AIR EMISSION PERMIT NO (MAJOR AMENDMENT) IS ISSUED TO. GOPHER RESOURCE CORPORATION 3385 South Highway 149 Eagan, Dakota County, MN 55121

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1 AIR EMISSION PERMIT NO (MAJOR AMENDMENT) IS ISSUED TO GOPHER RESOURCE CORPORATION 3385 South Highway 149 Eagan, Dakota County, MN The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date (s) Permit Issuance Date Total Facility Operating Permit April 14, 1995 August 15, 2002 Moderate Amendment April 03, 2002 w/tfp August 15, 2002 Major Amendment MPCA-Initiated See Below This permit amends Air Emission Permit No , and 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. Permit Type: Federal; Part 70/Major for NSR Major Amendment Issue Date: August 15, 2002 January 31, 2003 Expiration: August 15, 2007 August 15, 2007 All Title I Conditions Do Not Expire. Title I Condition: SIP for lead NAAQS 40 CFR pt. 50 and MN State Implementation Plan (SIP) or Title I Condition: MN State Implementation (SIP) for lead; 40 CFR 50.5 are required to go through the federal State Implementation Plan approval process before the change becomes effective. Ann M. Foss Major Facilities Section Manager Majors and Remediation Division for Sheryl Corrigan 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 NO TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Table C: Compliance Schedule (Not used in this permit) Appendices: Appendix A: Operator s Summary Appendix B: Parameters Relied Upon in Modeling Appendix C: Insignificant Activities And Applicable Requirements Appendix D: Smelting Raw Material Warehouse and Process Side of the Raw Material Processing Area Diagram Appendix E: Areas of the Building Under Negative Pressure Appendix F: Topographical Survey for Gopher Resource Appendix G: Testing and Maintenance of Pressure Drop Gauges and Broken Media Detectors and Alarm Response Procedures Appendix H: Negative Pressure System Testing Appendix I: Smoke Testing Methodology for Negative System Pressure Testing

3 PERMIT NO 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.

4 PERMIT NO FACILITY DESCRIPTION: oration (Gopher Resource) owns and operates a secondary lead smelter facility located at 3385 South Highway 149, Eagan, Dakato County, Minnesota. The stationary source includes the following four major operations and miscellaneous sources: scrap pretreatment, smelting, refining and casting. Lead is recovered from lead-acid batteries, scrap from the battery manufacturing plant, and miscellaneous lead bearing materials. The recovered lead is refined into alloys that are sold to a variety of customers. Gopher Resource facility is a major source under the federal Part 70 permit program, and a major source of carbon monoxide and sulfur dioxide under the federal Prevention of Significant Deterioration program. CURRENT PERMIT AMENDMENT (PERMIT ACTION 002): This permit amendment is the MPCA initiated major amendment under Minn. R , subp. 1(D)- mandatory reopening that is needed in order to assure compliance with applicable requirement. The amendment incorporates new limit into the permit. The limit has been imposed through performance testing under Minn. R , subp. 3 and is already in affect for Stack/Vent (SV) 003. The permit must be reopened in order to reflect the revised limits. See the attached MPCA letter sent on September 20, 2002, to oration (Permittee), that set new limit in the Permittee s Part 70 permit based on performance testing under Minn. R. ch

5 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 A. STATE IMPLEMENTATION PLAN (SIP) REQUIREMENTS hdr Why to do it Modeling: Any increase in lead emissions beyond modeled conditions associated with the emission units in the SIP shall be modeled at the new predicted lead emission rates to determine the impact on the National Ambient Quality Standards (NAAQS). CHANGES NOT REQUIRING A MODIFICATION FOR THE SIP: The owner or operator shall make changes to the facility without obtaining a modification as long as the change does not do or result in any of the following: A. an exceedance of the limitations associated with the emission units in the SIP; B. a physical change of the equipment that affects the stack parameters described in Appendix B; C. an increase of a maximum potential lead emission rate of pound per hour for any installation, modification, or operation of lead process or control equipment; and D. may replace, install and operate additional CEMs and CMS, so long as the new or replaced CEMs and CMSs are property certified and comply with Minn. R CHANGES REQUIRING A MODIFICATION TO THE SIP: A. any modification to the design of the equipment that decreases the stack gas volumetric flow rate below that contained in Appendix B; B. any modification to the design of the equipment that decreases the stack gas exit temperature below that contained in Appendix B; C. any modification to the design of the equipment that reduces the stack height below that contained in Appendix B; and D. any construction or modification of structures that increase the effective structual dimensions as they used in the building wake effects alogorithm in the ISC Air Dispersion Model, or its successor. General Operating and Maintenance Requirements for the SIP: The owner or operator shall operate and maintain the process equipment described in Appendix B according to the parameters set forth in Appendix B. The parameters were used in the computer modeling performed to demonstrate that the lead maintenance are attain compliance with the lead NAAQS. Property Access Restrictions: The owner or operator shall limit access to the portion of the property described in the Appendix F with fencing that continuously encloses that portion of the Facility property, excluding access points. The owner or operator shall limit access to the portion of the property indicated in Appendix F with gates at each access point. The owner or operator shall operate security cameras that monitor access to the main gate, shown in Appendix F during office hours. At all other times, the owner or operator shall keep the main gate locked when not in use. At all times, the owner or operator shall keep locked all other gates when not in use. The owner or operator shall post NO TRESPASSING signs at all access points. Property Access Recordkeeping: The owner or operator shall generate and maintain records containing information associated with the Facility property access restrictions requirements. At the minimum, the owner or operator shall retain records containing the following information: 1. Inspections: Records of the date of inspection, name of the person conducting the inspection, identification of each section of fence and each gate inspected, trespassers or evidence of trespassers, and identification of each location where repair or maintenance is required. 2. Repairs: Records of the date of repair or maintenance, a description of the repair and maintenance conducted, and the locations where repair and maintenance occured. and MN State Implementation Plan A-1

6 Operating Restrictions for SIP: 1. FUGITIVES CONTROL: Other lead emission sources at the Facility include building openings, reentrained dust from truck traffic at the Facility and wind erosion of unpaved, or otherwise uncovered, areas on the around the Facility site. The owner or operator shall limit the amount of fugitive lead emissions by, at a minimum, performing the activities indicated below. A. BUILDING OPENINGS: The owner or operator shall keep closed all barriers on outside openings of the Smelting, Raw Material Warehouse and process side of the Raw Material Processing Area, described in Appendix D of this permit, at all times except during ingress and egress through the building opening. The owner or operator shall keep closed all rail loading doors in the Refining area, described in Appendix D of this permit, at all times except when a rail car is being loaded. The owner or operator shall keep closed, at all times except during ingress and egress, all barriers on inside openings that separate areas of the building that are under negative pressure from those that are not under negative pressure, as shown in Appendix E of this permit. (THIS REQUIREMENT WILL BE TERMINATED ON THE DATE EPA APPROVES THE REVISION INTO THE SIP) The owner or operator shall monthly inspect all barriers on outside openings for damage which would result in lead emissions escaping the building. Any time that damage to the outside openings which would result in lead emissions escaping the building is detected, the owner or operator shall repair the damage within two weeks of the detection. The owner or operator shall prevent fugitive lead from emitting through outside openings by operating and maintaining a negative pressure system that puts the areas described in Appendix E under negative pressure, and a ventilation system that collects lead bearing air from the negative pressure areas described in Appendix E of this permit and routes it through a cartridge filter, which is described in Appendix B of this permit. B. SWEEPING The owner or operator shall sweep all paved outdoor areas, as indicated in Appendix J of this permit, with a vacuum equipped road sweeper. If there was a 0.1 inch rainfall during the previous 24 hours, or if these areas are covered with snow the owner or operator is exempt from sweeping uncovered outside areas during the subsequent 24 hours. The owner or operator shall collect manually record rainfall data with an on-site rain gauge. The owner or operator shall immediately (immediately shall mean as soon as is reasonably possible after giving consideration to plant and personnel safety) clean up spills of lead containing materials, flue dust, or slag with a vacuum equipped road sweeper, or by hand vacuuming or wet sweeping. The owner or operator shall store swept lead bearing material in the Raw Meterial Warehouse and recycle the swept lead bearing material in the furnaces, which are described in Appendix B of this permit. C. TRAFFIC LIMITATIONS The owner or operator shall limit mobile equipment traffic to the paved outdoor areas, described in Appendix J, except for lawn mowing equipment on vegetative (grass covered) areas and maintenance and inspection activities. (THIS REQUIREMENT WILL BECOME EFFECTIVE ON THE DATE EPA APPROVES THE REVISION INTO THE SIP.) A-2

7 D. EQUIPMENT HANDLING AND CLEANING Bag and Cartridge Replacement: The owner or operator shall immediately deposit used bags and cartridge filters in leak-proof containers when replacing the baghouse or cartridge filters for the control equipment described in Appendix B. The owner or operator shall recycle the used bags or cartridge filters in the furnaces, which are described in Appendix B of this permit. Mobile Equipment: The owner or operator shall daily clean all mobile equipment used in the containment building. Mobile equipment includes, but not limited to vacuum sweepers, forklifts, and front end loader(s). Cleaning shall be conducted by hand vacuuming, scrubbing or pressure washing with water in the wash bays indicated in Appendix D of this permit. The owner or operator shall keep the barriers on outside openings closed during cleaning. The owner or operator shall keep the barriers material on outside openings closed during cleaning. (THIS REQUIREMENT WILL BE TERMINATED ON THE DATE EPA APPROVES THE REVISION INTO THE SIP.) The owner or operator shall store vacuumed lead bearing material in the Raw Material Warehouse described in Appendix D of this permit, and recycle the vacuumed material in the furnaces, described in Appendix B. The owner or operator shall dispose of any water laden with lead in the Facility Water Treatment Plant. Ventilation System: The owner or operator shall on a monthly basis, inspect the ventilation system for holes and negative static pressure with an electronic or magnehelic pressure gauge. The owner or operator shall clean and/or repair the ventilation systems if there are visible holes. The owner or operator shall monthly test the magnehelic gauges for accuracy, and repair or replace defective gauges as prescribed by the manufacturer. (THIS REQUIREMENT WILL BECOME EFFECTIVE ON THE DATE EPA APPROVES THE REVISION INTO THE SIP.) Hazardous Material: The owner or operator shall store material inside the Facility building. The owner or operator shall apply water to hazardous material prior to loading it into trucks that haul the slag material outside the Facility building. Water application is not required when the air temperature outside is at or below 32 degree F. The owner or operator shall cover all trucks hauling hazardous residue outside the Facility building. E. WIND EROSION PREVENTION Vegetative Cover: The owner or operator shall maintain continuous vegetative cover (grasses) over all areas that are not paved or otherwise continuously covered. Railway Bed: The owner or operator shall maintain continuous railway ballast cover or pavement over the entire railway bed delimited by the Soo Line Railroad easement, which is described in Appendix F of this permit. (THIS REQUIREMENT WILL BE TERMINATED ON THE DATE EPA APPROVES THE REVISION INTO THE SIP.) E. WIND EROSION PREVENTION () Paved Areas: The owner or operator shall retain and maintain all paved roads. Soil Removal: If the owner or operator removes lead bearing soil to comply with Resource Conservation Recovery Act (RCRA) corrective action requirements, the owner or operator shall remove and handle the soil in accordance to a corrective action plan approved by the MPCA Hazardous Waste Program. If as a part of the corrective action plan the owner or operator replaces lead bearing soil with clean fill (without lead) that bars remaining lead bearing soil from exposure to the air, the owner or operator is exempt from vegetative cover, railway bed and paved areas requirements in those areas on which clean fill is in place. Recordkeeping for the MN State Implementation for Lead: Retain all records at the stationary source for a period of five (5) years from the date of the required monitoring, sample, measurement, or report that corresponds with the MN State Implementation Plan Title I Condition. Title I Condition: Recordkeeping for the MN State Implementation Plan (SIP) for Lead Requirements A-3

8 NEGATIVE PRESSURE TESTING: The owner or operator shall monthly conduct Negative Pressure testing in accordance with Appendix H of this permit. B. OPERATIONAL REQUIREMENTS hdr Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C. Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as specified by Minn. R following formal review of a subsequent performance test on the same unit. Performance Test Notifications and Submittals: Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements. Minn. R. ch Minn. R Minn. R , subp. 1-4 and Minn. R , subp. 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 Monitoring Equipment Calibration: Annually calibrate all required monitoring Minn. R , subp. 4(D) equipment (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 Minn. R , subp. 4(D) 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. Circumvention: Do not install or use a device or means that conceals or dilutes Minn. R emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. C. NOTIFICATION REQUIREMENTS hdr 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. Minn. R , subp. 1 Minn. R , subp. 1 A-4

9 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. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. 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 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. Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). 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. Record keeping: 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). 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. The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). Emission Inventory Report: due 91 days after end of each calendar year following permit issuance (April 1). To be submitted on a form approved by the Commissioner. Minn. R , subp. 4 Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R Minn. R through Minn. R Minn. R , subp. 1(H) Minn. R , subp. 5(B) Minn. R , subp. 5(C) Minn. R Minn. R , subp. 16 Minn. R , subp. 9(A) Minn. R through Minn. R Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R through Minn. R COMPLIANCE DATES UNDER 40 CFR 63, subp. X Compliance Date: The owner or operator shall achieve compliance with the requirements of 40 CFR 63, subp. X no later than December 23, Existing sources wishing to apply for an extension of compliance pursuant to section Sec (i) of this part must do so no later than June 23, Gopher Resources applied for a one-year extension and it was approved by the U.S. Environmental Protection Agency on September 12, Gopher Resources achieved compliance with 40 CFR 63, subp. X on December 23, TEST METHODS FOR COMPLIANCE UNDER 40 CFR 63, subp. X (a) The following test methods in appendix A of part 60 listed in paragraphs (a)(1) through (a)(5) of this section shall be used to determine compliance with the emission standards for lead compounds under Secs (a), (c), and (d), and (e): (1) Method 1 shall be used to select the sampling port location and the number of traverse points. (2) Method 2 shall be used to measure volumetric flow rate. (3) Method 3 shall be used for gas analysis to determine the dry molecular weight of the stack gas. (4) Method 4 shall be used to determine moisture content of the stack gas. (5) Method 12 shall be used to determine compliance with the lead compound emission standards. The minimum sample volume shall be 0.85 dry standard cubic meters (30 dry standard cubic feet) and the minimum sampling time shall be 60 minutes for each run. Three runs shall be performed and the average of the three runs shall be used to determine compliance. hdr 40 CFR Section (a) hdr 40 CFR Section (a) A-5

10 (b) The following tests methods in appendix A of part 60 listed in paragraphs (b)(1) through (b)(4) of this section shall be used, as specified, to determine compliance with the emission standards for total hydrocarbons Sec (c), (d), (e), and (g). (1) Method 1 shall be used to select the sampling port location to determine compliance under Sec (c), (d), (e), and (g). (2) The Single Point Integrated Sampling and Analytical Procedure of Method 3B shall be used to measure the carbon dioxide content of the stack gases to determine compliance under Sec (c), (d), and (e). (3) Method 4 shall be used to measure moisture content of the stack gases to determine compliance under Sec (c), (d), (e), and (g). (4) Method 25A shall be used to measure total hydrocarbon emissions to determine compliance under Sec (c), (d), (e), and (g). The minimum sampling time shall be 1 hour for each run. A minimum of three runs shall be performed. A 1-hour average total hydrocarbon concentration shall be determined for each run and the average of the three 1-hour averages shall be used to determine compliance. The total hydrocarbon emissions concentrations for determining compliance under Sec (c), (d), and (e) shall be expressed as propane and shall be corrected to 4 percent carbon dioxide, as described in paragraph (c) of this section. (c) For the purposes of determining compliance with the emission limits under Sec (c), (d), and (e), the measured total hydrocarbon concentrations shall be corrected to 4 percent carbon dioxide as listed in paragraphs (c)(1) through (c)(2) of this section in the following manner: (1) If the measured percent carbon dioxide is greater than 0.4 percent in each compliance test, the correction factor shall be determined by using equation (1). F= (4.0/CO2) where: F = correction factor (no units) CO2 = percent carbon dioxide measured using Method 3B, where the measured carbon dioxide is greater than 0.4 percent. (2) If the measured percent carbon dioxide is equal to or less than 0.4 percent, then a correction factor (F) of 10 shall be used. (3) The corrected total hydrocarbon concentration shall be determined by multiplying the measured total hydrocarbon concentration by the correction factor (F) determined for each compliance test. (e) Owners and operators shall determine compliance with the doorway in-draft requirement for enclosed buildings in Sec (b) using the procedures in paragraphs (e)(1) or (e)(2) of this section. (1)(i) Owners and operators shall use a propeller anemometer or equivalent device meeting the requirements of paragraphs (d)(2)(ii) through (d)(2)(iv) of this section. (ii) Doorway in-draft shall be determined by placing the anemometer in the plane of the doorway opening near its center. (iii) Doorway in-draft shall be demonstrated for each doorway that is open during normal operation with all remaining doorways in the position they are in during normal operation. RECORDKEEPING AND REPORTING REQUIREMENTS FOR 40 CFR 63, subpart X (a) The owner or operator of a secondary lead smelter shall comply with all of the recordkeeping requirements under Sec of the General Provisions. In addition, each owner or operator of a secondary lead smelter shall maintain for a period of 5 years, records of the information listed in paragraphs (a)(1) through (a)(6) of this section. (1) An identification of the date and time of all bag leak detection system alarms, their cause, and an explanation of the corrective actions taken. (2) Monitoring the reverberatory natural gas flow on a continuous basis. (4) Any recordkeeping required as part of the practices described in the standard operating procedures manual required under Sec (a) for the control of fugitive dust emissions. (5) Any recordkeeping required as part of the practices described in the standard operating procedures manual for baghouses required under Sec (a). 40 CFR Section (b) 40 CFR Section (b) 40 CFR Section (c) 40 CFR Section (c) 40 CFR Section (e) hdr 40 CFR Section (a) A-6

11 (b) The owner or operator of a secondary lead smelter shall comply with all of the reporting requirements under Sec of the General Provisions. The submittal of reports shall be no less frequent than specified under Sec (e)(3) of the General Provisions. Once a source reports a violation of the standard or excess emissions, the source shall follow the reporting format required under Sec (e)(3) until a request to reduce reporting frequency is approved. (c) In addition to the information required under Sec of the General Provisions, reports required under paragraph (b) of this section shall include the information specified in paragraphs (c)(1) through (c)(6) of this section. (1) The reports shall include records of all alarms from the bag leak detection system specified in Sec (e). (2) The reports shall include a description of the procedures taken following each bag leak detection system alarm pursuant to Sec (f)(1) and (2). (4) The reports shall contain a summary of the records maintained as part of the practices described in the standard operating procedures manual for baghouses required under Sec (a), including an explanation of the periods when the procedures were not followed and the corrective actions taken. (6) The reports shall contain a summary of the fugitive dust control measures performed during the required reporting period, including an explanation of the periods when the procedures outlined in the standard operating procedures manual pursuant to Sec (a) were not followed and the corrective actions taken. The reports shall not contain copies of the daily records required to demonstrate compliance with the requirements of the standard operating procedures manuals required under Secs (a) and (a). 40 CFR Section (b) and (c) 40 CFR Section (c) A-7

12 Subject Item: Associated Items: GP 001 East Reverberatory and Blast Furnace subject to NESHAPs, subp. X CE 004 Fabric Filter - High Temperature, i.e., T>250 Degrees F CE 005 Fabric Filter - High Temperature, i.e., T>250 Degrees F CE 007 Afterburner EU 007 East Reverberatory Furnace EU 009 Blast Furnace SV 003 Main Stack EMISSION LIMITS What to do hdr Why to do it Lead Compounds: less than grains/dry standard cubic foot using 3-hour Average (3-hour arithmetic average) for East Reverberatory and Blast Furnace [2.0 milligrams per dry standard cubic meter (mg/dscm)] THC (Total Hydrocarbons): less than 20 parts per million by volume, expressed as propane corrected to 4 percent carbon dioxide to correct for dilution, based on a 3-hour arithmetic average. This limit applies during the periods when the collocated blast furnace and reverberatory furnaces are both operating. THC (Total Hydrocarbons): less than 360 parts per million by volume, expressed as propance corrected to 4 percent carbon dioxide to correct for dilution, based on a 3-hour arithmetic average. This limit is based on during the periods when the reveberatory furnace is not operating. PERFORMANCE TESTING REQUIREMENTS Performance Test: due before end of each calendar year starting 11/30/1999 to measure for lead compounds. Performance test is also due biannually if the test result for lead is less than 1 milligram per dry standard cubic meter (mg/dscm). MONITORING REQUIREMENTS FOR AFTERBURNER Methodology: The owner or operator shall calculate 3-hour arithmetic average of the natural gas usage and the afterburner temperature from the 15-minute readings. The compliance demonstration shall follow the test protocol, and show compliance with the 20 ppm THC standard when the blast furnace and the east reverberatory furnace both operate. Whenever the blast furnance and the east reverberatory furnace both operating to show compliance with the THC standard of 20 ppm, Gopher Resource shall: 40 CFR Section (a) 40 CFR Section (c) 40 CFR Section (c) hdr 40 CFR Section (f) hdr 40 CFR Section 63.8 (f) [Alternative Monitoring Method] 40 CFR Section 63.8 (f) [Alternative Monitoring Method] 1. Maintain the natural gas usage at or above the arithmetic average established in most recent EPA and MPCA approved compliance test. OR 2. Maintain the propane usage at or above the arithmetic average established in most recent EPA and MPCA approved compliance test. Gopher Resource shall continuously record and monitor the natural gas or propane usage for the east reverberatory furnance. Reporting: The owner or operator shall report to U.S. EPA and copy to the MPCA on a semiannually basis whether any 3-hour arithmetic average natural gas usage or propane usage is less than the arithmetic average established in the most EPA and MPCA approved compliance test. Once any 3-hour usage is less than the established average, report on a quarterly basis until a request to reduce reporting frequency is approved by the EPA. Calibration of Continuous Monitoring Device: The Company shall service and calibrate the monitoring instrument at 1-year intervals and keep records of all calibrations for at least 5 years. 40 CFR Section 63.8 (f) [Alternative Monitoring Method] 40 CFR Section (f)[Alternative Monitoring Method] 40 CFR Section 63.8 (f) [Alternative Monitoring Method] A-8

13 Subject Item: Associated Items: GP 002 Process Fugitive Sources subject to NESHAPs, subp. X CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F FS 001 Furnace Area FS 002 West Reverberatory Furnace FS 003 East Reverberatory Furnace FS 004 Blast Furnace FS 005 Casting SV 002 Fugitive Emissions from Raw Material Handling, Blast Furnace and Reverb Furnace Areas EMISSION LIMIT What to do hdr Why to do it Lead Compounds: less than or equal to grains/dry standard cubic foot using 3-hour Average ( 3-hour arithmetic average). The ventilation air from all enclosures hoods and total enclosures shall be conveyed to a control device. Process Fugitive Emission Sources: shall be located in a total enclosure subject to general ventilation that maintain the building at a lower than ambient pressure to ensure in-draft through any doorway opening. PERFORMANCE TESTING REQUIREMENT Performance Test: due before end of each year starting 11/30/1999 to measure for lead compounds. Performance test is also due biannually if the test result for lead is less than 1 milligram per dry standard cubic meter (mg/dscm). 40 CFR Section (c) 40 CFR Section (b) hdr 40 CFR Section (f) A-9

14 Subject Item: Associated Items: GP 004 Control Equipment for the Process and Fugitive Sources CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 004 Fabric Filter - High Temperature, i.e., T>250 Degrees F CE 005 Fabric Filter - High Temperature, i.e., T>250 Degrees F What to do Pressure Drop: greater than or equal to 1.0 inches of water column and less than or equal to 10.0 inches of water column (for Control Equipment (CE 004)) Pressure Drop: greater than or equal to 1.0 inches of water column and less than or equal to 10 inches of water column (for Control Equiment (CE 005)) Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 15.0 inches of water column (for Control Equipment (CE 002)) Pressure Drop: greater than or equal to 0.5 inches of water column and less than 15.0 inches of water column (for Control Equipment (CE 003)) Air Pollution Control Equipment Monitors: The owner or operator shall operate and maintain pressure drop gauges and broken media detectors, which are described in Appendix B, to measure pressure drop across the cartridge filters and baghouse cells in inches of water and an increase in particulate grain loading at each baghouse and cartridge filter outlet. each broken media detector shall be equipped with a device that continually records grain loading, and an alarm that alerts the owner or operator personnel of increases in grain loading. Why to do it Alarm Triggers: In the event that the alarm on a broken media detector is triggered, the owner or operator shall immediately isolate the cartridge bank or baghouse cell for which the alarm was triggered as described in Appendix G of this permit. Broken media detectors are not required for cartridge collectors while controlling fugitive sources. (THIS REQUIREMENT WILL BECOME EFFECTIVE THE DATE EPA APPROVES THE REVISION INTO THE SIP.) MONITORING REQUIREMENTS FOR CONTROL EQUIPMENT UNDER 40 CFR 63, SUBPART X (a) Owners and operators of secondary lead smelters shall prepare, and at all times operate according to, a standard operating procedures manual that describes in detail procedures for inspection, maintenance, and bag leak detection and corrective action plans for all baghouses (fabric filters) that are used to control process, process fugitive, or fugitive dust emissions from any source subject to the lead emission standards in Secs , , and , including those used to control emissions from building ventilation. This provision shall not apply to process fugitive sources that are controlled by wet scrubbers. and MN State Implementation Plan hdr 40 CFR Section (a) and (b) (b) The standard operating procedures (SOP) manual for baghouses required by paragraph (a) of this section shall be submitted to the Administrator or delegated authority for review and approval. (c) The procedures specified in the standard operating procedures manual for inspections and routine maintenance shall, at a minimum, include the requirements of paragraphs (c)(1) through (c)(9) of this section. (1) Daily monitoring of pressure drop across each baghouse cell. (2) Weekly confirmation that dust is being removed from hoppers through visual inspection, or equivalent means of ensuring the proper functioning of removal mechanisms. (3) Daily check of compressed air supply for pulse-jet baghouses. (4) An appropriate methodology for monitoring cleaning cycles to ensure proper operation. (5) Monthly check of bag cleaning mechanisms for proper functioning through visual inspection or equivalent means. (6) Monthly check of bag tension on reverse air and shaker-type baghouses. Such checks are not required for shaker-type baghouses using self-tensioning (spring loaded) devices. 40 CFR Section (c) A-10

15 (7) Quarterly confirmation of the physical integrity of the baghouse through visual inspection of the baghouse interior for air leaks. (8) Quarterly inspection of fans for wear, material buildup, and corrosion through visual inspection, vibration detectors, or equivalent means. (9) Except as provided in paragraphs (g) and (h) of this section, continuous operation of a bag leak detection system. (d) The procedures specified in the standard operating procedures manual for maintenance shall, at a minimum, include a preventative maintenance schedule that is consistent with the baghouse manufacturer's instructions for routine and long-term maintenance. (e) The bag leak detection system required by paragraph (c)(9) of this section, shall meet the specification and requirements of paragraphs (e)(1) through (e)(8) of this section. (1) The bag leak detection system must be certified by the manufacturer to be capable of detecting particulate matter emissions at concentrations of 10 milligram per actual cubic meter ( grains per actual cubic foot) or less. (2) The bag leak detection system sensor must provide output of relative particulate matter loadings. (3) The bag leak detection system must be equipped with an alarm system that will alarm when an increase in relative particulate loadings is detected over a preset level. (4) The bag leak detection system shall be installed and operated in a manner consistent with available written guidance from the U.S. Environmental Protection Agency or, in the absence of such written guidance, the manufacturer's written specifications and recommendations for installation, operation, and adjustment of the system. (5) The initial adjustment of the system shall, at a minimum, consist of establishing the baseline output by adjusting the sensitivity (range) and the averaging period of the device, and establishing the alarm set points and the alarm delay time. (6) Following initial adjustment, the owner or operator shall not adjust the sensitivity or range, averaging period, alarm set points, or alarm delay time, except as detailed in the approved SOP required under paragraph (a) of this section. In no event shall the sensitivity be increased by more than 100 percent or decreased more than 50 percent over a 365 day period unless such adjustment follows a complete baghouse inspection which demonstrates the baghouse is in good operating condition. (7) For negative pressure, induced air baghouses, and positive pressure baghouses that are discharged to the atmosphere through a stack, the bag leak detector must be installed downstream of the baghouse and upstream of any wet acid gas scrubber. (8) Where multiple detectors are required, the system's instrumentation and alarm may be shared among detectors. (f) The standard operating procedures manual required by paragraph (a) of this section shall include a corrective action plan that specifies the procedures to be followed in the case of a bag leak detection system alarm. The corrective action plan shall include, at a minimum, the procedures used to determine and record the time and cause of the alarm as well as the corrective actions taken to correct the control device malfunction or minimize emissions as specified in paragraphs (f)(1) and (f)(2) of this section. (1) The procedures used to determine the cause of the alarm must be initiated within 30 minutes of the alarm. (2) The cause of the alarm must be alleviated by taking the necessary corrective action(s) which may include, but not be limited to, paragraphs (f)(2)(i) through (f)(2)(vi) of this section. (i) Inspecting the baghouse for air leaks, torn or broken filter elements, or any other malfunction that may cause an increase in emissions. (ii) Sealing off defective bags or filter media. (iii) Replacing defective bags or filter media, or otherwise repairing the control device. (iv) Sealing off a defective baghouse compartment. (v) Cleaning the bag leak detection system probe, or otherwise repairing the bag leak detection system. (vi) Shutting down the process producing the particulate emissions. 40 CFR Section (c) and (d) 40 CFR Section (e) 40 CFR Section (e) 40 CFR Section (e) 40 CFR Section (f) 40 CFR Section (f) A-11

16 (h) Baghouses that are used exclusively for the control of fugitive dust emissions from any source subject to the lead emissions standard in Sec are exempt from the requirement in Sec (c)(9) of this section to be equipped with a bag leak detector. j) The owner or operator of a blast furnace or collocated blast furnace and reverberatory furnace subject to the total hydrocarbon standards in Sec (c), (d), or (e), must comply with the requirements of either paragraph (j)(1) or (j)(2) of this section, to demonstrate continuous compliance with the total hydrocarbon emission standards. 40 CFR Section (h) 40 CFR Section (j) Gopher proposed an alternative monitoring plan of monitoring reverberatory natural gas flow instead of continuous temperature. This plan was approved by the EPA. A-12

17 Subject Item: Associated Items: GP 005 Emergency Diesel Generators EU 023 Diesel-Powered Electrical Generator EU 024 Diesel-Powered Electrical Generator SV 006 Diesel Electrical Generator SV 007 Diesel Electrical Generator EMISSION LIMITS What to do hdr Why to do it Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input Minn. R , subp. 2 Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained (visible air contaminants) OTHER LIMITS AND REQUIREMENTS Minn. R , subp. 1 hdr Fuel Restriction: Burn diesel fuel only Minn. R , subp. 2 Operating Hours: less than or equal to 500 hours/year using 12-month Rolling Sum Recordkeeping of Fuel Restriction: The Permittee shall record and maintain records of the amount of fuel combustion in the units on a monthly basis by the 15th day of each month for the previous month. The record shall be in the form of fuel bills or meter reading, for example. Recordkeeping for Operating Hours: The Permitteee shall calculate and record the 12-month rolling sum of the hours of operation by 15th day of each month for the previous month. Minn. R , subp. 2; EPA Policy Memo dated September 6, 1995 Minn. R , subp. 5 Minn. R , subp. 5 A-13

18 Subject Item: SV 002 Fugitive Emissions from Raw Material Handling, Blast Furnace and Reverb Furnace Areas Associated Items: EU 002 Raw Material Handling Operation EU 011 Refining Kettle No. 1 EU 012 Refining Kettle No. 2 EU 013 Refining Kettle No. 3 EU 014 Refining Kettle No. 4 EU 015 Refining Kettle No. 5 EU 016 Refining Kettle No. 6 EU 017 Refining Kettle No. 7 EU 018 Refining Kettle No. 8 EU 019 Refining Kettle No. 9 EU 020 Refining Kettle No. 10 GP 002 Process Fugitive Sources subject to NESHAPs, subp. X What to do Why to do it Lead: less than grains/dry standard cubic foot using 3-hour Average Opacity: less than or equal to 5 percent opacity Lead Compounds: less than grains/dry standard cubic foot using 3-hour Average ( 3-hour arithmetic average) from any gases into the atmosphere from any building or enclosure ventilation system. [ 2.0 mg/dscm] PERFORMANCE TESTING REQUIREMENT 40 CFR Section (e) hdr Performance Test: due before end of each calendar year starting 11/30/1999 to measure for lead emissions and opacity. OPERATIONAL REQUIREMENTS UNDER 40 CFR 63, subp. X (a) Each owner or operator of a secondary lead smelter shall prepare and at all times operate according to a standard operating procedures manual that describes in detail the measures that will be put in place to control fugitive dust emission sources within the areas of the secondary lead smelter listed in paragraphs (1) through (5) of this section. (1) Plant roadways; (2) Battery breaking area; (3) Furnace area; (4) Refining and casting area; and (5) Materials storage and handling area. (b) The standard operating procedures manual shall be submitted to the Administrator or delegated authority for review and approval. c) The controls specified in the standard operating procedures manual shall at a minimum include the requirements of paragraphs (c)(1) through (c)(5) of this section. (1) Plant roadways--paving of all areas subject to vehicle traffic and pavement cleaning twice per day of those areas, except on days when natural precipitation makes cleaning unnecessary or when sand or a similar material has been spread on plant roadways to provide traction on ice or snow. (2) Battery breaking area--partial enclosure of storage piles, wet suppression applied to storage piles with sufficient frequency and quantity to prevent the formation of dust, and pavement cleaning twice per day; or total enclosure of the battery breaking area. (3) Furnace area--partial enclosure and pavement cleaning twice per day; or total enclosure and ventilation of the enclosure to a control device. hdr 40 CFR Section (a) 40 CFR Section (b) 40 CFR Section (c) A-14

19 (4) Refining and casting area--partial enclosure and pavement cleaning twice per day; or total enclosure and ventilation of the enclosure to a control device. (5) Materials storage and handling area--partial enclosure of storage piles, wet suppression applied to storage piles with sufficient frequency and quantity to prevent the formation of dust, vehicle wash at each exit from the area, and paving of the area; or total enclosure of the area and ventilation of the enclosure to a control device, and a vehicle wash at each exit. Standard Operating Procedures (SOP) Manual: The SOP manual shall require that daily records be maintained of all wet suppression, pavement cleaning, and vehicle washing activities performed to control fugitive dust emissions. 40 CFR Section (c) 40 CFR Section (d) A-15