DRAFT. AIR EMISSION PERMIT NO Major Amendment IS ISSUED TO. Pan O Gold Baking Co

Transcription

1 DRAFT AIR EMISSION PERMIT NO Major Amendment IS ISSUED TO Pan O Gold Baking Co Pan O Gold Baking Co 444 St. Germain Street East St. Cloud, Sherburne County, MN The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the Permit Applications Table. This permit amendment supersedes Air Emission Permit No and authorizes the Permittee to the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Permit Type: State; Limits to Avoid Pt 70/Limits to Avoid NSR Operating Permit Issue Date: September 24, 2008 Major Amendment Issue Date: Expiration Date: Permit does not expire Title I Conditions do not expire. Don A. Smith, Manager Air Quality Permits Section Industrial Division for John Linc Stine Commissioner Minnesota Pollution Control Agency Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit 3/27/ Major Amendment (Reopening) 1/27/ TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

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3 TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements Table B: Submittals Table C: Compliance Schedule Not used in this permit Appendix: Insignificant Activities and General Applicable Requirements

4 NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area (651) Outside Metro Area TTY (651) The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

5 FACILITY DESCRIPTION: Pan O Gold Baking Company is a bakery facility that manufactures bread, buns, and other bakery products. Wheat and white flour are received at the facility and transferred to the mixing operations. Primary emissions at the facility are volatile organic compounds (VOC), which result from the fermentation of sugars while dough is rising. Existing facility consists of three baking lines with natural gas burners. VOC emissions from the facility are controlled using a Catalytic Oxidizer. Other emissions are from combustion of natural gas (primary fuel) in the baking ovens, air makeup units, and boilers. AMENDMENT DESCRIPTION: PER 002 (Major Amendment): This permit action is a mandatory reopening under Minn. R , subp. 1(D). No construction is being authorized. On November 18, 2010, a performance test for VOC control efficiency was conducted while operating at a rate of 19,770 pounds per hour of baked goods produced with the catalytic oxidizer (CE 001) operating with an inlet temperature of 614 degrees Fahrenheit. The compliant result was 98.6%. The minimum temperature inlet for the catalytic oxidizer, which is a Title I Condition, was incorporated with this permit action; therefore, it is a major amendment under Minn. R , subp. 1(C). Also, recurring stack testing for VOC control efficiency was added under GP 001. Worst case testing conditions and EPA Reference Methods required were added to the requirement.

6 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Pan-O-Gold Baking Co Permit Number: A-1 Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do SOURCE-SPECIFIC REQUIREMENTS Permit Appendix: This permit contains an appendix as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendix. The facility currently uses ozone-depleting substances as defined in 40 CFR pt. 82. Sections of the 1990 Clean Air Act Amendments and 40 CFR pt. 82 may apply to your facility. Read Sections and 40 CFR pt. 82 to determine all the requirements that apply to your facility. OPERATIONAL REQUIREMENTS 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. Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. PERFORMANCE TESTING Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C. hdr Why to do it Minn. R , subp CFR pt. 82 hdr 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 Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R , subps. 14 and 16(J) Minn. R , subp. 4 Minn. R Minn. R Minn. R , subp. 9(A) Minn. R , subp. 16 hdr Minn. R. ch. 7017

7 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Pan-O-Gold Baking Co Permit Number: A-2 Performance Test Notifications and Submittals: Performance Tests are due as outlined in Table A of the permit. See Table B for additional testing requirements. Minn. R ; Minn. R , subps. 1-4, Minn. R , subps. 1-2 Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R , subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. MONITORING REQUIREMENTS Monitoring Equipment Calibration - The Permittee shall either: Minn. R , subp. 3 hdr Minn. R , subp. 4(D) 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. RECORDKEEPING Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R , subp. 2), including records of the emissions resulting from those changes. If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R For nonexpiring permits, these records shall be kept for a period of five years from the date that the change was made. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. REPORTING/SUBMITTALS Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Minn. R , subp. 4(D) hdr Minn. R , subp. 5(C) Minn. R , subp. 5(B) Minn. R , subp. 4 hdr Minn. R , subp. 3

8 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Pan-O-Gold Baking Co Permit Number: A-3 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. Minn. R , subp. 2 At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment: As soon Minn. R , subp. 1 as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Minn. R , subp. 1 Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Application for Permit Amendment: If a permit amendment is needed, submit an Minn. R application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Extension Requests: The Permittee may apply for an Administrative Amendment to Minn. R , subp. 1(H) extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R , subp. 1(H). Emission Inventory Report: due on or before April 1 of each calendar year following Minn. R permit issuance, to be submitted on a form approved by the Commissioner. Emission Fees: due 30 days after receipt of an MPCA bill. Minn. R

9 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: Pan-O-Gold Baking Co Subject Item: GP 001 Baking Lines and Direct Heating Equipment A-4 Associated Items: CE 001 Catalytic Oxidizer EU 001 Bread Oven 1 - Dryer/Oven, unknown firing method EU 003 Bun Oven 2 - Dryer/Oven, unknown firing method EU 005 Bread and Bun Oven 3 - Dryer/Oven, unknown firing method EU 011 Control Equipment - Other Combustion SV 007 Stack for CE 001 What to do Volatile Organic Compounds: less than or equal to 48.0 tons/year using Other Method - based on a 13-accounting (4 week) period rolling sum as described later in this permit. Limit of 48.0 tons applies only if using the Adjustment Factor of 1.6 or the Limit of 34.0 tons per year without the 1.6 factor. Limit to be calculated using overall control efficiency (capture and control) of VOC emissions from all three baking ovens at the facility. The Permittee shall vent all vents from the baking lines to control equipment meeting the requirements of CE 001 at all times the baking lines are in operation. Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R This limit applies to each emission unit individually in GP 001. Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. This limit applies to each emission unit individually in GP 001. Fuel Type: Natural Gas only, by design. Performance Test: due before end of each calendar 60 months starting 11/18/2010 to measure VOC emissions overall control efficiency from all three baking ovens at the facility. Testing conducted during the two months prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required by: 1) this permit, 2) by the most recently approved Performance Test Frequency Plan, or 3) if specified within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date does not satisfy this test due date requirement and will be considered an additional test. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Methods 1-4 and Modified EPA Method 25/Modified EPA Method 18, or other method approved by MPCA in the performance test plan approval. The Permittee shall operate all three ovens during the performance test. CONTROL EQUIPMENT REQUIREMENTS - SEE CE 001 Performance Test Notifications and Submittals; 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 day before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy or CD: due 105 day after each Performance Test. The Notification, Test Plan, and Test Report may be submitted in alternate format as allowed by Minn. R The Permittee shall maintain daily records or production logs of the amount of bread/buns baked and the type of bread/buns baked. Why to do it Section & Minn. R ; To avoid major source classification under 40 CFR Section 70.2 and Minn. R Title I Condition: CAAA of 1990; To avoid major source classification under 40 CFR Section and Minn. R ; to avoid major source classification under 40 CFR Section 70.2 and Minn. R Minn. R , subp. 1(A)(1) Minn. R , subp. 1(A)(2) Minn. R , subp. 35a Minn. R , subp. 1 Minn. R , subp. 1-4; Minn. R and Minn. R , subp. 1-2 Title I Condition: CAAA of 1990; To avoid major source classification under 40 CFR Section and Minn. R ; to avoid major source classification under 40 CFR Section 70.2 and Minn. R

10 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Pan-O-Gold Baking Co Permit Number: A-5 Accounting Period Recordkeeping -- VOC Emissions: By the 15th day of each accounting period, the Permittee shall calculate and record the following: 1. The total VOC emissions for the previous accounting period using daily records (or production logs) of VOC containing materials processed at the facility (each product type and amount of bread/buns baked), applying overall control efficiency of the control equipment, and the AP-42 equation shown below. 2. The 13-accounting period rolling sum VOC emissions for the previous 13 accounting periods by summing the 4-week VOC emissions data for the previous periods. Definition of Accounting Period: The VOC emission limit is based on 13 accounting periods in a calendar year. The starting and ending dates of each accounting period (4 weeks) shall be included in the Annual Report that is due January 30th of each year. VOC Emission Calculation: VOC Emissions in pounds = EF * tons of bread baked * (100 - Percent Efficiency) VOC Emissions in tons = VOC Emissions in pounds * 1/2000 Section & Minn. R ; To avoid major source classification under 40 CFR Section 70.2 and Minn. R Section & Minn. R ; To avoid major source classification under 40 CFR Section 70.2 and Minn. R ; Minn. R subp. 4-5 EF = Maximum VOC emission factor, pounds VOC/ton bread baked Using equation specified in AP-42, shown below VOC EF = (0.95Yi+0.195ti-0.51S-0.86ts+1.90) Yi = initial baker's percent of yeast ti = total yeast action time in hours S = final (spike) baker's percent of yeast ts = spiking time in hours Adjustment factor = 1.6 (only if applicable) Percent Efficiency = Catalytic Oxidizer Overall Control efficiency, based on capture and control from the most recent performance test Recordkeeping: Retain all records at the stationary source 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)

11 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: Pan-O-Gold Baking Co Subject Item: GP 002 Indirect Heating Equipment A-6 Associated Items: EU 002 Bread Oven 1 Burner - Dryer/Oven, direct fired EU 004 Bun Oven 2 Burner - Dryer/Oven, direct fired EU 006 Bread and Bun Oven 3 Burner - Dryer/Oven, direct fired EU 007 Boiler # 1 - Boiler EU 008 Boiler # 2 - Boiler EU 009 Existing Air Makeup Units - Other Combustion EU 010 New Air Makeup Units - Other Combustion What to do Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input. Design based PTE for each unit, using AP-42, is compared to the rule limit of 0.4 lb/mmbtu. This limit applies to each emission unit individually in GP 002. Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. This limit applies to each emission unit individually in GP 002. Fuel Type: Natural Gas only, by design. Why to do it Minn. R , subp. 1 Minn. R , subp. 2 Minn. R , subp. 35a

12 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: Pan-O-Gold Baking Co Subject Item: CE 001 Catalytic Oxidizer A-7 Associated Items: EU 001 Bread Oven 1 - Dryer/Oven, unknown firing method EU 002 Bread Oven 1 Burner - Dryer/Oven, direct fired EU 003 Bun Oven 2 - Dryer/Oven, unknown firing method EU 004 Bun Oven 2 Burner - Dryer/Oven, direct fired EU 005 Bread and Bun Oven 3 - Dryer/Oven, unknown firing method EU 006 Bread and Bun Oven 3 Burner - Dryer/Oven, direct fired EU 011 Control Equipment - Other Combustion GP 001 Baking Lines and Direct Heating Equipment What to do 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 95 percent control efficiency Temperature: greater than or equal to 614 degrees F using 3-hour Rolling Average at the oxidizer inlet as determined during the Initial performance test, unless a new limit 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 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 Performance Testing Requirement is under GP 001. The control equipment is considered listed control equipment under Minn. R to The Permittee shall operate and maintain the catalytic oxidizer at all times that any process equipment controlled by the catalytic oxidizer is operating. The Permittee shall document periods of non-operation of the control equipment. Catalyst Reactivity: The Permittee shall verify the catalyst reactivity per the manufacturer's specifications or every 12-months, and shall maintain a record of the results. The Permittee shall maintain a copy of the manufacturer's specifications/operation and maintenance manual on-site. The Permittee shall send a representative sample of the catalyst to a laboratory to test the catalyst's destruction efficiency. If test results show a destruction efficiency of less than 95%, the Permittee shall follow the corrective actions contained in the Operation and Maintenance Plan. The Permittee shall maintain either a continuous hard copy or electronic readout of the inlet and outlet temperatures and the calculated three-hour rolling average inlet temperature, or maintain a hard copy of manual readings taken at least every 15 minutes. Monitoring Equipment: The Permittee shall install and maintain thermocouples for measuring and recording the temperature as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when operation of the monitored control equipment is required. For periods when the catalytic oxidizer is operated above the minimum inlet temperature, the Permittee shall use 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 (95%); b. If the Permittee chooses to use an alternative control efficiency as allowed in Minn. R , subp. 2, that new alternative control efficiency; or c. 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. Why to do it Section & Minn. R ; to avoid major source classification under 40 CFR Section 70.2 and Minn. R ; Minn. R , subp. 1 Section and Minn. R ; To avoid classification as a major source under 40 CFR Section 70.2 and Minn. R ; Minn. R ; Minn. R , subp. 3 Section and Minn. R ; To avoid classification as a major source under 40 CFR Section 70.2 and Minn. R ; Minn. R , subp. 2(A) Section and Minn. R ; To avoid classification as a major source under 40 CFR Section 70.2 and Minn. R ; Minn. R Section and Minn. R ; To avoid classification as a major source under 40 CFR Section 70.2 and Minn. R ; Minn. R Minn. R , subp. 3 Section and Minn. R ; To avoid classification as a major source under 40 CFR Section 70.2 and Minn. R ; Minn. R , subp. 2

13 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: Pan-O-Gold Baking Co 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). Corrective Actions: If the temperature is below the minimum specified by this permit or if the catalytic 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 catalytic oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. Minn. R , subp. 2 Minn. R , subp. 4, 5, and 14 A-8

14 TABLE B: SUBMITTALS Facility Name: Pan-O-Gold Baking Co Permit Number: Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term. B-1 Send any application for a permit or permit amendment to: Fiscal Services Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Unless another person is identified in the applicable Table, send all other submittals to: AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts to must be certified by a responsible official, defined in Minn. R , subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. Send submittals that are required to be submitted to the U.S. EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Send submittals that are required by the Acid Rain Program to: U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements.

15 TABLE B: RECURRENT SUBMITTALS Facility Name: Pan-O-Gold Baking Co Permit Number: B-2 What to send When to send Portion of Facility Affected Semiannual Deviations Report due 30 days after end of each calendar Total Facility half-year starting 09/24/2008. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations. Compliance Certification due 31 days after end of each calendar year starting 09/24/2008 (for the previous calendar year). The Permittee shall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. Total Facility

16 APPENDIX MATERIAL: Insignificant Activities and General Applicable Requirements Facility Name: Pan O Gold Baking Co. Permit Number: Minn. R , Rule Description of the Activity subp. (2) Equipment venting PM/PM 10 inside a building, provided that emissions from the equipment are filtered through an air cleaning system and vented inside of the building 100% of the time. Flour unloading operations and silos General Applicable Requirement Minn. R (PM and opacity)