Minnesota Pollution Control Agency

Transcription

1 Minnesota Pollution Control Agency Air Individual Permit Part 70 Reissuance Permittee: Facility name: Minnesota Diversified Products Inc -West Minnesota Diversified Products Inc -West 6901 West Road Rockford, MN Expiration date: January 26, 2021 * All Title I Conditions do not expire Part 70 Reissuance: January 26, 2016 Permit characteristics: Federal; Part 70/ Limits to avoid NSR; Limits to avoid NSR * The Permittee may continue to operate this facility after the expiration date of the permit, per the provision under Minn. R , subp. 3. (Title V Reissuance Application was received June 3, 2015.) The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the Permit Applications Table. This permit reissue supersedes Air Emission Permit No , and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in the permit. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the State Implementation Plan (SIP) under 40 CFR and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Signature: <0/- O 'ZD / This document has been electronically signed. for Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for the Minnesota Pollution Control Agency

2 Table of Contents Page 1. Permit applications table 1 2. Where to send submittals 2 3. Facility description 3 4. Summary of subject items 4 5. Limits and other requirements 5 6. Submittal/action requirements Appendices 13 Appendix A. Insignificant Activities and General Applicable Requirements 13 Appendix B. Equipment Capacity and Maximum Contents of Materials 14

3 Permit issued: January 26, 2016 Permit expires: January 26, Page 1 of Permit applications table Subsequent permit applications: Title description Application receipt date Action number Part 70 Reissuance 06/03/

4 Permit issued: January 26, 2016 Permit expires: January 26, Page 2 of Where to send submittals Send submittals that are required to be submitted to the U.S. EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by Minn. R to must be certified by a responsible official, defined in Minn. R , subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. Send submittals that are required by the Acid Rain Program to: U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C Send any application for a permit or permit amendment to: Fiscal Services - 6 th Floors Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term Unless another person is identified in the applicable Table, send all other submittals to: AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota

5 Permit issued: January 26, 2016 Permit expires: January 26, Page 3 of Facility description The Minnesota Diversified Products Inc -West (Facility) is located at 6901 West Rd in Rockford, MN, Wright County, Minnesota. Minnesota Diversified Products West is an existing facility that manufactures expanded polystyrene boardstock, primarily used in building materials and insulation. The boardstock is made through the use of expanded polystyrene beads molded into the desired shapes. The first step in the process is the preexpansion of the beads, which are similar in appearance to white sugar. Steam is mixed with the beads, releasing the blowing agent, pentane, which causes the beads to expand in size. Beads are typically stored in mesh bags for 8 to 48 hours after expansion, allowing time to stabilize. Beads are then transferred to the molding area, where blocks are formed, cured, and then conveyed to hot wire cutters where they are cut to size. Additionally, some final products are laminated with thin plastic sheeting. The main pollutant of concern for this facility is pentane, a Volatile Organic Compound (VOC). Additionally, small amounts of free styrene (both a hazardous air pollutant and a VOC) are emitted from the raw beads throughout the process. Combustion products are also emitted from a natural gas fired boiler. The facility has activities that are considered insignificant under Minnesota Rules. A complete list of these insignificant activities is available in Appendix A. In previous permit actions, the facility has taken limits on the emissions of VOC to avoid major source classification for New Source Review (40 CFR pt. 52). The facility is a major source under federal operation permits program (40 CFR pt. 70) and is an area source under the National Emissions Standards for Hazardous Air Pollutants (NESHAPs, 40 CFR pt. 63).

6 Permit issued: January 26, 2016 Permit expires: January 26, Page 4 of Summary of subject items SI ID: Description ACTV3: All la's COMG2: Total Facility VOC Limit EQUI1: Boiler 1- Boiler EQUI2: Pre- Expander - Mixing Equipment EQUI4: Molder - Molding Equipment EQUI5: Laminator - Adhesion Equipment EQUI6: Mold Press - Pressing Equipment EQUI7: Mold Press - Pressing Equipment Relationship Type has members sends to sends to sends to sends to sends to sends to Related SI ID: Description EQUI2, EQUI4, EQUI5, EQUI6, EQUI7 STRU3: Stack/Vent for Boiler EQUI1 STRU5: Stack/Vent for Pre-Expander EQUI2 STRU6: Stack/Vent for Molder EQUI4 STRU4: Building Ventilation STRU8: Stack/Vent for Mold Press EQUI6 STRU1: Stack/Vent for Mold Press EQUI7 STRU1: Stack/Vent for Mold Press EQUI7 STRU2: West Plant Production Line STRU3: Stack/Vent for Boiler EQUI1 STRU4: Building Ventilation STRU5: Stack/Vent for Pre-Expander EQUI2 STRU6: Stack/Vent for Molder EQUI4 STRU8: Stack/Vent for Mold Press EQUI6 TFAC1: Minnesota Diversified Products Inc -West

7 Permit Issued: January 26, 2016 Permit Expires: January 26, Page 5 of Limits and other requirements Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation TFAC Minnesota Diversified Products Inc - West PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R , (A)(2)] This permit establishes limits on the facility to keep it a minor source under New Source Review. The Permittee cannot make any change at the source that would make the source a major source under New Source Review until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments. [Title 1 Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title 1 Condition: Avoid major source under 40 CFR 52.21(b)(l)(i) and Minn. R , Title 1 Condition: Avoid major source classification under 40 CFR 63.2] Equipment Inventory: The Permittee shall maintain a written list of all emissions units and control equipment on site. The Permittee shall update the list to include any replaced, modified, or new equipment prior to making the change. The list shall correlate the units to the Subject Item numbers used in this permit and shall include the data on GI-04, GI-05B, and GI-05C. The date of construction shall be the date the change was made for replaced, modified, or new equipment. [Minn. R , subp. 2] Equipment Labeling: The Permittee shall permanently affix a unique number to each emissions unit for tracking purposes. The numbers shall correlate the unit to the appropriate Subject Item numbers used in this permit. The number can be affixed by placard, stencil, or other means. The number shall be maintained so that it is readable and visible at all times from a safe distance. If equipment is added, it shall be given a new unique number; numbers from replaced or removed equipment shall not be reused. [Minn. R , subp. 2]

8 Permit Issued: January 26, 2016 Permit Expires: January 26, Page 6 of 14 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendices A and B. [Minn. R , subp. 2] The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R to Compliance shall be demonstrated upon written request by the MPCA. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. [Minn. R ] Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R , subp. 16(J), Minn. R , subp. 2] Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. [Minn. R , subp. 14, Minn. R , subp. 16(J)] Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R , subp. 4] Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R [Minn. R ] Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator

9 Permit Issued: January 26, 2016 Permit Expires: January 26, Page 7 of 14 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation or citizens under the Clean Air Act. [Minn. R ] Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). [Minn. R , subp. 9(A)] The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. [Minn. R , subp. 16] Monitoring Equipment Calibration - The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. [Minn. R , subp. 4(D)] Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. [Minn. R , subp. 4(D)] Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). [Minn. R , subp. 5(C)] Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R , subp. 2), including records of the emissions resulting from those changes. [Minn. R , subp. 5(B)] 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

10 Permit Issued: January 26, 2016 Permit Expires: January 26, Page 8 of 14 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation 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. [Minn. R , subp. 4] Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. [Minn. R , subp. 3] Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R , subp. 2] Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R , subp. 1] Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected;

11 Permit Issued: January 26, 2016 Permit Expires: January 26, Page 9 of 14 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. [Minn. R , subp. 1] Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new or a mended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R , subp. 3. [Minn. R , subp. 3, Minn. R ] Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R , subp. 1(H). [Minn. R , subp. 1(H)] Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance, to be submitted on a form approved by the Commissioner. [Minn. R ] Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R ] COMG 2 GP001 Total Facility VOC Limit The Permittee shall limit emissions of Volatile Organic Compounds <= pounds per month 12-month rolling average to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. All VOC-emitting equipment at the Facility is subject to this limit except for the following: combustion and insignificant activities listed in Appendix A of this permit. If the Permittee replaces any existing VOC-emitting equipment, adds new VOCemitting equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the requirements in COMG 2. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee is not required to complete VOC calculations described in Minn. R ,

12 Permit Issued: January 26, 2016 Permit Expires: January 26, Page 10 of 14 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation subp. 2. A permit amendment will still be needed regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to the limits or monitoring and recordkeeping in this permit. VOC contents for each VOC-containing material shall be determined as described under the Material Content requirement in this permit. [Title 1 Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title 1 Condition: Avoid major source under 40 CFR 52.21(b)(l)(i) and Minn. R , Title 1 Condition: Avoid major source classification under 40 CFR 63.2] Total Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R This applies separately to each subject item. None of these processes are expected to produce any particulate matter. [Minn. R , subp. 1(A)(1)] Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. This limit applies to each subject item in this group individually. [Minn. R , subp. 1(A)(2)] Daily Recordkeeping: For VOC used in the EPS bead processes: On each day of operation, the Permittee shall maintain production records showing the total quantity of each VOC-containing material used at the facility. This shall be based on written usage logs and flow meters. For other VOC-containing materials: The Permittee shall calculate, record, and maintain monthly usage showing the amount of each material used. This shall be based on either written usage logs or purchase/delivery records. [Title 1 Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title 1 Condition: Avoid major source under 40 CFR 52.21(b)(l)(i) and Minn. R , Title 1 Condition: Avoid major source classification under 40 CFR 63.2] Volatile Organic Compounds: Monthly Recordkeeping -- VOC Emissions. By the 15th of the month, the Permittee shall calculate and record the following: ' 1) The total usage of VOC-containing materials for the previous calendar month using the daily usage records. This record shall also include the VOC and solids contents of each material as determined by the Material Content requirement of this permit; 2) The VOC emissions for the previous month using the formulas specified in this permit; and 3) The 12-month rolling average VOC emissions for the

13 Permit Issued: January 26, 2016 Permit Expires: January 26, Page 11 of 14 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation previous 12-month period by averaging the monthly VOC emissions data for the previous 12 months. [Minn. R , subps. 4-5] Volatile Organic Compounds: Monthly Calculation -- VOC Emissions. The Permittee shall calculate VOC emissions using the following equations: VOC (lbs/month) = V - W V = (A1 x Bl) + (A2 x B2) + (A3 x B3) + W = (CI x Dl) + (C2 x D2) + (C3 x D3) + where: V = total VOC used in pounds/month; A# = amount of each VOC-containing material used, in pounds/month; B# = weight percent VOC in A#, as a fraction; W = the amount of VOC shipped in waste, in pounds/month; C# = amount, in pounds/month, of each VOC-containing waste material shipped. If the Permittee chooses to not take credit for waste shipments, this parameter would be zero; and D# = weight percent of VOC in C#, as a fraction. [Minn. R , subps. 4-5] Material Content. EPS Beads: The Permittee shall use the Certificate of Analysis (COA) from the supplier to determine the VOC content of each bead shipment. If the COA is not available for a shipment, the Permittee shall use a Material Safety Data Sheet (MSDS ) or Safety Data Sheet (SDS) provided by the supplier. If there is a given range of VOC on the MSDS or SDS, the highest number in the range should be used. If a COA, MSDS, or SDS is not available or does not include VOC content from the supplier, the Permittee shall assume that the pentane content of that shipment is 7% by weight and the styrene monomer content is 0.1% by weight. However, if in the preceding 12 months, EPS beads with a VOC content greater than 7.1% was used, then the Permittee shall assume that the VOC content of that shipment is equivalent to the highest VOC content used in the preceding 12 months. Other Materials: VOC contents in other materials shall be determined by the Safety Data Sheet (SDS) or the Material Safety Data Sheet (MSDS) provided by the supplier for each material used. If a material content range is given on the SDS or the MSDS, the highest number in the range shall be used in all compliance calculations. If there is information provided in the Regulatory Section of the SDS, the highest number in the range of that section may be used.

14 Permit Issued: January 26, 2016 Permit Expires: January 26, Page 12 of 14 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Other alternative methods approved by the MPCA may be used to determine the VOC contents. The Commissioner reserves the right to require the Permittee to determine the VOC contents of any material, according to EPA or ASTM reference methods. If an EPA or ASTM reference method is used for material content determination, the data obtained shall supersede the SDS or the MSDS. [Minn. R , subps. 4-5] Maximum Contents of Materials: The Permittee assumed certain worst-case contents of materials when determining the short term potential to emit of units in COMG 2. These assumptions are listed in Appendix B of this permit. Changing to a material that has a higher content of any of the given pollutants is considered a change in method of operation that must be evaluated under Minn. R , subp. 3 to determine if a permit amendment or notification is required under Minn. R [Minn. R , subp. 35a] EQUI1 EU001 Boiler 1 - Boiler Total Particulate Matter <= 0.4 pounds per million Btu heat input. The potential to emit from the unit is Ib/MMBtu due to equipment design and allowable fuels. [Minn. R , subp. 1] Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R , subp. 2] Fuel type: Natural gas and Propane only, by design. [Minn. R , subp. 35a] The Permittee shall keep records of fuel type and usage on a monthly basis. [Minn. R , subp. 5] 6. Submittal/action requirements This section lists most of the submittals required by this permit. Please note that some submittal requirements may appear in the Limits and Other Requirements section, or, if applicable, within a Compliance Schedule section. Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation TFAC Minnesota Diversified Products Inc - West The Permittee shall submit an application for permit reissuance: Due 180 calendar days before Permit Expiration Date. [Minn. R , subp. 2] The Permittee shall submit a semiannual deviations report: Due semiannually, by the 30th of January and July. The first semiannual report submitted by the Permittee shall cover the

15 Permit Issued: January 26, 2016 Permit Expires: January 26, Page 13 of 14 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation 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 , subp. 6(A)(2)] The Permittee shall submit an annual report: Due annually, by the 31st of January. The report shall describe the changes made at the Facility during the previous calendar year using the latest MPCA application forms. The report shall include information for any new or replaced Subject Items. The report shall document the VOC 12-month rolling average calculations for the previous calendar year. The report shall be submitted with the annual Compliance Certification required by this permit. As part of the Annual Report, the Permittee shall verify and certify that the Facility has maintained minor source status for New Source Review. [Minn. R , subp. 2] The Permittee shall submit a compliance certification : Due annually, by the 31st of January (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 , subp. 6(C)] 7. A ppendices Appendix A. Insignificant Activities and General Applicable Requirements The table below lists the insignificant activities that are currently at the Facility and their associated general applicable requirements. Minn. R. Rule description of the activity General applicable requirement Minn. R , subp. 3(1) Individual units with potential emissions Minn. R less than 2000 lb/year of certain pollutants. Minn. R , subp. 3(1) MDP has hot wire cutting operations and EPS grinding, milling, and cutting operations that qualify under this subpart. Individual units with potential emissions Minn. R less than 2000 lb/year of certain pollutants. MDP has 22 space heaters at 0.3 MMBtu/hr and one make-up air unit at MMBtu/hr that qualify under this subpart.

16 Permit Issued: January 26, 2016 Permit Expires: January 26, Page 14 of 14 Appendix B. Equipment Capacity and Maximum Contents of Materials The maximum capacity of each process unit is given in the table below as well as the maximum VOC content of the raw material. Emission Unit (EQUI) Maximum Capacity Maximum VOC Content* EQUI lb bead/hour 7.10 wt% EQUI lb bead/hour 7.10 wt% EQUI5 10 gallons/hour 0.0 lb/gallon EQUI6 252 lb bead/hour 7.10 wt% EQUI7 350 lb bead/hour 7.10 wt% "includes all VOC (pentane, styrene, etc.)

17 TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR 70.7(a)(5) and Minn. R , subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the permit. 1. General Information 1.1 Applicant and Stationary Source Location Table 1. Applicant and Source Address Stationary Source/Address Applicant/Address (SIC Code: 3086) Minnesota Diversified Products 9091 County Road 50 Rockford, Minnesota Contact: Steve Slavik Phone: Minnesota Diversified Products Inc. -West 6901 West Rd Rockford Wright County, Minnesota Facility Description Minnesota Diversified Products West is an existing facility that manufactures expanded polystyrene boardstock, primarily used in building materials and insulation. The boardstock is made through the use of expanded polystyrene beads molded into the desired shapes. The first step in the process is the preexpansion of the beads, which are similar in appearance to white sugar. Steam is mixed with the beads, releasing the blowing agent, pentane, which causes the beads to expand in size. Beads are typically stored in mesh bags for 8 to 48 hours after expansion, allowing time to stabilize. Beads are then transferred to the molding area, where blocks are formed, cured, and then conveyed to hot wire cutters where they are cut to size. Additionally, some final products are laminated with thin plastic sheeting. The main pollutant of concern for this facility is pentane, a Volatile Organic Compound (VOC). Additionally, small amounts of free styrene (both a hazardous air pollutant and a VOC) are emitted from the raw beads throughout the process. Combustion products are also emitted from a natural gas fired boiler. The facility has activities that are considered insignificant under Minnesota Rules. A complete list of these insignificant activities is available in Appendix A. In previous permit actions, the facility has taken limits on the emissions of VOC to avoid major source classification for New Source Review (40 CFR pt ). The facility is a major source under federal operation permits program (40 CFR pt. 70) and is an area source under the National Emissions Standards for Hazardous Air Pollutants (NESHAPs, 40 CFR pt. 63). 1.3 Description of the Activities Allowed by this Permit Action This permit action is Part 70 Permit Reissuance. Technical Support Document, Permit Number: Page 1 of 8

18 1.4 Description of Notifications and Applications Included in this Action Ta ble 2. Notifications and Applications Included in this Action Date Received Application/Notification Type and description 06/03/2015 Part 70 Permit Reissuance 1.5 Facility Emissions Total Facility Limited Potential Emissions Total Facility Actual Emissions (2013) Table 3. Total Facility Potential to Emit Summary Single All PM PM 10 PM 2.5 so 2 NO, CO C0 2e VOC HAP HAPs tpy tpy tpy tpy tpy tpy tpy tpy tpy tpy , * 70.2 * *Not reported in Minnesota emission inventory. Table 4. Facility Classification Classification Major Synthetic Minor/Area Minor/Area New Source Review X Part 70 X Part 63 X 1.6 Changes to Permit The permit does not authorize any specific modifications, however, the MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R , the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action: The permit has been updated to reflect current MPCA templates and standard citation formatting. Construction authorization and requirements for EQUI3 and EQUI8 have been removed, as the facility currently has no plans to construct this equipment in the lifespan of this permit. The total facility limit on VOC has been reduced to 225 tons/year to reflect updated MPCA policy. EQUI7 data has been updated based on the equipment that was actually installed. Some requirements have been reordered to help with clarity (i.e., similar requirements are grouped). 2. Regulatory and/or Statutory Basis 2.1 New Source Review (NSR) The permit carries forward limits on the facility such that it is a minor source under New Source Review regulations. No changes are authorized by this permit. 2.2 Part 70 Permit Program The facility is a major source under the Part 70 permit program. Technical Support Document, Permit Number: Page 2 of 8

19 2.3 New Source Performance Standards (NSPS) The Permittee has stated that no New Source Performance Standards apply to the operations at this facility. 2.4 National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility has accepted limits on VOC emissions such that it limits hazardous air pollutants (HAPs) and is an area source under 40 CFR pt. 63. Thus, no major source NESHAPs apply. In addition, the Permittee has stated that no area source NESHAPs apply to the facility. 2.5, Minnesota State Rules Portions of the facility are subject to the following Minnesota Standards of Performance: Minn. R Standards of Performance for New Indirect Heating Equipment Minn. R Standards of Performance for Post-1969 Industrial Process Equipment Table 5. Regulatory Overview of Facility Subject Item* Applicable Regulations Rationale COMG2- Air Component Group COMG2 - Air Component Group EQUI1 - Boiler Minn. R Title 1 Condition: Avoid major source under 40 CFR pt. 52 and 40 CFR pt. 63 Minn. R Standards of Performance for Post 1969 Industrial Process Equipment. This applies to all units in COMG2, individually. Prevention of Significant Deterioration (PSD) and NESHAPS. Limits taken to avoid major source and modification classification under PSD for all noncombustion emissions of VOC. This VOC limit also results in the facility remaining an area source of HAPs. It is a rolling limit due to substantial and unpredictable variations in operation. This limit is carried forward from the previous permit. Standards of Performance for New Indirect Heating Equipment. Fuel is limited to natural gas and propane only. State indirect heating standard with fuel type restricted to natural gas or propane. Additional Information: all units constructed after 1977 facility is located outside of the Minneapolis-St. Paul Air Quality Control Region each unit capacity is less than 250 MMEStu/hr.; and the facility has less than 250 MMBtu/hr. of indirect heating equipment. ""Location of the requirement in the permit (e.g., EQUI, STRU, COMG, etc.). 3. Technical Information 3.1 Synthetic Minor Limit for PSD As in previous Minnesota Diversified Products West permits, the permittee maintains a VOC limit to avoid classification as a major source for NSR/PSD. EPA guidance recommends that there is a 10% buffer between the PSD limit of 250 tons per year and the allowable limit taken by a Permittee. This margin is necessary to account for the accuracy of the proposed compliance method and any emissions that may be left out of the on-going compliance tracking, like insignificant activities. To comply with this guidance Technical Support Document, Permit Number: Page 3 of 8

20 and common MPCA practice, the limit on the facility is being reduced from 240 tons per year in previous permits to 225 tons per year. 3.2 Calculations of Potential to Emit (PTE) Attachment 1 to this TSD contains Form GI-07, which summarizes the PTE of the Facility, while Attachment 3 contains detailed spreadsheets and supporting information prepared by the MPCA and the Permittee. EPS Bead Processes These processes consist of the pre-expander, molders, and storage. Based on EPA 450/ , Control of VOC Emissions from Polystyrene Foam Manufacturing, the majority (85%) of the VOC emissions from the beads take place during the pre-expansion and molding. It is unknown how long it takes the remaining 15% of VOC to be released during storage. As there is no time limit on how long the Permittee can store the finished product, it is assumed that all of the remaining VOC is released within the facility. The calculations assume 50% of VOC is released in pre-expansion and 50% is released in molding, which gives more conservative calculations than EPA 450/ Additionally, there is free styrene present in small amounts within the bead, and it is assumed that all of this free styrene is emitted within the facility. While the Permittee has provided test results that indicate only 31% of the styrene is emitted onsite, this test data is from 1999, making it fifteen years old. Per Minn. R subp. D, if an emission factor is taken from a performance test that is over ten years old, it should not be used in calculations unless it results in a higher emission rate than the default emission factor. In this case, the default emission factor is 100% of the styrene is emitted, so this 31% was not used in the PTE calculations as it would result in a lower PTE. However, due to the Permittee taking limits to be a synthetic minor source for NSR, there is no change in applicable requirements for not using this emission factor. Laminator The Permittee has changed the type of adhesive used in this piece of equipment, with the new adhesive containing no VOCs. However, as there is still the ability for the Permittee to use alternative adhesives that contain VOC, the laminator will remain in the permit to continue the recordkeeping requirements for the equipment. PTE calculations are based on a mass-balance, assuming that 100% of the VOC in the adhesive is emitted. Boiler The PTE calculations are based on EPA approval emission factors in AP-42, the fuels burned, and the boiler capacity. 3.3 Permitting Calculations Section 3.4 of this TSD explains the various monitoring required by the permit. For the VOC limit, this includes calculating actual emissions on a monthly basis. Calculation of VOC emissions Total VOC emissions must each be calculated monthly by using the following equation: MER = (A1 x Bl) + (A2 x B2) + (A3 x B3) + Where: Technical Support Document, Permit Number: Page 4 of 8

21 MER = the monthly VOC emissions rate, in pounds/month A# = the amount of each VOC-containing material used in the previous month (e.g., EPS bead, adhesive, etc.), in pounds. B# = the weight of VOC in A#, as a fraction. For example, if a material were 50% by weight VOC, this would be Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considered the following: the likelihood of the facility violating the applicable requirements; whether add-on controls are necessary to meet the emission limits; the variability of emissions over time; the type of monitoring, process, maintenance, or control equipment data already available for the emission unit; the technical and economic feasibility of possible periodic monitoring methods; and the kind of monitoring found on similar units elsewhere. Table 6 summarizes the monitoring requirements. Subject Item* Table 6. Monitoring Requirement (basis) Monitoring Discussion Volatile Organic Compounds < 225 tons per year 12- month rolling sum (Limit to avoid major source under NSR) Recordkeeping: Daily records of EPS beads; Ongoing MSDS records of coating content; Monthly calculations of emissions. Records can be generated on a daily basis for EPS bead processes using written production records and meter readings. The remaining materials (adhesives) are low volume and will be based on monthly usage records. PM: variable, depending on air flow. None. None of these processes are reasonably expected to generate any particulate matter. It is highly unlikely that they could violate the applicable requirement. COMG2 Opacity: < 20%. [Minn. R ] Technical Support Document, Permit Number: Page 5 of 8

22 Subject Item* EQUI1 Requirement (basis) Monitoring Discussion PM: < 0.4 lb/ MMBtu Opacity: < 20%. [Minn. R ] Recordkeeping: Monthly fuel records. * Location o : the requirement in the permit (e.g., EQUI, STRU, COMG, etc.). This boiler only burns natural gas or propane, and is therefore unlikely to violate either of these emission limits. The Permittee can continue to demonstrate that the unit will continue to operate such that emissions are well below the emission limits by burning only natural gas or propane. Potential emissions from the boiler based on equipment design and allowable fuels are Ib/MMBtu compared to the rule limit of 0.4 Ib/MMBtu. 3.5 Insignificant Activities Minnesota Diversified Products Inc. -West has several operations which are classified as insignificant activities under the MPCA's permitting rules. These are listed in Appendix A to the permit. The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities. See Attachment 3 of this TSD for PTE information for the insignificant activities. Insignificant Activity Individual units with potential emissions less than 2000 lb/year of certain pollutants Table 7. Insignificant Activities General Applicable Emission limit PM: variable, depending on air flow. Opacity: < 20%. [Minn. R ] Discussion Based on potential emissions for these units, it is unlikely that they could violate the applicable requirement. In addition, these units are operated and vented inside a building, so testing for PM or opacity would not be feasible. 3.6 Permit Organization In general, the permit meets the MPCA Tempo Guidance for ordering and grouping of requirements. One 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. 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). This is the case for the requirements at COMG Comments Received Public Notice Period: December 4, January 4, 2016 EPA Review Period: December 4, January 19, 2016 Comments were not received during the public comment period or from EPA review; no changes were made to the draft/proposed permit. 4. Permit Fee Assessment Technical Support Document, Permit Number: Page 6 of 8

23 This permit action is the reissuance of an individual Part 70; therefore, no application fees apply under Minn. R , subp Conclusion Based on the information provided by Minnesota Diversified Products Inc. -West the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Jenna Vanderbosch (permit engineer) Janice Noggle (compliance) Lad Strzok (compliance) Peggy Bartz (peer reviewer) Beckie Olson (permit writing assistant) Laurie O'Brien (administrative support) TEMP0360 Activities: Part 70 Permit Reissuance Attachments: 1. PTE Summary Spreadsheets 2. Subject Item Inventory and Facility Requirements 3. Permittee's Calculations Technical Support Document, Permit Number: Page 7 of 8

24 Minnesota Diversified Products Inc. - West Air Emission Permit No TSD Attachment 1 - PTE Summary Spreadsheets

25 la) AQ Facility ID No.: ) Facility Name: Minnesota Diversified Products, Inc. - West lb) Agency Interest ID No.: 2273B 3a) Delta ID No.: EU 001 3a) Delta ID No.: EU 002 3b) Tempo SI ID No.: EQUI 1 3b) Tempo SI ID No.: EQUI 2 3c) 3d) 3e) Potential 3f) 3c) 3d) 3e) Potential 3f) Pollutant Lbs Unc Lim Actual Pollutant Lbs Unc Lim Actual Name CAS# per Hr tpy tpy tpy Name CAS # per Hr tpy tpy tpy PM PM - - PM PM10 - PM PM2.5 - S S02 NOx NOx VOC VOC see GP 001 CO CO - Pb 4.17E E E-05 Pb - - C02-1,178 5,160 5,160 - C02 - CH CH4 N N20 - C02e NA 5,181 5,181 C02e - - Total HAPs E E E-02 Total HAPs Arsenic E E E-06 Arsenic Benzene E E E-05 Benzene Beryllium E E E-07 - Beryllium Cadmium E E E-05 - Cadmium Chromium E E E-05 Chromium Cobalt E E E-06 Cobalt DIchlorobenzene E E E-05 DIchlorobenzene Formaldehyde E E E-03 - Formaldehyde Hexane E E E-02 - Hexane Manganese E E E-05 - Manganese Mercury E E E-06 Mercury Naphthalene E E E-05 Naphthalene Nickel E E E-05 - Nickel POM E E E-06 POM Selenium E E E-07 - Selenium Toluene E E E-04 - Toluene Styrene Styrene Substitute for Form aq-fi-gi07 with revision date 12/1/14 H:\Minnesota Diversified Products Reissue\Corrected Calculations MDP West Reissuance 2015_ xisx

26 ! la) AQ Facility ID No.: ) Facility Name: Minnesota Diversified Products, Inc. - West lb) Agency Interest ID No.: 2273B 3a) Delta ID No.: EU 004 3a) Delta ID No.: EU 006 3b) Tempo SI ID No.: EQUI 4 3b) Tempo SI ID No.: EQUI 5 3c) 3d) 3e) Potential 3f) 3c) 3d) 3e) Potential 3f) CAS# Pollutant Lbs Unc Lim Actual Pollutant Lbs Unc Lim Actual per Hr >Name tpy tpy Name CAS U per Hr tpy tpy tpy. Q PM PM - - PM PM PM PM S S NOx NOx VOC seegpool VOC seegpool - CO - - CO Pb - - Pb - C C CH CH4 - N N C02e C02e - Total HAPs Total HAPs - Arsenic Arsenic Benzene Benzene Beryllium Beryllium Cadmium Cadmium Chromium Chromium Cobalt Cobalt Dichlorobenzene Dichlorobenzene Formaldehyde Formaldehyde Hexane Hexane Manganese Manganese Mercury Mercury Naphthalene Naphthalene Nickel Nickel POM - - POM - - Selenium Selenium Toluene Toluene Styrene Styrene " - Substitute for Form aq-f1-gi07 with revision date 12/1/14 H:\Minnesota Diversified Products Reissue\Corrected Calculations MDP West Reissuance 2015_ xlsx

27 la) AQ Facility ID No.: ) Facility Name: Minnesota Diversified Products, Inc. - West lb) Agency Interest ID No.: 2273B 3a) Delta ID No.; EU 007 3a) Delta ID No.: EU 008 3b) Tempo SI ID No.: EQUI 6 3b) Tempo SI ID No.: EQUI 7 3c) 3d) 3e) Potential 3f) 3c) 3d) 3e) Potential 3f) Pollutant Lbs Unc Urn Actual Pollutant Lbs Unc Lim Actual Name CAS # per Hr tpy tpy tpy Name CAS # per Hr tpy tpy tpy PM PM - - PM PM PM2.5 PM S02 S02 - NOx - NOx - - VOC see GP VOC see GP CO CO - Pb Pb - C02 C CH4 N N20 C02e C02e - - Total HAPs - - Total HAPs - Arsenic Arsenic Benzene Benzene Beryllium Beryllium Cadmium Cadmium Chromium Chromium Cobalt Cobalt Dichlorobenzene Dichlorobenzene Formaldehyde Formaldehyde Hexane Hexane Manganese Manganese Mercury Mercury Naphthalene Naphthalene Nickel Nickel POM - - POM - Selenium Selenium Toluene Toluene Styrene Styrene CH4 Substitute for Form aq-f1-gi07 with revision date 12/1/14 H:\Minnesota Diversified Products Reissue\Corrected Calculations MDP West Reissuance 2015_ xlsx

28 la) AQ Facility ID No.: ) Facility Name: Minnesota Diversified Products, Inc. - West lb) Agency Interest ID No.: 2273B 3a) Delta ID No.: GP 001 3a) Delta 1D No.: IA Hot Wire Cutters 3b) Tempo SI ID No.: COMG 2 3b) Tempo SI ID No.: ACTV 3 3c) 3d) 3e) Potential 3f) 3c) 3d) 3e) Potential 3f> Pollutant Lbs Unc Lim Actual Pollutant Lbs Unc Lim Actual Name CAS # per Hr tpy tpy tpy Name CAS # per Hr tpy tpy tpy PM - - PM PM PM PM PM S NOx NOx VOC , VOC CO CO Pb Pb C C CH4 - - CH N20 - N C02e C02e NA Total HAPs Total HAPs 0.00E E+00 O.OOE+OO Arsenic Arsenic Benzene Benzene Beryllium Beryllium Cadmium Cadmium Chromium Chromium Cobalt Cobalt Dichlorobenzene Dichlorobenzene Formaldehyde Formaldehyde Hexane Hexane Manganese Manganese Mercury Mercury Naphthalene Naphthalene Nickel Nickel POM - - POM - Selenium Selenium Toluene Toluene Styrene E E E+00 - Styrene Substitute for Form aq-f1-gi07 with revision date 12/1/14 H:\Minnesota Diversified Products Reissue\Corrected Calculations MDP West Reissuance 2015_ xlsx

29 la) AQ Facility ID No.: ) Facility Name: Minnesota Diversified Products, Inc. - West lb) Agency Interest ID No.: 2273B 3a) Delta ID No.: IA Space Heaters (Total for 22) 3a) Delta ID No.: IA Makeup Air Unit 3b) Tempo SI ID No.: ACTV 3 3b) Tempo SI ID No.: ACTV 3 3c) 3d) 3e) Potential 3f) 3c) 3d) 3e) Potential 3f) Pollutant Lbs Uric Lim Actual Pollutant Lbs Unc Lim Actual Name CAS # per Hr tpy tpy tpy Name CAS # per Hr tpy tpy tpy PM PM PM PM PM PM S E E E-02 - S E E E-03 NOx NOx VOC 3.56E E E-01 VOC CO CO Pb 3.24E E E-05 - Pb 7.20E E E-06 C , , C CH4-1.46E E E-02 CH4 3.24E E E-02 N E E E-03 N E E E-03 C02e - NA 3, , C02e NA Total HAPs E E E-02 - Total HAPs 2.72E E E-02 - Arsenic E E E-06 Arsenic E E E-06 Benzene E E E-05 Benzene E E E-05 Beryllium E E E-07 - Beryllium E E E-08 - Cadmium E E E-05 - Cadmium E E E-06 - Chromium E E E-05 Chromium E E E-06 Cobalt E E E-06 - Cobalt E E E-07 Dlchlorobenzene E E E-05 - Oichlorobenzene E E E-06 - Formaldehyde E E E-03 - Formaldehyde E E E-04 Hexane E E E-02 Hexane E E E-02 - Manganese E E E-05 - Manganese E E E-06 - Mercury E E E-06 - Mercury E E E-06 Naphthalene E E E-05 Naphthalene E E E-06 - Nickel E E E-05 - Nickel E E E-05 - POM 5.71E E E-06 POM E E E-07 - Selenium E E E-07 - Selenium E E E-07 - Toluene E E E-05 Toluene E E E-05 - Styrene Styrene Substitute for Form aq-f1-gi07 with revision date 12/1/14 H:\Minnesota Diversified Products ReissueVCorrected Calculations MDP West Reissuance 2015_ xlsx

30 Minnesota Diversified Products, Inc. - West Minnesota Diversified Products, Inc. - Wes a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year PM Pb 1.83E E-05-4a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year PM C02 5,160 5,160-4a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year PM CH a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year S N a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year NOx C02e a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year voc Total HAPs a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year CO Arsenic 1.42E E-05 - Substitute for Form aq-f1-gi07 with revision date 12/1/14 H:\Minnesota Diversified Products Reissue\Corrected Calculations MDP West Reissuance 2015_ xlsx

31 Minnesota Diversified Products, Inc. - West Minnesota Diversified Products, Inc. - West a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year Benzene 1.49E E-04 - Hexane 1.28E E-01-4a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year Beryllium 8.54E E-07 - Manganese 2.70E E-05-4a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year Cadmium 7.83E E-05 - Mercury 1.85E E-05-4a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year Chromium 9.96E E-05 - Naphthalene 4.34E E-05-4a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year Cobalt 5.98E E-06 - Nickel 1.49E E-04-4a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year Dichlorobenzene 8.54E E-05 - POM 6.28E E-06-4a) 4b) Potential (tpy) 4c) Actual 4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Pollutant Name Unrestricted Limited tons/year Formaldehyde 5.34E E-03 - Selenium 1.71E E-06 - Substitute for Form aq-f1-gi07 with revision date 12/1/14 HAMinnesota Diversified Products Reissue\Corrected Calculations MDP West Reissuance 2015_ xlsx

32 Minnesota Diversified Products, Inc. - West a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Toluene 2.42E E-04-4a) 4b) Potential (tpy) 4c) Actual Pollutant Name Unrestricted Limited tons/year Styrene Substitute for Form aq-f1-gi07 with revision date 12/1/14 H:\Minnesota Diversified Products Reissue\Corrected Calculations MDP West Reissuance xlsx

33 Minnesota Diversified Products Inc. - West Air Emission Permit No TSD Attachment 2 - Subject Item Inventory and Facility Requirements

34 Subject Item Inventory AQ Facility ID: Facility Name: Minnesota Diversified Products Inc - West Category Type ID Designation Description Groups Activity Insignificant Air Emissions Activity ACTV3 All ia's None Equipment Adhesion Equipment EQUI 5 EU006 Laminator - A dhesion Equipment COMG 2 Equipment Boiler EQUI 1 EU001 Boiler 1 - Boiler None Equipment Mixing Equipment EQUI 2 EU002 Pre-Expander - Mixing Equipment COMG 2 Equipment Molding Equipment EQUI 4 EU004 Molder Molding Equipment COMG 2 Equipment Pressing Equipment EQUI 6 EU007 Mold Press - Pressing Equipment COMG 2 Equipment Pressing Equipment EQUI 7 EU008 Mold Press - Pressing Equipment COMG 2 Structure Building STRU 2 BG001 West Plant Production Line None Structure Stack/Vent STRU 1 SV006 Stack/Vent for Mold Press EQUI7 None Structure Stack/Vent STRU 3 SVOOl Stack/Vent for Boiler EQUI1 None Structure Stack/Vent STRU 4 SV002 Building Ventilation None Structure Stack/Vent STRU S SV003 Stack/Vent for Pre-Expander EQUI2 None Structure Stack/Vent STRU 6 SV004 Stack/Vent for Molder EQUI4 None Structure Stack/Vent STRU 8 SV005 Stack/Vent for Mold Press EQUI6 None Total Facility Air Quality Total Facility TFAC Minnesota Diversified Products Inc -West None Category Type ID Designation Description Components EQUI 2, EQUI 4, EQUI 5, Component Group Air Component Group COMG 2 GP001 Total Facility VOC Limit EQUI 6, EQUI 7

35 Facility Name: Permit Number: Facility Requirements Minnesota Diversified Products Inc - West Subject Item: Total Facility Sequence # Type Description Citation PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. 1 Text [Minn. R , (A)(2)] [Minn. R , (A)(2)] 2 Text 3 Text 4 Text 5 Text 6 Text 7 Text 8 Text [Title 1 Condition: Avoid major This permit establishes limits on the facility to keep it a minor source under New modification under 40 CFR Source Review. The Permittee cannot make any change at the source that would 52.21(b)(2) and Minn. R. make the source a major source under New Source Review until a permit , Title I Condition: amendment has been issued. This includes changes that might otherwise qualify as Avoid major source under 40 CFR insignificant modifications and minor or moderate amendments. (Title 1 Condition: 52.21(b)(l)(i) and Minn. R. Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title , Title 1 Cond ition: Condition: Avoid major source under 40 CFR 52.21(b)(l)(i) and Minn. R , Avoid major source classification Title 1 Condition: Avoid major source classification under 40 CFR 63.2] under 40 CFR 63.2] Equipment Inventory: The Permittee shall maintain a written list of all emissions units and control equipment on site. The Permittee shall update the list to include any replaced, modified, or new equipment prior to making the change. The list shall correlate the units to the Subject Item numbers used in this permit and shall include the data on GI-04, GI-05B, and GI-05C. The date of construction shall be the date the change was made for replaced, modified, or new equipment. [Minn. R , subp. 2] [Minn. R , subp. 2] Equipment Labeling: The Permittee shall permanently affix a unique number to each emissions unit for tracking purposes. The numbers shall correlate the unit to the appropriate Subject Item numbers used in this permit. The number can be affixed by placard, stencil, or other means. The number shall be maintained so that it is readable and visible at all times from a safe distance, If equipment is added, it shall be given a new unique number; numbers from replaced or removed equipment shall not be reused. [Minn. R , subp. 2] [Minn. R , subp. 2] Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendices A and B. [Minn. R , subp. 2] [Minn. R , subp. 2] The Permittee shall comply with National Primary and Secondary Ambient Air Quality [Minn. R , subp. 7(A), Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7(L), & 7(M), Minn. R , to Compliance shall be demonstrated upon written request by subp. 4, Minn. R , the MPCA. [Minn. R , subp. 7(A), 7(L), & 7{M), Minn. R , subp. subps. 1-2, Minn. Stat , 4, Minn. R , subps. 1-2, Minn. Stat , subd. 4a, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] subd. 9] Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. [Minn. R ] [Minn. R ] Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R. [Minn. R , subp. 16(J), , subp. 16(J), Minn. R , subp. 2] Minn. R , subp. 2]