DRAFT. AIR EMISSION PERMIT NO Total Facility Operating Permit IS ISSUED TO. Magnetation LLC

Transcription

1 DRAFT AIR EMISSION PERMIT NO Total Facility Operating Permit IS ISSUED TO Magnetation LLC MAGNETATION LLC PLANT County Road 10 Bovey, Itasca County, Minnesota The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the Permit Applications Table. This permit authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Permit Type: Federal Permit; Part 70/True Minor for NSR; Operating Permit Issue Date: <issue date> Expiration Date: <expiration date> All Title I Conditions do not expire. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for John Linc Stine Commissioner Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

2 Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit June 23, TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Table C: Compliance Schedule Appendices Appendix A: Operator s Summary Not used in this permit Appendix B: Insignificant Activities Appendix C: Fugitive Dust Control Plan

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

4 FACILITY DESCRIPTION: Magnetation LLC Plant 2 conducts scram mining operations, as defined in Minn. R , subp. 16, at existing tailing basins and operates a processing facility to produce iron ore concentrate from the recovered tailing material. The facility operates under a Scram Permit to Mine issued by the Minnesota Department of Natural Resources (DNR) and a State Disposal System Permit issued by the Minnesota Pollution Control Agency (MPCA). Air emissions from the scram mining operation can be characterized as fugitive emissions from the excavation and truck haul of ponded fine tailings special concentrate material and the truck haul of reprocessed iron oxide concentrate. There are also process fugitive emission from material handling operations involving tailing material and concentrate. There are no capture hoods, vents, or air pollution control equipment at the facility and consequently no stack emissions associated with the process. Mining and plant operations occur on a 24 hour, 7 days a week continuous basis with downtime for maintenance and repairs. The ponded fine tailings special concentrate, tailings left behind from historical mining and benefaction operations, is the feedstock for Magnetation s process. The material contains approximately percent total iron oxide concentrations of various oxide types such as magnetite (Fe 3 O 4 ), hematite (Fe 2 O 3 ), wüstite (FeO), and goethite (FeO 2 H). The remaining feedstock composition consists of other soils and non ferrous materials and contains approximately 15 percent moisture content at excavation. Excavation of the tailing material is performed by backhoe excavators and then loaded onto haul trucks. The feedstock is then hauled and fed into the plant through an enclosed dump pocket, where it is processed into hematite containing iron oxide concentrate. The benefaction process performed on the recovered tailing material (feedstock) is a cold, wet process; there are no furnaces, boilers or associated dryers. The feedstock is initially passed through a static grizzly which screens off large rocks, tree stumps, and other oversize materials. Oversize material is collected and hauled to a primary reject area and later returned to the tailings basin where it originated. The remaining material is conveyed to a container where it is mixed with water to create a slurry and fed to a vibrating wet screen. The oversize from the vibrating screen is fed to a ball mill inside the production building for use later in the process. The undersize, a high percent solids slurry, then continues through additional processing steps comprising the proprietary Magnetation Process. This process includes but is not limited to pumps, hydro cyclones, wet screens, ball mills, the Rev 3 Separators, conveyors, slurry tanks, and dewatering devices. The final concentrate is dewatered to a filter cake suitable for shipment. Haul trucks are loaded by conveyor discharge inside the production building or by front end loaders adjacent to the conveyor discharge with final concentrate that contains approximately 95 percent iron oxide (hematite) and dewatered to approximately 9 percent moisture content.

5 Facility Name: Magnetation LLC - Plant 2 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 Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices. The Permittee shall comply with all requirements contained in Appendix B: Insignificant Activities. Comply with Fugitive Emission Control Plan: The Permittee shall follow the actions and recordkeeping specified in the control plan. The plan may be amended by the Permittee with the Commissioner's approval. If the Commissioner determines the Permittee is out of compliance with Minn. R or the fugitive control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors as requested by the Commissioner. CONTRACTORS Contractors: Prior to any contractor activities that cause or contribute to air emissions being conducted on site, the Permittee shall determine whether the contractor activities are part of the stationary source as defined by Minn. R , subpart 42c. hdr Why to do it Minn. R , subp. 2 Minn. Stat. Section , subd. 4a; Minn. R ; Minn. R , subp. 2; Minn. R ; Minn. R hdr Minn. R , subp. 4; Minn. R , subp. 5 If the contractor activities are part of the stationary source, the Permittee shall evaluate the activities to determine whether a permit amendment is needed. If a permit amendment is needed, the Permittee shall apply for and obtain the appropriate permit amendment or permit prior to making the change. If the Permittee determines a permit amendment is not needed, the Permittee shall retain records of the calculations and other information used to determine a permit amendment is not needed. Contractors Continued: If the contractor activities are not part of the stationary source, the Permittee shall retain the following records on site for each contractor: 1. The contractor company name; 2. The information used to determine the contractor activities are not part of the stationary source; 3. The date the contractor starts operating on site; 4. The date the contractor stops operating on site; 5. The contractor's MPCA air emissions permit number, if a permit is needed for the activities; 6. A brief description of the activities undertaken by the contractor, including types and amounts of materials handled and hours of operation; 7. A list of the equipment operated on site by the contractor; and 8. Estimated emissions for the contractor activities. NONROAD ENGINES The Permittee shall not have engines that meet Section (1)(iii) under the definition of Nonroad Engine at 40 CFR Section in one location within the stationary source for more than 12 consecutive months. A location is any single site at a building, structure, facility, or installation. Minn. R , subp. 4; Minn. R , subp. 5 hdr 40 CFR Section Any engine, or engines, that replaces an engine at a location and that is intended to perform the same or similar function as the engine it replaced will be included in calculating the consecutive time period. For a nonroad engine that is excluded from any requirements of 40 CFR Part 1068 because it is a stationary engine, the Permittee may not move it or install it in any mobile equipment, except as allowed by the provisions of 40 CFR Part The Permittee may not circumvent or attempt to circumvent the residence-time requirements of Section (2)(iii) of the Nonroad Engine definition at 40 CFR Section CFR Section (b)(3)

6 Facility Name: Magnetation LLC - Plant 2 Permit Number: A-2 The Permittee shall conduct an inventory of all engines on-site that meet Section (1)(iii) under the definition of Nonroad Engine at 40 CFR Section , once each calendar quarter; inventories shall not take place in consecutive months. This applies to nonroad engines that are owned by the Permittee, or rented and operated by the Permittee, or brought onsite and operated by a vendor or contractor. The inventory shall include the following: 1) Date that the nonroad engine is inventoried. 2) Identification number. 3) Function of the nonroad engine (e.g. compressor, welder). 4) Location of the engine within the stationary source. 5) Statement that the nonroad engine has not been located in a single location for 12 consecutive months, and movement between locations has not been for purposes of circumvention of residence time requirements of Section (2)(iii) under the definition of Nonroad Engine at 40 CFR Section A nonroad engine ceases to be a nonroad engine and becomes a new stationary engine if: 40 CFR Section ; Minn. R , subp. 4; Minn. R , subp CFR Section (e) 1. At any time, it meets the criteria specified in Section (2)(iii) under the definition of Nonroad Engine in 40 CFR Section For example, a portable generator engine ceases to be a nonroad engine if it is used or will be used in a single specific location for 12 months or longer. If the Administrator or the Permitting authority determines that an engine will be or has been used in a single specific location for 12 months or longer, it ceased to be a nonroad engine when it was placed in that location. OR 2. It is otherwise regulated by a federal New Source Performance Standard promulgated under section 111 of the Clean Air Act (42 U.S.C. 7411). 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 hdr Minn. Stat. Section , subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subp. 1; Minn. R , subp. 2; Minn. R , subp. 4; Minn. R Minn. R Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R , subp. 14; Minn. R , subp. 16(J) Minn. R , subp. 4 Minn. R Minn. R Minn. R , subp. 9(A) Minn. R , subp. 16 hdr

7 Facility Name: Magnetation LLC - Plant 2 Permit Number: A-3 Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C. 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. ch 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 expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. REPORTING/SUBMITTALS Minn. R , subp. 4(D) hdr Minn. R , subp. 5(C) Minn. R , subp. 5(B) Minn. R , subp. 4 hdr

8 Facility Name: Magnetation LLC - Plant 2 Permit Number: A-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. 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. 3 Minn. R , subp. 2 At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Minn. R , subp. 1 Minn. R , subp. 1 Minn. R ; Minn. R , subp. 3 Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R , subp. 3. Extension Requests: The Permittee may apply for an Administrative Amendment to Minn. R , subp. 1(H) extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R , subp. 1(H). Emission Inventory Report: due on or before April 1 of each calendar year following Minn. R permit issuance, to be submitted on a form approved by the Commissioner. Emission Fees: due 30 days after receipt of an MPCA bill. Minn. R

9 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: GP 001 Emission Units subject to NSPS Subpart LL A-5 Associated Items: EU 001 Truck Dumps to Inside Grizzly - Screens EU 002 Inside Grizzly Discharge to Conveyor - Conveyor EU 003 Conveyor Discharge to Concentrator Plant - Conveyor EU 004 Vacuum Filter Discharge to Conveyor - Conveyor EU 005 Conveyor Discharge to Bin/Transfer Conveyor - Conveyor EU 006 Bin Discharge to Loadout Conveyor - Conveyor EU 007 Loadout Conveyor Discharge to Concentrate Truck - Conveyor EU 008 Transfer Conveyor to Bunker - Conveyor What to do The provisions of 40 CFR pt. 60, subp. LL apply to the following affected facilities: Each crusher and screen in open-pit mines; each crusher, screen, bucket elevator, conveyor belt transfer point, thermal dryer, product packaging station, storage bin, enclosed storage area, truck loading station, truck unloading station, railcar loading station, and railcar unloading station at the mill or concentrator. Opacity: less than or equal to 10 percent opacity for any process fugitive emissions. This limit applies individually to each emission unit in this group. The opacity limit applies at all times except during periods of startup, shutdown, or malfunction. Visible Emissions: The Permittee shall check EU 001, EU 007, and EU 008 at a location in which emissions from each emission unit would be expected to vent to the atmosphere once each day of operation for any visible emissions during daylight hours while the each unit is operating. For days when an emission unit is not in operation, the Permittee shall record that the emission unit was not in operation that day. Recordkeeping: The Permittee shall keep a record of all visible emission checks, the date and time of the visible emissions check, whether or not any visible emissions were observed and of any corrective actions taken. Corrective Actions: The Permittee shall take corrective actions listed in the Fugitive Dust Control Plan when visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken. In conducting the performance testing for opacity from process fugitive emissions contained in this group, the observer shall read opacity only when emissions are clearly identified as emanating solely from the affected facility being observed. A single visible emission observer may conduct visible emission observations for up to three fugitive, stack, or vent emission points within a 15-second interval. This option is subject to the following limitations: Why to do it 40 CFR Section (a); Minn. R CFR Section (b); Minn. R CFR Section 60.11(c); Minn. R Minn. R , subp. 4 Minn. R , subp. 5 Minn. R , subp. 4; Minn. R , subp. 5; Minn. R , subp CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp No more than three emission points are read concurrently; 2. All three emission points must be within a 70 (seventy) degree viewing sector or angle in front of the observer such that the proper sun position can be maintained for all three points; and 3. If an opacity reading for any one of the three emission points is within five percent opacity of the application standard, then the observer must stop taking readings for the other two points and continue reading just that single point.

10 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: GP 002 Fugitive Sources subject to NSPS Subpart LL A-6 Associated Items: FS 012 Dump on to Outside Grizzly - Material Handling/Transfer/Storage FS 014 Outside Grizzly Discharge to Conveyor- Material Handling/Transfer/Storage FS 015 Transfer Conveyor to Pile - Material Handling/Transfer/Storage FS 017 Transfer Conveyor to Crusher - Material Handling/Transfer/Storage FS 018 Crushing Operation - Material Handling/Transfer/Storage FS 019 Crushing Discharge to Transfer Conveyor - Material Handling/Transfer/Storage FS 020 Transfer Conveyor to Screen Intake Conveyor - Material Handling/Transfer/Storage What to do The provisions of 40 CFR pt. 60, subp. LL apply to the following affected facilities: Each crusher and screen in open-pit mines; each crusher, screen, bucket elevator, conveyor belt transfer point, thermal dryer, product packaging station, storage bin, enclosed storage area, truck loading station, truck unloading station, railcar loading station, and railcar unloading station at the mill or concentrator. Opacity: less than or equal to 10 percent opacity for any process fugitive emissions. This limit applies individually to each fugitive source in this group. The opacity limit applies at all times except during periods of startup, shutdown, or malfunction. Visible Emissions: The Permittee shall check each fugitive source in this group at a location in which emissions from the fugitive source would be expected to vent to the atmosphere once each day of operation for any visible emissions during daylight hours while the each unit is operating. For days when a fugitive source is not in operation, the Permittee shall record that the fugitive source was not in operation that day. Recordkeeping: The Permittee shall keep a record of all visible emission checks, the date and time of the visible emissions check, whether or not any visible emissions were observed and of any corrective actions taken. Corrective Actions: The Permittee shall take corrective actions listed in the Fugitive Dust Control Plan when visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken. In conducting the performance testing for opacity from process fugitive emissions contained in this group, the observer shall read opacity only when emissions are clearly identified as emanating solely from the affected facility being observed. A single visible emission observer may conduct visible emission observations for up to three fugitive, stack, or vent emission points within a 15-second interval. This option is subject to the following limitations: Why to do it 40 CFR Section (a); Minn. R CFR Section (b); Minn. R CFR Section 60.11(c); Minn. R Minn. R , subp. 4 Minn. R , subp. 5 Minn. R , subp. 4; Minn. R , subp. 5; Minn. R , subp CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp No more than three emission points are read concurrently; 2. All three emission points must be within a 70 (seventy) degree viewing sector or angle in front of the observer such that the proper sun position can be maintained for all three points; and 3. If an opacity reading for any one of the three emission points is within five percent opacity of the application standard, then the observer must stop taking readings for the other two points and continue reading just that single point.

11 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: GP 003 Fugitive Sources not subject to NSPS Subpart LL A-7 Associated Items: FS 001 Loader Activity - Material Handling/Transfer/Storage FS 002 Crusher: Loader Activity - Material Handling/Transfer/Storage FS 003 Excavator Activity - Material Handling/Transfer/Storage FS 004 Bulldozer Activity - Material Handling/Transfer/Storage FS 005 Paved Roads - Paved Road FS 006 Unpaved Roads - Unpaved Roads FS 007 Winter Stockpile - Piles FS 008 Primary Rejects Stockpile - Piles FS 009 Exposed/Open Mine Strip - Piles FS 010 Inside Grizzly Rejects - Material Handling/Transfer/Storage FS 011 Front End Loader into Concentrate Truck - Material Handling/Transfer/Storage FS 013 Outside Grizzly Rejects - Material Handling/Transfer/Storage FS 016 Front End Loader into Haul Truck - Material Handling/Transfer/Storage What to do Opacity: less than or equal to 20 percent opacity Minn. R Visible Emissions: The Permittee shall check each fugitive source in this group, except for FS 010, at a location in which emissions from the fugitive source would be expected to vent to the atmosphere once each day of operation for any visible emissions during daylight hours while the each unit is operating. Why to do it Minn. R , subp. 4 For days when a fugitive source is not in operation, the Permittee shall record that the fugitive source was not in operation that day. Recordkeeping: The Permittee shall keep records of the following: 1. All visible emission checks; 2. The date and time of the visible emissions check; 3. Whether or not any visible emissions were observed and of any corrective actions taken; 4. The number of watering truck loads applied to haul roads and open excavation areas; 5. The date and time of watering truck load applications, and; 6. The number of haul truck vehicle miles traveled. Corrective Actions: The Permittee shall take corrective actions listed in the Fugitive Dust Control Plan when visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken. Minn. R , subp. 5 Minn. R , subp. 4; Minn. R , subp. 5; Minn. R , subp. 14

12 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: EU 001 Truck Dumps to Inside Grizzly - Screens A-8 Associated Items: GP 001 Emission Units subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

13 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: EU 002 Inside Grizzly Discharge to Conveyor - Conveyor A-9 Associated Items: GP 001 Emission Units subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

14 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: EU 003 Conveyor Discharge to Concentrator Plant - Conveyor A-10 Associated Items: GP 001 Emission Units subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

15 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: EU 004 Vacuum Filter Discharge to Conveyor - Conveyor A-11 Associated Items: GP 001 Emission Units subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

16 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: EU 005 Conveyor Discharge to Bin/Transfer Conveyor - Conveyor A-12 Associated Items: GP 001 Emission Units subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

17 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: EU 006 Bin Discharge to Loadout Conveyor - Conveyor A-13 Associated Items: GP 001 Emission Units subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

18 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: EU 007 Loadout Conveyor Discharge to Concentrate Truck - Conveyor A-14 Associated Items: GP 001 Emission Units subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

19 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: EU 008 Transfer Conveyor to Bunker - Conveyor A-15 Associated Items: GP 001 Emission Units subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

20 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: FS 012 Dump on to Outside Grizzly - Material Handling/Transfer/Storage A-16 Associated Items: GP 002 Fugitive Sources subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

21 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: FS 014 Outside Grizzly Discharge to Conveyor- Material Handling/Transfer/Storage A-17 Associated Items: GP 002 Fugitive Sources subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

22 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: FS 015 Transfer Conveyor to Pile - Material Handling/Transfer/Storage A-18 Associated Items: GP 002 Fugitive Sources subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

23 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: FS 017 Transfer Conveyor to Crusher - Material Handling/Transfer/Storage A-19 Associated Items: GP 002 Fugitive Sources subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

24 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: FS 018 Crushing Operation - Material Handling/Transfer/Storage A-20 Associated Items: GP 002 Fugitive Sources subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

25 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: FS 019 Crushing Discharge to Transfer Conveyor - Material Handling/Transfer/Storage A-21 Associated Items: GP 002 Fugitive Sources subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

26 Facility Name: Permit Number: Magnetation LLC - Plant Subject Item: FS 020 Transfer Conveyor to Screen Intake Conveyor - Material Handling/Transfer/Storage A-22 Associated Items: GP 002 Fugitive Sources subject to NSPS Subpart LL What to do Initial Performance Test: due 60 days after achieving maximum capacity at which the affected facility will be operated, but not later than 180 days after permit issuance to measure opacity of process fugitive emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9 and the procedures in 40 CFR Section 60.11, or other method approved by MPCA in the performance test plan approval. Why to do it 40 CFR Section (a); 40 CFR Section 60.8(a); Minn. R ; Minn. R , subp. 1

27 TABLE B: SUBMITTALS Facility Name: Magnetation LLC - Plant 2 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 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 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 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 Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 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. 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

28 TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: Magnetation LLC - Plant 2 Permit Number: B-2 What to send When to send Portion of Facility Affected Application for Permit Reissuance due 180 days before expiration of Existing Total Facility Permit. Computer Dispersion Modeling Information due 1,096 days after Permit Issuance. Total Facility Submit modeling data as specified in MPCA guidance for Modeling Information Requests (for PM10). This modeling information is for data collection purposes, no modeling analysis is required at this time. Testing Frequency Plan due 60 days after Initial Performance Test for GP001 opacity of process fugitive emissions contained in this group. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. Testing Frequency Plan due 60 days after Initial Performance Test for opacity of process fugitive emissions contained in this group. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. GP002

29 TABLE B: RECURRENT SUBMITTALS Facility Name: Magnetation LLC - Plant 2 Permit Number: B-3 What to send When to send Portion of Facility Affected Semiannual Deviations Report due 30 days after end of each calendar Total Facility half-year following Permit Issuance. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations. Compliance Certification due 31 days after end of each calendar year following Permit Issuance (for the previous calendar year). The Permittee shall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. Total Facility

30 TABLE C: COMPLIANCE SCHEDULE Facility Name: Magnetation LLC - Plant 2 Permit Number: C-1 07/08/15 Table C contains the compliance schedule as required by Minn. R , subp. 2 (K). You must complete the actions required in Table C by the dates listed in the table. All submittals must be postmarked or received by the date specified in the table, and certified by a responsible official, defined in Minn. R , subp. 21. Subject Item: Total Facility Citation Minn. R Corrective Action Within 90 days of Permit Issuance the Permittee shall submit a "Root Cause Analysis" that identifies the cause(s) of the fugitive emission events in 2014 and The Root Cause Analysis shall identify the conditions which led to the events, and what corrective measures the Permittee has, or will undertake to prevent fugitive emissions from occurring in the future. Any corrective action(s) the Permittee includes in its root cause analysis shall be submitted as an amendment to the facility s Fugitive Emission Control Plan which will be an enforceable part of this permit. When to complete the action

31 APPENDIX B Facility Name: Magnetation LLC Plant 2 Permit Number: Insignificant Activities: The table below lists the insignificant activities that are currently at the facility and their associated general applicable requirements. Minn. R , subpart 3(C) 3(E)(1) 3(E)(2) 3(G) 3(H)(3) 3(I) Rule Description of the Activity Fabrication operations: equipment used exclusively for forging, pressing, drawing, spinning, or extruding hot metals. Magnetation LLC Plant 2 has and operates maintenance cutting and welding equipment. Gasoline storage tanks with a combined total tankage capacity of not more than 10,000 gallons. Magnetation LLC Plant 2 has an above ground storage tank used for gasoline (1000 gallons). Non hazardous air pollutant VOC storage tanks with a combined total tankage capacity of not more than 10,000 gallons of nonhazardous air pollutant VOCs and with a vapor pressure of not more than 1.0 psia at 60 degrees Fahrenheit. Magnetation LLC Plant 2 has above ground storage tanks used for process chemicals including amines (two 4500 gallon tanks), frothing agents (one 7000 gallon tank), and above ground storage tanks for diesel fuel (one 2000 gallon tank and three 1000 gallon tanks). Emissions from a laboratory, as defined in the subpart. Magnetation LLC Plant 2 has and utilizes a laboratory. Brazing, soldering or welding equipment. Magnetation LLC Plant 2 has and operates welding equipment. Individual emissions units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than: 1. 4,000 lbs/year of carbon monoxide; and 2. 2,000 lbs/year each of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, volatile organic compounds (including hazardous air pollutant containing VOC), and ozone; and 3. 1,000 tons/year of CO 2 e. Magnetation LLC Plant 2 has and operates air compressors, conveyor belt scales, and 15 propane fired space heaters (525,000 Btu/hr each, MMBtu total). Applicable Requirement Minn. R Minn. R , subp. 3(A) Minn. R , subp. 3(A) Minn. R , subp. 3(B) Minn. R Minn. R Minn. R Minn. R Minn. R Appendix B, Page 1

32 Fugitive Dust Control Plan: Magnetation LLC Plant 2 Holman, East Trout Lake, and Plummer Tailings Basins Prepared for: Magnetation LLC, Plant County Road 10 Bovey, Minnesota Rev 2: June 1, 2015 (Rev 1: March 26, 2015) (Rev 0: June 12, 2012) Prepared by: Magnetation LLC 102 NE Third Street, Suite 120 Grand Rapids, Minnesota (218) Mike.Twite@magnetation.com APPENDIX C Facility Name: Magnetation LLC Plant 2 Permit Number: Appendix C, Page 1

33 APPENDIX C Facility Name: Magnetation LLC Plant 2 Permit Number: Table of Contents Summary Introduction Objectives Fugitive Emission Sources Excavation Unpaved Roads Metallic Mineral Crushing Paved Roads Control Measures and Operating Practices Excavation Unpaved Roads Metallic Mineral Crushing Paved Roads Training Mine Operators Mine Supervisors Mine Manager Reporting and Recordkeeping Periodic Site Inspections Employee Training Chemical Dust Suppressant Annual Report Appendix A: Inspection Form Appendix C, Page 2

34 APPENDIX C Facility Name: Magnetation LLC Plant 2 Permit Number: Summary Magnetation LLC owns and operates an iron oxide processing facility and related iron tailings reclamation operations at a facility located south of Taconite, Minnesota. This manufacturing process has the potential to create fugitive dust emissions and thus active measures are taken to minimize dust creation. The manufacturing processes and related potential fugitive dust emissions are regulated by Minnesota s Department of Natural Resources (MNDNR) and Pollution Control Agency (MPCA). This plan is prepared and implemented to ensure regulatory compliance with both state agencies and ensure that facility operations minimize any potential adverse environmental impact related to fugitive dust. Introduction Magnetation LLC (hereafter Magnetation) has prepared this Fugitive Dust Control plan for operations at their Plant 2 facility, located near Taconite, MN including the Holman, East Trout Lake and Plummer tailings basins associated with Plant 2 operations. This Fugitive Dust Control Plan has been written to address fugitive emissions for their scram mining operation. This Fugitive Dust Control Plan will outline the best management practices to be used by Magnetation to comply with MN Rule Preventing Particulate Matter From Becoming Airborne. That regulation requires Magnetation take all reasonable measures and reasonable precautions to prevent avoidable amounts of particulate matter from becoming airborne and leaving the facility s boundaries. Objectives The Fugitive Dust Control Plan identifies control measures and practices to minimize and control fugitive dust from the scram mining operation. The plan defines: the procedures Magnetation personnel will follow to control emissions; when emissions are at levels requiring corrective actions; steps that will be followed to bring emissions within appropriate ranges; and steps and procedures Magnetation will use to demonstrate procedures are followed and to verify the facility is controlling avoidable fugitive emissions. To meet these objectives, the Fugitive Dust Control Plan: Identifies major fugitive emission sources within the scram mining operation. Identifies the primary and contingent control measures and practices to control and minimize fugitive emissions. Identifies visible emission observation and corrective action requirements. Describes fugitive dust control training elements. Identifies fugitive dust control recordkeeping requirements. Appendix C, Page 3

35 APPENDIX C Facility Name: Magnetation LLC Plant 2 Permit Number: Fugitive Emission Sources There are four potential sources of fugitive dust emissions related to facility operations. Each are described in further detail and are listed in descending order of dust generating potential. EXCAVATION Excavation work within the tailings basins is driven by the iron oxide mining plan and other operational needs. At any given time, forty to sixty (40 ~60) acres of tailings basin material is actively being reclaimed for processing. This activity exposes horizontal and sloped surfaces of fine tailings material to surface winds. Excavation of large areas within the tailings basin is required for operational reasons, specifically to allow for feedstock blending that provides consistent metallurgical and physical properties into the beneficiation process. It is typical to simultaneously excavate from two or more discrete areas not only to meet immediate plant feed needs, but also to prepare additional areas for excavation. Although the material generally has a 10~15% moisture content, the exposed edges can dry out and thus become more susceptible to becoming airborne. The facility also maintains stockpiles of previously mined material to feed into the processing facility in order to sustain operations when weather conditions prevent feedstock removal from the actively mined portions of a tailings basin. UNPAVED ROADS Unpaved haul roads exist around the perimeter of the tailings basins and also in interior basin dikes. Material on these roads in largely material typical of a gravel road, but there is a higher silt concentration due to the tailings reclamation activity and accumulated spillage from haul trucks. METALLIC MINERAL CRUSHING The facility intends to periodically crush oversize iron bearing materials from existing stockpiles. This size reduction process has the potential to generate fugitive dust emissions from both the crushing activity and associated material handling of the material. PAVED ROADS The facility entrance road from County Road 10 providing access to plant processing buildings is fully paved and the smallest source of potentially generating fugitive dust. Appendix C, Page 4

36 APPENDIX C Facility Name: Magnetation LLC Plant 2 Permit Number: Control Measures and Operating Practices The control measures and operating practices that have been implemented and recorded for the fugitive dust sources identified in Section 4 are described below. In general, daily site inspections will document any fugitive dust episodes, the adjustments to the applicable control measures used to minimize fugitive dust generation, and comment on the effectiveness of said adjustments. If chemical dust suppressant products are used, the approval and reporting process identified within the facility s regulatory permits 1 will be followed. EXCAVATION Excavation activities require the most vigilance and active mitigation to minimize potential fugitive dust emissions. The goal is to minimize the amount of exposed tailings material. Primary Controls The primary control measures Magnetation will use include, but are not limited to: Minimize area disturbed by excavation leaving existing or temporary vegetation in place as long as practical prior to mining. While timber and brush clearing may be required well in advance of active mining, basin grubbing (practice of removing any surface overburden, organic materials, etc.) is delayed until immediately prior to active mining commencing in a given area. Frequent watering of exposed mining areas using tailings basin process water and/or a solution of MPCA approved dust suppressant solutions such as Magnesium Chloride, various polymers or other commercially available products. Utilization of the full range of equipment available including truck mounted watering equipment, sprinklers, etc. Some weather conditions during the summer months, such as low humidity and high winds, require a higher water frequency. The water application rate will be adjusted, depending on weather conditions. Apply organic mulch such as hay, straw or wood fiber within 15 days to exposed tailing basin areas that are not expected to be mined within 30 days. Apply non toxic sprayed paper mulch or similar substitute dust control agents (hydro mulch tacifying agent) within 45 days on steep slopes that are likely to be undisturbed for more than 60 days. During winter months, leave snow cover undisturbed except in active mining areas. Contingent Controls The contingent controls are an increased frequency of applying effective primary controls as described above. Operating Practices The operating practices Magnetation will use include, but are not limited to the following: Check for visible emissions (VEs) throughout the tailings basins during daylight hours from the haul roads while mining activities are in progress. If VEs are observed, determine the cause and take corrective actions to adjust the use of primary controls (above) as soon as possible to eliminate the VEs. Review and adjust the facility mining plan as feasible to minimize the active excavation areas. Document the number of watering truck loads applied to haul roads and open excavation areas. 1 Chapter 7, Section 1.43 and Chapter 6, Section 7 of SDS Permit # MN Appendix C, Page 5

37 APPENDIX C Facility Name: Magnetation LLC Plant 2 Permit Number: UNPAVED ROADS Unpaved roads and access areas are largely found within the tailings basin mining areas and also immediately surrounding the processing buildings. While a much smaller exposed area than the actively mined portions of the tailings basins, dust generation is possible due to the amount of haul truck traffic. The goal is to maintain safe road conditions while minimizing potential fine dust generation. Primary Controls The primary control measures Magnetation will use include, but are not limited to: Maintain unpaved haul roads and access areas around the processing buildings with aggregate oversize clean material. Grade the roads as necessary to maintain safe working surfaces. Apply water and/or a solution of MPCA approved dust suppressant solutions such as Magnesium Chloride or other commercially available products. Utilize truck mounted watering equipment, sprinklers, etc. Some weather conditions during the summer months, such as low humidity and high winds, require a higher water frequency. The application rate will be adjusted, depending on weather conditions. During freezing conditions, plow enough snow to make for safe operation conditions, but leave some snow cover on the unpaved surfaces if feasible. Contingent Controls The contingent controls are an increased frequency of applying effective primary controls as described above. Operating Practices The operating practices Magnetation will use include, but are not limited to the following: Check for visible emissions (VEs) throughout the tailings basins during daylight hours from the haul roads while mining activities are in progress. If VEs are observed, determine the cause and take corrective actions to adjust the use of primary controls (above) as soon as possible to eliminate the VEs. Document the number of watering truck loads applied to haul roads and open excavation areas. Document the number of haul truck vehicle miles traveled for emissions estimating for the annual air emissions inventory report. Appendix C, Page 6

38 APPENDIX C Facility Name: Magnetation LLC Plant 2 Permit Number: METALLIC MINERAL CRUSHING Size reduction of iron bearing materials from existing stockpiles or frozen fine tailings will be accomplished via portable crushing operations and associated material handling systems. While a much smaller footprint than the actively mined portions of the tailings basins, dust generation is possible due to the nature of this process. The goal is to control maintain safe operation of the equipment while minimizing potential fine dust generation. Any contracted crushing services will have to comply with this section. Magnetation will ensure the contractual language includes this requirement. Primary Controls The primary control measures Magnetation will use include, but are not limited to: Screen iron bearing materials ahead of a crushing operation so that only oversize material is processed by the crusher. Adjust the crusher operations so that material is not size reduced more than necessary. Over crushing increases the potential for fine dust generation in addition to wasting energy. Use the manufacturers installed spray systems to water mist potential dust generating points in the crushing operation. Locate the crushing operation to maximize use of available screening from the prevailing winds. Contingent Controls If the primary controls are not effective in controlling fugitive dust emissions from this process, the following additional actions will be taken: Implement additional water spray manifolds to enhance those provided in the original manufacturers design. Consider operating restrictions to minimize crushing operations when all available primary control measures are not effective. Examples may include restricting operating hours, reducing material throughput, curtailing operations in high wind conditions, etc. Operating Practices The operating practices Magnetation will use include, but are not limited to the following: Check for visible emissions (VEs) at the crushing operation during daylight hours while crushing activities are in progress. If VEs are observed, determine the cause and take corrective actions to adjust the use of primary and contingent controls (above) as soon as possible to eliminate the VEs. Appendix C, Page 7

39 APPENDIX C Facility Name: Magnetation LLC Plant 2 Permit Number: PAVED ROADS The paved entrance road from County Road 10 may become a source of fugitive dust emissions due to the vehicle sediment track out and the number of trucks using this road. Primary Controls The primary control measures Magnetation will use include, but are not limited to: The primary means of minimizing material tracking onto paved roads is to separate paved and unpaved road traffic. Vehicles that have operated off road (within the mining areas) must be washed before entering the paved roads within the plant area. The paved entrance road is mechanically cleaned (broom style sweeping or vacuum) when inspections or plant experience indicates that sediment track out on paved roads may occur beyond the tailings basin drainage boundaries. Contingent Controls The contingent controls are an increased frequency of applying effective primary controls as described above. Operating Practices The operating practices Magnetation will use include, but are not limited to the following: The paved entrance road is visually inspected once each day when the plant is transporting finished product via over the road trucks to ensure that there is no sediment track out beyond the facility boundaries or any VEs are noticed. If VEs or sediment track out are observed, determine the cause and take corrective actions to adjust the use of primary controls (above) as soon as possible to eliminate the VEs and /or track out. Appendix C, Page 8

40 APPENDIX C Facility Name: Magnetation LLC Plant 2 Permit Number: Training An integral part of the implementation of the Fugitive Dust Control Plan is appropriate training for the personnel involved. Training is completed annually or when an employee assumes new responsibilities relevant to the Fugitive Dust Control Plan. Mine Operators MSHA requires that equipment operators receive annual training for specific equipment types, this includes rolling stock such as broom sweepers, vacuum trucks, water trucks, hydro seeders and other equipment used to implement the fugitive dust control plan. What to look for when working in the tailings basins Who to contact to increase corrective actions in this plan Mine Supervisors Mine Supervisors (one per shift) will receive training from the Mine Manager on the following topics: Fugitive Dust Control Plan components Completing the Daily Visible Emission Inspection Sheet Effectiveness of various corrective action techniques Primary and Contingent Dust Controls Recordkeeping Mine Manager In addition to the Mine Supervisor training topics, the Mine Manager will receive training from the Environmental Manager on the following topics: Regulatory Reporting Responding to Facility Complaints Appendix C, Page 9

41 APPENDIX C Facility Name: Magnetation LLC Plant 2 Permit Number: Reporting and Recordkeeping Periodic Site Inspections Daily Site Inspections records will be retained at the facility for five years. Employee Training Equipment Operator records will be retained according to MSHA requirements, Supervisor and Superintendent training records will be retained at the facility for five years. Chemical Dust Suppressant Annual Report The SDS permit requires an annual report be submitted by January 31 for the previous calendar year if any chemical dust suppressants are used at the facility. File copies of these submittals will be retained at either the facility or corporate offices for two years. Appendix C, Page 10

42 APPENDIX C Facility Name: Magnetation LLC Plant 2 Permit Number: Appendix A: Inspection Form Magnetation LLC, Plant 2: Fugitive Dust Site Inspection Form (Complete once per day while mining or material processing activities are taking place on site) Supervisor: Date: Time: Weather (circle): sunny partly cloudy overcast rain sleet snow Temp: F Wind from (circle): N NW W SW S SE E NE Speed: Paved Entrance Road 1. Are there any visible emissions from road dust? No Yes If yes, describe corrective actions taken and their effectiveness: 2. Is there any visible sediment track out from haul trucks? No Yes If yes, describe corrective actions taken and their effectiveness: 3. Are trucks leaving the pit using the tire washing equipment? No Yes If no, describe corrective actions taken and their effectiveness: 4. Has the broom sweeper or vacuum truck been operated in the past 24 hours? No Yes If yes, describe location and number of hours operated: Unpaved Roads and Access Areas 1. Are there any visible emissions from unpaved haul roads or access areas around the facility? No Yes If yes, describe location(s), corrective actions taken, and their effectiveness: Excavation Areas and Stockpiles 1. Are there any visible emissions from any disturbed tailings basin areas or winter stockpile? No Yes If yes, describe location(s), corrective actions taken, and their effectiveness: 2. Are there any visible emissions from crushing operations or associated stockpiles? No Yes If yes, describe location(s), corrective actions taken, and their effectiveness: (over) Appendix C, Page 11

43 APPENDIX C Facility Name: Magnetation LLC Plant 2 Permit Number: Magnetation LLC, Plant 2: Fugitive Dust Site Inspection Form (continued) Have water trucks or sprinklers been used in the past 24 hours? No Yes Have chemical dust suppressants been used in the past 24 hours? No Yes If yes, complete the following: Tailings basin (circle): Holman East Trout Lake Plummer Plant Area Product name: Quantity applied: (gallons solution, gallons, product, concentration, etc.) (Retain record for 5 years) Appendix C, Page 12