of utilizing an oil analysis program in order to extend the specified oil change requirement. The oil analysis shall be performed at the same frequency specified for changing the oil. The analysis program shall at a minimum analyze the following 3 parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. (continued below) (continued from above) If none of the condemning limits are exceeded, the Permittee is not required to change the oil. If any of the limits are exceeded, the Permittee shall change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the Permittee shall change the oil within 2 business days or before commencing operation, whichever is later. The Permittee shall keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program shall be part of the maintenance plan for the engine. 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. hdr NESHAP, 40 CFR pt. 63, subp. ZZZZ GENERAL PROVISIONS 40 CFR Section 63.4(b); Minn. R CFR Section 63.5(b)(4); Minn. R CFR Section 63.5(b)(6); Minn. R CFR Section 63.6(f)(2); Minn. R CFR Section 63.6(f)(3); Minn. R Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, but is not limited to: 1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere or 2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions. The Permittee must submit notification according to 40 CFR Section 63.9(b) if the Permittee constructs or reconstructs a source such that the source becomes an affected source subject to a standard. After the effective date of any relevant standard promulgated under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source. Methods for determining compliance will be, in part, based on the results of performance tests, conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 40 CFR Section 63.6(f)(2) The Permittee many use the results of performance testing conducted previously if it meets the requirements of 40 CFR Section 63.6(f)(iii). Finding of compliance. The Commissioner or the Administrator will make a finding concerning an affected source's compliance with a non-opacity emission standard upon obtaining all the compliance information required by the relevant standard. hdr GENERAL MONITORING REQUIREMENTS 40 CFR Section 63.8(b)(1); Minn. R Conduct of monitoring. Monitoring shall be conducted as set forth in 40 CFR Section 63.8(a)(b)(1). hdr GENERAL NOTIFICATION REQUIREMENTS 40 CFR Section 63.9(b)(4); Minn. R The Permittee of a new or reconstructed major affected source for which an application for approval of construction or reconstruction is required under 40 CFR Section 63.5(d) must provide the following information in writing to the the Commissioner and the Administrator: 1) A notification of intention to construct a new major-emitting affected source, reconstruct a major-emitting affected source, or reconstruct a major source such that the source becomes a major-emitting affected source; and 2) A notification of the actual date of startup of the source, delivered or postmarked within 15 calendar days after that date.

73 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 33 of Feb, :07 COMPLIANCE PLAN CFR Section 63.9(h); Minn. R CFR Section 63.9(j); Minn. R Notification of compliance status. Each time a notification of compliance status is required under 40 CFR pt. 63, subp. A, the Permittee shall submit to the Commissioner a notification of compliance status containing the information required by 40 CFR Section 63.9(h), signed by the responsible official who shall certify its accuracy, attesting to whether the source has complied with the relevant standard. The notification must be sent by the 60th day following the completion of the relevant compliance demonstration activity specified in the relevant standard. If no performance test is required but opacity or visible emission observations are required, the notification of compliance status shall be sent by the 30th day following the completion of opacity or visible emission observations. Notifications may be combined as long as the due date requirement for each notification is met. Notification. Any change in the information already provided under 40 CFR Section 63.9 shall be provided to the Commissioner and the Administrator in writing within 15 calendar days after the change. hdr GENERAL RECORDKEEPING AND REPORTING REQUIREMENTS 40 CFR Section 63.10(a); Minn. R CFR Section 63.10(b)(1); Minn. R , subp. 2(B) 40 CFR Section 63.10(d)(1); Minn. R The Permittee shall submit reports to the Commissioner and shall send a copy of each report to the Administrator. Recordkeeping. The Permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), the Permittee shall submit reports to the Commissioner and the Administrator in accordance with the reporting requirements in the relevant standard.

74 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 34 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: EU 024 Emergency Natural Gas Generator - Reciprocating IC Engine Associated Items: SV 083 Unit Heater EQ ID NC/ CA Type Citation Requirement hdr EMISSION LIMITS LIMIT Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. LIMIT Minn. R , subp. 2 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. Minn. R , subp. 35a Fuel type: Natural gas only, by design. hdr RECORDKEEPING LIMIT Minn. R , subps. 4 & 5 Hours of Operation: The Permittee shall maintain documentation on site that the 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. Minn. R , subp. 5 The Permittee shall keep records of fuel type and usage on a monthly basis. hdr NESHAP, 40 CFR pt. 63, subp. ZZZZ REQUIREMENTS 40 CFR Section (a)(2)(iii); 40 CFR Section (c); Minn. R EU 024 is a new affected source as defined under 40 CFR pt. 63, subp. ZZZZ, and the facility is an area source as defined at 40 CFR Section The Permittee shall meet the requirements of 40 CFR pt. 63, subp. ZZZZ by meeting the requirements of 40 CFR pt. 60, subp. JJJJ. No further requirements of 40 CFR pt. 63, subp. ZZZZ apply to EU 024. hdr NSPS, 40 CFR pt. 60, subp. JJJJ REQUIREMENTS hdr NSPS, 40 CFR pt. 60, subp. JJJJ APPLICABILITY 40 CFR Section (c); 40 CFR Section (a)(4)(iv) and Minn. R The Permittee is an owner and operator of EU 024 which is an emergency, stationary SI internal combustion engine (ICE) with a maximum engine power greater than 19 kw (25 HP) that commenced construction after June 12, 2006 and manufactured on or after January 1, The date that construction commences is the date that the engine is ordered by the Permittee. hdr NSPS, 40 CFR pt. 60, subp. JJJJ EMISSION AND OPERATING LIMITS LIMIT 40 CFR Section (d); 40 CFR pt. 60, subp. JJJJ, Table 1; Minn. R ; 40 CFR Section (c); Minn. R LIMIT 40 CFR Section (d); 40 CFR pt. 60, subp. JJJJ, Table 1; Minn. R ; 40 CFR Section (c); Minn. R CFR Section (d); 40 CFR Section (c); Minn. R Nitrogen Oxides: less than or equal to 10 grams/horsepower-hour. This emission limit applicable to EU 024 is in terms of Nitrogen Oxides + Hydrocarbons (NOx + HC). Carbon Monoxide: less than or equal to 387 grams/horsepower-hour. EU 024 may be operated 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, or the insurance company associated with the engine. Maintenance checks and readiness testing of EU 024 is limited to 100 hours per year. There is no time limit on the use of EU 024 in emergency situations. 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 ICE beyond 100 hours per year. EU 024 may operate up to 50 hours per year in non-emergency situations, but those 50 hours are counted towards the 100 hours per year provided for maintenance and testing.

75 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 35 of Feb, :07 COMPLIANCE PLAN CFR Section (d); 40 CFR Section (c); Minn. R The 50 hours per year for non-emergency situations cannot be used for peak shaving 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. For the Permittee of emergency engines, any operation other than emergency operation, maintenance and testing, and operation in non-emergency situations for 50 hours per year, as permitted in 40 CFR Section , is prohibited. hdr NSPS, 40 CFR pt. 60, subp. JJJJ OPERATIONAL REQUIREMENTS 40 CFR Section ; 40 CFR Section (c); Minn. R CFR Section (c); 40 CFR Section (c); Minn. R CFR Section (b)(1); 40 CFR Section (c); Minn. R CFR Section ; 40 CFR Section (c); Minn. R CFR Section ; 40 CFR pt. 60, subp. JJJJ, Table 1; 40 CFR Section 60.7(a)(4); 40 CFR Section (c); Minn. R ; Minn. R , subp CFR Section ; 40 CFR pt. 60, subp. JJJJ, Table 1; 40 CFR Section 60.12; 40 CFR Section (c); Minn. R ; Minn. R hdr JJJJ RECORDKEEPING 40 CFR Section (a); 40 CFR Section (c); Minn. R CFR Section (b); 40 CFR Section (c); Minn. R CFR Section ; 40 CFR Section 60.7(b); 40 CFR Section (c); Minn. R ; Minn. R , subp CFR Section ; Minn. R , subp. 5(C); 40 CFR Section 60.7(f); 40 CFR Section (c); Minn. R ; Minn. R , subp. 1 The Permittee shall operate and maintain the stationary SI RICE that achieves the emission standards as required in 40 CFR Section over the entire life of the engine. The Permittee shall install a non-resettable hour meter upon startup of EU 024, if one is not already installed. The Permittee shall operate and maintain the certified stationary SI RICE and control device according to the manufacturer's emission-related written instructions and keep records of conducted maintenance to demonstrate compliance. No performance testing is required if the Permittee is the owner or operator. The Permittee shall also meet the requirements as specified in 40 CFR pt. 1068, subps. A through D as applicable. If engine settings are adjusted according to and consistent with the manufacturer's instructions, your SI RICE will not be considered out of compliance. The Permittee shall comply with the applicable provisions of 40 CFR pt. 60, subp. A, as required by Table 3 of 40 CFR pt. 60, subp. JJJJ. Notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. The Permittee shall keep records of the following: (1) All notifications submitted to comply with Subpart JJJJ and all documentation supporting any notification; (2) Maintenance conducted on the engine; (3) If the engine is certified, documentation from the manufacturer that the engine is certified to meet the emission standards and information as required in 40 CFR Parts 90 and 1048; and (4) If the engine is non-certified or is certified but operating in a non-certified manner and subject to 40 CFR Section (a), documentation that the engine meets the emission standards. The Permittee shall keep records of the hours of operation of the engine that is 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. Recordkeeping: Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. Recordkeeping: Maintain a file of all measurements, maintenance, reports and records for at least five years. 40 CFR Section 60.7(f) specifies two years. hdr PERFORMANCE TESTING REQUIREMENTS FOR A NON-CERTIFIED ENGINE

76 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 36 of Feb, :07 COMPLIANCE PLAN CFR Section (b)(2)(i); Minn. R ; 40 CFR Section (c); Minn. R S/A 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R , subp. 1 S/A 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R , subp. 1 S/A 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R , subp CFR Section (a); 40 CFR pt. 60, subp. JJJJ, Table 2; Minn. R ; 40 CFR Section (c); Minn. R The Permittee shall keep a maintenance plan and records of conducted maintenance and must, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, you must conduct an initial performance test to demonstrate compliance. Initial Performance Test: due 180 days after Effective Date of Permit to measure NOx emissions. The performance test must be conducted within 10 percent of 100 percent peak (or the highest achievable) load and according to the requirements in Section 60.8 and under the specific conditions that are specified by Table 2 to Subpart JJJJ of Part 60. Initial Performance Test: due 180 days after Effective Date of Permit to measure CO emissions. The performance test must be conducted within 10 percent of 100 percent peak (or the highest achievable) load and according to the requirements in Section 60.8 and under the specific conditions that are specified by Table 2 to Subpart JJJJ of Part 60. Initial Performance Test: due 180 days after Effective Date of Permit to measure VOC emissions. The performance test must be conducted within 10 percent of 100 percent peak (or the highest achievable) load and according to the requirements in Section 60.8 and under the specific conditions that are specified by Table 2 to Subpart JJJJ of Part 60. a. For EU 024 demonstrating compliance according to 40 CFR Section and complying with the requirement to limit the concentration of NOx in the exhaust from EU 024, the Permittee shall; i. Select the sampling port location and the number/location of traverse points at the exhaust of EU024 using Method 1 or 1A of 40 CFR part 60, appendix A-1. ii. Determine the oxygen concentration of the exhaust from EU 024 at the sampling port location using Method 3, 3A, or 3B of 40 CFR pt. 60, appendix A-2 or ASTM Method D (2005). Measurements to determine oxygen concentration must be made at the same time as the measurements for NOx concentration. iii. If necessary, determine the exhaust flowrate of the exhaust from EU 024 using Method 2 or 2C of 40 CFR part 60, appendix A-1 or Method 19 of 40 CFR part 60, appendix A CFR Section (a); 40 CFR pt. 60, subp. JJJJ, Table 2 (cont.); Minn. R ; 40 CFR Section (c); Minn. R CFR Section (a); 40 CFR pt. 60, subp. JJJJ, Table 2 (cont.); Minn. R ; 40 CFR Section (c); Minn. R iv. If necessary, measure moisture content of the exhaust from EU 024 at the sampling port location using Method 4 of 40 CFR pt. 60, appendix A-3, Method 320 of 40 CFR pt. 63, appendix A, or ASTM D (incorporated by reference, see 40 CFR Section 60.17). Measurements to determine moisture must be made at the same time as the measurement for NOx concentration. v. Measure NOx at the exhaust of EU 024 using Method 7E of 40 CFR pt. 60, appendix A-4, ASTM Method D (2005), Method 320 of 40 CFR pt. 63, appendix A, or ASTM Method D (incorporated by reference, see 40 CFR Section 60.17). Results of this test consist of the average of the three 1-hour or longer runs. b. For EU 024 demonstrating compliance according to 40 CFR Section and complying with the requirement to limit the concentration of CO in the exhaust from EU 024, the Permittee shall; i. Select the sampling port location and the number/location of traverse points using Method 1 or 1A of 40 CFR pt. 60, appendix A-1. ii. Determine the oxygen concentration of the exhaust from EU 024 at the sampling port location using Method 3, 3A, or 3B of 40 CFR pt. 60, appendix A-2 or ASTM Method D (2005). Measurements to determine oxygen concentration must be made at the same time as the measurements for CO concentration. iii. If necessary, determine the exhaust flowrate of the exhaust from EU 024 using Method 2 or 2C of 40 CFR part 60, appendix A-1 or Method 19 of 40 CFR part 60, appendix A-7.

77 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 37 of Feb, :07 COMPLIANCE PLAN CFR Section (a); 40 CFR pt. 60, subp. JJJJ, Table 2 (cont.); Minn. R ; 40 CFR Section (c); Minn. R CFR Section (a); 40 CFR pt. 60, subp. JJJJ, Table 2 (cont.); Minn. R ; 40 CFR Section (c); Minn. R iv. If necessary, measure moisture content of the exhaust from EU 024 at the sampling port location using Method 4 of 40 CFR pt. 60, appendix A-3, Method 320 of 40 CFR part 63, appendix A, or ASTM D (incorporated by reference, see 40 CFR Section 60.17). Measurements to determine moisture must be made at the same time as the measurement for CO concentration. v. Measure CO at the exhaust of EU 024 using Method 10 of 40 CFR part 60, appendix A4, ASTM Method D (2005), Method 320 of 40 CFR part 63, appendix A, or ASTM Method D Results of this test consist of the average of the three 1-hour or longer runs. c. For EU 024 demonstrating compliance according to 40 CFR Section and complying with the requirement to limit the concentration of VOC in the exhaust from EU 017, the Permittee shall; i. Select the sampling port location and the number of traverse points using Method 1 or 1A of 40 CFR pt. 60, appendix A-1. ii. Determine the oxygen concentration of the exhaust from EU 024 at the sampling port location using Method 3, 3A, or 3B of 40 CFR pt. 60, appendix A-2 or ASTM Method D (2005). Measurements to determine oxygen concentration must be made at the same time as the measurements for VOC concentration CFR Section (a); 40 CFR pt. 60, subp. JJJJ, Table 2 (cont.); Minn. R ; 40 CFR Section (c); Minn. R iii. If necessary, determine the exhaust flowrate of the exhaust from EU 024 using Method 2 or 2C of 40 CFR part 60, appendix A-1 or Method 19 of 40 CFR part 60, appendix A-7. iv. If necessary, measure moisture content of the exhaust from EU 024 at the sampling port location using Method 4 of 40 CFR pt. 60, appendix A-3, Method 320 of 40 CFR part 63, appendix A, or ASTM Method D (incorporated by reference, see 40 CFR Section 60.17). Measurements to determine moisture must be made at the same time as the measurement for VOC concentration CFR Section (a); Minn. R ; 40 CFR Section (c); Minn. R CFR Section (b); Minn. R ; 40 CFR Section (c); Minn. R CFR Section (c); Minn. R ; 40 CFR Section (c); Minn. R CFR Section (d); Minn. R ; 40 CFR Section (c); Minn. R CFR Section (e); Minn. R ; 40 CFR Section (c); Minn. R CFR Section (f); Minn. R ; 40 CFR Section (c); Minn. R v. Measure VOC at the exhaust of EU 024 using Methods 25A and 18 of 40 CFR pt. 60, appendices A-6 and A-7, Method 25A with the use of a methane cutter as described in 40 CFR , Method 18 or 40 CFR pt. 60, appendix A-6, Method 320 of 40 CFR pt. 63, appendix A, or ASTM Method D (incorporated by reference, see 40 CFR Section 60.17). Results of this test consist of the average of the three 1-hour or longer runs. The Permittee shall conduct each performance test within 10 percent of 100 percent peak (or the highest achievable) load and according to the requirements in 40 CFR Section 60.8 and under the specific conditions specified 40 CFR pt. 60, subp. JJJJ, Table 2. The Permittee shall not conduct performance tests during periods of startup, shutdown, or malfunction, as specified in 40 CFR Section 60.8(c). If the engine is non-operational, the Permittee does not need to startup the engine solely to conduct a performance test; however, a performance test shall be conducted immediately upon startup of the engine. The Permittee shall conduct three separate test runs for each performance test, as specified in 40 CFR Section 60.8(f). Each test run must be conducted within 10 percent of 100 percent peak (or the highest achievable) load and last at least one hour. The Permittee shall determine compliance with the nitrogen oxides (NOx) mass per unit output emission limit by converting the concentration of NOx in the engine exhaust using Equation 1 in Appendix C to this permit, according to 40 CFR Section (d). The permittee shall determine compliance with the carbon monoxide (CO) mass per unit output emission limit by converting the concentration of CO in the engine exhaust using Equation 2 in Appendix C to this permit, according to 40 CFR Section (e). When calculating emissions of volatile organic compounds (VOC), do not include emissions of formaldehyde. The Permittee must determine compliance with the VOC mass per unit output emission limit by converting the concentration of VOC in the engine exhaust using Equation 3 in Appendix C to this permit, according to 40 CFR Section (f).

78 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 38 of Feb, :07 COMPLIANCE PLAN S/A S/A S/A 40 CFR Section (g); Minn. R ; 40 CFR Section (c); Minn. R CFR Section (d); Minn. R ; 40 CFR Section (c); Minn. R CFR Section (d); Minn. R ; 40 CFR Section (c); Minn. R CFR Section (d); Minn. R ; 40 CFR Section (c); Minn. R If the Permittee chooses to measure VOC emissions using either Method 18 of 40 CFR part 60, appendix A, or Method 320 of 40 CFR part 63, appendix A, then the Permittee has the option of correcting the measured VOC emissions to account for the potential differences in measured values between these methods and Method 25A. The results from Method 18 and Method 320 can be corrected for response factor differences using Equations 4 and 5 in Appendix C to this permit, according to 40 CFR Section (g). Submit: due 60 days after Performance Test has been completed, a copy of the performance test to measure NOx emissions as conducted in 40 CFR Section Submit: due 60 days after Performance Test has been completed, a copy of the performance test to measure CO emissions as conducted in 40 CFR Section Submit: due 60 days after Performance Test has been completed, a copy of the performance test to measure VOC emissions as conducted in 40 CFR Section hdr PERFORMANCE TESTING REQUIREMENTS FOR A CERTIFIED ENGINE 40 CFR Section (b)(1); 40 CFR Section (a)(1); Minn. R ; 40 CFR Section (c); Minn. R The Permittee shall operate and maintain the certified stationary SI internal combustion engine and control device according to the manufacturer's emission-related written instructions, you must keep records of conducted maintenance to demonstrate compliance, but no performance testing is required if you are an owner or operator. The Permittee shall meet the requirements as specified in 40 CFR part 1068, subparts A through D, as they apply to you. If you adjust engine settings according to and consistent with the manufacturer's instructions, your stationary SI internal combustion engine will not be considered out of compliance.

79 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 39 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: EU 134 Thermal Reclaimer - Dryer/Oven, indirect fired Associated Items: CE 019 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 093 Bin Vent NC/ CA Type Citation Requirement Minn R , subp. 2 The permittee shall comply with 40 CFR pt Standards of Performance for New Stationary Sources Subpart UUU - Standards of Performance for Calciners and Dryers in Mineral Industries. hdr NSPS SUBPART UUU REQUIREMENTS- Enforcement Not Delegated to MPCA LIMIT LIMIT 40 CFR Section (a); Minn. R , subp CFR Section (b); Minn. R , subp. 2 Minn. R , subps. 2 and 14 Total Particulate Matter: less than or equal to grains/dry standard cubic foot Opacity: less than or equal to 10 percent opacity hdr RECORDKEEPING AND REPORTING 40 CFR Sections (a); Minn. R CFR Section (c); Minn. R hdr PERFORMANCE TESTING S/A S/A 40 CFR Section (a) & (b); Minn. R , subps CFR Section (a) & (b); Minn. R , subp CFR Section (a) & (b); Minn. R , subp. 1 Maintain air pollution control equipment in proper operating condition and utilize the air pollution control systems as designed. See CE 019 for fabric filter requirements. Recordkeeping: Records of the original measurements shall be retained for at least 2 years. Reporting: Submit semiannual reports to the Administrator of exceedances of control device operating parameters. Exceedances are defined as all 6-minute periods during which the average opacity from dry control devices is greater than 10 percent. To verify compliance with the EU 134 emission limits, Performance testing on EU 134 must be performed such that no dilution air enters the process during testing; testing is to be representative of EU 134 alone. Initial Performance Test: due 180 days after Effective Date of Permit to measure Total Particulate Matter. The Permittee shall use EPA reference test method number 5, and the sampling time and volume for each test run shall be at least 2 hours and 1.70 dscm. During the test the permittee shall use the monitoring devices to determine the control equipment pressure drop range(s). The arithmetic averages of the three runs shall be used as the baseline average values for the limits. Initial Performance Test: due 180 days after Effective Date of Permit to measure Opacity. The Permittee shall use EPA reference test method number 9, and the procedures in 40 CFR Section During the test the permittee shall use the monitoring devices to determine the control equipment pressure drop range(s). The arithmetic averages of the three runs shall be used as the baseline average values for the limits. hdr NEW SOURCE PERFORMANCE STANDARDS - GENERAL PROVISIONS 40 CFR Section 60.7(a)(6); Minn. R , subp CFR Section 60.7(b), Minn. R , subp. 1 Minn. R , subp. 5(C); 40 CFR Section 60.7(f); Minn. R , subp. 1 Notification of Anticipated Date for Conducting Opacity Observations: due 30 day prior to observation date. Recordkeeping: Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. Recordkeeping: Maintain a file of all measurements, maintenance, reports and records for at least five years. 40 CFR Section 60.7(f) specifies two years.

80 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 40 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: EU 138 Kloster Cold Box Mixer - Mixing Equipment Associated Items: CE 014 Fabric Filter - Low Temperature, i.e., T<180 Degrees F NC/ CA Type Citation Requirement hdr The requirements of this group apply separately to each unit listed under this group. LIMIT Minn. R , subp. 1(A), subp. 2 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 Because EU 138 is controlled by control equipment which has a collection efficiency of 99 percent by weight, EU 138 is considered to be in compliance with this requirement. LIMIT Minn. R , subp. 1(B) Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. major source classification under 40 CFR Section 70.2 and Minn. R The Permittee shall vent emissions from EU 138 to CE 014 whenever the EU 138 operates, and operate and maintain CE 014 at all times that any emissions are vented to the CE 014. The Permittee shall document periods of non-operation of the control equipment.

81 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 41 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: EU 208 Emergency Diesel Generator - Reciprocating IC Engine NC/ CA Type Citation Requirement hdr EMISSION LIMITS LIMIT Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. LIMIT Minn. R , subp. 2 Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input. The potential to emit from the unit is 0.29 lb/mmbtu due to equipment design and allowable fuels. Minn. R , subp. 35a Fuel type: No. 2 fuel oil/diesel fuel meeting the requirements of 40 CFR Section (c) only by design. hdr RECORDKEEPING Minn. R , subps. 4 & 5 Hours of Operation: The Permittee shall maintain documentation on site that the 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. Minn. R , subp. 5 The Permittee shall keep records of fuel type and usage on a monthly basis.

82 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 42 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: EU 209 Emergency Natural Gas Generator - Reciprocating IC Engine NC/ CA Type Citation Requirement hdr EMISSION LIMITS LIMIT Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. LIMIT Minn. R , subp. 2 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. Minn. R , subp. 35a Fuel type: Natural gas only, by design. hdr RECORDKEEPING Minn. R , subps. 4 & 5 Hours of Operation: The Permittee shall maintain documentation on site that the 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. Minn. R , subp. 5 The Permittee shall keep records of fuel type and usage on a monthly basis. hdr NESHAP SUBPART ZZZZ REQUIREMENTS 40 CFR Section (a)(2); 40 CFR Section (c); Minn. R EU 209 is a new affected source as defined under 40 CFR pt. 63, subp. ZZZZ, and the facility is a major source as defined at 40 CFR Section The Permittee shall meet the requirements of 40 CFR pt. 63, subp. ZZZZ by meeting the requirements of 40 CFR pt. 60, subp. JJJJ. No further requirements of 40 CFR pt. 63, subp. ZZZZ apply to EU 041. hdr NSPS SUBPART JJJJ REQUIREMENTS hdr JJJJ APPLICABILITY 40 CFR Section (c); 40 CFR Section (a)(4)(iii); Minn. R ; Minn. R The Permittee is an owner and operator of EU 209 which is an emergency, stationary spark ignition (SI) internal combustion engine (ICE) with a maximum engine power less than 500 HP that commenced construction after June 12, 2006 and manufactured on or after January 1, The date that construction commences is the date that the engine is ordered by the Permittee. hdr JJJJ LIMITS AND OPERATIONAL REQUIREMENTS LIMIT 40 CFR Section (a); 40 CFR Section (a); 40 CFR Section (a); 40 CFR Section ; 40 CFR Section (c); Minn. R ; Minn. R LIMIT 40 CFR Section (a); 40 CFR Section (a); 40 CFR Section (a); 40 CFR Section ; 40 CFR Section (c); Minn. R ; Minn. R CFR Section (a); 40 CFR Section (a); 40 CFR Section ; 40 CFR Section (c); Minn. R ; Minn. R CFR Section ; 40 CFR Section (a); 40 CFR Section (a); 40 CFR Section ; 40 CFR Section (c); Minn. R ; Minn. R CFR Section (d)(1); 40 CFR Section (c); Minn. R ; Minn. R NMHC+NOx: less than or equal to 8.0 grams/kilowatt-hour Carbon Monoxide: less than or equal to 610 grams/kilowatt-hour Engines with displacement at or above 225 cc and a manufacturing date between July 1, 2008 and December 31, 2010 must meet emission standards and related requirements for nonhandheld engines under 40 CFR pt. 90, Control of Emissions from Nonroad Spark-Ignition Engines at or Below 19 Kilowatts. The Permittee shall operate and maintain the stationary SI RICE that achieves the emission standards as required in 40 CFR Section over the entire life of the engine. There is no time limit on the use of EU 209 in emergency situations.

83 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 43 of Feb, :07 COMPLIANCE PLAN LIMIT 40 CFR Section (d)(2); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (d)(2); 40 CFR Section (c); Minn. R ; Minn. R LIMIT 40 CFR Section (d)(3); 40 CFR Section (c); Minn. R ; Minn. R Operating Hours: less than or equal to 100 hours/year for any combination of the purposes specified in paragraphs (d)(2)(i) through (iii) of section (i) Emergency stationary ICE may be operated for the purpose of maintenance checks and readiness testing, provided that the tests are recommended by Federal, State or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The Permittee may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency ICE beyond 100 hours per year. (continued below) (continued from above) (ii) Emergency stationary RICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see 40 CFR Section 63.17), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP (iii) Emergency stationary 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. Operating Hours: less than or equal to 50 hours/year for each calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response CFR Section (d)(3)(i); 40 CFR Section (c); Minn. R ; Minn. R The 50 hours per year for non-emergency situations cannot be used for peak shaving 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. For the Permittee of emergency engines, any operation other than emergency operation, maintenance and testing, and operation in non-emergency situations for 50 hours per year, as permitted in 40 CFR Section , is prohibited. The 50 hours per year for non-emergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met: (A) The engine is dispatched by the local balancing authority or local transmission and distribution system operator; (B) The dispatch is intended to mitigate local transmission and/or distribution limitations 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 CFR Section (d)(3)(i); 40 CFR Section (c); Minn. R ; Minn. R CFR Section (c); 40 CFR Section (c); Minn. R ; Minn. R (D) The power is provided only to the Permittee or to support the local transmission and distribution system. (E) The Permittee identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the Permittee. The Permittee shall install a non-resettable hour meter upon startup of EU 041, if one is not already installed.

84 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 44 of Feb, :07 COMPLIANCE PLAN CFR Section (a)(1); 40 CFR Section (c); Minn. R ; Minn. R CFR Section ; 40 CFR Section (c); Minn. R ; Minn. R CFR Section and Table 3 to subp. JJJJ of pt. 60; 40 CFR Section 60.7(a)(4); 40 CFR Section (c); Minn. R ; Minn. R , subp CFR Section ; and Table 3 to subp. JJJJ of pt. 60; 40 CFR Section 60.12; 40 CFR Section (c); Minn. R ; Minn. R ; Minn. R hdr JJJJ RECORDKEEPING 40 CFR Section (a); 40 CFR Section (c); Minn. R ; Minn. R The Permittee shall operate and maintain the certified stationary SI RICE and control device according to the manufacturer's emission-related written instructions and keep records of conducted maintenance to demonstrate compliance. No performance testing is required if the Permittee is the owner or operator. The Permittee shall also meet the requirements as specified in 40 CFR pt. 1068, subps. A through D as applicable. If engine settings are adjusted according to and consistent with the manufacturer's instructions, the SI RICE will not be considered out of compliance. The Permittee shall comply with the applicable provisions of 40 CFR pt. 60, subp. A, as required by Table 3 of 40 CFR pt. 60, subp. JJJJ. Notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced and shall include information describing the precise nature of the change, present and proposed emission control systems, productive capacity of the facility before and after the change, and the expected completion date of the change. The Administrator may request additional relevant information subsequent to this notice. No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. The Permittee shall keep records of the following information: (1) All notifications submitted to comply with 40 CFR pt. 60, subp. JJJJ and all documentation supporting any notification CFR Section and Table 3 to subp. JJJJ of pt. 60; 40 CFR Section 60.7(b); 40 CFR Section (c); Minn. R ; Minn. R , subp. 1 (2) Maintenance conducted on the engine. (3) If the stationary SI RICE is a certified engine, documentation from the manufacturer that the engine is certified to meet the emission standards and information as required in 40 CFR pts. 90, 1048, 1054, and 1060 as applicable. Recordkeeping: Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative.

85 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 45 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 042 Blast Cabinet - Abrasive Equipment EU 043 Blast Cabinet - Abrasive Equipment GP 012 Abrasive Blasting NC/ CA Type Citation Requirement hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 042 and EU 043 to CE 003 whenever EU 042 and EU 043 operates, and operate and maintain CE 003 at all times that any emissions are vented to CE 003. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 99 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 93 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 93 percent capture efficiency Pressure Drop: greater than or equal to 1.0 inches of water column and less than or equal to 7.5 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

86 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 46 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I).

87 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 47 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 005 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 038 Knockout Cabinet - Casting Equipment GP 010 Knockout NC/ CA Type Citation Requirement Hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 038 to CE 005 whenever EU 038 operates, and operate and maintain CE 005 at all times that any emissions are vented to CE 005. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 79 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 74 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 74 percent capture efficiency Pressure Drop: greater than or equal to 0.40 inches of water column and less than or equal to 4.5 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

88 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 48 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I). Minn. R , supb. 4 Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method as required by Minn. R , subp. 4. The Permittee shall maintain a copy of the annual evaluation on site.

89 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 49 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 007 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 046 Wheelabrator - Abrasive blasting EU 047 Jet Wheelblast - Abrasive Equipment GP 012 Abrasive Blasting NC/ CA Type Citation Requirement Hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 046 and EU 047 to CE 007 whenever EU 046 and EU 047 operates, and operate and maintain CE 007 at all times that any emissions are vented to CE 003. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 99 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 93 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 93 percent capture efficiency Pressure Drop: greater than or equal to 0.10 inches of water column and less than or equal to 1.2 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

90 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 50 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I).

91 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 51 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 048 Mesh Belt Blaster - Abrasive Equipment GP 012 Abrasive Blasting NC/ CA Type Citation Requirement Hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 048 to CE 008 whenever EU 048 operates, and operate and maintain CE 008 at all times that any emissions are vented to CE 008. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 99 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 93 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 93 percent capture efficiency Pressure Drop: greater than or equal to 0.50 inches of water column and less than or equal to 3.5 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

92 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 52 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I).

93 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 53 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 009 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 049 Blast Cabinet - Abrasive Equipment GP 012 Abrasive Blasting NC/ CA Type Citation Requirement Hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 042 and EU043 to CE 003 whenever EU 042 and 043 operates, and operate and maintain CE 003 at all times that any emissions are vented to CE 003. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 99 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 93 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 93 percent capture efficiency Pressure Drop: greater than or equal to 0.10 inches of water column and less than or equal to 12 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

94 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 54 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I).

95 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 55 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 010 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 055 Blast Cabinet - Abrasive Equipment GP 012 Abrasive Blasting NC/ CA Type Citation Requirement Hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 055 to CE 010 whenever EU 055 operates, and operate and maintain CE 010 at all times that any emissions are vented to CE 010. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 99 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 93 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 93 percent capture efficiency Pressure Drop: greater than or equal to 0.10 inches of water column and less than or equal to 2.0 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

96 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 56 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I).

97 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 57 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 011 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 044 Wheelabrator Blast Cabinet - Abrasive Equipment EU 045 Blast Cabinet - Abrasive Equipment EU 050 Blast Cabinet - Abrasive Equipment GP 012 Abrasive Blasting NC/ CA Type Citation Requirement Hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 044, EU 045, and EU 050 to CE 011 whenever EU 044, EU 045, and EU 050 operates, and operate and maintain CE 011 at all times that any emissions are vented to CE 011. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 99 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 93 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 93 percent capture efficiency Pressure Drop: greater than or equal to 0.10 inches of water column and less than or equal to 1.0 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter.

98 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 58 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I).

99 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 59 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 012 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 056 Blast Room - Abrasive Equipment GP 012 Abrasive Blasting NC/ CA Type Citation Requirement Hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 056 to CE 012 whenever EU 056 operates, and operate and maintain CE 012 at all times that any emissions are vented to CE 012. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 99 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 93 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 93 percent capture efficiency Pressure Drop: greater than or equal to 0.20 inches of water column and less than or equal to 1.5 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

100 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 60 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I).

101 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 61 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 013 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 083 Knockout Cabinet - Casting Equipment EU 097 Blast Cabinet (alum oxide) - Abrasive Equipment GP 010 Knockout GP 012 Abrasive Blasting NC/ CA Type Citation Requirement Hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 083 and EU 097 to CE 013 whenever EU 083 and EU 097 operates, and operate and maintain CE 013 at all times that any emissions are vented to CE 013. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 99 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 93 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 93 percent capture efficiency Pressure Drop: greater than or equal to 0.10 inches of water column and less than or equal to 5.0 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter.

102 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 62 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I).

103 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 63 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 014 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 082 Empire Blast Cabinet (glass bead) - Abrasive Equipment EU 120 Sand SIlo-silica - Silo/bin EU 138 Kloster Cold Box Mixer - Mixing Equipment GP 012 Abrasive Blasting GP 017 Sand Handling - Silos (New Sand) NC/ CA Type Citation Requirement Hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 082, EU 120, and EU 138 to CE 014 whenever EU 082, EU 120, and EU 138 operates, and operate and maintain CE 014 at all times that any emissions are vented to CE 014. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 99 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 93 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 93 percent capture efficiency Pressure Drop: greater than or equal to 0.20 inches of water column and less than or equal to 4.0 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter.

104 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 64 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I).

105 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 65 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 015 Gas Scrubber (General, Not Classified) Associated Items: EU 121 Cold Box Machine - Casting Equipment EU 122 Cold Box Machine - Casting Equipment EU 123 Cold Box Machine - Casting Equipment EU 124 Laempe L2 Core Machine - Casting Equipment EU 125 Laempe L1 Core Machine - Casting Equipment EU 139 Laempe L3 Core Machine - Casting Equipment EU 144 Core Blower - CB-10 - Casting Equipment EU 147 Core Blower - Gaylord SATB-15 - Casting Equipment EU 148 Laempe L4 Core Machine - Casting Equipment GP 013 Core Molding - Isocure/Cold Box NC/ CA Type Citation Requirement hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT under 40 CFR Section 70.2; Minn. R classification as major source Minn. R classification as major source Minn. R The Permittee shall operate and maintain the gas scrubber at all times that any emission unit controlled by the gas scrubber is in operation. The Permittee shall document periods of non-operation of the control equipment. hdr MONITORING AND RECORDKEEPING The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to 99 percent control efficiency ph: less than or equal to 4.5 unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA approved performance test where compliance was demonstrated. The Permittee shall record the ph once every 24 hours when any unit controlled by CE 015 is in operation. Recordkeeping of ph. The Permittee shall record the time and date of each ph reading and whether or not the recorded ph was within the range specified in this permit. Minn. R , subp. 4 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording the ph, as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored gas scrubber is in operation. Minn. R , subps. 4, 5, & 14 Minn. R , subps. 4, 5, & 14 Minn. R , subps. 4, 5, & 14 Quarterly Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer specifications, the Permittee shall inspect the control equipment internal and external system components. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. Annual Calibration: The Permittee shall calibrate the ph meter at least annually and shall maintain a written record of the calibration and any action resulting from the calibration. Corrective Actions: If the ph is above the maximum or if the gas scrubber or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the ph, to the specified range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the gas scrubber. The Permittee shall keep a record of the type and date of any corrective action taken. Minn. R , subp. 14 The Permittee shall operate and maintain the scrubber in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

106 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 66 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 016 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 136 Vibro mill - Abrasive Equipment EU 141 Shakeout - Casting Equipment GP 011 Shakeout NC/ CA Type Citation Requirement Hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 136 and EU 141 to CE 016 whenever EU 136 and EU 141 operates, and operate and maintain CE 016 at all times that any emissions are vented to CE 016. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 79 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 74 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 74 percent capture efficiency Pressure Drop: greater than or equal to 1.0 inches of water column and less than or equal to 8.0 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

107 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 67 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I). Minn. R , supb. 4 Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method as required by Minn. R , subp. 4. The Permittee shall maintain a copy of the annual evaluation on site.

108 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 68 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 146 Blast Cabinet - Abrasive Equipment GP 012 Abrasive Blasting NC/ CA Type Citation Requirement Hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 146 to CE 018 whenever EU 146 operates, and operate and maintain CE 018 at all times that any emissions are vented to CE 018. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 99 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 93 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 93 percent capture efficiency Pressure Drop: greater than or equal to 0.20 inches of water column and less than or equal to 4.5 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

109 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 69 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I).

110 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 70 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 019 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 134 Thermal Reclaimer - Dryer/Oven, indirect fired NC/ CA Type Citation Requirement Hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 134 to CE 019 whenever EU 134 operates, and operate and maintain CE 019 at all times that any emissions are vented to CE 019. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 99 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 93 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 93 percent capture efficiency Pressure Drop: greater than or equal to 0.40 inches of water column and less than or equal to 12 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

111 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 71 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I).

112 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 72 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 020 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 166 Bucket Elevator Muller - Mixing Equipment EU 167 Elevator EU 170 Shaker, vibratory - Abrasive Equipment GP 011 Shakeout GP 018 Sand Handling/Transfer - Conveyors, Mullers, Elevators NC/ CA Type Citation Requirement Hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) Minn. R The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 166, EU 167, and EU 170 to CE 020 whenever EU 166, EU 167, and EU 170 operates, and operate and maintain CE 020 at all times that any emissions are vented to CE 020. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 79 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 74 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 74 percent capture efficiency Pressure Drop: greater than or equal to 0.20 inches of water column and less than or equal to 4.5 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Visible Emissions: The Permittee shall check the fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter.

113 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 73 of Feb, :07 COMPLIANCE PLAN Minn. R , subp. 3 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. Minn. R , subp. 2 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R , subp. 2(A) to 2(I). Minn. R , supb. 4 Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method as required by Minn. R , subp. 4. The Permittee shall maintain a copy of the annual evaluation on site.

114 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 74 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 021 Direct Flame Afterburner Associated Items: EU 027 Shell Firing Furnace - Wax Burnout Oven GP 027 Investment Casting - Wax Burnout Ovens NC/ CA Type Citation Requirement hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp. 1 classification as major source , subp. 1(A) , subp. 1(A) , subp. 1(A) The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 027 to CE 021 whenever EU 027 operates, and operate and maintain CE 021 at all times that any emissions are vented to CE 021. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to 97 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 62 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4 and 5 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 62 percent control efficiency Temperature: greater than or equal to 1500 degrees F using 3-hour Rolling Average at the combustion chamber, unless a new limit is required to be set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the <3-hour rolling average> temperature is below the minimum temperature limit, the VOC used during that time shall be considered uncontrolled until the <average> temperature is above the minimum temperature limit. This shall be reported as a deviation. The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three-hour rolling average temperatures for the combustion chamber. Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. Minn. R , subp. 4 Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. Minn. R , subps. 4 and 5 Minn. R , subps. 4, 5, and 14 The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/ percent of the temperature being measured or +/- 4.5 degrees Fahrenheit. The recording device shall also calculate the three-hour rolling average combustion chamber temperature. Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

115 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 75 of Feb, :07 COMPLIANCE PLAN Minn. R , subps. 4, 5, and , subps. 4 and 5 Minn. R , subps. 4, 5, and 14 Annual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration. For periods when the thermal oxidizer is operated above the minimum combustion chamber temperature, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit: a. The overall control efficiency limit specified in this permit for this equipment (x%); or b. The overall control efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test. Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. Minn. R , subp. 14 The Permittee shall operate and maintain the thermal oxidizer in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

116 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 76 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 022 Direct Flame Afterburner Associated Items: EU 027 Shell Firing Furnace - Wax Burnout Oven GP 027 Investment Casting - Wax Burnout Ovens NC/ CA Type Citation Requirement hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp. 1 classification as major source , subp. 1(A) , subp. 1(A) , subp. 1(A) The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 027 to CE 022 whenever EU 027 operates, and operate and maintain CE 022 at all times that any emissions are vented to CE 022. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to 97 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 62 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4 and 5 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 62 percent control efficiency Temperature: greater than or equal to 1500 degrees F using 3-hour Rolling Average at the combustion chamber, unless a new limit is required to be set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the <3-hour rolling average> temperature is below the minimum temperature limit, the VOC used during that time shall be considered uncontrolled until the <average> temperature is above the minimum temperature limit. This shall be reported as a deviation. The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three-hour rolling average temperatures for the combustion chamber. Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. Minn. R , subp. 4 Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. Minn. R , subps. 4 and 5 Minn. R , subps. 4, 5, and 14 The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/ percent of the temperature being measured or +/- 4.5 degrees Fahrenheit. The recording device shall also calculate the three-hour rolling average combustion chamber temperature. Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

117 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 77 of Feb, :07 COMPLIANCE PLAN Minn. R , subps. 4, 5, and , subps. 4 and 5 Minn. R , subps. 4, 5, and 14 Annual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration. For periods when the thermal oxidizer is operated above the minimum combustion chamber temperature, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit: a. The overall control efficiency limit specified in this permit for this equipment (x%); or b. The overall control efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test. Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. Minn. R , subp. 14 The Permittee shall operate and maintain the thermal oxidizer in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

118 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 78 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 023 Direct Flame Afterburner Associated Items: EU 031 Shell Firing Furnace - Wax Burnout Oven GP 027 Investment Casting - Wax Burnout Ovens NC/ CA Type Citation Requirement hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp. 1 classification as major source , subp. 1(A) , subp. 1(A) , subp. 1(A) The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 031 to CE 023 whenever EU 031 operates, and operate and maintain CE 023 at all times that any emissions are vented to CE 023. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to 97 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 62 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4 and 5 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 62 percent control efficiency Temperature: greater than or equal to 1500 degrees F using 3-hour Rolling Average at the combustion chamber, unless a new limit is required to be set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the <3-hour rolling average> temperature is below the minimum temperature limit, the VOC used during that time shall be considered uncontrolled until the <average> temperature is above the minimum temperature limit. This shall be reported as a deviation. The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three-hour rolling average temperatures for the combustion chamber. Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. Minn. R , subp. 4 Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. Minn. R , subps. 4 and 5 Minn. R , subps. 4, 5, and 14 The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/ percent of the temperature being measured or +/- 4.5 degrees Fahrenheit. The recording device shall also calculate the three-hour rolling average combustion chamber temperature. Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

119 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 79 of Feb, :07 COMPLIANCE PLAN Minn. R , subps. 4, 5, and , subps. 4 and 5 Minn. R , subps. 4, 5, and 14 Annual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration. For periods when the thermal oxidizer is operated above the minimum combustion chamber temperature, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit: a. The overall control efficiency limit specified in this permit for this equipment (x%); or b. The overall control efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test. Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. Minn. R , subp. 14 The Permittee shall operate and maintain the thermal oxidizer in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

120 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 80 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 024 Direct Flame Afterburner Associated Items: EU 034 Shell Firing Furnace - Wax Burnout Oven GP 027 Investment Casting - Wax Burnout Ovens NC/ CA Type Citation Requirement hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT LIMIT , subp. 1 classification as major source , subp. 1(A) , subp. 1(A) , subp. 1(A) The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EU 031 to CE 024 whenever EU 031 operates, and operate and maintain CE 024 at all times that any emissions are vented to CE 024. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to 97 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 62 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4 and 5 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 62 percent control efficiency Temperature: greater than or equal to 1500 degrees F using 3-hour Rolling Average at the combustion chamber, unless a new limit is required to be set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the <3-hour rolling average> temperature is below the minimum temperature limit, the VOC used during that time shall be considered uncontrolled until the <average> temperature is above the minimum temperature limit. This shall be reported as a deviation. The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three-hour rolling average temperatures for the combustion chamber. Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. Minn. R , subp. 4 Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. Minn. R , subps. 4 and 5 Minn. R , subps. 4, 5, and 14 The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/ percent of the temperature being measured or +/- 4.5 degrees Fahrenheit. The recording device shall also calculate the three-hour rolling average combustion chamber temperature. Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

121 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 81 of Feb, :07 COMPLIANCE PLAN Minn. R , subps. 4, 5, and , subps. 4 and 5 Minn. R , subps. 4, 5, and 14 Annual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration. For periods when the thermal oxidizer is operated above the minimum combustion chamber temperature, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit: a. The overall control efficiency limit specified in this permit for this equipment (x%); or b. The overall control efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test. Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. Minn. R , subp. 14 The Permittee shall operate and maintain the thermal oxidizer in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

122 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 82 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 026 Mat or Panel Filter Associated Items: EU 116 Sand Silo-silica - Silo/bin GP 017 Sand Handling - Silos (New Sand) NC/ CA Type Citation Requirement hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) , subp. 1(A) The Permittee shall vent emissions from EU 116 to CE 026 whenever EU 116 operates, and operate and maintain CE 026 at all times that any emissions are vented to CE 026. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 85 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 85 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 85 percent control efficiency Daily Inspections: Once each operating day, the Permittee shall visually inspect the condition of each panel filter with respect to alignment, saturation, tears, holes and any other condition that may affect the filter's performance. The Permittee shall maintain a daily written record of filter inspections. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturer's specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Corrective Actions: If the filters or any of their components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 14 Operation and Maintenance of Filters: The Permittee shall operate and maintain each filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

123 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 83 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 027 Mat or Panel Filter Associated Items: EU 117 Sand Silo-silica - Silo/bin EU 118 Sand Silo-silica - Silo/bin GP 017 Sand Handling - Silos (New Sand) NC/ CA Type Citation Requirement hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) , subp. 1(A) The Permittee shall vent emissions from EU 117 and EU 118 to CE 027 whenever EU 117 and EU 118 operates, and operate and maintain CE 027 at all times that any emissions are vented to CE 027. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 85 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 85 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 85 percent control efficiency Daily Inspections: Once each operating day, the Permittee shall visually inspect the condition of each panel filter with respect to alignment, saturation, tears, holes and any other condition that may affect the filter's performance. The Permittee shall maintain a daily written record of filter inspections. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturer's specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Corrective Actions: If the filters or any of their components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 14 Operation and Maintenance of Filters: The Permittee shall operate and maintain each filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

124 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 84 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 028 Mat or Panel Filter Associated Items: EU 119 Sand Silo-silica - Silo/bin GP 017 Sand Handling - Silos (New Sand) NC/ CA Type Citation Requirement hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) , subp. 1(A) The Permittee shall vent emissions from EU 119 to CE 028 whenever EU 119 operates, and operate and maintain CE 028 at all times that any emissions are vented to CE 028. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 85 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 85 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 85 percent control efficiency Daily Inspections: Once each operating day, the Permittee shall visually inspect the condition of each panel filter with respect to alignment, saturation, tears, holes and any other condition that may affect the filter's performance. The Permittee shall maintain a daily written record of filter inspections. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturer's specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Corrective Actions: If the filters or any of their components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 14 Operation and Maintenance of Filters: The Permittee shall operate and maintain each filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

125 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Permit Number: Page 85 of Feb, :07 COMPLIANCE PLAN -01 Subject Item: CE 029 Mat or Panel Filter Associated Items: EU 149 Sand Silo - Olivine - Silo/bin GP 017 Sand Handling - Silos (New Sand) NC/ CA Type Citation Requirement hdr EMISSION AND OPERATIONAL LIMITS LIMIT LIMIT LIMIT , subp , subp. 1(A) , subp. 1(A) , subp. 1(A) The Permittee shall vent emissions from EU 149 to CE 029 whenever EU 149 operates, and operate and maintain CE 029 at all times that any emissions are vented to CE 029. The Permittee shall document periods of non-operation of the control equipment. The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 85 percent control efficiency hdr MONITORING AND RECORDKEEPING Minn. R , subps. 4, 5, and 14 Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 10 micron: greater than or equal to 85 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to 85 percent control efficiency Daily Inspections: Once each operating day, the Permittee shall visually inspect the condition of each panel filter with respect to alignment, saturation, tears, holes and any other condition that may affect the filter's performance. The Permittee shall maintain a daily written record of filter inspections. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturer's specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Corrective Actions: If the filters or any of their components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 14 Operation and Maintenance of Filters: The Permittee shall operate and maintain each filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

126 Carley Foundry Attachment 3 Points Calculator

127 Points Calculator 1) AQ Facility ID No.: Total Points 110 2) Facility Name: Carley Foundry 3) Small business? y/n? no 4) DQ Numbers (including all rolled) : ) Date of each Application Received: 07/21/2014 6) Final Permit No ) Permit Staff Robert Little 8) "Work completed" in which.xls file (i.e. unit 2b, unit 1a, biofuels)? Total Application Type DQ No. Qty. Points Points Details Administrative Amendment 1 0 Minor Amendment 4 0 Applicability Request 10 0 Moderate Amendment 15 0 Major Amendment 25 0 Individual State Permit (not reissuance) Individual Part 70 Permit (not reissuance) 75 0 Additional Points Modeling Review 15 0 BACT Review 15 0 LAER Review 15 0 CAIR/Part 75 CEM analysis 10 0 NSPS Review UUU, JJJJ NESHAP Review ZZZZZZ, ZZZZZ, ZZZZ Case-by-case MACT Review 20 0 Netting 10 0 Limits to remain below threshold Part 70 Plantwide Applicability Limit (PAL) 20 0 AERA review 15 0 Variance request under Confidentiality request under EAW review Part , subparts 18, item A; and Part , subparts 8, items A & B; 10, items A to C; 16, items A & D; 17, items A to C & E to G; and 18, items B & C 35 0 Part , subparts 4; 5 items A & B; 13; 15; 16, items B & C; and 17 item D 70 0 Add'l Points 60 NOTES: (DQ DQ#)

128 Carley Foundry Attachment 4 EPA Applicability for NSPS UUU

129 U.S. Environmental Protection Agency Applicability Determination Index Control Number: Category: EPA Office: Date: Title: Recipient: Author: NSPS Region 4 01/05/2000 NSPS Applicability to Sand Reclamation Facilities Jeryl Stewart R. Douglas Neeley Subparts: Part 60, OOO, Nonmetallic Mineral Processing Part 60, UUU, Calciners and Dryers in Mineral Ind. References: (c) Abstract: Q: Are furnaces used in sand reclamation facilities at foundries subject to 40 CFR Part, Subpart UUU? A: Furnaces constructed, reconstructed, or modified after April 23, 1986, would be subject to Subpart UUU because industrial sand is a nonmetallic mineral and the rule does not specify a size or throughput cutoff. Q: Are all calciners and dryers that emit less than 11 tons of particulate exempt from opacity monitoring requirements under 40 CFR Part, Subpart UUU? A: Yes. Subpart UUU identifies a number of specific types of calciners and dryers that are exempt from opacity monitoring because their particulate emissions are known to be less than 11 tons per year. In several previous determinations the Agency has extended this exemption to other types of calciners and dryers that emit less than 11 tons of particulate per year. Q: Are crushing and grinding operations that occur in sand reclamation processes at foundries subject to 40 CFR Part 60, Subpart OOO? A: The applicability of Subpart OOO to such operations depends upon whether the process is used merely to break up the organic binder that holds the molds together or whether the process also results in size reduction of the sand particles in the mold. Letter: 4APT-ARB Mr. Jeryl W. Stewart Compliance Validation Program Tennessee Department of Environment and Conservation Division of Air Pollution Control 9th Floor, L&C Annex 401 Church Street Nashville, Tennessee SUBJ: New Source Performance Standard Applicability to Sand Reclamation Systems Used in Foundry Operations Dear Mr. Stewart: Thank you for your letter of October 19, 1999, in which you asked for determinations regarding the applicability of 40 C.F.R. Part 60, Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants) and 40 C.F.R. Part 60, Subpart UUU (Standards of Performance for Calciners and Dryers in Mineral Industries) to sand reclamation systems used in foundry operations. Based upon our review of the applicability provisions in these regulations, we concur with the following interpretations presented in your letter: (1) Furnaces used in sand reclamation operations at foundries are subject to Subpart UUU if the furnace is constructed, reconstructed, or modified after the applicability date of the standard (April 23, 1986). The basis for this conclusion is that industrial sand is classified as a nonmetallic mineral under the definitions in 40 C.F.R. Section , and calciners and dryers of any size that process nonmetallic minerals are subject to the Subpart UUU since size or throughput are not among the criteria considered when determining applicability under this regulation. As noted in your letter, U.S. Environmental Protection Agency (EPA) Region 6, previously determined in 1997 that calciners used in sand reclamation operations at foundries are subject to Subpart UUU. (2) Owners and operators of calciners or dryers that emit less than 11 tons of particulate per year are exempt from all opacity monitoring requirements in 40 C.F.R. Section At the time Subpart UUU was promulgated, EPA had determined that opacity monitoring was unnecessary for affected facilities that emit less than 11 tons of particulate per year, and a list of calciners and dryers that are specifically exempt from opacity monitoring requirements because their particulate emission rates were known to be less than 11 tons per year was promulgated at 40 C.F.R. Section (c). In several determinations issued following the promulgation of Subpart UUU, EPA has indicated that the exemption in 40 C.F.R. Section (c) may be extended to any calciner or dryer that has been demonstrated to have a particulate emission rate of less than 11 tons per year. Based upon the precedents established in these previous determinations, we agree with your position that EPA does not need to make a case-by-case determination granting an opacity monitoring exemption to each Subpart UUU facility that emits less than 11 tons of particulate per year. Since the authority to implement Subpart UUU in the state of Tennessee has been delegated to your agency, any company that supplies you with information demonstrating that particulate emissions from their calciner or dryer are less than 11 tons per year would qualify for an opacity monitoring exemption. (3) Crushing and grinding that occurs in the sand reclamation process would not result in Subpart OOO applicability if these operations are used to break down the organic binder holding the sand in the molds together rather than to crush the sand itself. The basis for this conclusion is that, although industrial sand is classified as a nonmetallic mineral under the definitions in 40 C.F.R. Section , Subpart OOO is only applicable to operations where crushing or grinding of nonmetallic minerals occurs. Therefore, if the crushing that takes place in the sand reclamation operation separates the sand from the binder that holds the molds together but does not result in a reduction in the size of the sand particles, equipment in the reclamation operation would not be part of a nonmetallic mineral processing line and would not be subject to Subpart OOO. If you have any questions about the determinations provided in this letter, please contact Mr. David McNeal of the EPA Region 4 staff at (404) Sincerely, R. Douglas Neeley Chief Air and Radiation Technology Branch Air, Pesticides and Toxics Management Division

130 Carley Foundry Attachment State of Wisconsin Air Emissions Inventory Report

131 6/21/2012 9:13:00 AM 2011 Air Emissions Inventory Summary Report Page: 1 FINAL State of Wisconsin Department of Natural Resources FID: Bureau of Air Management MERCURY MARINE - Plants 3,4,10,12,15,17,98 W6250 W PIONEER RD FOND DU LAC DNR Region: County: SIC Code: NAICS Code: Northeast Fond du Lac INTERNAL COMBUSTION ENGINES, NEC Other Engine Equipment Manufacturing Constr Date: # Employees: Area: ft2 UTM Zone: 16 UTM X: m UTM Y: m CRAIG DOUSHARM Facility Air Management Contact W6250 W PIONEER RD FOND DU LAC WI Craig_Dousharm@mercmarine.com CRAIG DOUSHARM Facility Billing Contact W6250 W PIONEER RD FOND DU LAC WI Craig_Dousharm@mercmarine.com Mark Schwabero Facility Responsible Official W6250 Pioneer Road Fond du Lac WI mark_schwabero@mercmarine.com MATTHEW HOSTAK DNR Emission Inventory Contact E CTY RD Y OSHKOSH WI Matthew.Hostak@Wisconsin.gov

132 6/21/2012 9:13:00 AM 2011 Air Emissions Inventory Summary Report Page: 2 FINAL State of Wisconsin Department of Natural Resources FID: Bureau of Air Management D E V I C E A N D P R O C E S S L I S T DEVICE ID DEVICE CODE DEVICE NAME DEVICE CATEGORY > PROCESS ID > PROCESS CODE > PROCESS NAME > PROCESS DESCRIPTION C04 FILTER DRY FILTERS, PRIME/FINISH METAL PARTS - PLT 15 Fabric Filters --> 01 CONTROLLING PARTICULATE CONTROL Used for collectors C05 FILTER PRIME ^ FINISH METAL PARTS (P31) - Fabric Filters PLT 15 --> 01 CONTROLLING Used for collectors C08 CONTROL VOC CONTROL, ALUM. CHIP DRYING/CLEANING - PLT 17 Miscellaneous --> 01 CONTROLLING Used for collectors C10 BAGHOUSE BEADBLASTER AND SHOTBLASTER - Baghouse/Fabric Filter PLT98 --> 01 CONTROLLING Used for collectors C11 BAGHOUSE KNOCKOUT, CUTOFF, COOLING HOODS PLT98 Baghouse/Fabric Filter --> 01 CONTROLLING Used for collectors C33 CONTROL FINISH PAINTING PLASTIC PARTS Miscellaneous (P32) - PLT C42 THERMAL OXIDIZR VOC CONTROL, CERAMIC MOLD BURNOUT OVENS - PLT 98 Catalytic or Thermal Oxidation --> 01 CONTROLLING Used for collectors C47 THERMAL OXIDIZR REGEN. THERM. OXID.- INDOOR TESTING (Plant 12) Catalytic or Thermal Oxidation --> 01 CONTROLLING Used for collectors C60 BAGHOUSE "NEW" LOST-FOAM CASTING,CLEAN SAND (PLT 17) Baghouse/Fabric Filter --> 01 CONTROLLING Used for collectors C61 BAGHOUSE "NEW" LOST-FOAM SYSTEM, DIRTY SAND (PLT 17) Baghouse/Fabric Filter --> 01 CONTROLLING Used for collectors C62 THERMAL OXIDIZR "NEW" LOST-FOAM CASTING OXIDIZER (PLT 17) Catalytic or Thermal Oxidation --> 01 CONTROLLING Used for collectors C63 BAGHOUSE "NEW" LOST-FOAM SAND RECLAIM SYSTEM(PLT17) Baghouse/Fabric Filter --> 01 CONTROLLING Lost Foam Sand Reclaim Used for collectors P02 IC ENGINE Sound Lab - Plant 12 Boiler/Furnace --> 01 GENERIC Gasoline Combustion Generic Throughput Process P03 IC ENGINE Wet test cells (Plant 15) Boiler/Furnace --> 01 GENERIC GASOLINE COMBUSTION Generic Throughput Process P04 COATER Electrodeposition primer (EDP) coating dip tank (Plant 15). Painting/Coating --> 01 GENERIC EDP DIP-PRIMING Generic Throughput Process P08 COATER Midsection paint line touch up booths (2) Painting/Coating (Plant 15)

133 6/21/2012 9:13:00 AM 2011 Air Emissions Inventory Summary Report Page: 3 FINAL State of Wisconsin Department of Natural Resources Bureau of Air Management FID: > 01 GENERIC PRIME FINISH PAINT METAL Generic Throughput Process PARTS P09 COATER Midsection assembly and powerhead paint booths (Plant 15) Painting/Coating --> 01 GENERIC PRIME FINISH PAINT METAL Generic Throughput Process PARTS P11 IC ENGINE PROCESSES P11, P12, AND P13 HAVE BEEN COMBINED. P11 - TEST TANKS (PLT 12) P HP WET TEST CELL (PLT 12) P HP WET TEST CELL (PLT 12) Boiler/Furnace --> 01 GENERIC GASOLINE COMBUSTION Generic Throughput Process P14 IC ENGINE Three new dynamometers (Plant 12) (25, 60, 150 hp) Boiler/Furnace --> 01 GENERIC GASOLINE COMBUSTION Generic Throughput Process P15 IC ENGINE Eleven dynamometers (Plant 12) Boiler/Furnace --> 01 GENERIC GASOLINE COMBUSTION Generic Throughput Process P24 GENERIC (2) STAINLESS STEEL ELECT. INDUCT. FURNACES-PLT 98 Miscellaneous --> 01 GENERIC STEEL MELTING Generic Throughput Process P27 GENERIC Die cast operation - 45 machines, 2 permitted (Plant 17) Miscellaneous --> 01 GENERIC ALUM. DIE CASTING Generic Throughput Process P28 GENERIC (5) Reverberatory melting furnaces for aluminum (Plant 17) Miscellaneous --> 01 GENERIC ALUM. MELTING Generic Throughput Process P31 GENERIC ALUMINUM CHIP DRYER/CLEANER - PLANT 17 Miscellaneous --> 01 GENERIC ALUM. CHIP DRYING/CLEANING Generic Throughput Process P39 GENERIC GLASS BEAD BLASTER/SHOT BLASTER - PLT 98 Miscellaneous --> 01 GENERIC STEEL GLASS BEAD Generic Throughput Process BLASTER/SHOT BLASTER P40 GENERIC CERAMIC MOLD BURNOUT OVENS (NEW ^ OLD) - PLT 98 Miscellaneous --> 01 GENERIC CERAMIC MOLD BURNOUT Generic Throughput Process P42 GENERIC (3) ALUM. ELECTRIC MELT FURNACES - PLT 17 Miscellaneous --> 01 GENERIC ALUM. MELTING - (3) INDUCTION Generic Throughput Process FURNACES P44 GENERIC KNOCKOUT/CUTOFF/POURING HOODS/GRINDERS - PLT 98 Miscellaneous --> 01 GENERIC KNOCKOUT/CUTOFF/POURING Generic Throughput Process HOODS/GRINDERS P45 BOILER (DUMMY BOILER) NAT. GAS USAGE - FACILITY WIDE Boiler/Furnace --> 01 GENERIC NATURAL GAS COMBUSTION - Generic Throughput Process FACILITY WIDE P47 IC ENGINE INDOOR ENDURANCE TEST CENTER - PLANT 12 Boiler/Furnace --> 01 GENERIC INDOOR ENGINE ENDURANCE Generic Throughput Process TESTING P60 CASTING LINE "NEW" LOST-FOAM LINE, CLEAN SAND (PLT 17) Miscellaneous

134 6/21/2012 9:13:00 AM 2011 Air Emissions Inventory Summary Report Page: 4 FINAL State of Wisconsin Department of Natural Resources Bureau of Air Management FID: > 01 GENERIC LOST-FOAM CASTING Generic Throughput Process P61 CASTING LINE NEW LOST-FOAM LINE, DIRTY SAND (Plant 17) Miscellaneous --> 01 GENERIC NEW LOST FOAM CASTING -DIRTY Generic Throughput Process SAND P62 CASTING LINE NEW LOST-FOAM LINE - THERM. SAND RECLAIM - Plant 17 Miscellaneous --> 01 GENERIC THERMAL SAND RECLAIM Generic Throughput Process P63 GENERIC NEW LOST FOAM REVERB HOLDING FURNACE - Plt 17 Miscellaneous --> 01 GENERIC ALUMINUM MELTING/HOLDING Generic Throughput Process

135 6/21/2012 9:13:01 AM 2011 Air Emissions Inventory Summary Report Page: 22 FINAL State of Wisconsin Department of Natural Resources FID: Bureau of Air Management P28 Miscellaneous Any Device DEVICE DESC: (5) Reverberatory melting furnaces for aluminum (Plant 17) CONSTR DATE: 01/01/1972 DEVICE COMMENTS: Includes emissions from P28 and P29 P28, Process 01 Generic Throughput Process PROCESS NAME: ALUM. MELTING SCC CODE: PROCESS COMMENTS: SCHEDULE: 24 Hrs/Day 7 Dys/Wk 245 Dys/Yr QTRLY SCHEDULE: Q1: 25% Q2: 25% Q3: 25% Q4: 25% ANNUAL TPUT: TON of PRODUCT - METALS AVG TPUT: TON/HR MAX TPUT: 4 TON/HR --EMISSION FACTORS-- POLLUTANT VALUE / UNIT ORIGIN NOX.76 LB / TON EPA PM 1.1 LB / TON OTHR PM LB / TON OTHR ROG.2 LB / TON EPA SO2.9 LB / TON EPA --EMISSIONS / YR-- POLLUTANT NR438_THRESH UNCNTRLD CNTRLD OZONE/DY NOX (c) LB 10, LB 10, LB LB PM (c) LB 15, LB 15, LB PM10 (c) LB 15, LB 15, LB ROG (c) 6000 LB 2, LB 2, LB LB SO2 (c) LB 12, LB 12, LB NICKEL CMP (r) (fs) 3.42 LB LB LB --INCOMING STREAMS-- TPUT --> P OUTGOING STREAMS-- P28-01 (100%) --> S21-01 (100%) --> OUT

136 6/21/2012 9:13:01 AM 2011 Air Emissions Inventory Summary Report Page: 32 FINAL State of Wisconsin Department of Natural Resources FID: Bureau of Air Management P62 Miscellaneous Casting Line DEVICE DESC: NEW LOST-FOAM LINE - THERM. SAND RECLAIM - Plant 17 CONSTR DATE: 05/01/2002 DEVICE COMMENTS: P62, Process 01 Generic Throughput Process PROCESS NAME: THERMAL SAND RECLAIM SCC CODE: PROCESS COMMENTS: SCHEDULE: 24 Hrs/Day 7 Dys/Wk 245 Dys/Yr QTRLY SCHEDULE: Q1: 25% Q2: 25% Q3: 25% Q4: 25% ANNUAL TPUT: 5412 HR of PRODUCT - MINERALS AVG TPUT: HR/HR MAX TPUT: 1.1 HR/HR --EMISSION FACTORS-- POLLUTANT VALUE / UNIT ORIGIN PM.62 LB / HR STK PM LB / HR EPA ROG.081 LB / HR STK --EMISSIONS / YR-- POLLUTANT NR438_THRESH UNCNTRLD CNTRLD OZONE/DY PM (c) LB 3, LB 3, LB PM10 (c) LB LB LB ROG (c) 6000 LB LB LB LB --INCOMING STREAMS-- TPUT --> P OUTGOING STREAMS-- P62-01 (100%) --> C63-01 (100%) --> S62-01 (100%) --> OUT

137 4/24/2012 9:02:10 AM 2011 Air Emissions Inventory Summary Report Page: 1 FINAL State of Wisconsin Department of Natural Resources FID: Bureau of Air Management WISCONSIN ALUMINUM FOUNDRY 838 S 16TH ST MANITOWOC DNR Region: County: SIC Code: NAICS Code: Northeast Manitowoc ALUMINUM FOUNDRIES Nonferrous Metal Foundries Constr Date: 01/01/1956 # Employees: Area: ft2 UTM Zone: 16 UTM X: m UTM Y: m JIM BEHNKE Facility Air Management Contact SOUTH 16TH STREET MANITOWOC WI jbehnke@wafco.com James Hatt Facility Billing Contact P.O. Box 246 Manitowoc WI Jhatt@WAFCO.COM James Hatt Facility Responsible Official P.O. Box 246 Manitowoc WI Jhatt@WAFCO.COM RANDALL MATTY DNR Emission Inventory Contact SHAWANO AV GREEN BAY WI randall.matty@wisconsin.gov

138 4/24/2012 9:02:10 AM 2011 Air Emissions Inventory Summary Report Page: 2 FINAL State of Wisconsin Department of Natural Resources FID: Bureau of Air Management D E V I C E A N D P R O C E S S L I S T DEVICE ID DEVICE CODE DEVICE NAME DEVICE CATEGORY > PROCESS ID > PROCESS CODE > PROCESS NAME > PROCESS DESCRIPTION C07 BAGHOUSE MULLER CARTRIDGE COLLECTOR Baghouse/Fabric Filter --> 01 CONTROLLING Used for collectors C22 BAGHOUSE Baghouse/Fabric Filter --> 01 CONTROLLING Used for collectors C24 BAGHOUSE Baghouse/Fabric Filter --> 01 CONTROLLING Used for collectors C34a SCRUBBER Rotoclone Wet Collector Wet Collection Systems --> 01 CONTROLLING Collecting Used for collectors C35 BAGHOUSE This fabric filter is used to control emissions generated on the chipping line. A cyclone, located up stream of the filter, removes some of the particulates from the exhaust stream. EI: P35 BAGHOUSE Baghouse/Fabric Filter --> 01 CONTROLLING Used for collectors C36 BAGHOUSE Emissions generated from finishing castings on the Permanent Mold i1sanding Line are controlled with this baghouse. EI: FILTER, FABRIC - PERMANENT MOLD SANDING LINE Baghouse/Fabric Filter --> 01 CONTROLLING Used for collectors C38 CYCLONE P35 CYCLONE Cyclone/Settling Chambers --> 01 CONTROLLING Used for collectors P05 MULLER FOR HUNTER #2, OSBORN^SQUEEZER Miscellaneous --> 01 GENERIC MULLER FOR HUNTER #1 ^ #2 Generic Throughput Process P06 MULLER FOR HUNTER #3 AND DISA Miscellaneous --> 01 GENERIC MULLER FOR HUNTER #3 Generic Throughput Process P21 GENERIC TOWER MELT - DISA Miscellaneous --> 01 GENERIC FURNACE BURNERS Generic Throughput Process --> 02 GENERIC TONS MELTED Generic Throughput Process --> 03 GENERIC TONS POUR/COOL Generic Throughput Process --> 22 GENERIC TONS SHAKEOUT Generic Throughput Process P24 GENERIC THERMAL RECLAIM Miscellaneous --> 01 GENERIC HEATER Generic Throughput Process --> 02 GENERIC THERMAL RECLAIM Generic Throughput Process P25 GENERIC Thermal Reclaim System #2 EI: THERMAL RECLAIM Miscellaneous --> 01 GENERIC HEATER Generic Throughput Process --> 02 GENERIC THERMAL RECLAIM Generic Throughput Process P30 GENERIC Perm Mold: 4 NG Reverb furnaces were installed before 1972 and are therefore subject to different particulate matter emission limits than the furnaces installed after NG JetMelt Furn., 1 electric crucible Miscellaneous

139 4/24/2012 9:02:10 AM 2011 Air Emissions Inventory Summary Report Page: 3 FINAL State of Wisconsin Department of Natural Resources Bureau of Air Management FID: > 00 GENERIC SMELTING Generic Throughput Process --> 01 GENERIC BURNERS Generic Throughput Process P31 GENERIC One electric and two gas-fired reverberatory furnaces in the Hunter 1 and 2 area. Installed in 1989 EI: HUNTER 2 ELE.^ REV. FURN. Miscellaneous --> 00 GENERIC TONS Generic Throughput Process MELT/POUR/COOL/SHAKEOUT --> 01 GENERIC BURNERS Generic Throughput Process P32 GENERIC CRUCIBLE FURNACES - These furnaces are described the attached text. Miscellaneous --> 00 GENERIC SMELTING ALUMINUM Generic Throughput Process --> 01 GENERIC BURNERS Generic Throughput Process P34 GENERIC PANGBORN - ROTOBLASTER with wet Miscellaneous collector. --> 00 GENERIC THRUPUT IS METAL Generic Throughput Process ROTOBLASTED P35 SANDER CHIPPING LINE with Torit baghouse and cyclone EI: SANDING LINES Miscellaneous --> 00 GENERIC THRUPUT IS ALL METAL Generic Throughput Process PROCESSED BY P P37 GENERIC Hunter 3 - One Natural Gas-fired Reverbatory Furnace and one Electric Crucible Furnaces EI: HUNTER 3 ELE. (1)^ REV.(2) FURN. (3) Miscellaneous --> 00 GENERIC TONS MELTED Generic Throughput Process --> 01 GENERIC BURNERS Generic Throughput Process --> 03 GENERIC TONS POUR Generic Throughput Process --> 22 GENERIC TONS SHAKEOUT Generic Throughput Process P38 GENERIC PLANT 2 Jet Melt Furnaces (3) Miscellaneous --> 01 GENERIC BURNER Generic Throughput Process --> 02 GENERIC REPORT TONS MELTED Generic Throughput Process P39 GENERIC BRASS CRUCIBLES Miscellaneous --> 00 GENERIC REPORT TONS LEADED BRASS Generic Throughput Process MELTED. --> 01 GENERIC REPORT TONS UNLEADED BRASS Generic Throughput Process MELTED P40 MIXER Four Air Set Mixers EI: AIR SET COREMAKING Miscellaneous --> 01 GENERIC WT. BINDER CHEMICALS Generic Throughput Process --> 02 GENERIC LB OF IPA CORE WASH USED Generic Throughput Process --> 03 GENERIC LB OF W.B. CORE WASH USED Generic Throughput Process --> 04 GENERIC LB IPA-CONTAINING CORE WASH Generic Throughput Process --> 05 GENERIC CO2 Gas Foundry Binder Generic Throughput Process

140 4/24/2012 9:02:10 AM 2011 Air Emissions Inventory Summary Report Page: 11 FINAL PM10 0 LB / MMCF STK ROG 2.8 LB / MMCF EPA --EMISSIONS / YR-- POLLUTANT NR438_THRESH UNCNTRLD CNTRLD OZONE/DY NOX (c) LB 5, LB 5, LB LB ROG (c) 6000 LB LB LB.410 LB --INCOMING STREAMS-- TPUT --> P OUTGOING STREAMS-- P21-01 (100%) --> S21-01 (100%) --> OUT State of Wisconsin Department of Natural Resources Bureau of Air Management FID: P21, Process 02 Generic Throughput Process PROCESS NAME: TONS MELTED SCC CODE: PROCESS COMMENTS: SCHEDULE: 16 Hrs/Day 5 Dys/Wk 245 Dys/Yr QTRLY SCHEDULE: Q1: 25% Q2: 25% Q3: 25% Q4: 25% ANNUAL TPUT: 1707 TON of PRODUCT - METALS AVG TPUT: TON/HR MAX TPUT: 1.5 TON/HR --EMISSION FACTORS-- POLLUTANT VALUE / UNIT ORIGIN COPPER FUME LB / TON MBAL NICKEL CMP LB / TON MBAL PM.46 LB / TON STK PM10.46 LB / TON STK ROG.56 LB / TON STK --EMISSIONS / YR-- POLLUTANT NR438_THRESH UNCNTRLD CNTRLD OZONE/DY PM (c) LB LB LB PM10 (c) LB LB LB ROG (c) 6000 LB LB LB LB COPPER FUME (c) (s) 47.1 LB LB LB NICKEL CMP (c) (fs) 3.42 LB.314 LB.314 LB --INCOMING STREAMS-- TPUT --> P OUTGOING STREAMS-- P21-02 (100%) --> S21-01 (100%) --> OUT P21, Process 03 Generic Throughput Process PROCESS NAME: TONS POUR/COOL SCC CODE: PROCESS COMMENTS: SCHEDULE: 16 Hrs/Day 5 Dys/Wk 245 Dys/Yr QTRLY SCHEDULE: Q1: 25% Q2: 25% Q3: 25% Q4: 25% ANNUAL TPUT: 1707 TON of PRODUCT - METALS AVG TPUT: TON/HR

141 4/24/2012 9:02:10 AM 2011 Air Emissions Inventory Summary Report Page: 12 FINAL MAX TPUT: 1.5 TON/HR --EMISSION FACTORS-- POLLUTANT VALUE / UNIT ORIGIN NOX.01 LB / TON EPA PM.92 LB / TON STK PM10.92 LB / TON STK ROG 1.5 LB / TON EPA --EMISSIONS / YR-- POLLUTANT NR438_THRESH UNCNTRLD CNTRLD OZONE/DY NOX (c) LB LB LB.066 LB PM (c) LB 1, LB 1, LB PM10 (c) LB 1, LB 1, LB ROG (c) 6000 LB 2, LB 2, LB LB --INCOMING STREAMS-- TPUT --> P OUTGOING STREAMS-- P21-03 (100%) --> S17-01 (100%) --> OUT State of Wisconsin Department of Natural Resources Bureau of Air Management FID: P21, Process 22 Generic Throughput Process PROCESS NAME: TONS SHAKEOUT SCC CODE: PROCESS COMMENTS: SCHEDULE: 16 Hrs/Day 5 Dys/Wk 245 Dys/Yr QTRLY SCHEDULE: Q1: 25% Q2: 25% Q3: 25% Q4: 25% ANNUAL TPUT: 1707 TON of PRODUCT - METALS AVG TPUT: TON/HR MAX TPUT: 1.5 TON/HR --EMISSION FACTORS-- POLLUTANT VALUE / UNIT ORIGIN NOX 0 LB / TON DNR PM.183 LB / TON STK PM LB / TON STK ROG.14 LB / TON EPA --EMISSIONS / YR-- POLLUTANT NR438_THRESH UNCNTRLD CNTRLD OZONE/DY PM (c) LB LB LB PM10 (c) LB LB LB ROG (c) 6000 LB LB LB.919 LB --INCOMING STREAMS-- TPUT --> P OUTGOING STREAMS-- P21-22 (100%) --> C22-01 (100%) --> S22-01 (100%) --> OUT P24 Miscellaneous Any Device DEVICE DESC: THERMAL RECLAIM

142 Carley Foundry Attachment 6 Revised PM Natural Gas Emission Factors

143 Revised PM Natural Gas Emission Factors for Small EI Type Permitted Facilities This spreadsheet was created per request by EPA Region 5 states during a call in late January It is the Particulate Matter (PM) emission factors for natural gas, process gas, and Liquified Petrolium Gas. For these fuels, the Emission Factors were revised dramatically around 2004 using some preliminary data from Ron Myers-U.S. Environmental Protection Agency. (Ron Myers is the lead on the development of a condensable PM test method) Units Key E6FT3=1,000,000 Cubic Feet E6BTU=1,000,000 BTU E3GAL=1,000 Gallons The method is not final but some preliminary data was available and the data showed the current AP42 factors were off by a factor of 10 or 20. The emission inventory group in U.S EPA used the preliminary data to adjust the 2002 National Emissions Inventory. This spreadsheet is an attempt to pull together the PM factors for gaseous fuel into one place. SCC Level 1 Level 2 Level 3 Level 4 Pollutant Contol External Combustion Boilers Electric Generation Natural Gas Boilers > 100 Million Btu/hr except Tangential PM Uncontrolled External Combustion Boilers Electric Generation Natural Gas Boilers > 100 Million Btu/hr except Tangential PM10, primary Uncontrolled External Combustion Boilers Electric Generation Natural Gas Boilers < 100 Million Btu/hr except Tangential PM Uncontrolled External Combustion Boilers Electric Generation Natural Gas Boilers < 100 Million Btu/hr except Tangential PM10, primary Uncontrolled External Combustion Boilers Electric Generation Natural Gas Tangentially Fired Units PM Uncontrolled External Combustion Boilers Electric Generation Natural Gas Tangentially Fired Units PM10, primary Uncontrolled External Combustion Boilers Electric Generation Process Gas Boilers > 100 Million Btu/hr PM Uncontrolled External Combustion Boilers Electric Generation Process Gas Boilers > 100 Million Btu/hr PM10, primary Uncontrolled External Combustion Boilers Electric Generation Process Gas Boilers < 100 Million Btu/hr PM Uncontrolled External Combustion Boilers Electric Generation Process Gas Boilers < 100 Million Btu/hr PM10, primary Uncontrolled External Combustion Boilers Electric Generation Liquified Petroleum Gas (LPG) Butane PM10, primary Uncontrolled External Combustion Boilers Electric Generation Liquified Petroleum Gas (LPG) Butane PM Uncontrolled External Combustion Boilers Electric Generation Liquified Petroleum Gas (LPG) Propane PM10, primary Uncontrolled External Combustion Boilers Electric Generation Liquified Petroleum Gas (LPG) Propane PM Uncontrolled External Combustion Boilers Industrial Natural Gas > 100 Million Btu/hr PM Uncontrolled External Combustion Boilers Industrial Natural Gas > 100 Million Btu/hr PM10, primary Uncontrolled External Combustion Boilers Industrial Natural Gas Million Btu/hr PM Uncontrolled External Combustion Boilers Industrial Natural Gas Million Btu/hr PM10, primary Uncontrolled External Combustion Boilers Industrial Natural Gas < 10 Million Btu/hr PM Uncontrolled External Combustion Boilers Industrial Natural Gas < 10 Million Btu/hr PM10, primary Uncontrolled External Combustion Boilers Industrial Natural Gas Cogeneration PM Uncontrolled External Combustion Boilers Industrial Natural Gas Cogeneration PM10, primary Uncontrolled External Combustion Boilers Industrial Process Gas Petroleum Refinery Gas PM Uncontrolled External Combustion Boilers Industrial Process Gas Petroleum Refinery Gas PM10, primary Uncontrolled External Combustion Boilers Industrial Process Gas Blast Furnace Gas PM Uncontrolled External Combustion Boilers Industrial Process Gas Blast Furnace Gas PM10, primary Uncontrolled External Combustion Boilers Industrial Process Gas Coke Oven Gas PM Uncontrolled External Combustion Boilers Industrial Process Gas Coke Oven Gas PM10, primary Uncontrolled External Combustion Boilers Industrial Liquified Petroleum Gas (LPG) Butane PM Uncontrolled External Combustion Boilers Industrial Liquified Petroleum Gas (LPG) Butane PM10, primary Uncontrolled External Combustion Boilers Industrial Liquified Petroleum Gas (LPG) Propane PM Uncontrolled External Combustion Boilers Industrial Liquified Petroleum Gas (LPG) Propane PM10, primary Uncontrolled External Combustion Boilers Commercial/Institutional Natural Gas > 100 Million Btu/hr PM Uncontrolled External Combustion Boilers Commercial/Institutional Natural Gas > 100 Million Btu/hr PM10, primary Uncontrolled External Combustion Boilers Commercial/Institutional Natural Gas Million Btu/hr PM Uncontrolled External Combustion Boilers Commercial/Institutional Natural Gas Million Btu/hr PM10, primary Uncontrolled aq-ei1-08 Minnesota Pollution Control Agency 520 Lafayette Rd. N., St. Paul, MN TTY or Available in alternative formats April 2012

144 SCC Level 1 Level 2 Level 3 Level 4 Pollutant Contol External Combustion Boilers Commercial/Institutional Natural Gas < 10 Million Btu/hr PM Uncontrolled External Combustion Boilers Commercial/Institutional Natural Gas < 10 Million Btu/hr PM10, primary Uncontrolled External Combustion Boilers Commercial/Institutional Liquified Petroleum Gas (LPG) Butane PM Uncontrolled External Combustion Boilers Commercial/Institutional Liquified Petroleum Gas (LPG) Butane PM10, primary Uncontrolled External Combustion Boilers Commercial/Institutional Liquified Petroleum Gas (LPG) Propane PM Uncontrolled External Combustion Boilers Commercial/Institutional Liquified Petroleum Gas (LPG) Propane PM10, primary Uncontrolled Internal Combustion Engines Electric Generation Natural Gas Turbine PM Uncontrolled Internal Combustion Engines Electric Generation Natural Gas Turbine PM10, primary Uncontrolled Internal Combustion Engines Electric Generation Natural Gas Reciprocating PM Uncontrolled Internal Combustion Engines Electric Generation Natural Gas Reciprocating PM10, primary Uncontrolled Internal Combustion Engines Industrial Natural Gas Turbine PM Uncontrolled Internal Combustion Engines Industrial Natural Gas Turbine PM10, primary Uncontrolled Internal Combustion Engines Industrial Natural Gas Reciprocating PM Uncontrolled Internal Combustion Engines Industrial Natural Gas Reciprocating PM10, primary Uncontrolled Internal Combustion Engines Industrial Natural Gas Turbine: Cogeneration PM Uncontrolled Internal Combustion Engines Industrial Natural Gas Turbine: Cogeneration PM10, primary Uncontrolled Internal Combustion Engines Industrial Natural Gas Reciprocating: Cogeneration PM Uncontrolled Internal Combustion Engines Industrial Natural Gas Reciprocating: Cogeneration PM10, primary Uncontrolled Internal Combustion Engines Industrial Natural Gas 2-cycle Lean Burn PM Uncontrolled Internal Combustion Engines Industrial Natural Gas 2-cycle Lean Burn PM10, primary Uncontrolled Internal Combustion Engines Industrial Natural Gas 4-cycle Rich Burn PM Uncontrolled Internal Combustion Engines Industrial Natural Gas 4-cycle Rich Burn PM10, primary Uncontrolled Internal Combustion Engines Industrial Natural Gas 4-cycle Lean Burn PM Uncontrolled Internal Combustion Engines Industrial Natural Gas 4-cycle Lean Burn PM10, primary Uncontrolled Internal Combustion Engines Commercial/Institutional Natural Gas Reciprocating PM Uncontrolled Internal Combustion Engines Commercial/Institutional Natural Gas Reciprocating PM10, primary Uncontrolled Internal Combustion Engines Commercial/Institutional Natural Gas Turbine PM Uncontrolled Internal Combustion Engines Commercial/Institutional Natural Gas Turbine PM10, primary Uncontrolled Internal Combustion Engines Commercial/Institutional Natural Gas Turbine: Cogeneration PM Uncontrolled Internal Combustion Engines Commercial/Institutional Natural Gas Turbine: Cogeneration PM10, primary Uncontrolled Internal Combustion Engines Commercial/Institutional Landfill Gas Turbine PM Uncontrolled Internal Combustion Engines Commercial/Institutional Landfill Gas Turbine PM10, primary Uncontrolled Revised PM Natural Gas Emission Factors for Small EI Type Permitted Facilities aq-ei1-08 April 2012 Page 2 of 4

145 Factor (Text) Unit Measure Material Action Notes 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data LB E6BTU Process Gas Burned Assumed same as Natural gas units adjust to thermal units LB E6BTU Process Gas Burned Assumed same as Natural gas units adjust to thermal units LB E6BTU Process Gas Burned Assumed same as Natural gas units adjust to thermal units LB E6BTU Process Gas Burned Assumed same as Natural gas units adjust to thermal units LB E3GAL LPG Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data LB E3GAL LPG Burned WebFIRE LB E3GAL LPG Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data LB E3GAL LPG Burned WebFIRE 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data LB E6BTU Process Gas Burned Assumed same as Natural gas units adjust to thermal units LB E6BTU Process Gas Burned Assumed same as Natural gas units adjust to thermal units LB E6BTU Process Gas Burned Assumed same as Natural gas units adjust to thermal units LB E6BTU Process Gas Burned Assumed same as Natural gas units adjust to thermal units LB E6BTU Process Gas Burned Assumed same as Natural gas units adjust to thermal units LB E6BTU Process Gas Burned Assumed same as Natural gas units adjust to thermal units LB E3GAL LPG Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data LB E3GAL LPG Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data LB E3GAL LPG Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data LB E3GAL LPG Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data Revised PM Natural Gas Emission Factors for Small EI Type Permitted Facilities aq-ei1-08 April 2012 Page 3 of 4

146 Factor (Text) Unit Measure Material Action Notes 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data LB E3GAL LPG Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data LB E3GAL LPG Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data LB E3GAL LPG Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data LB E3GAL LPG Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.52 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data 0.31 LB E6FT3 Natural Gas Burned Created by Roy Huntley EIAG US EPA from data from Ron Myers USEPA using preliminary test data LB E6BTU Landfill Gas Burned Used data from gas turbines and applied to IC engines. Used one half value due to LFG being 50% methane LB E6BTU Landfill Gas Burned Used data from gas turbines and applied to IC engines. Used one half value due to LFG being 50% methane Revised PM Natural Gas Emission Factors for Small EI Type Permitted Facilities aq-ei1-08 April 2012 Page 4 of 4

147 Carley Foundry Attachment 7 South Coast Air Quality PM2.5 Multipliers

148 SOUTH COAST MANAGEMENT DISTRICT Final Methodology to Calculate Particulate Matter (PM) 2.5 and PM 2.5 Significance Thresholds October 2006 Executive Officer Barry R. Wallerstein, D. Env. Deputy Executive Officer Planning, Rule Development and Area Sources Elaine Chang, DrPH Assistant Deputy Executive Officer Planning, Rule Development and Area Sources Laki Tisopulos, Ph.D., P.E. Planning and Rules Manager Planning, Rule Development and Area Sources Susan Nakamura Authors: Mike Krause Air Quality Specialist Steve Smith, Ph.D. Program Supervisor Technical Assistance: James Koizumi Air Quality Specialist Tom Chico Program Supervisor Robert Wu Air Quality Specialist Xinqiu Zhang Air Quality Specialist Joe Cassmassi Planning Manager Julia Lester, Ph.D.

149 SOUTH COAST MANAGEMENT DISTRICT GOVERNING BOARD CHAIRMAN: VICE CHAIRMAN: WILLIAM A. BURKE, Ed.D. Speaker of the Assembly Appointee S. ROY WILSON, Ed.D. Supervisor, Fourth District Riverside County Representative MEMBERS: MICHAEL D. ANTONOVICH Supervisor, Fifth District Los Angeles County Representative JANE W. CARNEY Senate Rules Committee Appointee RONALD O. LOVERIDGE Mayor, City of Riverside Cities Representative, Riverside County GARY OVITT Supervisor, Fourth District San Bernardino County Representative JAN PERRY Councilmember, Ninth District, City of Los Angeles Cities Representative, Los Angeles County, Western Region MIGUEL A. PULIDO Mayor, City of Santa Ana Cities Representative, Orange County TONIA REYES URANGA Councilmember, Seventh District, City of Long Beach Cities Representative, Los Angeles County, Eastern Region JAMES SILVA Supervisor, Second District Orange County Representative CYNTHIA VERDUGO-PERALTA Governor's Appointee DENNIS YATES Mayor, City of Chino Cities Representative, San Bernardino County EXECUTIVE OFFICER: BARRY R. WALLERSTEIN, D.Env.

150 TABLE OF CONTENTS CHAPTER 1 - PROJECT DESCRIPTION Introduction... 1 Background... 1 Methodology to Calculate PM Localized Significance Threshold for PM2.5 Emissions... 4 Regional Emissions Threshold of Significance for PM Conclusion... 8 Tables Table 1 Federal Standards for Particulate Matter... 1 Table 2 California Standards for Particulate Matter... 2 Table 3 Total Stationary Source Fuel Combustion Inventory (Tons/Day)... 6 Table 4 Total Fugitive PM Inventory (Tons/Day)... 6 Table 5 Combustion PM Inventory from Off-Road Equipment (Tons/Day)... 7 Table 6 Regional Air Quality Significance Thresholds... 7 APPENDIX A - UPDATED CEIDARS TABLE LIST WITH PM2.5 FRACTIONS APPENDIX B PM2.5 LOCALIZED SIGNIFICANCE THRESHOLD LOOK-UP TABLES i October 2006

151 Final PM2.5 Calculation Methodology and PM2.5 Significance Thresholds Introduction In the last few years, both California and the federal governments have established ambient air quality standards for fine particulate matter (PM) less than or equal to 2.5 microns in diameter (PM2.5). As a result, there is a need to establish a methodology for calculating PM2.5 and appropriate PM2.5 significance thresholds for the purpose of analyzing local and regional PM2.5 air quality impacts in California Environmental Quality Act (CEQA) and National Environmental Policy Act (NEPA) air quality analyses. This document provides a methodology for calculating PM2.5 and recommendations for localized and regional PM2.5 significance thresholds. Background PM larger than 2.5 microns and less than 10 microns, often referred to as the coarse PM fraction (or PM10), is mostly produced by mechanical processes. These include automobile tire wear, industrial processes such as cutting and grinding, and re-suspension of particles from the ground or road surfaces by wind and human activities such as construction or agriculture. In contrast, PM less than or equal to PM2.5 is mostly derived from combustion sources, such as automobiles, trucks, and other vehicle exhaust, as well as from stationary combustion sources. The particles are either directly emitted or are formed in the atmosphere from the combustion of gases, such as NOx and SOx combining with ammonia. PM2.5 components from material in the earth s crust, such as dust, are also present, with the amount varying in different locations. Staff s recommendation for calculating PM2.5 focuses only on directly emitted PM2.5. In 1997, U.S. EPA established an annual and a 24-hour standard for the finest fraction of particulates, PM2.5, to complement the existing PM10 standards. However, U.S. EPA recently modified the 24-hr PM2.5 standard and revoked the annual PM10 standard. (Table 1). The annual component of the standard was established to provide protection against typical day-to-day exposures as well as longer-term exposures, while the daily component protects against more extreme short-term events. TABLE 1 Federal Standards for Particulate Matter Federal Standards PM 10 PM 2.5 Annual Revoked a 15 μg/m 3 24-Hour 150 μg/m 3 35 μg/m 3 b In June 2002, the California Air Resources Board (CARB) adopted new, stricter standards for particulate matter that would affect both the coarse as well as fine particulate fraction (Table 2). CARB delayed action on the proposed 24-hour PM2.5 standard in light of the a U.S. EPA final rulemaking for CFR 40 Part 50.7 National Primary and Secondary Ambient Air Quality Standards at b U.S. EPA final rulemaking for CFR 40 Part National Primary and Secondary Ambient Air Quality Standards at 1 October 2006

152 Final PM2.5 Calculation Methodology and PM2.5 Significance Thresholds findings related to statistical issues in several key short-term exposure health effects studies. TABLE 2 California Standards for Particulate Matter California Standards PM 10 PM 2.5 Annual 20 μg/m 3 12 μg/m 3 24-Hour 50 μg/m 3 n/a Methodology to Calculate PM 2.5 Because there are currently few or no PM2.5 emission factors for mechanical or combustion processes, staff is recommending an indirect approach to calculating PM2.5 emissions until such time as PM2.5 factors are developed. Since PM2.5 is a subset of PM10, the current methodology for calculating PM10 from fugitive dust sources (grading, demolition, unpaved roads, open storage piles, etc.) and combustion sources (stationary combustion sources, vehicle exhaust) will continue to be used to calculate PM10 and can also be used to calculate PM2.5. Total suspended PM (TSP) emissions typically contain specific fractions of PM10 and PM2.5 that can be measured. In general, PM from fugitive dust generating sources is primarily composed of PM10 with a relatively small fraction of the fugitive PM consisting of PM2.5. Alternatively, PM from combustion sources is primarily composed of PM2.5 with a small fraction consisting of PM10. To calculate both PM10 and PM2.5, existing PM10 calculation methodologies for both fugitive dust PM10 and combustion PM10 can be used. To determine the PM2.5 fractions of the PM10 emission results, staff is recommending that the PM10 emissions be calculated using standard PM10 calculation methodologies. The PM10 emission results for each emission source or operation would then be multiplied by the applicable PM2.5 fraction, derived by emissions source, using PM profiles in the California Emission Inventory Data and Reporting System (CEIDARS) developed by the California Air Resources Board (CARB). The CEIDARS PM profiles are used to develop emission inventories for a variety of sources and operations in the Air Quality Management Plan (AQMP). The CEIDARS PM profiles have been streamlined to be used for most types of processes that would be encountered in a CEQA or NEPA document In addition, AQMD staff has identified the PM2.5 fraction of PM10. The streamlined CEIDARS PM profiles can be found in Appendix A. The CEIDARS PM profiles may be updated as necessary to reflect updates prepared by CARB. If the project being evaluated is not listed among the categories in Appendix A, then the closest related type of operation/process should be used. For example in analyzing construction activities, e.g., grading, earth moving, etc., if the specific activity is not located in the tables the CEQA practitioner can use the following default factors derived from the 2003 AQMP annual inventories (see Tables 3 and 4 below under the Localized Significance Thresholds for PM2.5 Emissions discussion). For mechanical dust generating sources, e.g., construction, the PM2.5 fraction of PM10 is 21 percent and for combustion sources the PM2.5 fraction of PM10 is 99 percent. For off-road combustions 2 October 2006

153 Final PM2.5 Calculation Methodology and PM2.5 Significance Thresholds sources, the PM2.5 fraction default would be 89 percent (Table 5). Other publicly available and peer reviewed sources of PM10 and PM2.5 emission factors can also be used if they more closely match the type of emission source than the sources identified in Appendix A. In addition, site-specific or project-specific information can be used. Once the PM10 fractions from all emissions sources are calculated, these are summed and compared to the appropriate PM10 significance thresholds to determine whether or not a project is significant. Similarly, once the PM2.5 fractions from all emissions sources have been calculated, these are also summed (separate from the PM10 fractions) and compared to the appropriate PM2.5 significance threshold (see following discussion) to determine project significance. The PM2.5 fraction of PM10 can be easily calculated as follows. Step 1: Calculate PM10 emissions for each emissions source category. Step 2: Look up the PM2.5 fraction of PM10 for the applicable source category by year that construction will occur or operation of the project will begin (Appendix A, column 6 of the appropriate table). Step 3: Multiply the PM2.5 fraction by the PM10 emissions for each source category (PM2.5 emissions = PM10 emissions x [PM2.5 fraction]) Step 4: Sum the PM2.5 emissions from each emissions source. Step 5: Compare PM2.5 emissions to the appropriate significance threshold. Example: A project is estimated to generate 8 pounds per day of PM10 from one piece of construction equipment. The PM2.5 emissions are as follows: PM2.5 emissions = 8 pounds of PM10 per day x 0.89 = 7.12 pounds of PM2.5 per day. In conjunction with establishing a methodology for calculating PM2.5, staff has developed the following recommended PM2.5 significance thresholds for both localized and regional significance for both construction and operation. Localized Significance Thresholds for PM 2.5 Emissions Localized significance thresholds (LSTs) were developed in response to the SCAQMD Governing Board s environmental justice (EJ) initiatives (EJ initiative I-4) in recognition of the fact that criteria pollutants, carbon monoxide (CO), oxides of nitrogen (NOx), and PM10 in particular, can have local impacts as well as regional impacts. The LST proposal went through extensive public outreach and was adopted by the Governing Board in October At the time the LST was adopted by the Governing Board, staff had not yet developed proposed LSTs for PM October 2006

154 Final PM2.5 Calculation Methodology and PM2.5 Significance Thresholds Determining localized air quality impacts requires dispersion modeling. Because local lead agencies may not have the expertise or resources to perform dispersion modeling, SCAQMD created a series of look-up tables for CO, NOx, and PM10 in which staff backcalculated the mass emissions necessary to equal or exceed the construction or operation LST. The look-up tables were created for projects one to five acres in size and take into consideration location (source receptor area) and distance to the sensitive receptor. To use the look-up tables, the lead agency calculates daily emission as it normally would and then compares the results to the emissions in the applicable look-up table. In general, the LSTs will apply primarily to construction because emissions from construction equipment occur at a fixed location compared to operation, which, for most land use projects, consists of emissions from vehicles traveling over the roadways, which, therefore, do not create impacts to a single location. To further assist lead agencies with calculating construction emissions, the SCAQMD conducted construction site surveys for each phase of construction to develop standard construction scenarios relative to construction equipment and hours of operation. Spreadsheets were developed to calculate emissions for the construction scenarios in an effort to create scenarios that would not exceed any applicable LSTs. When preparing a CEQA analysis, lead agencies could use the sample construction projects for their construction analyses, use the spreadsheets to tailor the analysis to their individual projects, or use a combination of the two. The following subsections describe the proposed PM2.5 LSTs for both operation and construction. Establishing LSTs To determine the effects of PM2.5 on local (nearby) receptors, such as residents, hospitals, schools, etc., a PM2.5 localized significance threshold (LST) needs to be established. Since the Basin exceeds one or more of the state or federal ambient air quality standards for PM2.5, the process used to determine significance for attainment pollutants, i.e., NO2 and CO, developed for the LST program cannot be used c. Under the LST program, since PM10 is a nonattainment pollutant, the LST methodology uses a different process for determining whether localized PM10 air quality impacts are significant. To determine localized PM10 air quality impacts during operation, the LST methodology uses as a significance threshold the allowable change in concentration threshold for PM10 listed in Rule 1303, Table A-2, which is 2.5 micrograms per cubic meter (μg/m 3 ). The allowable change in concentration threshold is a modeled concentration that cannot be exceeded at the sensitive receptor, and determines whether or not a permit applicant will receive a permit from the SCAQMD. For the LST program staff used a dispersion model (ISCST3) to convert the 2.5 μg/m 3 concentration into mass daily PM10 emissions numbers based on the size of the project, location of the project, and distance to the sensitive receptor. The c Under the LST program, to determine significance for attainment pollutants, the emissions contribution from the project expressed as a concentration is added to the highest local ambient concentration from the last three years where data are available. If the sum is equal to or greater than any applicable state or federal ambient air quality standard, the project is considered to have significant localized air quality impacts for that pollutant. More information on the LST program can be found at the following URL: 4 October 2006

155 Final PM2.5 Calculation Methodology and PM2.5 Significance Thresholds results were then incorporated into an LST look-up table. If the mass emissions from a project exceed the applicable LST look-up tables mass emission numbers (which are based on the 2.5 μg/m 3 concentration), then localized PM10 air quality impacts are considered to be significant. Operational Localized Significance Thresholds To establish operational PM2.5 localized significance thresholds, staff first reviewed the PM inventories in Appendix III of the 2003 AQMP. In particular, staff evaluated the composition of PM10 and PM2.5 from combustion processes in the 2003 AQMP to establish a general ratio of PM2.5 to PM10. Combustion processes were evaluated because, for most land use projects, mobile source combustion emissions comprise the majority of emissions. Table 3 shows the total PM10 and PM2.5 inventories for total fuel combustion process for the years 2005 through As can be seen in Table 3, over the five-year timeframe considered, the fraction of combustion PM10 that consists of PM2.5 is consistently 99 percent. Since combustion PM10 and PM2.5 fractions are essentially equivalent, staff is recommending that the operational localized significance threshold for PM2.5 be the same as the current operational localized significance threshold for PM10, i.e., 2.5 μg/m 3. TABLE 3 Total Stationary Source Fuel Combustion Inventory (Tons/Day) Year PM 10 PM 2.5 Percent of PM 10 which is PM Source: Appendix III, 2003 AQMP, Annual Average Emission Inventory Construction Localized Significance Thresholds Similarly, to develop a PM2.5 construction significance threshold for localized impacts, staff considered the PM2.5 contribution from fugitive sources and the PM2.5 contribution from combustion sources (construction equipment). As discussed in more detail in the following paragraphs, combustion emissions from the construction equipment contribute a larger portion of the total PM2.5 emissions from construction operations than fugitive sources. Staff then reviewed the 2003 AQMP, Appendix III fugitive PM inventory for construction and demolition to obtain the PM10 and PM2.5 compositions. Table 4 shows the total PM10 and PM2.5 inventories for construction activities for the years 2005 through As can be seen in Table 4, over the five-year timeframe, the fraction of PM10 that consists of PM2.5 is consistently 21 percent. Multiplying the fugitive PM2.5 percent fraction of 5 October 2006

156 Final PM2.5 Calculation Methodology and PM2.5 Significance Thresholds PM10 by the existing construction PM10 LST, 10.4 μg/m 3, produces a result of approximately 2.2 μg/m 3. TABLE 4 Total Fugitive PM Inventory (Tons/Day) Year PM 10 PM 2.5 Percent of PM 10 which is PM Source: Appendix III, 2003 AQMP, Annual Average Emission Inventory Off-road construction equipment, however, also contributes combustion PM as well as fugitive PM. To determine the contribution of PM2.5 from construction equipment combustion emissions, staff performed dispersion modeling using the ISCST3 dispersion model for one-, two-, and five-acre construction scenarios. The construction scenarios were developed from construction site surveys conducted in connection with staff s original LST proposal. Combustion sources were modeled as adjacent five-meter volume sources and fugitive sources were modeled as adjacent one-meter area sources. Worst-case meteorological data from the West Los Angeles source receptor area were used and receptors were placed at 25, 50, 100, 200, and 500 meter distances from the construction site. Using CARB speciation data, it was assumed that 21 percent of fugitive dust PM10 is comprised of PM2.5 and 89 percent of off-road equipment combustion PM10 emissions are comprised of PM2.5 (based 2003 AQMP inventories, see Table 5). TABLE 5 Combustion PM Inventory from Off-Road Equipment (Tons/Day) Year PM 10 PM 2.5 Percent of PM 10 which is PM Source: Appendix III, 2003 AQMP, Annual Average Emission Inventory The modeling results showed that combustion PM2.5 from off-road equipment comprise approximately 75 to 100 percent of the total PM2.5 emissions from construction activities. Further, the PM2.5 contribution from fugitive sources is dependant on the construction phase. For example, the modeling showed that the demolition and site preparation phases have the highest fugitive PM2.5 contribution to the overall results, whereas, the building and asphalt paving phases contribute the most combustion PM2.5 to the overall results. 6 October 2006

157 Final PM2.5 Calculation Methodology and PM2.5 Significance Thresholds The modeling results indicate that the contribution of off-road combustion PM2.5 emissions can be three to four times higher than the contribution of PM2.5 from fugitive sources. Based on this result, staff recommends that the PM2.5 fugitive dust component be adjusted upward by approximately four times to account for the PM2.5 emissions from the construction equipment. As a result, staff is recommending a PM2.5 construction LST of 10.4 μg/m 3, the same as the construction LST for PM10. Finally, an exceedance of either the PM10 construction LST or the PM2.5 construction LST is a significant adverse localized air quality impact. Regional Emission Threshold of Significance for PM 2.5 Emissions that exceed the regional significance thresholds are mass daily emissions that may have significant adverse regional effects and are the air quality significance thresholds with which most CEQA practitioners are familiar. Table 6 Regional Air Quality Significance Thresholds Mass Daily Thresholds a Pollutant Construction b Operation c NOx 100 lbs/day 55 lbs/day VOC 75 lbs/day 55 lbs/day PM lbs/day 150 lbs/day SOx 150 lbs/day 150 lbs/day CO 550 lbs/day 550 lbs/day Lead 3 lbs/day 3 lbs/day The following subsection describes the proposed PM2.5 regional significance thresholds for both operation and construction. Establishing Regional Significance Thresholds PM emissions also affect air quality on a regional basis. When fugitive dust enters the atmosphere, the larger particles of dust typically fall quickly to the ground, but smaller particles less than 10 microns in diameter may remain suspended for longer periods, giving the particles time to travel across a regional area and affecting receptors at some distance from the original emissions source. Fine PM2.5 particles have even longer atmospheric residency times. Staff is recommending a PM2.5 regional significance threshold based on a recent EPA proposal, as explained in the following paragraphs. On September 8, 2005, EPA published in the Federal Register Proposed Rule to Implement the Fine Particle National Ambient Air Quality Standards, which proposed a significant emission rate for PM2.5 of 10 tons per year. Staff is proposing to use EPA s 7 October 2006

158 Final PM2.5 Calculation Methodology and PM2.5 Significance Thresholds significant emission rate for PM2.5 to develop the daily mass emission regional significance threshold for PM2.5. Converting the annual rate, 10 tons, into a daily rate produces a daily rate of approximately 55 pounds per day. A similar approach was used to derive the operational regional significance thresholds for NO2 and VOC. NO2 and VOC operational regional significance thresholds were derived by using the NOx/VOC emission rate that defined a major source in the South Coast Air Basin, 10 tons per year. Converting the annual emissions rate into a daily rate resulted in a regional operational significance threshold of 55 pounds per day for each pollutant. Similar to the regional significance threshold for PM10 of 150 pounds per day, the proposed PM2.5 regional significance threshold of 55 pounds per day would apply to both construction and operation. Conclusion In this document staff identified a methodology to indirectly calculate PM2.5 emissions for a CEQA or NEPA air quality analysis, to be used until such time as PM2.5 emission factors are available, which will allow the CEQA practitioner to calculate PM2.5 emissions directly. In addition, PM2.5 construction and operation LSTs have been identified to address localized impacts. The PM2.5 LSTs will be used to develop look-up tables for projects five acres in size or smaller, similar to those prepared for PM10, nitrogen dioxide (NO2), and carbon monoxide (CO). As with the other pollutants, the PM2.5 look-up tables can be used as a screening procedure to determine whether or not small projects (less than or equal to five acres) will generate significant adverse localized air quality impacts. Screening procedures are by design conservative, that is, the predicted impacts tend to overestimate the actual impacts. If the predicted impacts are acceptable using the LST look-up tables, then a more detailed evaluation is not necessary. However, if the predicted impacts are significant, then the project proponent may wish to perform a more detailed emission and/or modeling analysis before concluding that the impacts are significant. Project proponents are not required to use this LST procedure; and may complete site specific modeling instead. Site-specific modeling is required for projects larger than five acres. 8 October 2006

159 A P P E N D I X A Updated CEIDARS Table with PM2.5 Fractions

160 Appendix A Updated CEIDARS List with PM2.5 Fractions Table A - Updated CEIDARS Table with PM2.5 Fractions SCC MAIN CATEGORY SCC SUBCATEGORY A-1 PM2.5 FRACTION OF TOTAL PM PM10 FRACTION OF TOTAL PM PM2.5 FRACTION OF PM10 ASBESTOS REMOVAL ASPHALT PAVING / ROOFING FUGITIVE EMISSIONS MANUFACTURING BURNING AGRICULTURE/FIELD CROPS, WEED ABATEMENT FOREST MANAGEMENT, TIMBER AND BRUSH FIRE ORCHARD PRUNINGS RANGE MANAGEMENT, WASTE BURNING UNPLANNED STRUCTURAL FIRES CEMENT MANUFACTURING CHEMICAL MANUFACTURING FERTILIZER-UREA COATINGS, SOLVENTS, INKS AND DYES ORGANIC AND INORGANIC CHEMICALS SOLVENT BASED WATER-BASED COATING CONSUMER PRODUCTS COOKING BAKING, CHARBROILING, DEEP FAT FRYING COOLING TOWER DRY CLEANING ELECTROPLATING HEXAVALENT CHROME, CADMIUM ZINC AND COPPER EXTERNAL COMBUSTION COAL, COKE, LIGNITE GASEOUS FUEL-EXCEPT PETROLEUM AND INDUSTRIAL PROCESS HEATERS GASEOUS FUEL-PETROLEUM AND INDUSTRIAL PROCESS HEATER ONLY LIQUID FUEL-EXCEPT RESIDUAL OIL RESIDUAL OIL-EXCEPT UTILITY BOILERS RESIDUAL OIL-UTILITY BOILERS ONLY STEEL FURNACE WOOD/BARK WASTE FABRICATED METALS ABRASIVE BLASTING ARC WELDING, OXY FUEL, COPPER, ZINC, BATH FOOD AND AGRICULTURE COFFEE ROASTING FERMENTATION, RENDERING, FISH AND NUT PROCESSING GRAIN ELEVATORS GRAIN MILLING, DRYING LIVESTOCK WASTE FUGITIVE DUST AGRICULTURAL TILLING DUST FUGITIVE EMISSIONS - ORGANIC AND INORGANIC CONSTRUCTION AND DEMOLITION LANDFILL DUST LIVESTOCK DUST PAVED ROAD DUST UNPAVED ROAD DUST LIQUID FUEL STORAGE/HANDLING, LOADING, UNLOADING DISPENSING NATURAL GAS PRODUCTION, CRUDE OIL PRODUCTION, PETROLEUM REFINING ORGANIC AND INORGANIC CHEMCALS PROCESSING WELL CELLEARS, PUMPS, VALVES, FLAGES, SEALS

161 Appendix A Updated CEIDARS List with PM2.5 Fractions Table A - Updated CEIDARS Table with PM2.5 Fractions (Continued) SCC MAIN CATAGORY SCC SUBCATAGORY PM2.5 Fraction of Total PM PM10 Fraction of Total PM PM2.5 Fraction of PM10 HEALTH CARE, LABS STERILIZATION INCINERATOR, AFTERBURNER, FLARES GASEOUS FUEL LIQUID FUEL SOLID FUEL INTERNAL COMBUSTION DISTILLATE AND DIESEL-ELECTRIC GENERATION DISTILLATE AND DIESEL-EXCEPT ELECTRIC GENERATION GASEOUS FUEL GASOLINE JET FUEL SOLID PROPELLANT MINERAL PROCESS LOSS BRICK, CEMENT, FIBERGLASS, GLASS MFG COAL CLEANING, SURFACE COAL MINE, NONMETALLIC MINERAL GRINDING, CRUSHING, SURFACE BLASTING LOADING AND UNLOADING BULK MATERIALS MINERAL PRODUCTS CLAY AND RELATED PRODUCTS GRINDING OPERATIONS CRUSHING, SCREENING, BLASTING, LOADING AND UNLOADING FIBERGLASS MANUFACTURING GLASS MELTING FURNACE GYPSUM MANUFACTURING LIME MANUFACTURING STONE QUARRYING OFF-ROAD EQUIPMENT DIESEL GASEOUS FUEL GASOLINE ON-ROAD VEHICLES BRAKE WEAR DIESEL GASOLINE-CATALYST GASOLINE-NO CATALYST HEAVY, MEDIUM, LIGHT DUTY TRUCKS AND VEHICLES, MOTORHOMES, BUSES, MOTORCYCLES TIRE WEAR PETROLEUM INDRY ASPHALT CONCRETE PRIMARY AND SECONDARY METALS ELECTRO REDUCTION, FURNACE, FLUXING, STORAGE, PROCESSING IRON & STEEL, FOUNDARY, HEAT TREATING STEEL FURNACE RESIDENTIAL FIREPLACES AND WOOD COMBUSTION SHIPS DIESEL LIQUID FUEL TRAINS HAULING, SWITCHING WASTEWATER, SEWAGE TREATMENT, DIGESTER WOOD PRODUCTS SANDING SAWING A-2

162 Carley Foundry Attachment 8 Emission Factors for Industrial Sand Mines

163 Air Pollution Control Requirements for Industrial Sand Mines 1,2 Publication AM P.O. Box 7921 Madison, Wisconsin What is an industrial sand mine? An industrial sand mine is any mine, pit or quarry engaged in mining or dredging of industrial grade sand and facilities engaged in washing, screening and preparing industrial grade sand. Typical industrial grade sands are used as abrasives, for sand blasting, as enamels, as filtration media, for frac sand or in the foundry or glass manufacturing industries. Industrial sand does not include sand and gravel that will be used in construction. If your mine produces both industrial and construction sand, the site would still be considered an industrial sand mine. NOTE: If you sell industrial grade sand that has been dug or dredged for other purposes such as creating or maintaining cranberry beds or other activities, your facility would still be considered an industrial sand mine. If you simply stockpile sand and use it on site for your own purposes, then your operations would not be considered industrial sand mining. Does my sand mining operation need a permit? Some industrial sand mining operations will need an air pollution control permit. Smaller operations may be exempt from air pollution permit requirements. IMPORTANT NOTE: Whether or not your operation needs an air permit, all sand mines must meet the requirements listed in the section on What must I do to comply? Exemptions: CAUTION: Operations that include sand dryers are not exempt even if their production meets an exemption threshold. This includes sand dryers on site and, with some rare exceptions, usually includes mines transporting wet sand to a dryer in the area. There are two ways a facility may be exempt from needing an air permit. Specific exemption: The first exemption is for very small mines that produce less than 2000 tons of sand per month averaged over any 12 consecutive month period. One way to estimate this is to assume a load of damp sand in a 15 yard dump truck is about 13 tons of sand. 1 This document is intended solely as guidance and does not contain any mandatory requirements except where requirements found in statute or administrative rule are referenced. This guidance does not establish or affect legal rights or obligations and is not finally determinative of any of the issues addressed. This guidance does not create any rights enforceable by any party in litigation with the State of Wisconsin or the Department of Natural Resources. Any regulatory decisions made by the Department of Natural Resources in any matter addressed by this guidance will be made by applying the governing statutes and administrative rules to the relevant facts. The Wisconsin Department of Natural Resources provides equal opportunity in employment, programs, services and functions under an Affirmative Action Plan. If you have any questions, please write to Equal Opportunity Office, Department of Interior, Washington, DC This publication is available in alternative format (large print, Braille, audio tape, etc.) upon request. Please contact the Bureau of Air Management, phone , for more information. 2 Author: Kristin Hart. Document Date: June 8,

164 10-Ton exemption: The second exemption is for mines that will not emit particulate matter and fugitive dust in excess of 10 tons per calendar year. Emissions at a mine depend on the amount of paved and unpaved roadways, how much sand is stored on site, and whether sand is screened, or if crushing occurs on site. As a rough estimate, wet sand operations averaging up to about 20,000 tons of sand per month can meet this exemption threshold. Operations over 20,000 tons per month may also be exempt, but some calculations need to be done to be certain. To use either of these exemptions, you need to prepare and follow a fugitive dust plan, and keep records of monthly sand production in tons per month. Without records, these exemptions are not valid. More information, including forms and instructions for applying for exemptions, is available at Permits and Waivers: Facilities that will exceed 10 tons of emissions over the course of a calendar year, or that will use a sand dryer on site or near the mining site, need to obtain an air pollution control permit before breaking ground unless a construction permit waiver is granted by the DNR. DNR has the ability to grant a waiver to allow construction to start before the air permit is issued, provided all other local, state and federal permits/approvals or reviews have been issued or conducted. The waiver can only be granted if a complete air permit application has been submitted and a fugitive dust control plan has been approved by DNR. However, no facility can operate without the air permit being issued if one is needed. More information on construction permit waivers is available at There are two types of permits available to sand mining operations: Type A Registration Permit is available for mining operations without dryers that emit less than 25 tons of particulate matter per year. NOTE: This 25 tons per year emission cap does not include fugitive dust. The Registration Permit s advantages include a faster, simplified application, and the permit covers both construction and facility operation. Applications are submitted through an on-line system. DNR reviews and decides whether to grant the permit within 15 days of receiving a complete application. Complete applications must include: o o o a hard copy of the on-line application signed by the responsible official a fugitive dust plan, and a facility description that includes the expected annual sand production rate. More information on Registration Permits is available at Source specific permits must be obtained for mines that will have a dryer at the mine site or an associated dryer nearby. Individual permits are more complicated to prepare, undergo a more rigorous review, and involve a public notice and public comment period. A public hearing may also be held if one is requested. Depending on the complexity of the project, it can take from 3 to 6 months to receive a source specific air permit. More information on obtaining air pollution permits is available at What must I do to comply with all Wisconsin s air pollution regulations? Whether or not your sand mine needs a permit, there are air pollution regulations that apply to your sand mine. You must keep records to document that you are meeting these requirements. All industrial sand mines must meet at least some of the requirements for controlling particulate matter emissions in s. NR of Wisconsin s regulation (available at Here is a quick summary of the requirements (refer to the rule for more details): Recordkeeping: All industrial sand mining operations, no matter how small, must keep records of: o o o monthly hours of operation monthly sand production in tons per month records that demonstrate you are following your fugitive dust plan 2

165 Fugitive Dust Control Plan: All sand mining operations must prepare and follow a fugitive dust plan to detect dust and prevent it from becoming airborne. Fugitive dust plans must be written and should be kept on-site to be available for review by a compliance inspector. For help preparing a fugitive dust plan, visit Ambient Air Monitoring: Mining operations with production averaging more than 2000 tons per month are required to install and operate ambient air monitors. Facilities can apply for a variance from this requirement if they can demonstrate that the general public will not be exposed to significant levels of particulate matter. Variance requests must be submitted to DNR in writing (see the contact information below for more information). How can I figure out what I emit? Estimating emissions from sand mining operations is not an exact science and can be done by a variety of methods. DNR will review any methods proposed by a facility as long as they are clearly explained and justified. The attached table gives some information that is useful when calculating emissions. Where can I get more information? General questions on sand mining in Wisconsin: Tom Woletz , thomas.woletz@wisconsin.gov Questions on air permits and exemptions: Kristin Hart , kristin.hart@wisconsin.gov Variance requests and other compliance questions: Rick Wulk , richard.wulk@wisconsin.gov 3

166 Attachment Calculating Emissions from Industrial Sand Mining One method for estimating emissions from various operations is to make use of emission factors. An emission factor basically estimates the amount of a pollutant released during certain operations (like sand crushing, or drying) and activities (for instance, hauling over unpaved roads). This table gives some emission factors that DNR has used for calculating emissions. To use this table, multiply the emission factor by the tons of sand produced at the operation or the miles of roadway traveled per truck (VMT) to get the annual emissions of particulate matter and PM10. Calculating Emissions of Particulate Matter from Sand Mining Operations Operation Control Method Emission Factor Notes Fugitive Emissions Truck traffic on unpaved roads Fugitive Dust Plan 2.7 lb particulate matter/vmt AP-42 section assume 25 ton trucks Truck traffic on paved roads Fugitive Dust Plan 1.4 lb particulate matter/vmt AP-42 section assume 25 ton trucks Drilling natural moisture lb/ton sand produced AP-42 section Material Transfers/Storage Piles fugitive dust plan lb/ton sand transferred assumes natural moisture. Can t be used if sand is allowed to dry out. Point Source Emissions (No dryers or dried sand processed) Crushing/delumping natural moisture lb/ton crushed AP-42 Section *Screening of damp sand natural moisture lb/ton screened per screen assumes no other controls *Handling from screening natural moisture lb/tons screened assumes no other controls Washing/screening/handling of saturated materials saturated materials negligible assumes screening and handling occurs immediately after washing Emissions from sand Processed in a Dry Plant Sand Dryer uncontrolled 2.0 lb/ton dried sand AP-42 section Sand Dryer with wet scrubber 0.39 lb/ton dried sand AP-42 section Sand Dryer with baghouse 0.10 lb/ton dried sand AP-42 section *Dry sand handling transfer storage with wet scrubber lb/ton dried sand per transfer point AP-42 section *Dry sand screening with venturi scrubber lb/ton dried sand per screen. 4 AP-42 section *Emissions will be generated from screening each time sand is run through a screen. So if a ton of sand is run through first one mesh screen, then the remaining half ton is screened again through a finer mesh screen emissions must be calculated for each of those screens. Similarly, if the same ton of sand is handled more than once, the emissions are generated each time the sand is handled. Simply multiplying annual sand production by these numbers may be underestimating emissions. If in doubt, call the DNR. VMT = Vehicle Miles Traveled PM10 = Particulate matter less than 10 microns in diameter AP-42 = USEPA document of emission factors available at

167 Carley Foundry Attachment 9 Thermal Reclaimer VOC Emission Factor

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171 Carley Foundry Attachment 10 Investment Casting Wax Burnout Emission Factors

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174 Carley Foundry Attachment 11 Core Molding Binder Formula

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177 Carley Foundry Attachment 12 Dakota Scrubber Reference Guide

178 Dakota Dakota International, Inc. Foundry Scrubbers Worldwide Amine Cold Box Scrubber Installation Reference Guide Dakota International Incorporated is a manufacture of packed bed gas scrubbers for cold box core machines. Dakota Scrubbers are designed specifically for the foundry environment with simplicity, reliability and safety as primary goals. Scrubbers are required during core making to comply with environmental regulations and provide core machine operators with a safe odor free working environment. Theory of Scrubber Operation Dakota Scrubbers are packed bed countercurrent gas absorption systems designed to absorb amine from core machine purge gas. Scrubbers work by absorbing amine, which is in the gas phase, from the core machine exhaust gas into a recirculating sulfuric acid solution. The amine is then neutralized through chemical reaction where two moles of amine react with one mole of acid to form a neutral amine sulfate salt. Amine is a catalyst in the core making process, which means it is not consumed except for minor adsorption on the sand and resin. As the amine is purged from the core box the contaminated gas stream is pulled up through a bed of wetted media (packed bed) using an exhaust fan. A sulfuric acid scrubbing solution is continuously pumped from the scrubber s liquid reservoir and distributed over the top of the packed bed through a spray nozzle. The scrubbing solution cascades down through the packed bed countercurrent to the gas flow back to the liquid reservoir. The packed bed provides a large surface area for absorption of amine into the scrubbing solution for reaction with sulfuric acid. The gas stream then passes through a mist eliminator assembly to remove entrained water droplets from the gas steam prior to discharge from the scrubber and exhaust fan. After the sulfuric acid in solution is consumed the scrubbing solution is considered spent and is drained from the scrubber and replaced with a fresh batch of sulfuric acid solution. The ph of the scrubbing solution is continuously monitored for automatic indication that the scrubber solutions is spent and needs replacement. Water lost due to evaporation is also monitored and automatically replaced. The spent scrubbing solution is typically sent off site for recycling where the amine is recovered for reuse. Dakota International, Inc. Telephone: PO Box 1111, Aberdeen, SD Fax: dakota@scrubbers.com

179 Dakota International, Inc. Foundry Scrubbers Worldwide Amine Scrubber Chemistry The chemistry for all amine catalysts is very similar with two moles of amine reacting with one mole of sulfuric acid to form one mole of amine sulfate. The chemical equation is: ph 4.5 2[R 3 N] + [H 2 SO 4 ]! [R 3 NH] 2 [SO 4 ] The scrubber is initially charged with a percent by weight sulfuric acid solution. This sulfuric acid solution starts at less than 1.0 ph and rises as amine is absorbed in the scrubber system. As the scrubber solution rises to ph 4.5 the scrubber efficiency begins to decrease. The decrease in scrubber efficiency is a result of the exponential increase of free amine in the acid-base equilibrium. As the free amine in solution increases the partial vapor pressure of amine above the solution also rises exponentially. Ultimately the scrubber outlet amine concentration is limited to the partial vapor pressure of amine of the recirculating amine sulfate salt solution. Capture Efficiency Capture efficiency is defined as the efficiency at which emissions are captured at the emission source, in our case the core machines. A scrubber that provides a 99.9 % scrubbing efficiency is of little use if the odors are not captured correctly at the source. Capture efficiency is of equal importance to scrubbing efficiency when looking at the overall effectiveness of a scrubber installation s ability to provide core room workers with a clean working environment. Enclosed Core Machines Good design practice requires that each core machine enclosure be provided with enough exhaust capacity to maintain a feet per min face velocity at all enclosure openings. For example if a core machine enclosure has a single door opening which measures 4 feet by 5 feet, the minimum exhaust capacity provided can be calculated as follows: (4 feet) x (5 feet) x (100 feet/minute) = 2,000 cubic feet per minute It is important to remember that amine gas is heavier than air and will settle to the floor. For this reason it is best to locate exhaust plenums near the floor, however special care should be taken to prevent sand or other debris from being sucked into the exhaust plenums. Dakota International, Inc. Telephone: PO Box 151, Aberdeen, SD Fax: dakota@scrubbers.com

180 Dakota International, Inc. Foundry Scrubbers Worldwide Core Machines Without Enclosures If a core machine is not enclosed, the core machine exhaust manifold should be vented directly to the scrubber and in addition a side draft should be provided to capture fugitive amine fumes released from the core box parting line and fresh cores. Dampers should be provided to balance the system. As a general rule the pressure in the core machine exhaust manifold should be maintained between +/- 1 psig. To prevent a high negative pressure it is best to run the hose from the core machine exhaust manifold into a duct with a diameter larger than the hose to provide an annular region where excess air is provided as required to maintain constant velocities in the exhaust ductwork. As an alternative, a gravity or actuating damper may be used on the core box manifold exhaust duct to maintain the +/- 1 psig recommended pressure. Scrubbing Efficiency Scrubbing efficiency is determined by the packing height in the scrubber and the corresponding number of transfer units (NTU). The height per transfer unit (HTU) can be calculated theoretically or determined by experimentation. HTU = height per transfer unit NTU = packing height HTU NTU = natural log of C in /C out where C in is the amine inlet concentration and C out is the amine outlet concentration For example if we determine experimentally that the height per transfer unit for a particular type of packing is 12 inches and we have a packing height of 96 inches in our scrubber and an inlet concentration of 200 parts per million (ppm) amine then: NTU = 96 inches = 8 12 inches 8 = natural log of C in /C out e 8 = 200ppm/ C out C out = 0.07 ppm 200 ppm 0.07 ppm = 99.9% scrubbing efficiency 200 ppm TRI-PACKS Packing Dakota International, Inc. Telephone: PO Box 151, Aberdeen, SD Fax: dakota@scrubbers.com

181 Dakota International, Inc. Foundry Scrubbers Worldwide Particulate Control Preventing particulate from entering the scrubber will save time and money in the long run. Sand entering the scrubber system will require periodic removal and may be classified as hazardous waste. Sand will also shorten the life span of pumps, ph sensors, flow meters and spray nozzles. Fine particulate such as that from shake out lines can lead to fouling of the scrubbers packed bed and mist eliminator components. The following particulate controls have proven to be effective and should all be considered along with available space and budget. Sand Drop Out Box A sand drop out box provides a large section of duct where the gas velocity is reduced and allows particulate to drop out of the gas stream. Most designs incorporate an impingement plate or baffle to help reduce the particulates velocity and direct the particulate to the bottom of the sand drop out box where it can be removed via a hopper with a slide or spring gate. The disadvantages are space requirements and removal efficiency especially for fine particulate. The advantages are lower cost and minimal pressure drop. Cyclones and Inertial Separators The cyclone uses the principle of inertial separation by forcing the gas to change direction and as the gas changes direction the inertia of the particulates causes them to continue in their original direction and become separated from the gas stream. The advantage is higher removal efficiency of fine particulate than a sand drop out box. The disadvantages are space requirements, cost and increased pressure drop. Fabric Filter Our experience shows that fabric filters are an excellent choice for eliminating particulate from entering the scrubber system. A simple arrangement that uses a standard furnace filter at the ductwork plenums provides very high removal efficiencies at low pressure drops. It is however critical that the filters be replaced on a regular if not daily basis. The pressure drop across a new filter can be monitored for a short period of time to establish proper replacement intervals. The advantage is superior removal efficiencies. The disadvantage is the maintenance required to replace filters. Dakota International, Inc. Telephone: PO Box 151, Aberdeen, SD Fax: dakota@scrubbers.com

182 Dakota International, Inc. Foundry Scrubbers Worldwide Frequently Asked Questions (FAQ) What are the disadvantages of indoors vs. outdoors scrubber installations? Outdoor scrubber installations require the following provisions Scrubber vessel must be fabricated from thermoplastic UV light inhibitor. A sump heater is required for outdoor installations to prevent freeze up in cold weather climates. Insulation for all liquid piping must be provided to prevent freeze up. Indoor scrubber installations When the gas stream passes through the wetted packed bed it essentially becomes saturated and the humid gas stream may condense out in the ductwork downstream of the scrubber, if the gas stream is discharged indoors provisions need to be made for condensation. The gas discharged from the scrubber will be very humid and if discharged indoors will increase the humidity of the environment. How much water is lost due to evaporation? Evaporation losses depend on the humidity of the ambient air. The less humid the air the greater the evaporation losses in the scrubber. The scrubber is designed to maintain a liquid level within a one-inch range and typical water makeup cycles occur every few hours. What is the batch life of a fresh acid solution? Batch life varies with the amount of amine that is captured and removed in the scrubber. Acid replacement may be required every few weeks or once a year depending amine consumption and volume of the scrubber liquid reservoir How do I dispose of the "spent acid" waste solution from an amine scrubber? Most suppliers of amine catalyst offer recycling programs for their customers spent acid solution. Ashland Specialty Chemical offers their Isocycle SM program. See Ashland Chemical's Bulletin # "Isocycle SM Amine Catalyst Recycling Program". Dakota International, Inc. Telephone: PO Box 151, Aberdeen, SD Fax: dakota@scrubbers.com

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