Air Individual Permit Part 70 Reissuance for Imperial

Air Individual Permit Part 70 Reissuance 06500002‐ 002

Permittee: Imperial Plastics Inc

Facility name: Imperial Plastics Inc 1020 Maple Ave E Mora, MN 55051 Kanabec County

Expiration date: January 26, 2021 * All Title I Conditions do not expire Part 70 Reissuance: January 26, 2016 Permit characteristics: Federal; Part 70/ Limits to avoid NSR; Limits to avoid NSR *The Permittee may continue to operate this facility after the expiration date of the permit, per the provision under Minn. R. 7007.0450, subp. 3. The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the Permit Applications Table. This permit reissuance supersedes Air Emission Permit No. 06500002‐01 and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in the permit. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. 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 § 52.1220 and as such as are enforceable by EPA Administrator or citizens under the Clean Air Act.

Signature: Carolina Espejel-Schutt This document has been electronically signed. for the Minnesota Pollution Control Agency

for Don Smith, P.E., Manager Air Quality Permits Section

Industrial Division

Table of Contents

Page

1. Permit applications table ............................................................................................................................................. 1 2. Where to send submittals ............................................................................................................................................ 2 3. Facility description ....................................................................................................................................................... 3 4. Summary of subject items ........................................................................................................................................... 4 5. Limits and other requirements .................................................................................................................................... 6 6. Submittal/action requirements ................................................................................................................................. 27 7. Compliance schedule ................................................................................................................................................. 29 8. Appendices ................................................................................................................................................................. 30

Appendix A. Insignificant Activities and General Applicable Requirements ............................................................ 30 Appendix B: 40 CFR pt. 63, subp. PPPP Compliance Equations ............................................................................... 32 Appendix C: GP001 Maximum Content of Materials Assumptions ......................................................................... 35

Permit issued: January 26, 2016 06500002‐ 002 Permit expires: January 26, 2021 Page 1 of 35

1. Permit applications table Title description Application receipt date Action number Administrative Amendment 02/11/2002 06500002‐002 Notification 03/31/05 06500002‐002 Part 70 Reissuance 01/13/2006 06500002‐002


2. Where to send submittals

Send submittals that are required to be submitted to the U.S. EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by Minn. R. 7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, 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. 20460

Send any application for a permit or permit amendment to:

Fiscal Services – 6th Floor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155‐4194

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of:

a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155‐4194


3. Facility description The Imperial Plastics Inc (Facility) is located at 1020 Maple Ave E in Mora, MN, Kanabec County, Minnesota.

Imperial Plastics Incorporated (IPI or the facility) operates a plastic parts manufacturing plant in Mora, Minnesota. The facility’s operations include injection molding, spray painting, sanding, grinding, boilers, and several small natural gas combustion sources (e.g., ovens and furnaces). The facility has taken limits on coating operations to avoid major source status under 40 CFR Section 52.21 for volatile organic compounds (VOCs), particulate matter less than ten microns (PM10), and particulate matter less than 2.5 microns (PM2.5). The facility has also accepted limits with Permit Action 002 to limit total and single hazardous air pollutants (HAPs) to below major source threshold levels. Particulate matter emissions from the coating booths are controlled by panel filters.


4. Summary of subject items

SI ID: Description

Relationship Type

Related SI ID: Description

ACTV3: COMG3: Indirect Heating Units

has members

EQUI7, EQUI8, EQUI19

COMG4: Coating Booth Limits

has members

EQUI2, EQUI3, EQUI4, EQUI5, EQUI18, EQUI20

COMG6: 40 CFR pt. 63 subp. PPPP

has members

EQUI2, EQUI3, EQUI4, EQUI5, EQUI18

COMG7: Paint Filters

has members

TREA12, TREA13, TREA14, TREA15, TREA16

EQUI17: Dryer/Oven ‐ Main

sends to STRU9: Dryer/Oven ‐ Main

EQUI18: Spray Booth/Coating Line ‐ Batch Booth

sends to STRU14: Batch Booth

EQUI18: Spray Booth/Coating Line ‐ Batch Booth

is controlled by

TREA16: Mat or Panel Filter

EQUI19: Thermal Unit ‐ Andersen Air Make Up Unit

sends to STRU15: Andersen Air Make Up

EQUI20: Cleaning Solvents for Spray Booths/Coating Lines

EQUI2: Spray Booth/Coating Line 1 (main)

sends to STRU19: Booth #1 (Main Line)


is controlled by





is controlled by




EQUI4: Spray is controlled TREA14: Mat or

SI ID: Description

Relationship Type


Booth/Coating Line 3 (main)

by Panel Filter




is controlled by


EQUI6: Boiler 2 sends to STRU18: Boiler #2

EQUI7: Boiler 1 sends to STRU17: Boiler #1

EQUI8: Thermal Unit ‐ Paint Line Air Make Up Unit

sends to STRU16: Main Paint Line Air Make Up

STRU13: Booth #4 (Main Line)

STRU14: Batch Booth

STRU15: Andersen Air Make Up

STRU16: Main Paint Line Air Make Up

STRU17: Boiler #1 STRU18: Boiler #2 STRU19: Booth #1 (Main Line)

STRU1: Main, smaller press room.



STRU2: Houses the paintline and finishing areas

STRU5: Sand on line STRU9: Dryer/Oven ‐ Main

TFAC1: Imperial Plastics Inc





SI ID: Description

Relationship Type



TREA16: Mat or

SI ID: Description

Relationship Type


Panel Filter

Permit Issued: January 26, 2016 06500002‐ 002 Permit Expires: January 26, 2021 Page 6 of 35

5. Limits and other requirements Subject Item Sec.SI.Reqt SI des:SI desc Requirement & CitationTFAC 1 06500002 Imperial Plastics

Inc 5.1.1 PERMIT SHIELD: Subject to the limitations in Minn. R.

7007.1800, 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. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R. 7007.1800, (A)(2)]

5.1.2 Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendices A, B and C. [Minn. R. 7007.0800, subp. 2]

5.1.3 The Permittee currently uses ozone‐depleting substances as defined in 40 CFR pt. 82. Sections 601‐618 of the 1990 Clean Air Act Amendments and 40 CFR pt. 82 may apply to the facility. Read Sections 601‐618 and 40 CFR pt. 82 to determine all the requirements that apply to the facility. [40 CFR pt. 82]

5.1.4 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. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1‐2, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.5 Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. [Minn. R. 7011.0020]

5.1.6 Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated unless otherwise noted in this permit. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 2]

5.1.7 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


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citationpractices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J)]

5.1.8 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R. 7019.1000, subp. 4]

5.1.9 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. 7011.0150. [Minn. R. 7011.0150]

5.1.10 Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R. 7030.0010‐7030.0080]

5.1.11 Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). [Minn. R. 7007.0800, subp. 9(A)]

5.1.12 The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. [Minn. R. 7007.0800, subp. 16]

5.1.13 Monitoring Equipment Calibration ‐ The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. [Minn. R. 7007.0800, subp.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation4(D)]

5.1.14 Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. [Minn. R. 7007.0800, subp. 4(D)]

5.1.15 Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, [or at another location identified here] for a period of five (5) years [or another longer time frame] 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. 7007.0800, subp. 5(A). [Minn. R. 7007.0800, subp. 5(C)]

5.1.16 Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. [Minn. R. 7007.0800, subp. 5(B)]

5.1.17 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. 7007.1200. 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. [Minn. R. 7007.1200, subp. 4]

5.1.18 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. 7019.1000, 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


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & CitationCommissioner when the shutdown is over. [Minn. R. 7019.1000, subp. 3]

5.1.19 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. 7019.1000, subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R. 7019.1000, subp. 2]

5.1.20 Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R. 7019.1000, subp. 1]

5.1.21 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. 7019.1000, subp. 1]

5.1.22 Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed. 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. 7007.0400, subp. 3. [Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 ‐


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation7007.1500]

5.1.23 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. 7007.1400, 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. 7007.1400, subp. 1(H). [Minn. R. 7007.1400, subp. 1(H)]

5.1.24 Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance, to be submitted on a form approved by the Commissioner. [Minn. R. 7019.3000‐7019.3100]

5.1.25 Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005‐7002.0095]

COMG 3 GP003 Indirect Heating

Units 5.2.1 Total Particulate Matter <= 0.60 pounds per million Btu heat

input 3‐hour average This limit applies individually to each indirect heating unit. The PM potential to emit from each unit is 0.0072 lb/MMBtu due to equipment design and allowable fuel. [Minn. R. 7011.0510, subp. 1]

5.2.2 Opacity <= 20.0 percent opacity except for one six‐minute period per hour of not more than 60 percent opacity. This limit applies individually to each indirect heating unit. [Minn. R. 7011.0510, subp. 2]

5.2.3 Fuel type: Natural gas only [Minn. R. 7005.0100, subp. 35a] COMG 4 GP001 Coating Booth

Limits 5.3.1 The Permittee shall limit emissions of Volatile Organic

Compounds <= 196 tons per year 12‐month rolling sum to be calculated by the 15th day of each month for the previous 12‐month period as described later in this permit. VOC contents for each VOC‐containing material shall be determined as described under the Material Content requirement at COMG4. The calculation of VOCs used may take into account recovered/recycled VOCs as described under the Waste Credit requirement at COMG4. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.3.2 The Permittee shall limit emissions of PM < 10 micron <= 225 tons per year 12‐month rolling sum to be calculated by the 15th day of each month for the previous 12‐month period as described later in this permit.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation

Solids contents for each material shall be determined as described under the Material Content requirement at COMG4. The calculation of solids used may take into account recovered/recycled solids as described under the Waste Credit requirement at COMG4. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.3.3 The Permittee shall limit emissions of PM < 2.5 micron <= 225 tons per year 12‐month rolling sum to be calculated by the 15th day of each month for the previous 12‐month period as described later in this permit. Solids contents for each material shall be determined as described under the Material Content requirement at COMG4. The calculation of solids used may take into account recovered/recycled solids as described under the Waste Credit requirement at COMG4. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.3.4 The Permittee shall vent emissions from all spray booths to control equipment meeting the requirements of COMG7. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.3.5 The Permittee shall limit emissions of HAPs ‐ Total <= 22.0 tons per year 12‐month rolling sum to be calculated by the 15th day of each month for the previous 12‐month period. HAP contents for each HAP‐containing material (i.e. coatings, gun cleaner,...) shall be determined as described under the Material Content requirement at COMG4. The calculation of HAPs used may take into account recovered/recycled HAPs as described under the Waste Credit requirement at COMG4. [Title I Condition: Avoid major source under 40 CFR 63.2]

5.3.6 The Permittee shall limit emissions of HAPs ‐ Single <= 9.0 tons per year 12‐month rolling sum to be calculated by the 15th day of each month for the previous 12‐month period. HAP contents for each HAP‐containing material (i.e. coatings, gun cleaner,...) shall be determined as described under the Material Content requirement COMG4. The calculation of HAPs used may take into account recovered/recycled HAPs as described under the Waste Credit requirement at COMG4. [Title I Condition: Avoid major source under 40 CFR 63.2]

5.3.7 Total Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. This limit applies separately to each emission unit in COMG4. The PM PTE for a COMG4 unit does not exceed 0.022 gr/dscf. [Minn. R. 7011.0715, subp. 1(A)]


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.3.8 Opacity <= 20 percent opacity. This limit applies separately to

each emission unit in COMG4. [Minn. R. 7011.0715, subp. 1(B)] 5.3.9 Daily Recordkeeping. On each day of operation, the Permittee

shall calculate, record, and maintain the total quantity of all coatings and other VOC, solids, and HAP‐containing materials used at the COMG4 emission units. This record shall be based on written usage logs and shall indicate the part number of the VOC, solids, or HAP‐containing material and the quantity used or dispensed from the central storage room. [Minn. R. 7007.0800, subps. 4‐5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.3.10 Volatile Organic Compounds: Monthly Recordkeeping. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total usage of VOC‐containing materials for the previous calendar month using the daily usage records. This record shall also include the VOC and solids contents of each material as determined by the Material Content requirement of this permit; 2) The VOC emissions for the previous month using the formulas specified in this permit; and 3) The 12‐month rolling sum VOC emissions for the previous 12‐month period by summing the monthly VOC emissions data for the previous 12 months. [Minn. R. 7007.0800, subps. 4‐5]

5.3.11 Volatile Organic Compounds: Monthly Calculations.The Permittee shall calculate VOC emissions using the following equations: VOC (tons/month) = V ‐ W V = (A1 x B1) + (A2 x B2) + (A3 x B3) + ..... W = (C1 x D1) + (C2 x D2) + (C3 x D3) + ..... where: V = total VOC used in tons/month; A# = amount of each VOC‐containing material used, in tons/month; B# = weight percent VOC in A#, as a fraction; W = the amount of VOC shipped in waste, in tons/month; C# = amount, in tons/month, of each VOC‐containing waste material shipped. If the Permittee chooses to not take credit for waste shipments, this parameter would be zero; and D# = weight percent of VOC in C#, as a fraction. [Minn. R. 7007.0800, subps. 4‐5]

5.3.12 HAPs: Monthly Recordkeeping. By the 15th of the month, the Permittee shall calculate and record the following using the formulas specified in this permit: 1) The total HAP‐containing materials used in the previous


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citationcalendar month using the daily usage records. This record shall also include the individual and total HAP contents of each HAP‐containing material used in the previous month, as determined by the Material Content requirement of this permit; 2) The total and individual HAP emissions for the previous month using the formulas specified in this permit; and 3) The 12‐month rolling sum total and individual HAP emissions for the previous 12‐month period by summing the monthly emissions data for the previous 12 months. [Minn. R. 7007.0800, subps. 4‐5]

5.3.13 HAPs: Monthly Calculation ‐‐ HAP Emissions. The Permittee shall calculate each individual HAP and total HAP emissions using the following equations: HAP Emissions (tons/month) = H ‐ W H = (A1 x B1) + (A2 x B2) + (A3 x B3) + .... W = (C1 x D1) + (C2 x D2) + (C3 x D3) + .... Where: H = the amount of each pollutant (either total HAP or each individual HAP), used, in tons/month. A# = Amount of each HAP‐containing material used in the previous month, in tons/month. B# = weight percent of each individual or total HAP in A#, as a fraction (e.g., 50% is 0.50). W = the amount of each pollutant (either total HAP or each individual HAP) shipped in waste, in tons/month. C# = amount, in tons/month, of each HAP‐containing waste material shipped. If the Permittee chooses to not take credit for waste shipments, this parameter would be zero. D# = weight percent of each individual or total HAP in C#, as a fraction. [Minn. R. 7007.0800, subps. 4‐5]

5.3.14 PM < 10 micron: Monthly Recordkeeping. By the 15th of the month, the Permittee shall calculate and record the following:1) The total usage of each solids‐containing material for the previous calendar month using the daily usage records. This record shall also include solids contents of each material as determined by the Material Content requirement of this permit; 2) The PM10 emissions for the previous month using the formulas specified in this permit; and 3) The 12‐month rolling sum PM10 emissions for the previous


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation12‐month period by summing the monthly PM10 emissions data for the previous 12 months. [Minn. R. 7007.0800, subps. 4‐5]

5.3.15 PM < 10 micron: Monthly Calculation. The Permittee shall calculate PM10 emissions from the spray booths using the following equations: PM10 (tons/month) = S(1‐CE)(1‐TE) ‐ W S = (A1 x B1) + (A2 x B2) + (A3 x B3) + ..... W = (C1 x D1) + (C2 x D2) + (C3 x D3) + ...... Where: S = total solids used in tons/month; CE = overall control efficiency, as a fraction. This shall be 0.68 for all spray booths; TE = transfer efficiency, as a fraction. This shall be 0.30, for all spray booths. A# = amount of each solids‐containing material sprayed, in tons/month; B# = weight percent solids in A#, as a fraction; W = the amount of solids shipped in waste, in tons/month; C# = amount, in tons/month, of each solids‐containing waste material shipped. If the Permittee chooses to not take credit for waste shipments, this parameter would be zero; and D# = weight percent of solids in C#, as a fraction. [Minn. R. 7007.0800, subps. 4‐5]

5.3.16 PM < 2.5 micron: Monthly Recordkeeping. By the 15th of the month, the Permittee shall calculate and record the following:1) The total usage of each solids‐containing material for the previous calendar month using the daily usage records. This record shall also include solids contents of each material as determined by the Material Content requirement of this permit; 2) The PM10 emissions for the previous month using the formulas specified in this permit; and 3) The 12‐month rolling sum PM2.5 emissions for the previous 12‐month period by summing the monthly PM2.5 emissions data for the previous 12 months. [Minn. R. 7007.0800, subps. 4‐5]

5.3.17 PM < 2.5 micron: Monthly Calculation. The Permittee shall calculate PM2.5 emissions from the spray booths using the following equations: PM2.5 (tons/month) = S(1‐CE)(1‐TE) ‐ W S = (A1 x B1) + (A2 x B2) + (A3 x B3) + ..... W = (C1 x D1) + (C2 x D2) + (C3 x D3) + ...... Where: S = total solids used in tons/month;


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & CitationCE = overall control efficiency, as a fraction. This shall be 0.68 for all spray booths; TE = transfer efficiency, as a fraction. This shall be 0.30 for all spray booths. A# = amount of each solids‐containing material sprayed, in tons/month; B# = weight percent solids in A#, as a fraction; W = the amount of solids shipped in waste, in tons/month; C# = amount, in tons/month, of each solids‐containing waste material shipped. If the Permittee chooses to not take credit for waste shipments, this parameter would be zero; and D# = weight percent of solids in C#, as a fraction. [Minn. R. 7007.0800, subps. 4‐5]

5.3.18 Waste Credit: If the Permittee elects to obtain credit for HAPs, solids, and/or VOC shipped in waste materials, the Permittee shall either use item 1 or 2 to determine the VOC, solids, and/or total and individual HAP content for each credited shipment. 1) The Permittee shall analyze a composite sample of each waste shipment to determine the weight content of VOC, solids, total HAP, and each individual HAP, excluding water. 2) The Permittee may use supplier data for raw materials to determine the VOC, solids, and total and individual HAP contents of each waste shipment, using the same content data used to determine the content of raw materials. If the waste contains several materials, the content of mixed waste shall be assumed to be the lowest VOC, solids, and total and individual HAP content of any of the materials. [Minn. R. 7007.0800, subps. 4‐5]

5.3.19 Material Content. VOC, HAPs, and Solids (PM, PM<10 microns, and PM<2.5 microns) contents in coating materials shall be determined by the Material Safety Data Sheet (MSDS) provided by the supplier for each material used. If a material content range is given on the MSDS, the highest number in the range shall be use in all compliance calculations. When using the MSDS as the basis of calculating particulate emissions, the conservative assumption is made that PM consistes entirely of PM less than 1‐ microns or less than 2.5 microns. Other alternative methods approved by the MPCA may be used to determine the VOC, HAPs, and Solids contents. The Commissioner reserves the right to require the Permittee to determine the VOC, HAP, and Solids contents of any material, according to EPA or ASTM reference methods. If an EPA or ASTM reference method is used for the material content determination, the data obtained shall supersede the MSDS. [Minn. R. 7007.0800, subps. 4‐5]

5.3.20 Maximum Contents of Materials: The Permittee assumed certain worst‐case contents of materials when determining the short term potential to emit of units in COMG4. These


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citationassumptions are listed in Appendix C of this permit. Changing to a material that has a higher content of any of the given pollutants is considered a change in method of operation that must be evaluated under Minn. R. 7007.1200, subp. 3 to determine if a permit amendment or notification is required under Minn. R. 7007.1150. [Minn. R. 7005.0100, subp. 35a]

5.3.21 Material Records: The Permittee shall keep records of all VOC, solids, or HAP‐containing materials used at the facility. The record shall include the part number of the material or mixture, and the VOC, solids, and HAP content of the material or mixture, determined as required by the Material Content requirement of this permit. [Minn. R. 7007.0800, subps. 4‐5]

COMG 6 GP007 40 CFR pt. 63

subp. PPPP 5.4.1 Based on the current and expected operations of the affected

source, this permit only includes the emission rate without add‐on controls option specified in 40 CFR Section 63.4491(b). If the Permittee later chooses to switch to or add one or both of the other compliance options allowed in the standard, the Permittee shall comply with all applicable portions of 40 CFR pt. 63, subp. PPPP for those options. In addition, the Permittee shall apply for a permit amendment, as appropriate (e.g., to add applicable NESHAP language, for installation of an oxidizer, etc.). [40 CFR 63.4491, Minn. R. 7011.8130]

5.4.2 The affected source is the collection of all of the items listed below that are used for surface coating of plastic parts and products: 1) All coating operations as defined in 40 CFR Section 63.4581;2) All storage containers and mixing vessels in which coatings, thinners and/or other additives, and cleaning materials are stored or mixed; 3) All manual and automated equipment and containers used for conveying coatings, thinners and/or other additives, and cleaning materials; and 4) All storage containers and all manual and automated equipment and containers used for conveying waste materials generated by a coating operation. [40 CFR 63.4482(b), Minn. R. 7011.8130]

5.4.3 The Permittee shall comply with the Maximum Achievable Control Technology (MACT) Standard for Surface Coating of Plastic Parts and Products. [40 CFR 63.4483(b), Minn. R. 7011.8130]

5.4.4 HAPs ‐ Organic <= 0.16 kilograms per kilograms (pounds per pound) of coating solids used during each 12‐month compliance period (HAP emission limit). [40 CFR 63.4490(b)(1), Minn. R. 7011.8130]

5.4.5 The Permittee must include all coatings (as defined in 40 CFR Section 63.4581), thinners and/or other additives, and cleaning


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citationmaterials used in the affected source when determining whether the HAP emission rate is equal to or less than the HAP emission limit. To make this determination, the Permittee must use at least one of the three compliance options listed in paragraphs (a) through (c) of 40 CFR Section 63.4491. As stated previously, this permit only includes the requirements associated with the emission rate without add‐on controls options specified in 40 CFR Section 63.4491(b). Even so, the Permittee may apply any of the compliance options to an individual coating operation, or to multiple coating operations as a group, or to the entire affected source. The Permittee may use different compliance options for different coating operations, or at different times on the same coating operation. The Permittee may employ different compliance options when different coatings are applied to the same part, or when the same coating is applied to different parts. However, the Permittee may not use different compliance options at the same time on the same coating operation. If the Permittee switches between compliance options for any coating operation or group of coating operations, the Permittee must document this switch as required by 40 CFR Section 63.4530(c), and the Permittee must report it in the next semiannual compliance report listed in Table B of this permit. [40 CFR 63.4491, Minn. R. 7011.8130]

5.4.6 The Permittee must be in compliance with the emission limitations as specified below: 1) Any coating operation(s) for which the Permittee uses the emission rate without add‐on controls option, as specified in 40 CFR Section 63.4491(b), must be in compliance with the HAP emission limit at all times. 2) The Permittee must always operate and maintain the affected source according to the provisions in 40 CFR Section 63.6(e)(1)(i). [40 CFR 63.4500(a)(1) & (b), Minn. R. 7011.8130]

5.4.7 HAPs ‐ Organic: Organic HAP Mass Fraction: The Permittee must determine the mass fraction of organic HAP for each coating, thinner and/or other additive, and cleaning material used during the compliance period by using one of the following options: 1) Method 311 (appendix A to 40 CFR pt. 63). The Permittee may use Method 311 for determining the mass fraction of organic HAP. To use Method 311, count each organic HAP that is measured to be present at 0.1 percent by mass fraction or more for Occupational Safety and Health Administration (OSHA)‐defined carcinogens as specified in 40 CFR Section 1910.1200(d)(4) and at 1.0 percent by mass or more for other compounds. Calculate the total mass fraction of organic HAP in the test material by adding up the individual organic HAP mass fractions and truncating the result to three places after the decimal point;


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation2) Method 24 (appendix A to 40 CFR pt. 60). For coatings, the Permittee may use Method 24 to determine the mass fraction of nonaqueous volatile matter and use that value as a substitute for mass fraction of organic HAP. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may use the alternative method described in appendix A to 40 CFR pt. 63, subp. PPPP, rather than Method 24. The Permittee may use the volatile fraction that is emitted, as measured by the alternative method in appendix A to 40 CFR pt. 63, subp. PPPP, as a substitute for the mass fraction of organic HAP; 3) Alternative Method. The Permittee may use an alternative test method for determining the mass fraction of organic HAP once the Administrator has approved it. The Permittee must follow the procedure in 40 CFR Section 63.7(f) to submit an alternative test method for approval; (continued below). [40 CFR 63.4551(a), Minn. R. 7011.8130]

5.4.8 HAPs ‐ Organic: (continued from above) 4) Information from the supplier or manufacturer of the material. The Permittee may rely on information other than that generated by the previous three paragraphs, such as manufacturer's formulation data, if it represents each organic HAP that is present in 0.1 percent by mass or more for OSHA‐defined carcinogens as specified in 40 CFR Section 1910.1200(d)(4) and at 1.0 percent by mass or more for the other compounds. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may rely on manufacturer's data that expressly states the organic HAP or volatile matter mass fraction emitted. If there is a disagreement between such information and the results of a test conducted in according to 40 CFR Section 63.4541(a)(1) through (3), then the test method results will take precedence unless, after consultation the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct; or 5) Solvent blends. Solvent blends may be listed as single components for some materials in data provided by manufacturers or suppliers. Solvent blends may contain organic HAP which must be counted toward the total organic HAP mass fraction of the materials. When test data and manufacturer's data for solvent blends are not available, the Permittee may use the default values for the mass fraction of organic HAP in these solvent blends listed in Table 3 or 4 of 40 CFR pt. 63, subp. PPPP. If the tables are used, the values in Table 3 of 40 CFR pt. 63, subp. PPPP for all solvent blends that match the entries according to the instructions for Table 3 may be used, and Table 4 of 40 CFR pt. 63, subp. PPPP may be used only if the solvent blends in materials that are used are known and they do not match any of the solvent blends in Table 3 and


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citationit is known only whether the blend is aliphatic or aromatic. However, if the results of a Method 311 (appendix A to 40 CFR pt. 63) test indicate higher values than those listed in Tables 3 or 4, the Method 311 results will take precedence unless, after consultation it is determined to the satisfaction of the MPCA that the formulation data are correct. [40 CFR 63.4551(a), Minn. R. 7011.8130]

5.4.9 Solids Mass Fraction: The Permittee must determine the mass fraction of coating solids kg(lb) per kg(lb) of coating for each coating used during the compliance period by a test, by information provided by the supplier or the manufacturer of the material, or by calculation, as specified by the following options: 1) Method 24 (appendix A to 40 CFR pt. 60). Use Method 24 for determining the mass fraction of coating solids. For reactive adhesives in which some of the liquid fraction reacts to form solids, the alternative method contained in Appendix A to 40 CFR pt. 63, subp. PPPP, rather than Method 24, may be used to determine the mass fraction of coating solids; 2) Alternative method. An alternative test method may be used for determining the solids content of each coating once the Administrator has approved it. The procedure in 40 CFR Section 63.7(f) must be followed to submit an alternative test method for approval; or 3) Information from the supplier or manufacturer of the material. The mass fraction of coating solids for each coating may be obtained from the supplier or manufacturer. If there is a disagreement between such information and the test method results, then the test method results will take precedence unless, after consultation it is demonstrated to the satisfaction of the MPCA that the formulation data are correct. [40 CFR 63.4551(b), Minn. R. 7011.8130]

5.4.10 The Permittee shall demonstrate that, based on the coatings, thinners and/or other additives, and cleaning materials used in the coating operation(s), the organic HAP emission rate for the coating operation(s) is less than or equal to the HAP emission limit, calculated as a rolling 12‐month emission rate and determined on a monthly basis. The Permittee must meet all the requirements of 40 CFR Sections 63.4550, 63.4551, and 63.4552 to demonstrate compliance with the emission limit using this option. [40 CFR 63.4491(b), Minn. R. 7011.8130]

5.4.11 The Permittee does not need to redetermine the mass of organic HAP in coatings, thinners and/or other additives, or cleaning materials that have been reclaimed on‐site (or reclaimed off‐site if the Permittee has documentation showing that they received back the exact same materials that were sent off‐site) and reused in the coating operation for which the Permittee uses the emission rate without add‐on controls option. If the Permittee uses coatings, thinners and/or other


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citationadditives, or cleaning materials that have been reclaimed on‐site, the amount of each used in a month may be reduced by the amount of each that is reclaimed. That is, the amount used may be calculated as the amount consumed to account for materials that are reclaimed. [40 CFR 63.4551, Minn. R. 7011.8130]

5.4.12 The Permittee shall determine the density of each liquid coating, thinner and/or other additive, and cleaning material used during each month from test results using ASTM Method D1475‐98, Standard Test Method for Density of Liquid Coatings, Inks, and Related Products (incorporated by reference, see 40 CFR Section 63.14), information from the supplier or manufacturer of the material, or reference sources providing density or specific gravity data for pure materials. If there is disagreement between ASTM Method D1475‐98 and other such information sources, the test results will take precedence unless, after consultation the Permittee demonstrates to the satisfaction of the Agency that the formulation data are correct. If the Permittee purchases materials or monitor consumption by weight instead of volume, the Permittee does not need to determine material density. Instead, the Permittee may use the material weight in place of the combined terms for density and volume in Equations 1A, 1B, 1C, and 2 in Appendix B to this permit. [40 CFR 63.4551(c), Minn. R. 7011.8130]

5.4.13 The Permittee shall determine the volume (liters/gallons) of each coating, thinner and/or other additive, and cleaning material used during each month by measurement or usage records. If the Permittee purchases materials or monitors consumption by weight instead of volume, the Permittee does not need to determine the volume of each material used. Instead, the Permittee may use the material weight in place of the combined terms for density and volume in Equations 1A, 1B, 1C and 2 in Appendix B to this permit. [40 CFR 63.4551(d), Minn. R. 7011.8130]

5.4.14 The mass of organic HAP emissions is the combined mass of organic HAP contained in all coatings, thinners and/or other additives, and cleaning materials used during each month minus the organic HAP in certain waste materials. The Permittee shall calculate the following using the referenced equations in Appendix B of this permit: 1) Calculate the mass of organic HAP emissions using Equation 1. 2) Calculate the kg (lb) organic HAP in the coatings used during the month using Equation 1A. 3) Calculate the kg (lb) of organic HAP in the thinners and/or other additives used during the month using Equation 1B. 4) Calculate the kg (lb) organic HAP in the cleaning materials used during the month using Equation 1C.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation5) If the Permittee chooses to account for the mass of organic HAP contained in waste materials sent or designated for shipment to a hazardous waste TSDF in Equation 1, then the Permittee must determine the mass according to 40 CFR Section 63.4551(e)(4)(i) through (iv). [40 CFR 63.4551(e), Minn. R. 7011.8130]

5.4.15 The Permittee shall determine the total mass of coating solids used, kg (lb), which is the combined mass of coating solids for all the coatings used during each month, using Equation 2 in Appendix B of this permit. [40 CFR 63.4551(f), Minn. R. 7011.8130]

5.4.16 The Permittee shall calculate the organic HAP emission rate for the compliance period, kg (lb) organic HAP emitted per kg (lb) coating solids used, using Equation 3 in Appendix B of this permit. [40 CFR 63.4551(g), Minn. R. 7011.8130]

5.4.17 To demonstrate continuous compliance, the organic HAP emission rate for each compliance period, determined according to 40 CFR Section 63.4551(a) through (g), must be less than or equal to the HAP emission limit. A compliance period consists of 12 months. Each month after the end of the initial compliance period described in 40 CFR Section 63.4550 is the end of a compliance period consisting of that month and the preceding 11 months. The Permittee must perform the calculations in 40 CFR Section 63.4551(a) through (g) on a monthly basis using data from the previous 12 months of operation. [40 CFR 63.4552(a), Minn. R. 7011.8130]

5.4.18 Deviation: If the organic HAP emission rate for any 12‐month compliance period exceeded the HAP emission limit, this is a deviation from the emission limitation for that compliance period and must be reported as specified in 40 CFR Sections 63.4510(c)(6) and 63.4520(a)(6). [40 CFR 63.4552(b), Minn. R. 7011.8130]

5.4.19 The Permittee shall collect and keep records of the data and information specified below. Failure to collect and keep these records is a deviation from the standard. 1) A copy of each notification and report that was submitted to comply with 40 CFR pt. 63, subp. PPPP, and the documentation supporting each notification and report; 2) A current copy of information provided by materials suppliers or manufacturer's formulation data, or test data used to determine the mass fraction of organic HAP and density for each coating, thinner and/or other additive, and cleaning material, and the mass fraction of coating solids for each coating. If a test was conducted to determine the mass fraction of organic HAP, density, or mass fraction of coating solids, keep a copy of the complete test report. If the information provided by the manufacturer or supplier that was based on testing was used, keep the summary sheet of results provided by the supplier. The Permittee is not required to


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citationobtain the test report or other documentation from the manufacturer or supplier; 3) If the Permittee changes compliance options, a record of the coating operations on which the Permittee used each compliance option and the time periods (beginning and ending dates) for each option that was used; 4) A record of the calculation of the total mass of organic HAP emissions for the coatings, thinners and/or other additives, and cleaning materials used each month using Equations 1, 1A through 1C, and 2 in Appendix B, and, if applicable, the calculation used to determine mass of organic HAP in waste materials according to 40 CFR Section 63.4551(e)(4). ‐ the calculation of the total mass of coating solids used each month using Equation 2 in Appendix B; and ‐ the calculation of each 12‐month organic HAP emission rate using Equation 3 in Appendix B; 5) A record of the name and mass of each coating, thinner and/or other additive, and cleaning material used during each compliance period; 6) A record of the mass fraction of organic HAP for each coating, thinner and/or other additive, and cleaning material used during each compliance period; 7) A record of the mass fraction of coating solids for each coating used during each compliance period; 8) If the Permittee uses an allowance in Equation 1 in Appendix II for organic HAP contained in waste materials sent to or designated for shipment to a treatment, storage, and disposal facility (TSDF) according to 40 CFR Section 63.4551(e)(4), the Permittee must keep records of the information specified in paragraphs 40 CFR Section 63.4530(g)(1) through (3); and 9) Records of the date, time and duration of each deviation. [40 CFR 63.4530, 40 CFR 63.4552(d), Minn. R. 7011.8130]

5.4.20 The Permittee's records must be in a form suitable and readily viewable for expeditious review according to 40 CFR Section 63.10(b)(1). Where appropriate, the records may be maintained as electronic spreadsheets or as a database. As specified in 40 CFR Section 63.10(b)(1), each record must be kept for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The record must be kept on‐site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record according to 40 CFR Section 63.10(b)(1). The remaining records may be kept off‐site for the remaining 3 years. [40 CFR 63.4552(d), 40 CFR pt. 63, 4531, Minn. R. 7011.8130]

5.4.21 Semiannual Compliance Report Content: The semiannual compliance report must contain the following information: i) Company name and address.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citationii) Statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report. iii) Date of report and beginning and ending dates of the reporting period. The reporting period is the 6‐month period ending on June 30 or December 31. Note that the information reported for each of the 6 months in the reporting period will be based on the last 12 months of data prior to the date of each monthly calculation. iv) Identification of the compliance option or options specified in 40 CFR Section 63.4491 that was used on each coating operation during the reporting period. If the compliance option was changed during the reporting period, the report must contain beginning and ending dates for each option that was used; and v) The calculation results for each rolling 12‐month organic HAP emission rate during the 6‐month reporting period. [40 CFR 63.4520(a)(3), Minn. R. 7011.8130]

5.4.22 If there were no deviations from the emissions limitations in 40 CFR Sections 63.4490, 63.4492, and 63.4493 which apply, the semiannual compliance report must contain a statement that there were no deviations from the emission limitations during the reporting period. [40 CFR 63.4520(a)(5), Minn. R. 7011.8130]

5.4.23 Deviation Report Requirements: If there was a deviation from the HAP emission limit, the semiannual compliance report must contain the following information: i) The beginning and ending dates of each compliance period during which the 12‐month organic HAP emission rate exceeded the HAP emission limit. ii) The calculations used to determine the 12‐month organic HAP emission rate for the compliance period in which the deviation occurred. The Permittee must submit the calculations for Equations 1, 1A through 1C, 2, and 3 in Appendix B of this permit; and if applicable, the calculation used to determine mass of organic HAP in waste materials according to 40 CFR Section 63.4551(e)(4). The Permittee does not need to submit background data supporting these calculations (e.g., information provided by materials suppliers or manufacturers, or test reports). iii) A statement of the cause of each deviation. [40 CFR 63.4520(a)(6), Minn. R. 7011.8130]

5.4.24 After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source. [40 CFR 63.5(b)(6), Minn. R.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation7011.7000]

5.4.25 Proper Operation and Maintenance. At all times, including periods of startup, shutdown, and malfunction, the Permittee shall operate and maintain the emission unit subject to the MACT standard and any associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by any relevant standard and as detailed in 40 CFR Section 63.6(e)(1)(i)‐(iii). The Permittee shall correct malfunctions as soon as practicable after their occurrence. [40 CFR pt. 63, 6(e)(1), Minn. R. 7011.7000]

5.4.26 Methods for determining compliance. The Administrator will determine compliance, in part, based on conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 40 CFR Section 63.6(f)(2). [40 CFR 63.6(f)(2), Minn. R. 7011.7000]

5.4.27 Finding of compliance. The Administrator will make a finding concerning an affected source's compliance with a non‐opacity emission standard upon obtaining all the compliance information required by the relevant standard. [40 CFR pt. 63, 6(f)(3), Minn. R. 7011.7000]

5.4.28 The Administrator may grant an extension of compliance with an emission standard, as specified in 40 CFR Section 63.6(i). Until an extension of compliance has been granted by the Administrator, the Permittee shall comply with all applicable requirements of 40 CFR pt. 63, subp. A. [40 CFR 63.6(i), Minn. R. 7011.7000]

5.4.29 Initial notification requirements apply to the Permittee when the Permittee's affected source becomes subject to a relevant standard. [40 CFR 63.9(b)(1), Minn. R. 7019.0100]

5.4.30 Notification of compliance status. Each time a notification of compliance status is required under 40 CFR pt. 63, subp. A, the Permittee shall submit to the MPCA a notification of compliance status containing the information required by 40 CFR Section 63.9(h), signed by the responsible official who shall certify its accuracy, attesting to whether the source has complied with the relevant standard. The Permittee shall submit the notification of compliance status on the dates specified in 40 CFR Section 63.4510. Notifications may be combined as long as the due date requirement for each notification is met. [40 CFR 63.9(h), Minn. R. 7019.0100]

5.4.31 Notification of information change. Any change in the information already provided under 40 CFR Section 63.9 shall be provided to the Administrator in writing within 15 calendar days after the change. [40 CFR 63.9(j), Minn. R. 7019.0100]

5.4.32 The Permittee shall submit reports to the MPCA and shall send a copy of each report to the Administrator. [40 CFR 63.10(a),


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & CitationMinn. R. 7019.0100]

5.4.33 General recordkeeping requirements.. The Permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent 2 years of data must be retained on site. [40 CFR 63.10(b)(1), Minn. R. 7019.0100, Minn. R. 7019.0100, subp. 2(B)]

5.4.34 General recordkeeping requirements. For each affected source, the Permittee shall maintain the relevant records of all documents supporting initial notifications and notifications of compliance status. [40 CFR 63.10(b)(2)(xiv), Minn. R. 7019.0100, subp. 2(B)]

5.4.35 Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), the Permittee shall submit reports to the Administrator in accordance with the reporting requirements in the relevant standard. Additional reporting requirements are specified in 40 CFR Section 4520. [40 CFR 63.10(d)(1), Minn. R. 7019.0100]

COMG 7 GP005 Paint Filters 5.5.1 If the Permittee does not submit a CAM plan in accordance

with the compliance schedule in Section 7 of this permit, or if the permitting authority disapproves the plan submitted, the Permittee shall be deemed not in compliance with 40 CFR pt. 64, unless the Permittee successfully challenges the disapproval. [40 CFR 64.6(e)(3)]

5.5.2 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Total Particulate Matter >= 99 percent control efficiency. [Minn. R. 7007.80, subp. 2, Minn. R. 7011.0070, subp. 1(A)]

5.5.3 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 85 percent control efficiency. [Minn. R. 7011.0070, subp. 1(A), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.5.4 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 85 percent control efficiency. [Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.5.5 The Permittee shall operate and maintain the panel filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

5.5.6 Daily Inspections: Once each operating day, the Permittee shall


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citationvisually inspect the condition of each paint filter with respect to alignment, saturation, tears, holes and any other condition that may affect the filter's performance. The Permittee shall maintain a daily written record of filter inspections. [Minn. R. 7007.0800, subp. 4‐5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.5.7 Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5]

5.5.8 Corrective Actions: The Permittee shall take corrective action as soon as possible if the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 5]

5.5.9 Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method as required by Minn. R. 7011.0072, subp. 4. The Permittee shall maintain a copy of the annual evaluation on site. [Minn. R. 7011.0072, subp. 4]

5.5.10 Initial Hood Certification and Evaluation: The control device hood must conform to the requirements listed in Minn. R. 7011.0072, subp. 2(B), and the Permittee shall certify this as specified in Minn. R. 7011.0072, subps. 2 and 3. The Permittee shall maintain a copy of the evaluation and certification on site. [Minn. R. 7011.0072, subps. 2‐4]

EQUI 6 EU002 Boiler 2 5.6.1 Total Particulate Matter <= 0.60 pounds per million Btu heat

input 3‐hour average The PM potential to emit from the unit is 0.024 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0510, subp. 1]

5.6.2 Opacity <= 20 percent opacity except for one six‐minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0510, subp. 2]

5.6.3 Fuel types: natural gas or distillate oil only. [Minn. R. 7005.0100, subp. 35a]

5.6.4 The Permittee shall operate EQUI6 such that it meet the definition of gas‐fired boiler in 40 CFR Section 63.11237. Gas‐fired boiler includes any boiler that burns gaseous fuels not combined with any solid fuels and burns liquid fuel only during periods of gas curtailment, gas supply interruption, startups, or


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citationperiodic testing on liquid fuel. Periodic testing of liquid fuel shall not exceed a combined total of 48 hours during any calendar year. [40 CFR 63.11195(e)]

EQUI 7 EU001 Boiler 1 5.7.1 Total Particulate Matter <= 0.60 pounds per million Btu heat

input. The potential to emit from the unit is 0.00724 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0510, subp. 1]

5.7.2 Opacity <= 20 percent opacity except for one six‐minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0510, subp. 2]

5.7.3 Fuel type: natural gas only. [Minn. R. 7005.0100, subp. 35a] EQUI 17 EU007 Dryer/Oven ‐

Main 5.7.1 Total Particulate Matter <= 0.30 grains per dry standard cubic

foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. The PM PTE for this unit is 0.0022 grains/dry standard cubic foot due to equipment design and allowable fuel. [Minn. R. 7011.0610, subp. 1(A)(1)]

5.7.2 Opacity <= 20 percent opacity except for one six‐minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0610, subp. 1(A)(2)]

5.7.3 Fuel type: Natural gas only [Minn. R. 7005.0100, subp. 35a]

6. Submittal/action requirements

This section lists most of the submittals required by this permit. Please note that some submittal requirements may appear in the Limits and Other Requirements section, or, if applicable, within a Compliance Schedule section.

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & CitationTFAC 1 06500002 Imperial Plastics

Inc 6.1.1 The Permittee shall submit a computer dispersion modeling

information : Due 1096 calendar days after Permit Issuance Date. 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. [Minn. R. 7007.0100, subp. 7(A), Minn. R. 7007.0100, subp. 7(L), Minn. R. 7007.0100, subp. 7(M), Minn. R. 7007.0800, subp. 1, Minn. R. 7007.0800, subp. 2, Minn. R. 7007.0800, subp. 4, Minn. R. 7009.0010‐0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 6.1.2 The Permittee shall submit a semiannual deviations report : Due

semiannually, by the 30th of January and July The first semiannual report submitted by the Permittee shall cover the calendar half‐year in which the permit is issued. The first report of each calendar year covers January 1 ‐ June 30. The second report of each calendar year covers July 1 ‐ December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations. [Minn. R. 7007.0800, subp. 6(A)(2)]

6.1.3 The Permittee shall submit an application for permit reissuance : Due 180 calendar days before Permit Expiration Date. [Minn. R. 7007.0400, subp. 2]

6.1.4 The Permittee shall submit a compliance schedule progress report : Due semiannually, by the 30th of January and July The Compliance Schedule Progress Report shall contain the information specified in Minn. R. 7007.0800, subp. 6(B) and shall be submitted on a form approved by the Commissioner in accordance with the Compliance Schedule contained in this permit. Progress Reports will not be needed upon completion of all activities contained in the Compliance Schedule. [Minn. R. 7007.0800, subp. 6(B)]

6.1.5 The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the previous calendar year). The Permittee shall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. [Minn. R. 7007.0800, subp. 6(C)]

COMG 6 GP007 40 CFR pt. 63

subp. PPPP 6.2.1 The Permittee shall submit a semiannual compliance report :

Due by 31 days after end of each calendar half‐year following Permit Issuance. The report shall contain the information specified in Semiannual Compliance Report Content requirement under COMG 6. Each semiannual compliance report must cover the semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. This report may be submitted with the Semiannual Deviations Report also listed in Table B of this permit. [40 CFR 63.4520(a)(1)(i),(ii),&(iv), Minn. R. 7011.8130]

COMG 7 GP005 Paint Filters 6.3.1 The Permitee was required to submit a plan : Due 180 calendar

days before 07/17/2006 (which was the expiration date of permit 06500002‐001). The Permittee was required to submit the information requested under 40 CFR Section 64.4 (CAM plans) for all Other pollutant‐specific emission units, as part of the application for the Part 70 permit renewal. This requirement


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citationwill be fulfilled upon completion of Requirement ID #1055244 found in Section 7 of this permit. [40 CFR 64.5(b)]

6.3.2 The Permittee shall submit a permit application : Due 30 calendar days after Permit Issuance Date. The application shall be a major amendment to incorporate requirements from approved CAM plans for TREA1, TREA2, TREA3, TREA4, and TREA5 for control of Total Particulate Matter. [Minn. R. 7007.0100, subp. 7(A), Minn. R. 7007.0100, subp. 7(F), Minn. R. 7007.0800, subps. 1‐2]

6.3.3 The Permittee was required to submit a report : Due 180 calendar days before 07/17/2006 (which was the expiration date for permit 06500002‐001). In order to use a certified hood control efficiency value from Minn. R. 7011.0070, subp. 1a, Table A, the Permittee must: 1) Arrange for a testing company to conduct a hood evaluation; 2) Document, on a form provided by the commissioner, that the hood conforms to the design and operation practices recommended in the manual incorporated by reference under Minn. R. 7011.0061; and 3) Include with the permit application a certification statement, as specified in Minn. R. 7011.0072, Subp. 2(C). This requirement will be fulfilled by completion of Requirement ID #1056026 found in Section 7 of this permit. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7011.0072, subp. 2]

7. Compliance schedule

This section of the permit contains the compliance schedule required by Minn. R. 7007.0500, subp. 2(K). You must complete the actions required in this section by the dates listed. All submittals must be postmarked or received by the date specified in the table, and certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21.

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & CitationCOMG 7 GP005 Paint Filters 7.1.1 The Permittee shall submit a plan : Due 30 calendar days after

Permit Issuance Date. The Permittee shall provide CAM plans for TREA1, TREA2, TREA3, TREA4, and TREA5 for control of Total Particulate Matter. The CAM plans shall be submitted according to the requirements in 40 CFR Section 64.4 and shall fulfill the monitoring design criteria in 40 CFR Section 64.3. [40 CFR 64.5(b), 40 CFR 64.6(e)(2), Corrective Action]

7.1.2 The Permittee shall submit a report : Due 14 calendar days after Permit Issuance Date. The Permittee shall submit a copy of the hood certification for the hood of each control equipment unit


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citationin COMG 7, demonstrating that the hood has been evaluated and certified according to the requirements of Minn. R. 7011.0072, subps. 2 and 3. [Corrective Action, Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5]

8. Appendices

Appendix A. Insignificant Activities and General Applicable Requirements The table below lists the insignificant activities that are currently at the Facility and their associated general applicable requirements.

Minn. R. Rule description of the activity General applicable requirementMinn. R. 7007.1300, subp. 3(B)(1) Infrared electric ovens Opacity <= 20% (Minn. R. 7011.0105)Minn. R. 7007.1300, subp. 3(H)(3) Brazing, soldering or welding equipment PM, variable depending on airflow

Opacity <= 20% (Minn. R. 7011.0715)

Minn. R. 7007.1300, subp. 3(H)(4) Blueprint copiers and photographic processes

Opacity <= 20% (Minn. R. 7011.0105)

Minn. R. 7007.1300, subp. 3(H)(7) Cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners

PM, variable depending on airflowOpacity <= 20% (Minn. R. 7011.0715)

Minn. R. 7007.1300, subp. 3(I) Individual units with potential emissions less than 2000 lb/year of certain pollutants

IPI has a number of space heaters fueled by kerosene, natural gas, or propane that qualify as insignificant activities under this subpart due to individual emissions below the thresholds in subpart 3(I). Each space heater has a capacity less than or equal to 0.4 MMBtu/hr. The total capacity for all the space heaters is 5.93 MMBtu/hr.

IPI has a 40 injection molding presses and 4 natural gas furnaces (with total capacity of 0.45 MMBtu/hr), that qualify under this subpart

IPI has 4 sanding booths that qualify under this subpart.

Minn. R. 7011.0510 (space heaters and furnaces)

Minn. R. 7011.0610 (oven)

Minn. R. 7011.0715 (injection molding presses and sanding booths)

Minn. R. 7007.1300, subp. 3(K) Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary



Minn. R. Rule description of the activity General applicable requirementproduction processes at the stationarysource

Minn. R. 7008.4110 Equipment venting PM/PM10 inside a building, provided that emissions from the equipment are: a). filtered through an air cleaning system; and b). vented inside of the building 100% of the time

IPI currently has 3 sanding booths and 4 grinding units that are vented internally. The grinding units are equipped with cyclones and the sanding booths are filtered.



Appendix B: 40 CFR pt. 63, subp. PPPP Compliance Equations

EQUATION 1 He = A + B + C ‐Rw

Where:

He = Total mass of organic HAP emissions during the month, kg.

A = Total mass of organic HAP in the coatings used during the month, kg, as calculated in Equation 1A.

B = Total mass of organic HAP in the thinners and/or other additives used during the month, kg, as calculated in Equation 1B.

C = Total mass of organic HAP in the cleaning materials used during the month, kg, as calculated in Equation 1C.

Rw = Total mass of organic HAP in waste materials sent or designated for shipment to a hazardous waste TSDF for treatment or disposal during the month, kg, determined according to 40 CFR § 63.4551(e)(4). (The Permittee may assign a value of zero to Rw if the Permittee does not wish to use this allowance.)

EQUATION 1A

icic

m

i

ic WDVolA ,,

1

,

Where:

A = Total mass of organic HAP in the coatings used during the month, kg.

Volc,i = Total volume of coating, i, used during the month, liter (gallon)s.

Dc,i = Density of coating, i, kg (lb)coating per liter (gallon) coating.

Wc,i = Mass fraction of organic HAP in coating, i, kg (lb)organic HAP per kg (lb)coating. For reactive adhesives as defined in 40 CFR § 63.4581, use the mass fraction of organic HAP that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP.

m = Number of different coatings used during the month.

EQUATION 1B


jtjt

n

jjt WDVolB ,,

1,

Where:

B = Total mass of organic HAP in the thinners and/or other additives used during the month, kg.

Volt,j = Total volume of thinner and/or other additive, j, used during the month, liter (gallon)s.

Dt,j = Density of thinner and/or other additive, j, kg (lb)per liter (gallon).

Wt,j = Mass fraction of organic HAP in thinner and/or other additive, j, kg (lb)organic HAP per kg (lb)thinner and/or other additive. For reactive adhesives as defined in 40 CFR § 63.4581, use the mass fraction of organic HAP that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP.

n = Number of different thinners and/or other additives used during the month.

EQUATION 1C

ksks

p

k

ks WDVolC ,,

1

,

Where:

C = Total mass of organic HAP in the cleaning materials used during the month, kg.

Vols,k = Total volume of cleaning material, k, used during the month, liter (gallon)s.

Ds,k = Density of cleaning material, k, kg (lb)per liter (gallon).

Ws,k = Mass fraction of organic HAP in cleaning material, k, kg (lb)organic HAP per kg (lb)material.

p = Number of different cleaning materials used during the month.


EQUATION 2

isic

m

iicst MDVolM ,,

1,

Where:

Mst = Total mass of coating solids used during the month, kg.

Volc,i = Total volume of coating, i, used during the month, liter (gallon)s.

Dc,i = Density of coating, i, kgs per liter (gallon) coating, determined according to 40 CFR § 63.4551(c).

Ms,i = Mass fraction of coating solids for coating, i, kgs solids per kg (lb)coating, determined according to 40 CFR § 63.4541(b).

m = Number of coatings used during the month.

EQUATION 3

n

y

st

n

y

e

yr

M

H

H

1

1

Where:

Hyr = Average organic HAP emission rate for the compliance period, kg (lb)organic HAP emitted per kg (lb)coating solids used.

He = Total mass of organic HAP emissions from all materials used during month, y, kg, as calculated by Equation 1.

Mst = Total mass of coating solids used during month, y, kg, as calculated by Equation 2.

y = Identifier for months.

n = Number of full or partial months in the compliance period (for the initial compliance period, n equals 12 if the compliance date falls on the first day of a month; otherwise n equals 13; for all following compliance periods, n equals 12).


Appendix C: GP001 Maximum Content of Materials Assumptions

The Permittee must consider emissions increases from changes in operation that alter the maximum content of any pollutant as listed in the table below. Use form CH‐04(a) to determine if the change triggers a major modification under NSR. The following is a table from the facility’s calculations spreadsheet that lists the factors involved in the PTE calculation of VOCs, Solids/PM, and HAPs from the coating processes at the facility.

Pollutant Product Name Material Density (lb/gal) Weight % Material Content (lb/gal)

VOCs Glycol Ether 7.96 100% 7.96

Solids Oyster Gray 14.40 85% 12.2

Toluene 82502‐2054 12.8 25% 3.21

Xylene Xylene 7.27 100% 7.27

Methyl Ethyl Ketone MEK 6.73 100% 6.73

Methyl Isobutyl Ketone V66VB11 7.03 36% 2.53

Methanol 3063FDLC 13.6 30% 4.07

Ethyl Benzene V66VB11 7.03 9.0% 0.633

Barium D61XXL2343‐4347 14.1 24% 3.39

Copper 599‐Z1619 Copper 11.9 30% 3.57

Nickel 3063FDLC 13.6 60% 8.14

2‐Butoxyethanol WLG0093 11.1 10% 1.11

Glycol Ethers Glycol Ether 7.96 100% 7.96

Toluene Diisocynate V66V44 9.32 0.8% 0.0746

Dibutyl Phthalate F73WXA 14296‐4347 Dk Gray 9.43 8.0% 0.754

2‐(2‐Butoxytthoxy)‐ethanol F63AC503 9.40 12% 1.15

Total HAP * 13.6 90% 12.2

Max Single HAP 3063FDLC 13.6 60% 8.14

*Total HAP is the sum of HAPs from the coating with the highest total HAP content in lb/gal, which is "Von Roll Isola" product #3063FDLC

Technical Support Document, Permit Number: 06500002‐ 002 Page 1 of 14

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 06500002‐002 This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the permit. 1. General Information 1.1 Applicant and Stationary Source Location

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address

(SIC Code: 3089)

Imperial Plastics Incorporated (owner)

21320 Hamburg Avenue West

Lakeville

Dakota County, MN 55051

Imperial Plastics Incorporated (operator)

1020 East Maple Avenue

Mora

Kanabec County, Minnesota 55051

Contact: Mr. Mark Becker

Phone: 953‐985‐7116

1.2 Facility Description Imperial Plastics Incorporated (IPI or the facility) operates a plastic parts manufacturing plant in Mora, Minnesota. The facility’s operations include injection molding, spray painting, sanding, grinding, boilers, and several small natural gas combustion sources (e.g., ovens and furnaces). The facility has taken limits on coating operations to avoid major source status under 40 CFR Section 52.21 for volatile organic compounds (VOCs), particulate matter less than ten microns (PM10), and particulate matter less than 2.5 microns (PM2.5). The facility has also accepted limits with Permit Action 002 to limit total and single hazardous air pollutants (HAPs) to below major source threshold levels. Particulate matter emissions from the coating booths are controlled by panel filters. 1.3 Description of the Activities Allowed by this Permit Action This permit action is the reissuance of the Part 70 operating permit which incorporates an administrative amendment and notification as follows:

Administrative Amendment dated 2/11/02 (DQ #2726). The amendment notified the MPCA that the production process labeled as the Anderson Line (EU010 and EU011), was removed along with its corresponding control equipment. This change has been incorporated in permit action 002. The Amendment also included a change in ownership, but the information was superseded by another change in ownership (see Section 1.6 below and Attachment 4 to this TSD).

Notification dated 01/13/06 (DQ #4979). The notification informed the MPCA that a sanding station that was previously vented internally, was modified so that is was controlled by a booth equipped


with panel filters and vented externally. Before the modification this station was considered an insignificant activity because it was vented internally. However, once the change was made the Permittee began to report emissions from the unit with their emission inventory, so emissions inventory staff added the unit to the facility description as EU019 (Sanding On‐Line Booth). With permit action 002 the Permittee submitted calculations demonstrating that EU019 (along with EU 016‐018) qualified as insignificant activities under Minn. R. 7007.1300, subp. 3(I). Consequently, EU019 was removed from the facility description with this permit action.

1.4 Description of Notifications and Applications Included in this Action Table 2. Notifications and Applications Included in this Action Date Received DQ# Application/Notification Type and description

02/11/02 2726 Administrative Amendment: Change of ownership and removal of EU 010 and EU 011

03/31/05 4979 Notification of physical change and control equipment installation

01/13/06 856 Part 70 Reissuance Application

1.5 Facility Emissions

Table 3. Total Facility Potential to Emit Summary

PM tpy

PM10 tpy

PM2.5 tpy

SO2 tpy

NOx tpy

CO tpy

CO2e tpy

VOC tpy

SingleHAP tpy

AllHAPs tpy

Total Facility Limited Potential Emissions

29.9 226 226 0.0608 8.22 6.18 9,324 196 9.12 22.1

Total Facility Actual Emissions (2013)

2.57 2.57 1.45 0.00600 1.04 0.876 * 11.5 *

*Not reported in MN emission inventory.

Table 4. Facility Classification Classification Major/Affected Source Synthetic Minor/Area Minor/Area

PSD X

Part 70 Permit Program X

Part 63 NESHAP X

1.6 Changes to Permit The MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R. 7007.0800 which gives the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action:

The ownership of the company and the name of the facility changed to Imperial Plastics Incorporated (see Attachment 4 to this TSD). The attached document notifies the MPCA of the change in ownership effective 09/23/14.

The permit has been updated to reflect current MPCA templates and standard citation formatting.


Completed requirements and the requirements for equipment that has been removed have been deleted.

Limits to avoid major source status under 40 CFR Section 52.21 for PM10 and PM2.5 emissions were added to COMG4 (Coating Booth Limits).

Limits to avoid major source status under 40 CFR Section 63.2 for emissions of single and total HAPs were added to COMG4 (Coating Booth Limits).

Requirements needed to comply with 40 CFR pt. 63, subp. PPPP for plastic parts and products surface coating were added to the permit.

Requirements needed to comply with 40 CFR pt. 63, subp. JJJJJJ were added at EQUI6.

A number of changes to the insignificant activities at the facility were made including: o Removal of 10 presses. o Reassignment of four sanding booths (formerly EU016‐019) to the insignificant activity

list. The sanding booths qualify as insignificant activities under Minn. R. 7007.1300, subp. 3(I). See Attachment 1 for the method of emissions determination from these activities.

GP 002 (Direct Heating Units) was removed since EU011 was retired; leaving EU007 (now EQUI 17) as the only unit in the group. The requirements for EQUI 17 are now at EQUI 17 in the permit.

The control equipment TREA12 – TREA16 were changed to Mat or Panel Filter, from paper filters, in the delta facility description.

A compliance action requiring the Permittee to submit CAM plans within 30 days of permit issuance was added to COMG7. The CAM plans should have been submitted along with the reissuance application.

A compliance action requesting that IPI submit copies of the hood certifications for all COMG7 hoods was added to COMG7. IPI should have submitted copies of the certification forms for each hood along with their reissuance application in order to use the capture efficiencies listed in Minn. R. 7011.0070, subp. 1a, Table A.

2. Regulatory and/or Statutory Basis 2.1 New Source Review (NSR) The Permittee has accepted limits on VOC, PM10, and PM2.5 emissions to avoid classification as a major source under New Source Review (NSR). The main source of VOCs at the facility is from the coating operations (COMG4). A limit on VOC usage/emissions of 196 tpy at COMG4 limits total facility PTE for VOCs to below the major source threshold. A limit on PM10/PM2.5 usage/emissions of 225 tpy at COMG4 limits total facility PTE for PM10 and PM2.5 to below major source thresholds. Compliance with the VOC, PM10, and PM2.5 limits is assured through recordkeeping of coating usage. For PM10 and PM2.5, the Permittee may take credit for control by COMG7 panel filters in the calculation, so the requirement to vent to, operate and maintain, the control equipment for COMG4 units is a Title I condition. Additionally, maintenance of the control equipment required to achieve specific control efficiencies for PM10, and PM2.5 are also Title I conditions at COMG7. 2.2 Part 70 Permit Program The facility is a major source under the Part 70 permit program.


2.3 New Source Performance Standards (NSPS) The Permittee has stated that no New Source Performance Standards apply to the operations at this facility. 2.4 National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility will take limits, effective with this permit action, to be categorized as an area source of HAPs for any future NESHAPs with compliance dates later than the issuance date of permit action 06500002‐002. According the calculations submitted to demonstrate compliance with the HAP emission rate limit required by 40 CFR pt. 63, subp. PPPP for the 2013/2014 compliance period, the total HAP emissions for the facility were less than 1 tpy. Due to the low actual emissions of HAPs, the facility elected to add limits on total and single HAP emissions to their permit with permit action 06500002‐002 that will limit their HAP emissions to below 22.0 tpy total HAPs and 9.0 tpy for any single HAP. The facility will demonstrate compliance with the limits through daily recordkeeping and monthly calculations of the 12‐month rolling sum of total and single HAP emissions. The facility was categorized as a major source of HAPs when the compliance date for 40 CFR pt. 63, subp. PPPP for Plastic Parts and Products surface coating passed, and is therefore subject to and must continue to comply with all applicable requirements of the NESHAP. This subpart was promulgated after the last permit action and the compliance date for existing sources was April 19th, 2007. The Permittee has stated that they will show compliance using the emission rate without add‐on controls option. The facility will not become subject to 40 CFR pt. 63, subp. JJJJJJ for Industrial, Commercial, and Institutional Boilers at Area Sources upon permit issuance. When permit action 06500002‐002 is issued, the limits to avoid major source status for total and single HAP emissions will become federally enforceable, and the facility will officially become an area source of HAPs. However, the boilers at the facility fit the definition of natural gas‐fired boilers at 40 CFR Section 63.11237 and are therefore exempt from 40 CFR pt. 63, subp. JJJJJJ according to 40 CFR Section 63.11195(e). EQUI6 does use distillate oil as a backup fuel, so the definition of gas‐fired boiler under 40 CFR pt. 63, subp. JJJJJJ has been put in the permit at EQUI6 to help ensure that the Permittee complies with the definition: to burn liquid fuel only during periods of gas curtailment, gas supply interruption, startups, or periodic testing on liquid fuel. The facility will not become subject to 40 CFR pt. 63, subp. DDDDD on the compliance date of January 31, 2016, since this permit action will establish limits on HAP emissions that make the facility an area source of HAPs prior to that date. 2.5 Compliance Assurance Monitoring (CAM) The table below lists the sources which are subject to CAM, whether the source is a Large pollutant specific emission unit (PSEU) or an Other PSEU, and the monitoring for the applicable pollutants.

Table 6. CAM Summary Unit Control CAM Applicability Pollutant

EQUI2 TREA12 Mat or Panel Filter Other PM






These units are subject to CAM because:

The units are subject to an emission limit or standard (PM limit from IPER).

The control device is necessary to achieve compliance with the limit.

Pre‐control emissions are >100 tpy (PM potential emissions are 633 tpy for EQUI2 – EQUI5, and 271 tpy for EQUI18).

The units are Other PSEUs because post‐control emissions are <100 tpy. The Permittee did not provide CAM plans for the units with the reissuance application nor was a CAM plan provided when requested by the MPCA after review of the application. Consequently, a compliance action was added to COMG7 requiring the Permittee to provide CAM plans for TREA12 ‐ 16 within 30 days of permit issuance. 2.6 Minnesota State Rules Portions of the facility are subject to the following Minnesota Standards of Performance:

Minn. R. 7011.0510 Standards of Performance for Existing Indirect Heating Equipment

Minn. R. 7011.0610 Standards of Performance for Fossil‐Fuel‐Burning Direct Heating Equipment

Minn. R. 7011.0715 Standards of Performance for Post‐1969 Industrial Process Equipment

Table 7. Regulatory Overview of Facility Subject Item* Applicable Regulations Rationale

TFAC (Total

Facility)

Minn. R. 7007.0800, subp. 2 This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices.

40 CFR pt. 82 The facility currently uses ozone‐depleting substances as defined in 40 CFR pt. 82. The facility must read Sections 601‐618 of the 1990 Clean Air Act Amendments and 40 CFR pt. 82 to determine the requirements that apply. This requirement pertains to a federal program that the state does not enforce.

Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010‐7009.0080

Requirement to submit modeling information. The Permittee is required to submit modeling information if they have total facility potential emissions of PM10 greater than 100 tpy, but actual emissions less than 100 tpy. The total facility potential emissions for PM10 are 2916 tpy and actual emissions are 2.57 tpy.

COMG4 (Coating Booth Limits)

Limits to avoid 40 CFR § 52.21 Prevention of Significant Deterioration. Limits taken on VOCs, PM10, and PM2.5 emissions to avoid major source classification under PSD. Requirement to vent to and operate control equipment to maintain PM10 and PM2.5 emissions below major source thresholds. The limits apply to the combined emissions from the COMG4 coating booths.

Limits to avoid 40 CFR § 63.2 Limit to avoid major source for HAPs. Limits taken on total and single HAP usage/emissions to avoid major source classification under 40 CFR § 63.2. The limits apply to the combined emissions from the COMG4 coating booths.

Minn. R. 7011.0715 Standards of Performance for Industrial Process Equipment. This rule applies to any process equipment that is not regulated by another standard of performance (NSPS or MN rules).


Subject Item* Applicable Regulations Rationale

COMG3

(Indirect Heating Units)

Minn. R. 7011.0510 Standards of Performance for Existing Indirect Heating Equipment. This standard applies to any indirect heating equipment for which a standard of performance has not been promulgated in a specific rule. Existing equipment are units that were constructed prior to January 31, 1977. Determination of applicable limit from rule:

COMG3 units were constructed in 1975;

the facility is located outside the cities in Table I;

the unit capacity is less than 250 MMBtu/hr; and

the facility has less than 250 MMBtu/hr of indirect heating equipment.

COMG7 (Paint Filters)

40 CFR pt. 64 (CAM) Compliance Assurance Monitoring. The paint booths and their associated filters are subject to CAM. The Permittee must provide CAM plans for all the control equipment in COMG7 within 30 days after permit issuance.

Limits to avoid 40 CFR § 52.21 Prevention of Significant Deterioration. Requirement to operate and maintain the control equipment such that they achieve a certain control efficiency. For PM10 and PM2.5, the control itself is not sufficient to ensure the threshold is not exceeded, but the control is taken into account in the compliance calculations for PM10 and PM2.5.

COMG6

(40 CFR pt.

63, subp.

PPPP)

40 CFR pt. 63, subp. PPPP National Emission Standards for Hazardous Air Pollutants from Surface Coating of Plastic Parts and Products. According to 40 CFR § 63.4481(a)(1) and (b) this subpart applies to facilities that conduct coating operations on plastic parts or products, use more than 100 gallons per year of HAP‐containing coatings, and are a major source of HAPs. According to their 2013/2014 subp. PPPP compliance calculations IPI used over 5,000 gallons of HAP‐containing coatings in a year. IPI is part of the general use coating subcategory because they do not fit under any of the more specific subcategories (automotive lamp, thermoplastic olefin, or assembled on‐road vehicle surface coating) as stated in 40 CFR § 63.4481(a)(2). The facility is an existing source because they commenced construction prior to December 4, 2002 (40 CFR § 63.4482(d)). The compliance date for existing sources was April 19, 2007 (40 CFR § 63.4482(b)).

EQUI6‐7 (Boilers 1‐2)

Minn. R. 7011.0510 Standards of Performance for Existing Indirect Heating Equipment. Determination of applicable limit from rule:

both units were constructed in 1975;

the facility is located outside the cities in Table I;

both boilers have a unit capacity less than 250 MMBtu/hr; and

the facility has less than 250 MMBtu/hr of indirect heating equipment.

EQUI17 (Dryer/Oven – Main)

Minn. R. 7011.0610 Standards of Performance for Fossil‐Fuel‐Burning Direct Heating Equipment. This standard applies to fossil‐fuel‐burning direct heating equipment for which a standard of performance has not been promulgated in a specific rule. This unit burns natural gas only.


*Location of the requirement in the permit (e.g., EQUI, STRU, COMG, etc.). 3. Technical Information 3.1 Calculations of Potential to Emit Attachment 1 to this TSD contains a summary of the PTE of the facility, as well as detailed spreadsheets and supporting information prepared by the MPCA and the Permittee. 3.2 Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considered the following:

the likelihood of the facility violating the applicable requirements;

whether add‐on controls are necessary to meet the emission limits;

the variability of emissions over time;

the type of monitoring, process, maintenance, or control equipment data already available for the emission unit;

the technical and economic feasibility of possible periodic monitoring methods; and

the kind of monitoring found on similar units elsewhere. Table 5 summarizes the monitoring requirements.

Table 8. Monitoring Subject Item*

Requirement (basis) Monitoring Discussion

COMG 4 (Coating Booth Limits)

VOC ≤ 196 tons per year, on a 12 month rolling sum basis (limit to avoid NSR)

Recordkeeping: Daily records of coating usage; On‐going MSDS records of coating contents; Monthly calculations of emissions.

Records are generated on a daily basis. Materials are dispensed from the central storage room based on production requisition forms that specify the part number and quantity needed. An employee records this data on usage logs. On a monthly basis the Permittee must use the daily logs to determine the total usage of VOC‐containing materials each month and then calculate the total amount of VOCs emitted during the month using the daily log and the record of material contents for each coating type. The monthly emissions can then be summed to calculate the 12‐month rolling sum and assure compliance with the limit. The Permittee has stated that taking credit for VOCs shipped as waste is currently unnecessary because actual emissions have been much lower than the limit (11.5 tpy for 2013), however, the option to take credit is available. If used, the Permittee must follow the specifications in the Waste Credit requirement at COMG 4.


Subject Item*


PM10/PM2.5 ≤ 225 tons per year, on a 12 month rolling sum basis (limit to avoid NSR)

Recordkeeping: Daily records of coating usage; On‐going MSDS records of coating contents; Requirement to vent to, operate, and maintain the associated control equipment; Monthly calculations of emissions.

Records are generated on a daily basis. Materials are dispensed from the central storage room based on production requisition forms that specify the part number and quantity needed. An employee records this data on usage logs. On a monthly basis the Permittee must use the daily logs to determine the total usage of solids‐containing materials each month and then calculate the total amount of PM10 and PM2.5 emitted during the month using the daily log and the record of material contents for each coating type. The terms of the emission calculations are specified in the permit. For solids, the conservative assumption is made that all coating operations are conducted using air atomization spray (30% transfer efficiency), since this is an option for all booths even though high‐volume low‐pressure technology is also used. Overall control efficiency is 0.68% based on the control equipment rule and assumptions regarding relative amounts of PM10 and PM2.5 (see Attachment 1 to this TSD for more details of assumptions used). The monthly emissions can be summed to calculate the 12‐month rolling sum and assure compliance with the limit. The Permittee may take credit for solids disposed as waste in the calculation of emissions, according to the specifications in the Waste Credit requirement at COMG 4.

HAPs‐Total ≤ 22.0 tons per year, HAP‐Single ≤ 9.0 tpy on a 12 month rolling sum basis (limit to avoid NSR)

Recordkeeping: Dailyrecords of coating usage; On‐going MSDS records of coating contents; Monthly calculations of emissions.

Records are generated on a daily basis. Materials are dispensed from the central storage room based on production requisition forms that specify the part number and quantity needed. An employee records this data on usage logs. On a monthly basis the Permittee must use the daily logs to determine the total usage of HAP‐containing materials each month and then calculate the total amount of HAPs emitted during the month using the daily log and the record of material contents for each coating type. The monthly emissions can then be summed to calculate the 12‐month rolling sum and assure compliance with the limit. The Permittee may take credit for solids disposed as waste in the calculation of emissions, according to the specifications in the Waste Credit requirement at COMG 4.

PM ≤ variable with airflow Opacity ≤ 20.0 % (Minn. R. 7011.0715)

Vent to associated control equipment meeting the requirements of COMG 7

Requirements to vent to, operate, and maintain the associated panel filters ensure compliance with IPER limits. With control, the PM PTE is 1.33 lbs/hr. The IPER limits for these units based on airflow are 15.6 lbs/hr for EQUI2 – EQUI5 and 5.98 lbs/hr for EQUI18.


Subject Item*


COMG 3 (Indirect Heating Equipment)

PM ≤ 0.60 lbs/MMBtu Opacity < 20 % with exceptions (Minn. R. 7011.0515)

None All units use natural gas; therefore, the likelihood of violating either of the emission limits is very small. The Permittee can demonstrate that these units will continue to operate such that emissions are well below the emission limits by only burning natural gas. Design based PM PTE for each unit, using AP‐42, is 0.0072 compared to the rule limit of 0.60 lbs/MMBtu.

Fuel Type: natural gas only

None These units burn natural gas only by design.

COMG 7 (Paint Filters)

PM Control efficiency ≥ 99.0%; PM10 control efficiency ≥ 85.0%; PM2.5 control efficiency ≥ 85.0% (limit to avoid NSR)

Operation and maintenance of the equipment according to the Operation and Maintenance (O&M) Plan; Daily filter inspections; Periodic component inspections; Corrective actions; Records

Operation according to the O&M plan, daily inspections, periodic inspections, and corrective actions are all sufficient to ensure that the equipment is adequately maintained, problems are quickly recognized, and corrective actions are taken when necessary, thereby ensuring that the control efficiency standards are achieved. The Permittee must keep records of all inspections and corrective actions so that compliance with these requirements can be verified.

COMG 6 (40 CFR pt. 63, subp. PPPP)

HAPS‐Organic ≤ 0.16 kilograms/ kilograms of coating solids used during each 12‐month compliance period

Recordkeeping; monthly calculation of the organic HAP emission rate for the previous 12‐month period

The Permittee has elected to use the ‘emission rate without add‐on controls’ compliance option. Monitoring according the requirements of the subpart is adequate to assure compliance with the limit.

EQUI 6 (Boiler 2)

PM ≤ 0.60 lbs/MMBtu heat input; Opacity: ≤ 20% (Minn. R. 7011.0715)

None This unit uses natural gas or distillate oil; therefore, the likelihood of violating either of the emission limits is very small. The Permittee can demonstrate that the unit will continue to operate such that emissions are well below the emission limits by only burning natural gas or distillate oil. PM PTE for distillate oil combustion, using AP‐42, is 0.024 lbs/MMBtu compared to the rule limit of 0.60 lbs/MMBtu.

Fuel Type: natural gas or distillate oil only

None This unit burns natural gas or distillate oil only, by design.

EQUI 7 (Boiler 1)

PM ≤ 0.60 lbs/MMBtu heat input; Opacity: ≤ 20% (Minn. R. 7011.0715)

None This unit uses natural gas only; therefore, the likelihood of violating either of the emission limits is very small. The Permittee can demonstrate that the unit will continue to operate such that emissions are well below the emission limits by only burning natural gas. PM PTE for distillate oil combustion, using AP‐42, is 0.0072 lbs/MMBtu compared to the rule limit of 0.60 lbs/MMBtu.


Subject Item*


Fuel Type: natural gas only

None This unit burns natural gas only, by design.

EQUI17 (Dryer/Oven – Main)

PM ≤ 0.30 grains/dscf; Opacity ≤ 20.0%, with exceptions (Minn. R. 7011.0610)

None This unit uses natural gas only, by design; therefore it is highly unlikely that it could violate the applicable requirements. The PM PTE for EQUI17 is 0.0022 grains/dscf compared to the rule limit of 0.30 grains/dscf.

*Location of the requirement in the permit (e.g., EQUI, STRU, COMG, etc.). 3.3 Insignificant Activities Imperial Plastics Incorporated has several operations which are classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix A to the permit. The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities. See Attachment 1 of this TSD for PTE information for the insignificant activities.

Table 9. Insignificant Activities

Insignificant Activity General Applicable

Emission limit Discussion

Infrared electric ovens Opacity ≤ 20% (Minn. R. 7011.0105)

This type of unit should not generate particulate matter. It is highly unlikely that they could violate the applicable requirement.

Brazing, soldering or welding equipment

PM, variable depending on airflow; Opacity ≤ 20% (Minn. R. 7011.0715)

For these units, based on EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, these units are typically operated and vented inside a building, so testing for PM or opacity is not feasible.

Blueprint copiers and photographic processes

Opacity ≤ 20% (Minn. R. 7011.0105)

While no known emissions estimation method exists for these units, based on general knowledge of how they operate, it is highly unlikely that they could generate visible emissions. In addition, these units would be operated and vented directly into an office area, so monitoring or testing is not feasible.

Cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners

PM, variable depending on airflow; Opacity ≤ 20% (Minn. R. 7011.0715)

For these units, there are some factors available for the burners, but very little information regarding the cleaning operation itself. However, based on general knowledge of how they operate, it is highly unlikely that they could violate the applicable requirement or that testing would be feasible.


Insignificant Activity General Applicable

Emission limit Discussion

Individual units with potential emissions less than 2000 lb/year of certain pollutants

PM ≤ 0.6 lb/MMBtu Opacity ≤ 20% with exceptions (Minn. R. 7011.0510) or PM, variable depending on airflow Opacity ≤ 20% (with exceptions) (Minn. R. 7011.0715 and Minn. R. 7011.0610)

These are natural gas‐fired combustion units (space heaters and 4 furnaces), injection molding presses, and 4 sanding booths. For the natural gas units, based on the fuel used and EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, all of these units are operated and vented inside a building, so testing for PM or opacity is not feasible. The molding presses are not expected to generate particulate matter. The PM emissions from the sanding booths are well below the thresholds under Minn. R. 7011.0715 for each unit (see Attachment 1 for calculations).

Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source

PM, variable depending on airflow or process weight rate Opacity ≤ 20% (Minn. R. 7011.0715)

While spray equipment will have the potential to emit particulate matter, these particular activities are those not associated with production, so they would be infrequent and usually occur outdoors. Testing or monitoring is not feasible.

Equipment venting PM/PM10 inside a building, provided that emissions from the equipment are: a) filtered through an air cleaning system; and b) vented inside of the building 100% of the time

PM, variable depending on airflow Opacity ≤ 20% (Minn. R. 7011.0715)

For these units, it is highly unlikely that they could violate the applicable requirement. In addition, these units are vented inside a building, so testing for PM or opacity is not feasible. Analysis for CAM applicability: The PM/PM10 emissions from the 4 sanding booths that are vented externally were evaluated for this reissuance and found to have combined emissions of less than 3 tpy without including reductions from control equipment. The 3 internally‐vented sanding booths are similar operations, therefore we do not expect these units to have pre‐control emissions greater than 100 tpy, so they are not subject to CAM.

3.4 Permit Organization In general, the permit meets the MPCA Tempo Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Tempo guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be electronically tracked (e.g., limits, submittals, etc.), should be in the Requirements table in Tempo. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these. This permit uses an appendix for specific calculation procedures from 40 CFR pt. 63, subp. PPPP. These procedures are too complex to enter into Delta and must go in an appendix. Another area that deviates from the guidance is in the use of groups where the requirements in the group apply to the members of the group individually. This was done in order to shorten the permit and


where no testing or tracking specific to a unit is in the permit (thereby reducing the likelihood that there where will be further unit‐specific requirements later). This is the case for the requirements at COMG4 (coating booth limits), COMG3 (Indirect Heating Units), COMG7 (Paint Filters), and COMG6 (40 CFR pt. 63 subp. PPPP). 3.5 Comments Received Public Notice Period: 11/26/15 ‐ 12/28/15 EPA 45‐day Review Period: 11/26/15 – 1/11/16

Comments were not received from the public during the public notice period. Comments were received from EPA during their review period. Changes to the permit were made as a result of the comments. The following are the comments and the MPCA responses. EPA Comment 1: Table 3 of the technical support document (TSD), lists the total facility limited potential emissions of PM10 and PM2.5 as 201 tons per year (tpy) each. However, permit #06500002‐002 appears to limit emission of PM10 and PM2.5 to 225 tpy from group COMG4 (p.12‐13, TSD). Please clarify or correct the TSD to reflect the facility limited potential emissions of PM10 and PM2.5. MPCA Response 1: That has been corrected to 226 tpy in the TSD Table 3. EPA Comment 2: Section 2.1 of the TSD also cites a total facility potential to emit (PTE) of 200 tpy of PM10 and PM2.5 at group COMG4. The limit in the permit is 225 tpy from group COMG4. Please correct the TSD to reflect the facility limited potential emissions of PM10 and PM2.5. MPCA Response 2: That has been corrected to 225 tpy in the TSD Section 2.1. EPA Comment 3: Section 2.4 of the TSD states that "the facility took limits in 2015 to be categorized as an area source of HAPs for any future standards." The TSD fails to explain further how/where this was done. Moreover, this does not appear to have been done with a permit action — the last permit issued to this facility is a total facility permit issued in 2001. Please explain how/where the facility's HAPs were limited in 2015. MPCA Response 3: The facility is accepting limits to become an area source of HAPs with this permit action. I clarified when and why this will happen by adding the following to the TSD Section 2.4: “The facility will take limits, effective with this permit action, to be categorized as an area source of HAPs for any future NESHAPs with compliance dates later than the issuance date of permit action 06500002‐002. According to the calculations submitted to demonstrate compliance with the HAP emission rate limit required by 40 CFR pt. 63, subp. PPPP for the 2013/2014 compliance period, the total HAP emissions for the facility were less than 1 tpy. Due to the low actual emissions of HAPs, the facility elected to add limits on total and single HAP emissions to their permit with permit action 06500002‐002 that will limit their HAP emissions to below 22.0 tpy total HAPs and 9.0 tpy for any single HAP. The facility will demonstrate compliance with the limits through daily recordkeeping and monthly calculations of the 12‐month rolling sum of total and single HAP emissions.” EPA Comment 4: In order for the facility to avoid applicability with a MACT standard, they must have an enforceable restriction in place prior to the compliance date of the standard. Section 2.4 of the TSD also states that "the facility is subject to 40 CFR part 63 by accepting a limit to avoid major source status for HAPs. The re‐designation of the facility as an area source of HAPs is effective upon permit issuance."


Section 2.4 of the TSD goes on to state "the facility is not subject to 40 CFR part 63, subpart DDDDD, since the facility accepted limits on HAPs prior to the compliance date of January 31, 2016." Unless enforceable restrictions have been taken in a previously issued permit, this statement assumes that this permit, and its restrictions on HAPs, will be issued by January 31, 2016. Please explain if/where enforceable restrictions were taken to limit PTE of HAPs to below major source thresholds for 40 CFR part 63, subpart DDDDD. MPCA Response 4: The limits to avoid major source status will not be federally enforceable until permit action ‐002 is issued (which I had initially assumed would happen in 2015). I clarified the statement regarding NESHAP subp. JJJJJJ by changing it to the following: “Upon permit issuance, the facility will be subject to 40 CFR pt. 63, subp. JJJJJJ for Industrial, Commercial, and Institutional Boilers at Area Sources. When permit action 06500002‐002 is issued, the limits to avoid major source status for total and single HAP emissions will become federally enforceable, the facility will officially become an area source of HAPs, and IPI will have to comply with all applicable requirements of NESHAP subp. JJJJJJ.” (Note: this has since been edited to the current TSD text in the third paragraph of Section 2.4 of this TSD, since realizing that neither of the boilers EQUI6 or 7 will be subject to NESHAP, subp. JJJJJJ.) The sentence regarding NESHAP subp. DDDDD was written assuming that the permit would be issued prior to January 31, 2016. I had thought that that time frame was reasonably certain when I took over the writing of this permit last summer. However, due to delays from implementing the new permitting database (and the lack of responsiveness of this facility) it is much closer to that date than anticipated. I am still very much hoping that the permit will be issued before the end of the month. I changed the TSD language to: “The facility will not become subject to 40 CFR pt. 63, subp. DDDDD on the compliance date of January 31, 2016, since this permit action will establish limits on HAP emissions that make the facility an area source of HAPs prior to that date.” EPA Comment 5: Page 33 of the draft permit requires the Permittee to submit a CAM plan for group COMG7 within 180 calendar days after permit issuance. Since a CAM plan was due in 2006, 180 days to submit one seems like an excessive amount of time to give the Permittee to come into compliance with this requirement. Please revise the permit to require the CAM plan be submitted within 30 days of permit issuance. MPCA Response 5: That change has been made. EPA Comment 6: Once the CAM plan is submitted and reviewed by MPCA, the elements of the plan need to be incorporated into the Title V permit. However, neither the draft permit nor the TSD explain how this will be performed. In addition, the draft permit does not specify the timeframe by which this should occur. Please explain, in terms of the permit process, how the elements of the CAM plan will be incorporated into the facility's Title V permit and revise the permit to specify details of the process for including permit conditions to address the compliance schedule. MPCA Response 6: I added the following language to the permit. The first requirement is directly from the CAM rule and seemed like a good thing to include as additional incentive for the Permittee to fulfill the requirement to submit CAM plans. The second is a requirement to submit a major amendment permit application within 30 days of permit issuance in order to incorporate the requirements from the CAM plans. Once the requirements are incorporated they will have fully addressed the non‐compliance.

If the Permittee does not submit a CAM plan in accordance with the compliance schedule in Section 7 of this permit, or if the permitting authority disapproves the plan submitted, the Permittee shall be deemed not in compliance with 40 CFR pt. 64, unless the Permittee successfully challenges the disapproval. [40 CFR Section 64.6(e)(3)]


The Permittee shall submit a permit application within 30 days after receipt of notification of approval of the submitted CAM plan to incorporate the requirements of the plan into the permit in accordance with 40 CFR Section 64.6(c). [Minn. R. 7007.0800, subps. 1‐2, Minn. R. 7007.0100, subp. 7(A), Minn. R. 7007.0100, subp. 7(F)]

EPA Comment 7: The following comment is typographical in nature: Page 3 of the TSD incorrectly cites 40 CFR Section 62.2 as the statutory authority for limiting HAP emissions. The correct statutory authority is 63.2. Please correct this error. MPCA Response 7: That has been corrected. 4. Permit Fee Assessment This permit action is the reissuance of an individual Part 70 with no rolled amendments applications; therefore, therefore no application fees or additional points apply under Minn. R. 7002.0016, subp. 1. 5. Conclusion Based on the information provided by Imperial Plastics Inc the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 06500002‐ 002 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Rachel Yucuis (permit engineer)

Steve Palzkill (enforcement) Steve Palzkill (compliance) Bonnie Nelson (peer reviewer) Beckie Olson (permit writing assistant) Laurie O’Brien (administrative support)

TEMPO360 Activities: Administrative Change, Part 70 Permit Reissuance Attachments: 1. PTE Summary and Calculation Spreadsheets

2. Facility Description and CD‐01 Forms 3. Filter Specifications for TREA12 – TREA16 4. Change of ownership request

TSD Attachments Attachment 1: PTE Summary and Calculation Spreadsheets

Imperial Plastics Inc. Facility ID Number: 06500002-002

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1.17

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159

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091.

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110.

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Clea

ning

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COM

G4(G

P00

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mits

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69.

0022

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tal*

*30

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120

10.

0608

8.22

6.18

9324

196

9.13

22.1

*Inc

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sem

issio

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omEU

003

006,

008,

and

020

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tali

sthe

sum

ofCO

MG4

(GP0

01)p

lusa

llot

here

miss

ions

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ptfo

rthe

indi

vidu

alem

issio

nsfr

omEQ

UI2

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8,an

d20

(EU

003

006,

008,

and

020)

Impe

rialP

last

icsI

ncor

pora

ted

Perm

it#0

6500

002

002

PMem

issio

nsfr

omBo

oths

,EU

s003

,004

,005

,006

,and

008

EQU

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eGu

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paci

ty(g

al/h

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10Ap

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d(lb

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Tran

sfer

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ptur

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ficie

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ffici

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ions

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py)

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ions

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ntro

lled

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ns(t

py)

200

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#121

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0.80

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144.

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Boot

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1.33

5.83

400

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144.

663

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Boot

h#4

21.1

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300.

800.

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4.6

633

1.33

5.83

1800

8Ba

tch

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h21

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8.3

0.30

0.80

0.99

144.

663

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335.

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ncon

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PM10

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(lb/h

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PM10

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PM10

Emiss

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(lb/h

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PM10

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(tpy

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003

Boot

h#1

21.1

258.

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563

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Boot

h#2

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30.

300.

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563

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Boot

h#3

21.1

258.

30.

300.

800.

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563

321

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Boot

h#4

21.1

258.

30.

300.

800.

8514

563

321

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Batc

hBo

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21.1

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30.

300.

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4.6

633

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633

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95.0

300

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144.

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.125

8.3

0.30

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144.

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321

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21.1

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300.

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4.6

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21.7

95.0

(2)A

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rtifi

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requ

ired

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rmit

(3)C

ontr

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ficie

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from

man

ufac

ture

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form

atio

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eTS

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000

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315

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3So

lid(%

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5Bo

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#413

2500

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60.

073

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0.00

623

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(lb/g

al)

12.2

418

Batc

hBo

oth

1470

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6974

0.10

05.

980.

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CAM

Appl

icab

ility

EU00

3EU

006,

EU00

8ar

esu

bjec

tto

CAM

forP

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bjec

tto

limit

orst

anda

rd(IP

ERlb

/hrl

imit)

The

cont

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evic

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nece

ssar

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achi

eve

com

plia

nce

with

IPER

Pre

cont

rolE

miss

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are

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(633

tpy

and

271

tpy

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U00

8)Th

eyar

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ther

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s(po

stco

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nsar

e<1

00tp

y)(N

otsu

bjec

tto

CAM

forP

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orPM

2.5

beca

use

ther

eis

nolim

itth

atap

plie

sind

ivid

ually

toea

chun

itfo

rPM

10or

PM2.

5,on

lyto

the

GP)

Wor

stca

seCo

atin

g

(1)T

hePe

rmitt

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ssta

ted

that

both

High

Pres

sure

/Low

Volu

me

(HPL

V)an

dai

rato

mize

dsp

ray

appl

icat

ion

met

hods

are

used

inBo

oths

14

(EU

003

006)

,the

refo

reth

elo

wer

tran

sfer

effic

ienc

yof

30%

isus

edfo

rthe

calc

ulat

ions

(5)A

lthou

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pect

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eca

ptur

eef

ficie

ncy

ofpa

nelf

ilter

sfor

part

icle

s les

stha

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5m

icro

nsw

ould

belo

wer

than

forP

M10

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also

expe

ctPM

2.5

tore

pres

enta

muc

hsm

alle

rpor

tion

ofth

eto

taln

umbe

rofp

artic

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A20

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ribut

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rom

ate

Pain

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ray

Boot

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ente

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%of

the

part

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erat

edw

hen

spra

ying

asu

rfac

eus

ing

HVLP

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refo

re,t

hesa

me

cont

rol

effic

ienc

yis

used

forP

M2.

5as

forP

M10

asa

com

prom

isebe

twee

nth

elo

wer

effic

ienc

yan

dth

elo

wer

port

ion

ofPM

2.5.

Impe

rialP

last

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ncor

pora

ted

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it#0

6500

002

002

VOC

and

HAPs

from

Boot

hs,E

QU

I002

,003

,004

,005

,and

018

(EU

s003

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,005

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,and

008)

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(sam

efo

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boot

hs)

21.1

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ally

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/gal

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633

13.3

58.5

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3971

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4Co

pper

3.57

75.3

330

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kel

8.14

172

752

2Bu

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111

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1.11

23.4

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7.96

168

736

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345

1.15

24.2

106

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ngle

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752

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the

sum

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omth

eco

atin

gw

ithth

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ghes

ttot

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Pco

nten

t in

lb/g

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hich

is"V

onRo

llIs

ola"

prod

uct#

3063

FDLC

Impe

rialP

last

icsI

ncor

pora

ted

Perm

it#0

6500

002

002

Dem

onst

ratio

nth

atfo

rmer

VOC

limit

does

notl

imit

PM

EPC

Num

ber

400

0041

0M

anuf

actu

rer

Sher

win

Will

iam

sPr

oduc

tNum

ber

D61X

XA14

804

Dens

ity(lb

/gal

)12

.48

VOC

(%)

6.65

%VO

C(lb

/gal

)0.

83VO

C(lb

/hr)

17.5

Hour

sto

reac

hVO

Clim

it22

386

(>87

60)

PM10

/PM

2.5

(%)

93.3

5%PM

10/P

M2.

5(lb

/gal

)11

.65

PM10

/PM

2.5

(lb/h

r)24

6PM

10/P

M2.

5(t

py)

1077

perb

ooth

PM10

/PM

2.5

w/c

ontr

ol(t

py)*

90.4

perb

ooth

PM10

/PM

2.5

(tpy

)53

83to

tal

PM10

/PM

2.5

w/c

ontr

ol(t

py)

452

tota

l*3

0%ef

ficie

ncy,

80%

capt

ure,

85%

cont

role

ffici

ency

VOC

limit

does

notl

imit

PM10

/PM

2.5.

Dem

onst

ratio

nus

ing

coat

ing

with

high

estP

M/V

OC

ratio

Impe

rialP

last

icsI

ncor

pora

ted

Perm

it#0

6500

002

002

VOCs

from

EQU

I020

(EU

020)

Clea

ning

Solv

ents

Pote

ntia

lVO

CEm

issi

onsf

rom

clea

ning

solv

entu

se

Valu

eU

nits

Not

es15

500

gallo

ns/y

ear

annu

alus

age

atCC

S8

lbs/

gallo

nVO

Cco

nten

tofw

orst

case

clea

ning

solv

enta

tCCS

1240

00lb

s/ye

arVO

Cus

age

rate

14.2

lbs/

hres

timat

edVO

Cem

issio

nsat

EPC

62.0

tpy

estim

ated

VOC

emiss

ions

atEP

CAs

sum

eth

atth

efa

cilit

yus

esth

esa

me

amou

ntof

clea

ning

solv

ents

asCr

own

Cork

&Se

al(C

CS)(

See

emiss

ion

calc

ulat

ions

forp

erm

it#1

3100

0700

4).C

CSis

aca

nm

anuf

actu

ring

faci

lity

that

cond

ucts

roll

coat

ing

onm

etal

shee

tspr

iort

oca

nas

sem

blag

e.Th

issh

ould

bea

cons

erva

tive

assu

mpt

ion

beca

use

actu

alVO

Cem

issio

nsfo

rCCS

are

muc

hhi

gher

than

for

CCS

than

forE

PC(3

8tp

yvs

.14

tpy)

and

solv

ents

tend

toha

vehi

ghVO

Cco

nten

t,th

eref

ore

solv

entu

sage

rate

shou

ldbe

high

erat

CCS.

Even

ifVO

Cem

issio

nsfr

omso

lven

tusa

getu

rnou

tto

behi

gher

atEP

C,th

isw

illbe

acco

unte

dfo

rin

the

com

plia

nce

calc

uala

tion

fort

heVO

Clim

it.

Impe

rialP

last

icsI

ncor

pora

ted

Perm

it#0

6500

002

002

Boile

rEQ

UI0

07(E

U00

1)He

atIn

putP

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iler

5M

MBt

u/hr

Fuel

Type

Nat

ural

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Gros

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ting

Valu

eof

NG

1050

btu/

scf

0.00

720.

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3809

5Po

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ntEm

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ctor

Emiss

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Fact

orU

nit

Emiss

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Fact

orSo

urce

Pote

ntia

lEm

issio

ns(lb

/hr)

Pote

ntia

lto

Emit

(tpy

)To

talP

artic

ulat

eM

atte

r7.

6lb

/MM

scf

AP42

Tabl

e1.

42

3.62

E02

1.59

E01

Tota

lPM

107.

6lb

/MM

scf

AP42

Tabl

e1.

42

3.62

E02

1.59

E01

Tota

lPM

2.5

7.6

lb/M

Msc

fAP

42Ta

ble

1.4

23.

62E

021.

59E

01SO

x0.

6lb

/MM

scf

AP42

Tabl

e1.

42

2.86

E03

1.25

E02

NO

x10

0lb

/MM

scf

AP42

Tabl

e1.

41

4.76

E01

2.09

E+00

CO84

lb/M

Msc

fAP

42Ta

ble

1.4

14.

00E

011.

75E+

00VO

C5.

5lb

/MM

scf

AP42

Tabl

e1.

42

2.62

E02

1.15

E01

CO2

116.

9760

76lb

/MM

Btu

40CF

RPa

rt98

5.85

E+02

2.56

E+03

CH4

2.20

E03

lb/M

MBt

u40

CFR

Part

981.

10E

024.

83E

02N

2O0.

0002

2046

lb/M

MBt

u40

CFR

Part

981.

10E

034.

83E

03CO

2e11

7.09

6888

1lb

/MM

Btu

40CF

RPa

rt98

5.85

E+02

2.56

E+03

HAPS

Benz

ene

2.10

E03

lb/M

Msc

fAP

42Ta

ble

1.4

31.

00E

054.

38E

05Di

chlo

robe

nzen

e1.

20E

03lb

/MM

scf

AP42

Tabl

e1.

43

5.71

E06

2.50

E05

Form

alde

hyde

7.50

E02

lb/M

Msc

fAP

42Ta

ble

1.4

33.

57E

041.

56E

03He

xane

1.80

E+00

lb/M

Msc

fAP

42Ta

ble

1.4

38.

57E

033.

75E

02N

apht

hale

ne6.

10E

04lb

/MM

scf

AP42

Tabl

e1.

43

2.90

E06

1.27

E05

PAH

(not

incl

udin

gna

phth

alen

e)8.

82E

05lb

/MM

scf

AP42

Tabl

e1.

43

4.20

E07

1.84

E06

Tolu

ene

3.40

E03

lb/M

Msc

fAP

42Ta

ble

1.4

31.

62E

057.

09E

05Ar

seni

c2.

00E

04lb

/MM

scf

AP42

Tabl

e1.

44

9.52

E07

4.17

E06

Bery

llium

1.20

E05

lb/M

Msc

fAP

42Ta

ble

1.4

45.

71E

082.

50E

07Ca

dmiu

m1.

10E

03lb

/MM

scf

AP42

Tabl

e1.

44

5.24

E06

2.29

E05

Chro

miu

m1.

40E

03lb

/MM

scf

AP42

Tabl

e1.

44

6.67

E06

2.92

E05

Coba

lt8.

40E

05lb

/MM

scf

AP42

Tabl

e1.

44

4.00

E07

1.75

E06

Lead

5.00

E04

lb/M

Msc

fAP

42Ta

ble

1.4

22.

38E

061.

04E

05M

anga

nese

3.80

E04

lb/M

Msc

fAP

42Ta

ble

1.4

41.

81E

067.

93E

06M

ercu

ry2.

60E

04lb

/MM

scf

AP42

Tabl

e1.

44

1.24

E06

5.42

E06

Nic

kel

2.10

E03

lb/M

Msc

fAP

42Ta

ble

1.4

41.

00E

054.

38E

05Se

leni

um2.

40E

05lb

/MM

scf

AP42

Tabl

e1.

44

1.14

E07

5.01

E07

TOTA

LHA

PS8.

99E

033.

94E

02M

axSi

ngle

HAP

8.57

E03

3.75

E02

§98

Subp

artC

Fuel

HHV

Pollu

tant

Glob

alW

arm

ing

Pote

ntia

lEF

(kg/

MM

Btu)

EF(lb

/MM

Btu)

Nat

ural

Gas

1050

CO2

153

.06

116.

9760

76bt

u/sc

fCH

425

0.00

10.

0022

046

N2O

298

0.00

010.

0002

2046

Impe

rialP

last

icsI

ncor

pora

ted

Perm

it#0

6500

002

002

Boile

rEQ

UI0

06(E

U00

2)He

atIn

putP

erBo

iler

3.85

MM

Btu/

hrFu

elTy

peN

atur

alGa

sw/N

o.2

Fuel

Oil

Back

upGr

ossH

eatin

gVa

lue

ofN

G10

50bt

u/sc

f

Pollu

tant

Emiss

ion

Fact

orEm

issio

nFa

ctor

Uni

tEm

issio

nFa

ctor

Sour

cePo

tent

ialE

miss

ions

(lb/h

r)Po

tent

ialt

oEm

it(t

py)

Tota

lPar

ticul

ate

Mat

ter

7.6

lb/M

Msc

fAP

42Ta

ble

1.4

22.

79E

021.

22E

01To

talP

M10

7.6

lb/M

Msc

fAP

42Ta

ble

1.4

22.

79E

021.

22E

01To

talP

M2.

57.

6lb

/MM

scf

AP42

Tabl

e1.

42

2.79

E02

1.22

E01

SOx

0.6

lb/M

Msc

fAP

42Ta

ble

1.4

22.

20E

039.

64E

03N

Ox

100

lb/M

Msc

fAP

42Ta

ble

1.4

13.

67E

011.

61E+

00CO

84lb

/MM

scf

AP42

Tabl

e1.

41

3.08

E01

1.35

E+00

VOC1

5.5

lb/M

Msc

fAP

42Ta

ble

1.4

22.

02E

028.

83E

02CO

22

116.

9760

76lb

/MM

Btu

40CF

RPa

rt98

4.50

E+02

1.97

E+03

CH4

20.

0022

046

lb/M

MBt

u40

CFR

Part

988.

49E

033.

72E

02N

2O2

0.00

0220

46lb

/MM

Btu

40CF

RPa

rt98

8.49

E04

3.72

E03

CO2e

211

7.09

6888

1lb

/MM

Btu

40CF

RPa

rt98

4.51

E+02

1.97

E+03

HAPS

Benz

ene

0.00

21lb

/MM

scf

AP42

Tabl

e1.

43

7.70

E06

3.37

E05

Dich

loro

benz

ene

0.00

12lb

/MM

scf

AP42

Tabl

e1.

43

4.40

E06

1.93

E05

Form

alde

hyde

0.07

5lb

/MM

scf

AP42

Tabl

e1.

43

2.75

E04

1.20

E03

Hexa

ne1.

8lb

/MM

scf

AP42

Tabl

e1.

43

6.60

E03

2.89

E02

Nap

htha

lene

0.00

061

lb/M

Msc

fAP

42Ta

ble

1.4

32.

24E

069.

80E

06PA

H(n

otin

clud

ing

naph

thal

ene)

0.00

0088

2lb

/MM

scf

AP42

Tabl

e1.

43

3.23

E07

1.42

E06

Tolu

ene

0.00

34lb

/MM

scf

AP42

Tabl

e1.

43

1.25

E05

5.46

E05

Arse

nic

0.00

02lb

/MM

scf

AP42

Tabl

e1.

44

7.33

E07

3.21

E06

Bery

llium

0.00

0012

lb/M

Msc

fAP

42Ta

ble

1.4

44.

40E

081.

93E

07Ca

dmiu

m0.

0011

lb/M

Msc

fAP

42Ta

ble

1.4

44.

03E

061.

77E

05Ch

rom

ium

0.00

14lb

/MM

scf

AP42

Tabl

e1.

44

5.13

E06

2.25

E05

Coba

lt0.

0000

84lb

/MM

scf

AP42

Tabl

e1.

44

3.08

E07

1.35

E06

Lead

0.00

05lb

/MM

scf

AP42

Tabl

e1.

42

1.83

E06

8.03

E06

Man

gane

se0.

0003

8lb

/MM

scf

AP42

Tabl

e1.

44

1.39

E06

6.10

E06

Mer

cury

0.00

026

lb/M

Msc

fAP

42Ta

ble

1.4

49.

53E

074.

18E

06N

icke

l0.

0021

lb/M

Msc

fAP

42Ta

ble

1.4

47.

70E

063.

37E

05Se

leni

um0.

0000

24lb

/MM

scf

AP42

Tabl

e1.

44

8.80

E08

3.85

E07

TOTA

LHA

PS6.

92E

033.

03E

02M

axSi

ngle

HAP

6.60

E03

2.89

E02

§98

Subp

artC

Fuel

HHV

Pollu

tant

Glob

alW

arm

ing

Pote

ntia

lEF

(kg/

MM

Btu)

EF(lb

/MM

Btu)

Nat

ural

Gas

1020

CO2

153

.06

116.

9760

76bt

u/sc

fCH

425

0.00

10.

0022

046

N2O

298

0.00

010.

0002

2046

Nat

ural

Gas(

Prim

ary

Fuel

)

Impe

rialP

last

icsI

ncor

pora

ted

Perm

it#0

6500

002

002

Boile

rEQ

UI0

06(E

U00

2)Gr

ossH

eatin

gVa

lue

ofN

o.2

Fuel

Oil

1370

00bt

u/ga

lpe

rAP

42Ap

pend

ixA

Pollu

tant

Emiss

ion

Fact

orEm

issio

nFa

ctor

Uni

tEm

issio

nFa

ctor

Sour

cePo

tent

ialE

miss

ions

(lb/h

r)Po

tent

ialt

oEm

it(t

py)

Tota

lPar

ticul

ate

Mat

ter

3.30

E+00

lb/1

03ga

lAP

42Ta

ble

1.3

19.

27E

024.

06E

01To

talP

M10

2.38

E+00

lb/1

03ga

lAP

42Ta

ble

1.3

76.

69E

022.

93E

01To

talP

M2.

52.

13E+

00lb

/103

gal

AP42

Tabl

e1.

37

5.99

E02

2.62

E01

SOx

2.13

E01

lb/1

03ga

lAP

42Ta

ble

1.3

15.

99E

032.

62E

02N

Ox

2.00

E+01

lb/1

03ga

lAP

42Ta

ble

1.3

15.

62E

012.

46E+

00CO

5.00

E+00

lb/1

03ga

lAP

42Ta

ble

1.3

11.

41E

016.

15E

01VO

C3.

40E

01lb

/103

gal

AP42

Tabl

e1.

33

9.55

E03

4.18

E02

CO2

1.63

E+02

lb/M

MBt

u40

CFR

Part

986.

28E+

022.

75E+

03CH

46.

61E

03lb

/MM

Btu

40CF

RPa

rt98

2.55

E02

1.12

E01

N2O

1.32

E03

lb/M

MBt

u40

CFR

Part

985.

09E

032.

23E

02CO

2e1.

64E+

02lb

/MM

Btu

40CF

RPa

rt98

6.30

E+02

2.76

E+03

HAPS

Benz

ene

2.14

E04

lb/1

03ga

lAP

42Ta

ble

1.3

96.

01E

062.

63E

05Et

hylb

enze

ne6.

36E

05lb

/103

gal

AP42

Tabl

e1.

39

1.79

E06

7.83

E06

Form

alde

hyde

3.30

E02

lb/1

03ga

lAP

42Ta

ble

1.3

99.

27E

044.

06E

03N

apht

hale

ne1.

13E

03lb

/103

gal

AP42

Tabl

e1.

39

3.18

E05

1.39

E04

1,1,

1,tr

ichl

oroe

than

e2.

36E

04lb

/103

gal

AP42

Tabl

e1.

39

6.63

E06

2.90

E05

PAH

(not

incl

udin

gna

phth

alen

e)lb

/103

gal

AP42

Tabl

e1.

39

0.00

E+00

0.00

E+00

Tolu

ene

6.20

E03

lb/1

03ga

lAP

42Ta

ble

1.3

91.

74E

047.

63E

04Xy

lene

1.09

E04

lb/1

03ga

lAP

42Ta

ble

1.3

93.

06E

061.

34E

05Ar

seni

c4.

00E+

00lb

/1012

Btu

AP42

Tabl

e1.

310

1.54

E05

6.75

E05

Bery

llium

3.00

E+00

lb/1

012Bt

uAP

42Ta

ble

1.3

101.

16E

055.

06E

05Ca

dmiu

m3.

00E+

00lb

/1012

Btu

AP42

Tabl

e1.

310

1.16

E05

5.06

E05

Chro

miu

m3.

00E+

00lb

/1012

Btu

AP42

Tabl

e1.

310

1.16

E05

5.06

E05

Lead

9.00

E+00

lb/1

012Bt

uAP

42Ta

ble

1.3

103.

47E

051.

52E

04M

anga

nese

6.00

E+00

lb/1

012Bt

uAP

42Ta

ble

1.3

102.

31E

051.

01E

04M

ercu

ry3.

00E+

00lb

/1012

Btu

AP42

Tabl

e1.

310

1.16

E05

5.06

E05

Nic

kel

3.00

E+00

lb/1

012Bt

uAP

42Ta

ble

1.3

101.

16E

055.

06E

05Se

leni

um1.

50E+

01lb

/1012

Btu

AP42

Tabl

e1.

310

5.78

E05

2.53

E04

TOTA

LHA

PS1.

34E

035.

87E

03M

axsin

gle

HAP

9.27

E04

4.06

E03

§98

Subp

artC

Fuel

HHV

Pollu

tant

Glob

alW

arm

ing

Pote

ntia

lEF

(kg/

MM

Btu)

EF(lb

/MM

Btu)

Dies

elFu

el13

7000

CO2

173

.96

163.

0522

16bt

u/ga

lCH

425

0.00

30.

0066

138

N2O

298

0.00

060.

0013

2276

No.

2Fu

elO

il(B

ack

upFu

el)

Impe

rialP

last

icsI

ncor

pora

ted

Boile

rEQ

UI0

06(E

U00

2)Pe

rmit

#065

0000

200

2W

orst

Case

Pote

ntia

lto

Emit

(nat

ural

gaso

rdie

sel)

Pollu

tant

Pote

ntia

lEm

issio

ns(lb

/hr)

Pote

ntia

lto

Emit

(tpy

)To

talP

artic

ulat

eM

atte

r9.

27E

024.

06E

01To

talP

M10

6.69

E02

2.93

E01

Tota

lPM

2.5

5.99

E02

2.62

E01

SOx

5.99

E03

2.62

E02

NO

x5.

62E

012.

46E+

00CO

3.08

E01

1.35

E+00

VOC

2.02

E02

8.83

E02

CO2

6.28

E+02

2.75

E+03

CH4

2.55

E02

1.12

E01

N2O

5.09

E03

2.23

E02

CO2e

6.30

E+02

2.76

E+03

HAPS

Benz

ene

7.70

E06

3.37

E05

Dich

loro

benz

ene

4.40

E06

1.93

E05

Ethy

lben

zene

1.79

E06

7.83

E06

Form

alde

hyde

9.27

E04

4.06

E03

Hexa

ne6.

60E

032.

89E

02N

apht

hale

ne3.

18E

051.

39E

041,

1,1,

tric

hlor

oeth

ane

6.63

E06

2.90

E05

PAH

(not

incl

udin

gna

phth

alen

e)3.

23E

071.

42E

06To

luen

e1.

74E

047.

63E

04Xy

lene

3.06

E06

1.34

E05

Arse

nic

1.54

E05

6.75

E05

Bery

llium

1.16

E05

5.06

E05

Cadm

ium

1.16

E05

5.06

E05

Chro

miu

m1.

16E

055.

06E

05Co

balt

3.08

E07

1.35

E06

Lead

3.47

E05

1.52

E04

Man

gane

se2.

31E

051.

01E

04M

ercu

ry1.

16E

055.

06E

05N

icke

l1.

16E

055.

06E

05Se

leni

um5.

78E

052.

53E

04TO

TAL

HAPS

7.95

E03

3.48

E02

Max

singl

eHA

P6.

60E

032.

89E

02

Impe

rialP

last

icsI

ncor

pora

ted

Perm

it#0

6500

002

002

SV00

7Dr

yer/

Ove

nM

ain

EQU

I017

(EU

007)

Airf

low

(acf

m)

450

Heat

Inpu

t1

MM

Btu/

hrGa

stem

p(F

)15

0Fu

elTy

peN

atur

alGa

sDS

CFM

389

Gros

sHea

ting

Valu

eof

NG

1050

btu/

scf

PMPT

E(g

r/ds

cf)

0.00

217

Pollu

tant

Emiss

ion

Fact

orEm

issio

nFa

ctor

Uni

tEm

issio

nFa

ctor

Sour

cePo

tent

ialE

miss

ions

(lb/h

r)Po

tent

ialt

oEm

it(t

py)

Tota

lPar

ticul

ate

Mat

ter

7.6

lb/M

Msc

fAP

42Ta

ble

1.4

27.

24E

033.

17E

02To

talP

M10

7.6

lb/M

Msc

fAP

42Ta

ble

1.4

27.

24E

033.

17E

02To

talP

M2.

57.

6lb

/MM

scf

AP42

Tabl

e1.

42

7.24

E03

3.17

E02

SOx

0.6

lb/M

Msc

fAP

42Ta

ble

1.4

25.

71E

042.

50E

03N

Ox

100

lb/M

Msc

fAP

42Ta

ble

1.4

19.

52E

024.

17E

01CO

84lb

/MM

scf

AP42

Tabl

e1.

41

8.00

E02

3.50

E01

VOC

5.5

lb/M

Msc

fAP

42Ta

ble

1.4

25.

24E

032.

29E

02CO

211

6.97

6076

lb/M

MBt

u40

CFR

Part

981.

11E

014.

88E

01CH

40.

0022

046

lb/M

MBt

u40

CFR

Part

982.

10E

069.

20E

06N

2O0.

0002

2046

lb/M

MBt

u40

CFR

Part

982.

10E

079.

20E

07CO

2e11

7.09

6888

1lb

/MM

Btu

40CF

RPa

rt98

1.12

E01

4.88

E01

HAPS

Benz

ene

2.10

E03

lb/M

Msc

fAP

42Ta

ble

1.4

32.

00E

068.

76E

06Di

chlo

robe

nzen

e1.

20E

03lb

/MM

scf

AP42

Tabl

e1.

43

1.14

E06

5.01

E06

Form

alde

hyde

7.50

E02

lb/M

Msc

fAP

42Ta

ble

1.4

37.

14E

053.

13E

04He

xane

1.80

E+00

lb/M

Msc

fAP

42Ta

ble

1.4

31.

71E

037.

51E

03N

apht

hale

ne6.

10E

04lb

/MM

scf

AP42

Tabl

e1.

43

5.81

E07

2.54

E06

PAH

(not

incl

udin

gna

phth

alen

e)8.

82E

05lb

/MM

scf

AP42

Tabl

e1.

43

8.40

E08

3.68

E07

Tolu

ene

3.40

E03

lb/M

Msc

fAP

42Ta

ble

1.4

33.

24E

061.

42E

05Ar

seni

c2.

00E

04lb

/MM

scf

AP42

Tabl

e1.

44

1.90

E07

8.34

E07

Bery

llium

1.20

E05

lb/M

Msc

fAP

42Ta

ble

1.4

41.

14E

085.

01E

08Ca

dmiu

m1.

10E

03lb

/MM

scf

AP42

Tabl

e1.

44

1.05

E06

4.59

E06

Chro

miu

m1.

40E

03lb

/MM

scf

AP42

Tabl

e1.

44

1.33

E06

5.84

E06

Coba

lt8.

40E

05lb

/MM

scf

AP42

Tabl

e1.

44

8.00

E08

3.50

E07

Lead

5.00

E04

lb/M

Msc

fAP

42Ta

ble

1.4

24.

76E

072.

09E

06M

anga

nese

3.80

E04

lb/M

Msc

fAP

42Ta

ble

1.4

43.

62E

071.

59E

06M

ercu

ry2.

60E

04lb

/MM

scf

AP42

Tabl

e1.

44

2.48

E07

1.08

E06

Nic

kel

2.10

E03

lb/M

Msc

fAP

42Ta

ble

1.4

42.

00E

068.

76E

06Se

leni

um2.

40E

05lb

/MM

scf

AP42

Tabl

e1.

44

2.29

E08

1.00

E07

TOTA

LHA

PS1.

80E

037.

88E

03M

axSi

ngle

HAP

1.71

E03

7.51

E03

§98

Subp

artC

Fuel

HHV

Pollu

tant

Glob

alW

arm

ing

Pote

ntia

lEF

(kg/

MM

Btu)

EF(lb

/MM

Btu)

Nat

ural

Gas

1050

CO2

153

.06

116.

9760

76bt

u/sc

fCH

425

0.00

10.

0022

046

N2O

298

0.00

010.

0002

2046

Impe

rialP

last

icsI

ncor

pora

ted

Perm

it#0

6500

002

002

AirM

akeu

pU

nitE

QU

I019

(EU

013)

Heat

Inpu

t2.

8M

MBt

u/hr

Fuel

Type

Nat

ural

Gas

Gros

sHea

ting

Valu

eof

NG

1050

btu/

scf

0.00

724

Pollu

tant

Emiss

ion

Fact

orEm

issio

nFa

ctor

Uni

tEm

issio

nFa

ctor

Sour

cePo

tent

ialE

miss

ions

(lb/h

r)Po

tent

ialt

oEm

it(t

py)

Tota

lPar

ticul

ate

Mat

ter

7.6

lb/M

Msc

fAP

42Ta

ble

1.4

22.

03E

028.

88E

02To

talP

M10

7.6

lb/M

Msc

fAP

42Ta

ble

1.4

22.

03E

028.

88E

02To

talP

M2.

57.

6lb

/MM

scf

AP42

Tabl

e1.

42

2.03

E02

8.88

E02

SOx

0.6

lb/M

Msc

fAP

42Ta

ble

1.4

21.

60E

037.

01E

03N

Ox

100

lb/M

Msc

fAP

42Ta

ble

1.4

12.

67E

011.

17E+

00CO

84lb

/MM

scf

AP42

Tabl

e1.

41

2.24

E01

9.81

E01

VOC

5.5

lb/M

Msc

fAP

42Ta

ble

1.4

21.

47E

026.

42E

02CO

211

6.97

6076

lb/M

MBt

u40

CFR

Part

983.

28E+

021.

43E+

03CH

40.

0022

046

lb/M

MBt

u40

CFR

Part

986.

17E

032.

70E

02N

2O0.

0002

2046

lb/M

MBt

u40

CFR

Part

986.

17E

042.

70E

03CO

2e11

7.09

6888

1lb

/MM

Btu

40CF

RPa

rt98

3.28

E+02

1.44

E+03

HAPS

Benz

ene

2.10

E03

lb/M

Msc

fAP

42Ta

ble

1.4

35.

60E

062.

45E

05Di

chlo

robe

nzen

e1.

20E

03lb

/MM

scf

AP42

Tabl

e1.

43

3.20

E06

1.40

E05

Form

alde

hyde

7.50

E02

lb/M

Msc

fAP

42Ta

ble

1.4

32.

00E

048.

76E

04He

xane

1.80

E+00

lb/M

Msc

fAP

42Ta

ble

1.4

34.

80E

032.

10E

02N

apht

hale

ne6.

10E

04lb

/MM

scf

AP42

Tabl

e1.

43

1.63

E06

7.12

E06

PAH

(not

incl

udin

gna

phth

alen

e)8.

82E

05lb

/MM

scf

AP42

Tabl

e1.

43

2.35

E07

1.03

E06

Tolu

ene

3.40

E03

lb/M

Msc

fAP

42Ta

ble

1.4

39.

07E

063.

97E

05Ar

seni

c2.

00E

04lb

/MM

scf

AP42

Tabl

e1.

44

5.33

E07

2.34

E06

Bery

llium

1.20

E05

lb/M

Msc

fAP

42Ta

ble

1.4

43.

20E

081.

40E

07Ca

dmiu

m1.

10E

03lb

/MM

scf

AP42

Tabl

e1.

44

2.93

E06

1.28

E05

Chro

miu

m1.

40E

03lb

/MM

scf

AP42

Tabl

e1.

44

3.73

E06

1.64

E05

Coba

lt8.

40E

05lb

/MM

scf

AP42

Tabl

e1.

44

2.24

E07

9.81

E07

Lead

5.00

E04

lb/M

Msc

fAP

42Ta

ble

1.4

21.

33E

065.

84E

06M

anga

nese

3.80

E04

lb/M

Msc

fAP

42Ta

ble

1.4

41.

01E

064.

44E

06M

ercu

ry2.

60E

04lb

/MM

scf

AP42

Tabl

e1.

44

6.93

E07

3.04

E06

Nic

kel

2.10

E03

lb/M

Msc

fAP

42Ta

ble

1.4

45.

60E

062.

45E

05Se

leni

um2.

40E

05lb

/MM

scf

AP42

Tabl

e1.

44

6.40

E08

2.80

E07

TOTA

LHA

PS5.

04E

032.

21E

02M

axSi

ngle

HAP

4.80

E03

2.10

E02

§98

Subp

artC

Fuel

HHV

Pollu

tant

Glob

alW

arm

ing

Pote

ntia

lEF

(kg/

MM

Btu)

EF(lb

/MM

Btu)

Nat

ural

Gas

1050

CO2

153

.06

116.

9760

76bt

u/sc

fCH

425

0.00

10.

0022

046

N2O

298

0.00

010.

0002

2046

Impe

rialP

last

icsI

ncor

pora

ted

Perm

it#0

6500

002

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AirM

akeu

pU

nitE

QU

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(EU

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Heat

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t5

MM

Btu/

hrFu

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atur

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Pollu

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Fact

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Sour

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tent

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Mat

ter

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Msc

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42Ta

ble

1.4

23.

62E

021.

59E

01To

talP

M10

7.6

lb/M

Msc

fAP

42Ta

ble

1.4

23.

62E

021.

59E

01To

talP

M2.

57.

6lb

/MM

scf

AP42

Tabl

e1.

42

3.62

E02

1.59

E01

SOx

0.6

lb/M

Msc

fAP

42Ta

ble

1.4

22.

86E

031.

25E

02N

Ox

100

lb/M

Msc

fAP

42Ta

ble

1.4

14.

76E

012.

09E+

00CO

84lb

/MM

scf

AP42

Tabl

e1.

41

4.00

E01

1.75

E+00

VOC

5.5

lb/M

Msc

fAP

42Ta

ble

1.4

22.

62E

021.

15E

01CO

211

6.97

6076

lb/M

MBt

u40

CFR

Part

985.

85E+

022.

56E+

03CH

40.

0022

046

lb/M

MBt

u40

CFR

Part

981.

10E

024.

83E

02N

2O0.

0002

2046

lb/M

MBt

u40

CFR

Part

981.

10E

034.

83E

03CO

2e11

7.09

6888

1lb

/MM

Btu

40CF

RPa

rt98

5.85

E+02

2.56

E+03

HAPS

Benz

ene

2.10

E03

lb/M

Msc

fAP

42Ta

ble

1.4

31.

00E

054.

38E

05Di

chlo

robe

nzen

e1.

20E

03lb

/MM

scf

AP42

Tabl

e1.

43

5.71

E06

2.50

E05

Form

alde

hyde

7.50

E02

lb/M

Msc

fAP

42Ta

ble

1.4

33.

57E

041.

56E

03He

xane

1.80

E+00

lb/M

Msc

fAP

42Ta

ble

1.4

38.

57E

033.

75E

02N

apht

hale

ne6.

10E

04lb

/MM

scf

AP42

Tabl

e1.

43

2.90

E06

1.27

E05

PAH

(not

incl

udin

gna

phth

alen

e)8.

82E

05lb

/MM

scf

AP42

Tabl

e1.

43

4.20

E07

1.84

E06

Tolu

ene

3.40

E03

lb/M

Msc

fAP

42Ta

ble

1.4

31.

62E

057.

09E

05Ar

seni

c2.

00E

04lb

/MM

scf

AP42

Tabl

e1.

44

9.52

E07

4.17

E06

Bery

llium

1.20

E05

lb/M

Msc

fAP

42Ta

ble

1.4

45.

71E

082.

50E

07Ca

dmiu

m1.

10E

03lb

/MM

scf

AP42

Tabl

e1.

44

5.24

E06

2.29

E05

Chro

miu

m1.

40E

03lb

/MM

scf

AP42

Tabl

e1.

44

6.67

E06

2.92

E05

Coba

lt8.

40E

05lb

/MM

scf

AP42

Tabl

e1.

44

4.00

E07

1.75

E06

Lead

5.00

E04

lb/M

Msc

fAP

42Ta

ble

1.4

22.

38E

061.

04E

05M

anga

nese

3.80

E04

lb/M

Msc

fAP

42Ta

ble

1.4

41.

81E

067.

93E

06M

ercu

ry2.

60E

04lb

/MM

scf

AP42

Tabl

e1.

44

1.24

E06

5.42

E06

Nic

kel

2.10

E03

lb/M

Msc

fAP

42Ta

ble

1.4

41.

00E

054.

38E

05Se

leni

um2.

40E

05lb

/MM

scf

AP42

Tabl

e1.

44

1.14

E07

5.01

E07

TOTA

LHA

PS8.

99E

033.

94E

02M

axSi

ngle

HAP

8.57

E03

3.75

E02

§98

Subp

artC

Fuel

HHV

Pollu

tant

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alW

arm

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Pote

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(kg/

MM

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EF(lb

/MM

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Nat

ural

Gas

1050

CO2

153

.06

116.

9760

76bt

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425

0.00

10.

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046

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298

0.00

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0002

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TSD Attachments Attachment 2: Facility Requirements


Sequence # Subject Item Description1 TFAC (Total Facility)

RequirementsPermit Appendices: This permit contains appendices as listed in the permitTable of Contents. The Permittee shall comply with all requirementscontained in Appendices A, B and C. [Minn. R. 7007.0800, subp. 2]

2 TFAC (Total Facility)Requirements

PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliancewith the conditions of this permit shall be deemed compliance with thespecific provision of the applicable requirement identified in the permit as thebasis of each condition. Subject to the limitations of Minn. R. 7007.1800 and7017.0100, subp. 2, notwithstanding the conditions of this permit specifyingcompliance practices for applicable requirements, any person (including thePermittee) may also use other credible evidence to establish compliance ornoncompliance with applicable requirements. This permit shall not alter oraffect the liability of the Permittee for any violation of applicablerequirements prior to or at the time of permit issuance. [Minn. R. 7007.1800,(A)(2)]


The Permittee currently uses ozone depleting substances as defined in 40 CFRpt. 82. Sections 601 618 of the 1990 Clean Air Act Amendments and 40 CFRpt. 82 may apply to the facility. Read Sections 601 618 and 40 CFR pt. 82 todetermine all the requirements that apply to the facility. [40 CFR pt. 82]


The Permittee shall comply with National Primary and Secondary Ambient AirQuality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air QualityStandards, Minn. R. 7009.0010 to 7009.0080. Compliance shall bedemonstrated upon written request by the MPCA. [Minn. R. 7007.0100, subp.7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 12, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]


Circumvention: Do not install or use a device or means that conceals ordilutes emissions, which would otherwise violate a federal or state airpollution control rule, without reducing the total amount of pollutantemitted. [Minn. R. 7011.0020]


Air Pollution Control Equipment: Operate all pollution control equipmentwhenever the corresponding process equipment and emission units areoperated unless otherwise noted in this permit. [Minn. R. 7007.0800, subp.16(J), Minn. R. 7007.0800, subp. 2]


Operation and Maintenance Plan: Retain at the stationary source anoperation and maintenance plan for all air pollution control equipment. At aminimum, the O & M plan shall identify all air pollution control equipmentand control practices and shall include a preventative maintenance programfor the equipment and practices, a description of (the minimum but notnecessarily the only) corrective actions to be taken to restore the equipmentand practices to proper operation to meet applicable permit conditions, adescription of the employee training program for proper operation andmaintenance of the control equipment and practices, and the records kept todemonstrate plan implementation. [Minn. R. 7007.0800, subp. 14, Minn. R.7007.800, subp. 16(J)]


Operation Changes: In any shutdown, breakdown, or deviation the Permitteeshall immediately take all practical steps to modify operations to reduce theemission of any regulated air pollutant. The Commissioner may requirefeasible and practical modifications in the operation to reduce emissions ofair pollutants. No emissions units that have an unreasonable shutdown orbreakdown frequency of process or control equipment shall be permitted tooperate. [Minn. R. 7019.1000, subp. 4]


RequirementsFugitive Emissions: Do not cause or permit the handling, use, transporting, orstorage of any material in a manner which may allow avoidable amounts ofparticulate matter to become airborne. Comply with all other requirementslisted in Minn. R. 7011.0150. [Minn. R. 7011.0150]


Noise: The Permittee shall comply with the noise standards set forth in Minn.R. 7030.0010 to 7030.0080 at all times during the operation of any emissionunits. This is a state only requirement and is not enforceable by the EPAAdministrator or citizens under the Clean Air Act. [Minn. R. 7030.00107030.0080]


Inspections: The Permittee shall comply with the inspection procedures andrequirements as found in Minn. R. 7007.0800, subp. 9(A). [Minn. R.7007.0800, subp. 9(A)]


The Permittee shall comply with the General Conditions listed in Minn. R.7007.0800, subp. 16. [Minn. R. 7007.0800, subp. 16]


Monitoring Equipment Calibration The Permittee shall either: 1. Calibrate orreplace required monitoring equipment every 12 months; or 2. Calibrate atthe frequency stated in the manufacturer's specifications. For each monitor,the Permittee shall maintain a record of all calibrations, including the dateconducted, and any corrective action that resulted. The Permittee shallinclude the calibration frequencies, procedures, and manufacturer'sspecifications (if applicable) in the Operations and Maintenance Plan. Anyrequirements applying to continuous emission monitors are listed separatelyin this permit. [Minn. R. 7007.0800, subp. 4(D)]


Operation of Monitoring Equipment: Unless noted elsewhere in this permit,monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks ofthe monitoring systems, such as calibration checks and zero and spanadjustments. If monitoring records are required, they should reflect any suchperiods of process shutdown or checks of the monitoring system. [Minn. R.7007.0800, subp. 4(D)]


The Permittee shall submit a computer dispersion modeling information : Due1096 calendar days after Permit Issuance Date. Submit modeling data asspecified in MPCA guidance for Modeling Information Requests for PM10.This modeling information is for data collection purposes, no modelinganalysis is required at this time. [Minn. R. 7007.0100, subp. 7(A), Minn. R.7007.0100, subp. 7(L), Minn. R. 7007.0100, subp. 7(M), Minn. R. 7007.0800,subp. 1, Minn. R. 7007.0800, subp. 2, Minn. R. 7007.0800, subp. 4, Minn. R.7009.0010 0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]


Recordkeeping: Retain all records at the stationary source, unless otherwisespecified within this permit, [or at another location identified here] for aperiod of five (5) years [or another longer time frame] from the date ofmonitoring, sample, measurement, or report. Records which must beretained at this location include all calibration and maintenance records, alloriginal recordings for continuous monitoring instrumentation, and copies ofall reports required by the permit. Records must conform to the requirementslisted in Minn. R. 7007.0800, subp. 5(A). [Minn. R. 7007.0800, subp. 5(C)]


Recordkeeping: Maintain records describing any insignificant modifications(as required by Minn. R. 7007.1250, subp. 3) or changes contravening permitterms (as required by Minn. R. 7007.1350, subp. 2), including records of theemissions resulting from those changes. [Minn. R. 7007.0800, subp. 5(B)]


RequirementsIf the Permittee determines that no permit amendment or notification isrequired prior to making a change, the Permittee must retain records of allcalculations required under Minn. R. 7007.1200. For expiring permits, theserecords shall be kept for a period of five years from the date the change wasmade or until permit reissuance, whichever is longer. The records shall bekept at the stationary source for the current calendar year of operation andmay be kept at the stationary source or office of the stationary source for allother years. The records may be maintained in either electronic or paperformat. [Minn. R. 7007.1200, subp. 4]


Shutdown Notifications: Notify the Commissioner at least 24 hours in advanceof a planned shutdown of any control equipment or process equipment if theshutdown would cause any increase in the emissions of any regulated airpollutant. If the owner or operator does not have advance knowledge of theshutdown, notification shall be made to the Commissioner as soon as possibleafter the shutdown. However, notification is not required in thecircumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3. Atthe time of notification, the owner or operator shall inform the Commissionerof the cause of the shutdown and the estimated duration. The owner oroperator shall notify the Commissioner when the shutdown is over. [Minn. R.7019.1000, subp. 3]


Breakdown Notifications: Notify the Commissioner within 24 hours of abreakdown of more than one hour duration of any control equipment orprocess equipment if the breakdown causes any increase in the emissions ofany regulated air pollutant. The 24 hour time period starts when thebreakdown was discovered or reasonably should have been discovered by theowner or operator. However, notification is not required in the circumstancesoutlined in Items A, B and C of Minn. R. 7019.1000, subp. 2. At the time ofnotification or as soon as possible thereafter, the owner or operator shallinform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over. [Minn. R. 7019.1000, subp. 2]


Notification of Deviations Endangering Human Health or the Environment: Assoon as possible after discovery, notify the Commissioner or the state dutyofficer, either orally or by facsimile, of any deviation from permit conditionswhich could endanger human health or the environment. [Minn. R.7019.1000, subp. 1]


Notification of Deviations Endangering Human Health or the EnvironmentReport: Within 2 working days of discovery, notify the Commissioner inwriting of any deviation from permit conditions which could endanger humanhealth or the environment. Include the following information in this writtendescription: 1. the cause of the deviation; 2. the exact dates of the period ofthe deviation, if the deviation has been corrected; 3. whether or not thedeviation has been corrected; 4. the anticipated time by which the deviationis expected to be corrected, if not yet corrected; and 5. steps taken orplanned to reduce, eliminate, and prevent reoccurrence of the deviation.[Minn. R. 7019.1000, subp. 1]


RequirementsThe Permittee shall submit a semiannual deviations report : Duesemiannually, by the 30th of January and July The first semiannual reportsubmitted by the Permittee shall cover the calendar half year in which thepermit is issued. The first report of each calendar year covers January 1 June30. The second report of each calendar year covers July 1 December 31. Ifno deviations have occurred, the Permittee shall submit the report stating nodeviations. [Minn. R. 7007.0800, subp. 6(A)(2)]


Application for Permit Amendment: If a permit amendment is needed, submitan application in accordance with the requirements of Minn. R. 7007.1150through Minn. R. 7007.1500. Submittal dates vary, depending on the type ofamendment needed. Upon adoption of a new or amended federal applicablerequirement, and if there are more than 3 years remaining in the permitterm, the Permittee shall file an application for an amendment within ninemonths of promulgation of the applicable requirement, pursuant to Minn. R.7007.0400, subp. 3. [Minn. R. 7007.0400, subp. 3, Minn. R. 7007.11507007.1500]


The Permittee shall submit an application for permit reissuance : Due 180calendar days before Permit Expiration Date. [Minn. R. 7007.0400, subp. 2]


Extension Requests: The Permittee may apply for an AdministrativeAmendment to extend a deadline in a permit by no more than 120 days,provided the proposed deadline extension meets the requirements of Minn.R. 7007.1400, subp. 1(H). Performance testing deadlines from the GeneralProvisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which theMPCA does not have authority to grant extensions and therefore do not meetthe requirements of Minn. R. 7007.1400, subp. 1(H). [Minn. R. 7007.1400,subp. 1(H)]


The Permittee shall submit a compliance schedule progress report : Duesemiannually, by the 30th of January and July The Compliance ScheduleProgress Report shall contain the information specified in Minn. R.7007.0800, subp. 6(B) and shall be submitted on a form approved by theCommissioner in accordance with the Compliance Schedule contained in thispermit. Progress Reports will not be needed upon completion of all activitiescontained in the Compliance Schedule. [Minn. R. 7007.0800, subp. 6(B)]


The Permittee shall submit a compliance certification : Due annually, by the31st of January (for the previous calendar year). The Permittee shall submitthis to the Commissioner on a form approved by the Commissioner. Thisreport covers all deviations experienced during the calendar year. [Minn. R.7007.0800, subp. 6(C)]


Emission Inventory Report: due on or before April 1 of each calendar yearfollowing permit issuance, to be submitted on a form approved by theCommissioner. [Minn. R. 7019.3000 7019.3100]

30 TFAC (Total Facility)Requirements Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R.

7002.0005 7002.0095]

Sequence # Subject Item Description1 COMG3 (GP003)

Indirect HeatingUnits

Total Particulate Matter <= 0.60 pounds per million Btu heat input 3 houraverage This limit applies individually to each indirect heating unit. The PMpotential to emit from each unit is 0.0072 lb/MMBtu due to equipmentdesign and allowable fuel. [Minn. R. 7011.0510, subp. 1]

2 COMG3 (GP003)Indirect HeatingUnits

Opacity <= 20.0 percent opacity except for one six minute period per hour ofnot more than 60 percent opacity. This limit applies individually to eachindirect heating unit. [Minn. R. 7011.0510, subp. 2]

3 COMG3 (GP003)Indirect HeatingUnits Fuel type: Natural gas only [Minn. R. 7005.0100, subp. 35a]

1 COMG4 (GP001)Coating BoothLimits

The Permittee shall limit emissions of Volatile Organic Compounds <= 196tons per year 12 month rolling sum to be calculated by the 15th day of eachmonth for the previous 12 month period as described later in this permit.VOC contents for each VOC containing material shall be determined asdescribed under the Material Content requirement at COMG4. Thecalculation of VOCs used may take into account recovered/recycled VOCs asdescribed under the Waste Credit requirement at COMG4. [Title I Condition:Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]


The Permittee shall limit emissions of PM < 10 micron <= 225 tons per year12 month rolling sum to be calculated by the 15th day of each month for theprevious 12 month period as described later in this permit. Solids contents foreach material shall be determined as described under the Material Contentrequirement at COMG4. The calculation of solids used may take into accountrecovered/recycled solids as described under the Waste Credit requirementat COMG4. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i)and Minn. R. 7007.3000]


The Permittee shall limit emissions of PM < 2.5 micron <= 225 tons per year12 month rolling sum to be calculated by the 15th day of each month for theprevious 12 month period as described later in this permit. Solids contents foreach material shall be determined as described under the Material Contentrequirement at COMG4. The calculation of solids used may take into accountrecovered/recycled solids as described under the Waste Credit requirementat COMG4. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i)and Minn. R. 7007.3000]


The Permittee shall vent emissions from all spray booths to controlequipment meeting the requirements of COMG7. [Title I Condition: Avoidmajor source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]


The Permittee shall limit emissions of HAPs Total <= 22.0 tons per year 12month rolling sum to be calculated by the 15th day of each month for theprevious 12 month period. HAP contents for each HAP containing material(i.e. coatings, gun cleaner,...) shall be determined as described under theMaterial Content requirement at COMG4. The calculation of HAPs used maytake into account recovered/recycled HAPs as described under the WasteCredit requirement at COMG4. [Title I Condition: Avoid major source under40 CFR 63.2]


Coating BoothLimits

The Permittee shall limit emissions of HAPs Single <= 9.0 tons per year 12month rolling sum to be calculated by the 15th day of each month for theprevious 12 month period. HAP contents for each HAP containing material(i.e. coatings, gun cleaner,...) shall be determined as described under theMaterial Content requirement COMG4. The calculation of HAPs used maytake into account recovered/recycled HAPs as described under the WasteCredit requirement at COMG4. [Title I Condition: Avoid major source under40 CFR 63.2]


Total Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaustgas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. This limitapplies separately to each emission unit in COMG4. The PM PTE for a COMG4unit does not exceed 0.022 gr/dscf. [Minn. R. 7011.0715, subp. 1(A)]


Opacity <= 20 percent opacity. This limit applies separately to each emissionunit in COMG4. [Minn. R. 7011.0715, subp. 1(B)]


Daily Recordkeeping. On each day of operation, the Permittee shall calculate,record, and maintain the total quantity of all coatings and other VOC, solids,and HAP containing materials used at the COMG4 emission units. This recordshall be based on written usage logs and shall indicate the part number of theVOC, solids, or HAP containing material and the quantity used or dispensedfrom the central storage room. [Minn. R. 7007.0800, subps. 4 5, Title ICondition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R.7007.3000]


Volatile Organic Compounds: Monthly Recordkeeping. By the 15th of themonth, the Permittee shall calculate and record the following: 1) The totalusage of VOC containing materials for the previous calendar month using thedaily usage records. This record shall also include the VOC and solids contentsof each material as determined by the Material Content requirement of thispermit; 2) The VOC emissions for the previous month using the formulasspecified in this permit; and 3) The 12 month rolling sum VOC emissions forthe previous 12 month period by summing the monthly VOC emissions datafor the previous 12 months. [Minn. R. 7007.0800, subps. 4 5]


Volatile Organic Compounds: Monthly Calculations. The Permittee shallcalculate VOC emissions using the following equations: VOC (tons/month) = VW V = (A1 x B1) + (A2 x B2) + (A3 x B3) + ..... W = (C1 x D1) + (C2 x D2) + (C3 x

D3) + ..... where: V = total VOC used in tons/month; A# = amount of eachVOC containing material used, in tons/month; B# = weight percent VOC in A#,as a fraction; W = the amount of VOC shipped in waste, in tons/month; C# =amount, in tons/month, of each VOC containing waste material shipped. Ifthe Permittee chooses to not take credit for waste shipments, this parameterwould be zero; and D# = weight percent of VOC in C#, as a fraction. [Minn. R.7007.0800, subps. 4 5]


Coating BoothLimits

HAPs Single: Monthly Recordkeeping. By the 15th of the month, thePermittee shall calculate and record the following using the formulasspecified in this permit: 1) The total HAP containing materials used in theprevious calendar month using the daily usage records. This record shall alsoinclude the individual and total HAP contents of each HAP containing materialused in the previous month, as determined by the Material Contentrequirement of this permit; 2) The total and individual HAP emissions for theprevious month using the formulas specified in this permit; and 3) The 12month rolling sum total and individual HAP emissions for the previous 12month period by summing the monthly emissions data for the previous 12months. [Minn. R. 7007.0800, subps. 4 5]


HAPs Single: Monthly Calculation HAP Emissions. The Permittee shallcalculate each individual HAP and total HAP emissions using the followingequations: HAP Emissions (tons/month) = H W H = (A1 x B1) + (A2 x B2) + (A3x B3) + .... W = (C1 x D1) + (C2 x D2) + (C3 x D3) + .... Where: H = the amountof each pollutant (either total HAP or each individual HAP), used, intons/month. A# = Amount of each HAP containing material used in theprevious month, in tons/month. B# = weight percent of each individual ortotal HAP in A#, as a fraction (e.g., 50% is 0.50). W = the amount of eachpollutant (either total HAP or each individual HAP) shipped in waste, intons/month. C# = amount, in tons/month, of each HAP containing wastematerial shipped. If the Permittee chooses to not take credit for wasteshipments, this parameter would be zero. D# = weight percent of eachindividual or total HAP in C#, as a fraction. [Minn. R. 7007.0800, subps. 4 5]


PM < 10 micron: Monthly Recordkeeping. By the 15th of the month, thePermittee shall calculate and record the following: 1) The total usage of eachsolids containing material for the previous calendar month using the dailyusage records. This record shall also include solids contents of each materialas determined by the Material Content requirement of this permit; 2) ThePM10 emissions for the previous month using the formulas specified in thispermit; and 3) The 12 month rolling sum PM10 emissions for the previous 12month period by summing the monthly PM10 emissions data for the previous12 months. [Minn. R. 7007.0800, subps. 4 5]


PM < 10 micron: Monthly Calculation. The Permittee shall calculate PM10emissions from the spray booths using the following equations: PM10(tons/month) = S(1 CE)(1 TE) W S = (A1 x B1) + (A2 x B2) + (A3 x B3) + ..... W= (C1 x D1) + (C2 x D2) + (C3 x D3) + ...... Where: S = total solids used intons/month; CE = overall control efficiency, as a fraction. This shall be 0.68 forall spray booths; TE = transfer efficiency, as a fraction. This shall be 0.30, forall spray booths. A# = amount of each solids containing material sprayed, intons/month; B# = weight percent solids in A#, as a fraction; W = the amountof solids shipped in waste, in tons/month; C# = amount, in tons/month, ofeach solids containing waste material shipped. If the Permittee chooses tonot take credit for waste shipments, this parameter would be zero; and D# =weight percent of solids in C#, as a fraction. [Minn. R. 7007.0800, subps. 4 5]


Coating BoothLimits

PM < 2.5 micron: Monthly Recordkeeping. By the 15th of the month, thePermittee shall calculate and record the following: 1) The total usage of eachsolids containing material for the previous calendar month using the dailyusage records. This record shall also include solids contents of each materialas determined by the Material Content requirement of this permit; 2) ThePM10 emissions for the previous month using the formulas specified in thispermit; and 3) The 12 month rolling sum PM2.5 emissions for the previous12 month period by summing the monthly PM2.5 emissions data for theprevious 12 months. [Minn. R. 7007.0800, subps. 4 5]


PM < 2.5 micron: Monthly Calculation. The Permittee shall calculate PM2.5emissions from the spray booths using the following equations: PM2.5(tons/month) = S(1 CE)(1 TE) W S = (A1 x B1) + (A2 x B2) + (A3 x B3) + ..... W= (C1 x D1) + (C2 x D2) + (C3 x D3) + ...... Where: S = total solids used intons/month; CE = overall control efficiency, as a fraction. This shall be 0.68 forall spray booths; TE = transfer efficiency, as a fraction. This shall be 0.30 for allspray booths. A# = amount of each solids containing material sprayed, intons/month; B# = weight percent solids in A#, as a fraction; W = the amountof solids shipped in waste, in tons/month; C# = amount, in tons/month, ofeach solids containing waste material shipped. If the Permittee chooses tonot take credit for waste shipments, this parameter would be zero; and D# =weight percent of solids in C#, as a fraction. [Minn. R. 7007.0800, subps. 4 5]


Material Content. VOC, HAPs, and Solids (PM, PM<10 microns, and PM<2.5microns) contents in coating materials shall be determined by the MaterialSafety Data Sheet (MSDS) provided by the supplier for each material used. If amaterial content range is given on the MSDS, the highest number in the rangeshall be used in all compliance calculations. When using the MSDS as thebasis of calculating particulate emissions, the conservative assumption ismade that PM consists entirely of PM less than 10 microns or less than 2.5microns. Other alternative methods approved by the MPCA may be used todetermine the VOC, HAPs, and solids contents. The Commissioner reservesthe right to require the Permittee to determine the VOC, HAP, and solidscontents of any material, according to EPA or ASTM reference methods. If anEPA or ASTM reference method is used for material content determination,the data obtained shall supersede the MSDS. [Minn. R. 7007.0800, subps. 4 5]


Waste Credit: If the Permittee elects to obtain credit for HAPs, solids, and/orVOC shipped in waste materials, the Permittee shall either use item 1 or 2 todetermine the VOC, solids, and/or total and individual HAP content for eachcredited shipment. 1) The Permittee shall analyze a composite sample of eachwaste shipment to determine the weight content of VOC, solids, total HAP,and each individual HAP, excluding water. 2) The Permittee may use supplierdata for raw materials to determine the VOC, solids, and total and individualHAP contents of each waste shipment, using the same content data used todetermine the content of raw materials. If the waste contains severalmaterials, the content of mixed waste shall be assumed to be the lowest VOC,solids, and total and individual HAP content of any of the materials. [Minn. R.7007.0800, subps. 4 5]


Coating BoothLimits

Maximum Contents of Materials: The Permittee assumed certain worst casecontents of materials when determining the short term potential to emit ofunits in COMG4. These assumptions are listed in Appendix C of this permit.Changing to a material that has a higher content of any of the givenpollutants is considered a change in method of operation that must beevaluated under Minn. R. 7007.1200, subp. 3 to determine if a permitamendment or notification is required under Minn. R. 7007.1150. [Minn. R.7005.0100, subp. 35a]


Material Records: The Permittee shall keep records of all VOC, solids, or HAPcontaining materials used at the facility. The record shall include the partnumber of the material or mixture, and the VOC, solids, and HAP content ofthe material or mixture, determined as required by the Material Contentrequirement of this permit. [Minn. R. 7007.0800, subps. 4 5]

1 COMG6 (GP007) 40CFR pt. 63 subp.PPPP

Based on the current and expected operations of the affected source, thispermit only includes the emission rate without add on controls optionspecified in 40 CFR Section 63.4491(b). If the Permittee later chooses toswitch to or add one or both of the other compliance options allowed in thestandard, the Permittee shall comply with all applicable portions of 40 CFR pt.63, subp. PPPP for those options. In addition, the Permittee shall apply for apermit amendment, as appropriate (e.g., to add applicable NESHAP language,for installation of an oxidizer, etc.). [40 CFR 63.4491, Minn. R. 7011.8130]


The affected source is the collection of all of the items listed below that areused for surface coating of plastic parts and products: 1) All coatingoperations as defined in 40 CFR Section 63.4581; 2) All storage containers andmixing vessels in which coatings, thinners and/or other additives, andcleaning materials are stored or mixed; 3) All manual and automatedequipment and containers used for conveying coatings, thinners and/or otheradditives, and cleaning materials; and 4) All storage containers and all manualand automated equipment and containers used for conveying wastematerials generated by a coating operation. [40 CFR 63.4482(b), Minn. R.7011.8130]


The Permittee shall comply with the Maximum Achievable ControlTechnology (MACT) Standard for Surface Coating of Plastic Parts andProducts. [40 CFR 63.4483(b), Minn. R. 7011.8130]


HAPs Organic <= 0.16 kilograms per kilograms of coating solids used duringeach 12 month compliance period (HAP emission limit). [40 CFR63.4490(b)(1), Minn. R. 7011.8130]

Sequence # Subject Item Description5 COMG6 (GP007) 40

CFR pt. 63 subp.PPPP

The Permittee must include all coatings (as defined in 40 CFR Section63.4581), thinners and/or other additives, and cleaning materials used in theaffected source when determining whether the HAP emission rate is equal toor less than the HAP emission limit. To make this determination, thePermittee must use at least one of the three compliance options listed inparagraphs (a) through (c) of 40 CFR Section 63.4491. As stated previously,this permit only includes the requirements associated with the emission ratewithout add on controls options specified in 40 CFR Section 63.4491(b). Evenso, the Permittee may apply any of the compliance options to an individualcoating operation, or to multiple coating operations as a group, or to theentire affected source. The Permittee may use different compliance optionsfor different coating operations, or at different times on the same coatingoperation. The Permittee may employ different compliance options whendifferent coatings are applied to the same part, or when the same coating isapplied to different parts. However, the Permittee may not use differentcompliance options at the same time on the same coating operation. If thePermittee switches between compliance options for any coating operation orgroup of coating operations, the Permittee must document this switch asrequired by 40 CFR Section 63.4530(c), and the Permittee must report it inthe next semiannual compliance report listed in Table B of this permit. [40CFR 63.4491, Minn. R. 7011.8130]


The Permittee must be in compliance with the emission limitations asspecified below: 1) Any coating operation(s) for which the Permittee uses theemission rate without add on controls option, as specified in 40 CFR Section63.4491(b), must be in compliance with the HAP emission limit at all times. 2)The Permittee must always operate and maintain the affected sourceaccording to the provisions in 40 CFR Section 63.6(e)(1)(i). [40 CFR63.4500(a)(1) & (b), Minn. R. 7011.8130]



HAPs Organic: Organic HAP Mass Fraction: The Permittee must determinethe mass fraction of organic HAP for each coating, thinner and/or otheradditive, and cleaning material used during the compliance period by usingone of the following options: 1) Method 311 (appendix A to 40 CFR pt. 63).The Permittee may use Method 311 for determining the mass fraction oforganic HAP. To use Method 311, count each organic HAP that is measured tobe present at 0.1 percent by mass fraction or more for Occupational Safetyand Health Administration (OSHA) defined carcinogens as specified in 40 CFRSection 1910.1200(d)(4) and at 1.0 percent by mass or more for othercompounds. Calculate the total mass fraction of organic HAP in the testmaterial by adding up the individual organic HAP mass fractions andtruncating the result to three places after the decimal point; 2) Method 24(appendix A to 40 CFR pt. 60). For coatings, the Permittee may use Method 24to determine the mass fraction of nonaqueous volatile matter and use thatvalue as a substitute for mass fraction of organic HAP. For reactive adhesivesin which some of the HAP react to form solids and are not emitted to theatmosphere, the Permittee may use the alternative method described inappendix A to 40 CFR pt. 63, subp. PPPP, rather than Method 24. ThePermittee may use the volatile fraction that is emitted, as measured by thealternative method in appendix A to 40 CFR pt. 63, subp. PPPP, as a substitutefor the mass fraction of organic HAP; 3) Alternative Method. The Permitteemay use an alternative test method for determining the mass fraction oforganic HAP once the Administrator has approved it. The Permittee mustfollow the procedure in 40 CFR Section 63.7(f) to submit an alternative testmethod for approval; 4) Information from the supplier or manufacturer of thematerial. The Permittee may rely on information other than that generatedby the previous three paragraphs, such as manufacturer's formulation data, ifit represents each organic HAP that is present in 0.1 percent by mass or morefor OSHA defined carcinogens as specified in 40 CFR Section 1910.1200(d)(4)and at 1.0 percent by mass or more for the other compounds. For reactiveadhesives in which some of the HAP react to form solids and are not emittedto the atmosphere, the Permittee may rely on manufacturer's data thatexpressly states the organic HAP or volatile matter mass fraction emitted. Ifthere is a disagreement between such information and the results of a testconducted in according to 40 CFR Section 63.4541(a)(1) through (3), then thetest method results will take precedence unless, after consultation thePermittee demonstrates to the satisfaction of the MPCA that the formulationdata are correct; or (continued below). [40 CFR 63.4551(a), Minn. R.7011.8130]



HAPs Organic: (continued from above) 5) Solvent blends. Solvent blends maybe listed as single components for some materials in data provided bymanufacturers or suppliers. Solvent blends may contain organic HAP whichmust be counted toward the total organic HAP mass fraction of the materials.When test data and manufacturer's data for solvent blends are not available,the Permittee may use the default values for the mass fraction of organic HAPin these solvent blends listed in Table 3 or 4 of 40 CFR pt. 63, subp. PPPP. Ifthe tables are used, the values in Table 3 of 40 CFR pt. 63, subp. PPPP for allsolvent blends that match the entries according to the instructions for Table 3may be used, and Table 4 of 40 CFR pt. 63, subp. PPPP may be used only if thesolvent blends in materials that are used are known and they do not matchany of the solvent blends in Table 3 and it is known only whether the blend isaliphatic or aromatic. However, if the results of a Method 311 (appendix A to40 CFR pt. 63) test indicate higher values than those listed in Tables 3 or 4,the Method 311 results will take precedence unless, after consultation it isdetermined to the satisfaction of the MPCA that the formulation data arecorrect. [40 CFR 63.4551(a), Minn. R. 7011.8130]


Solids Mass Fraction: The Permittee must determine the mass fraction ofcoating solids kg(lb) per kg(lb) of coating for each coating used during thecompliance period by a test, by information provided by the supplier or themanufacturer of the material, or by calculation, as specified by the followingoptions: 1) Method 24 (appendix A to 40 CFR pt. 60). Use Method 24 fordetermining the mass fraction of coating solids. For reactive adhesives inwhich some of the liquid fraction reacts to form solids, the alternativemethod contained in Appendix A to 40 CFR pt. 63, subp. PPPP, rather thanMethod 24, may be used to determine the mass fraction of coating solids; 2)Alternative method. An alternative test method may be used for determiningthe solids content of each coating once the Administrator has approved it.The procedure in 40 CFR Section 63.7(f) must be followed to submit analternative test method for approval; or 3) Information from the supplier ormanufacturer of the material. The mass fraction of coating solids for eachcoating may be obtained from the supplier or manufacturer. If there is adisagreement between such information and the test method results, thenthe test method results will take precedence unless, after consultation it isdemonstrated to the satisfaction of the MPCA that the formulation data arecorrect. [40 CFR 63.4551(b), Minn. R. 7011.8130]


The Permittee shall demonstrate that, based on the coatings, thinners and/orother additives, and cleaning materials used in the coating operation(s), theorganic HAP emission rate for the coating operation(s) is less than or equal tothe HAP emission limit, calculated as a rolling 12 month emission rate anddetermined on a monthly basis. The Permittee must meet all therequirements of 40 CFR Sections 63.4550, 63.4551, and 63.4552 todemonstrate compliance with the emission limit using this option. [40 CFR63.4491(b), Minn. R. 7011.8130]



The Permittee does not need to redetermine the mass of organic HAP incoatings, thinners and/or other additives, or cleaning materials that havebeen reclaimed on site (or reclaimed off site if the Permittee hasdocumentation showing that they received back the exact same materialsthat were sent off site) and reused in the coating operation for which thePermittee uses the emission rate without add on controls option. If thePermittee uses coatings, thinners and/or other additives, or cleaningmaterials that have been reclaimed on site, the amount of each used in amonth may be reduced by the amount of each that is reclaimed. That is, theamount used may be calculated as the amount consumed to account formaterials that are reclaimed. [40 CFR 63.4551, Minn. R. 7011.8130]


The Permittee shall determine the density of each liquid coating, thinnerand/or other additive, and cleaning material used during each month fromtest results using ASTM Method D1475 98, Standard Test Method for Densityof Liquid Coatings, Inks, and Related Products (incorporated by reference, see40 CFR Section 63.14), information from the supplier or manufacturer of thematerial, or reference sources providing density or specific gravity data forpure materials. If there is disagreement between ASTM Method D1475 98and other such information sources, the test results will take precedenceunless, after consultation the Permittee demonstrates to the satisfaction ofthe Agency that the formulation data are correct. If the Permittee purchasesmaterials or monitor consumption by weight instead of volume, thePermittee does not need to determine material density. Instead, thePermittee may use the material weight in place of the combined terms fordensity and volume in Equations 1A, 1B, 1C, and 2 in Appendix B to thispermit. [40 CFR 63.4551(c), Minn. R. 7011.8130]


The Permittee shall determine the volume (liters) of each coating, thinnerand/or other additive, and cleaning material used during each month bymeasurement or usage records. If the Permittee purchases materials ormonitors consumption by weight instead of volume, the Permittee does notneed to determine the volume of each material used. Instead, the Permitteemay use the material weight in place of the combined terms for density andvolume in Equations 1A, 1B, 1C and 2 in Appendix B to this permit. [40 CFR63.4551(d), Minn. R. 7011.8130]


The mass of organic HAP emissions is the combined mass of organic HAPcontained in all coatings, thinners and/or other additives, and cleaningmaterials used during each month minus the organic HAP in certain wastematerials. The Permittee shall calculate the following using the referencedequations in Appendix B of this permit: 1) Calculate the mass of organic HAPemissions using Equation 1. 2) Calculate the kg organic HAP in the coatingsused during the month using Equation 1A. 3) Calculate the kg of organic HAPin the thinners and/or other additives used during the month using Equation1B. 4) Calculate the kg organic HAP in the cleaning materials used during themonth using Equation 1C. 5) If the Permittee chooses to account for the massof organic HAP contained in waste materials sent or designated for shipmentto a hazardous waste TSDF in Equation 1, then the Permittee must determinethe mass according to 40 CFR Section 63.4551(e)(4)(i) through (iv). [40 CFR63.4551(e), Minn. R. 7011.8130]



The Permittee shall determine the total mass of coating solids used, kg, whichis the combined mass of coating solids for all the coatings used during eachmonth, using Equation 2 in Appendix B of this permit. [40 CFR 63.4551(f),Minn. R. 7011.8130]


The Permittee shall calculate the organic HAP emission rate for thecompliance period, kg (lb) organic HAP emitted per kg (lb) coating solids used,using Equation 3 in Appendix B of this permit. [40 CFR 63.4551(g), Minn. R.7011.8130]


To demonstrate continuous compliance, the organic HAP emission rate foreach compliance period, determined according to 40 CFR Section 63.4551(a)through (g), must be less than or equal to the HAP emission limit. Acompliance period consists of 12 months. Each month after the end of theinitial compliance period described in 40 CFR Section 63.4550 is the end of acompliance period consisting of that month and the preceding 11 months.The Permittee must perform the calculations in 40 CFR Section 63.4551(a)through (g) on a monthly basis using data from the previous 12 months ofoperation. [40 CFR 63.4552(a), Minn. R. 7011.8130]


Deviation: If the organic HAP emission rate for any 12 month complianceperiod exceeded the HAP emission limit, this is a deviation from the emissionlimitation for that compliance period and must be reported as specified in 40CFR Sections 63.4510(c)(6) and 63.4520(a)(6). [40 CFR 63.4552(b), Minn. R.7011.8130]



The Permittee shall collect and keep records of the data and informationspecified below. Failure to collect and keep these records is a deviation fromthe standard. 1) A copy of each notification and report that was submitted tocomply with 40 CFR pt. 63, subp. PPPP, and the documentation supportingeach notification and report; 2) A current copy of information provided bymaterials suppliers or manufacturer's formulation data, or test data used todetermine the mass fraction of organic HAP and density for each coating,thinner and/or other additive, and cleaning material, and the mass fraction ofcoating solids for each coating. If a test was conducted to determine the massfraction of organic HAP, density, or mass fraction of coating solids, keep acopy of the complete test report. If the information provided by themanufacturer or supplier that was based on testing was used, keep thesummary sheet of results provided by the supplier. The Permittee is notrequired to obtain the test report or other documentation from themanufacturer or supplier; 3) If the Permittee changes compliance options, arecord of the coating operations on which the Permittee used eachcompliance option and the time periods (beginning and ending dates) foreach option that was used; 4) A record of the calculation of the total mass oforganic HAP emissions for the coatings, thinners and/or other additives, andcleaning materials used each month using Equations 1, 1A through 1C, and 2in Appendix B, and, if applicable, the calculation used to determine mass oforganic HAP in waste materials according to 40 CFR Section 63.4551(e)(4).the calculation of the total mass of coating solids used each month usingEquation 2 in Appendix B; and the calculation of each 12 month organic HAPemission rate using Equation 3 in Appendix B; 5) A record of the name andmass of each coating, thinner and/or other additive, and cleaning materialused during each compliance period; 6) A record of the mass fraction oforganic HAP for each coating, thinner and/or other additive, and cleaningmaterial used during each compliance period; 7) A record of the mass fractionof coating solids for each coating used during each compliance period; 8) Ifthe Permittee uses an allowance in Equation 1 in Appendix II for organic HAPcontained in waste materials sent to or designated for shipment to atreatment, storage, and disposal facility (TSDF) according to 40 CFR Section63.4551(e)(4), the Permittee must keep records of the information specifiedin paragraphs 40 CFR Section 63.4530(g)(1) through (3); and 9) Records of thedate, time and duration of each deviation. [40 CFR 63.4530, 40 CFR63.4552(d), Minn. R. 7011.8130]


The Permittee's records must be in a form suitable and readily viewable forexpeditious review according to 40 CFR Section 63.10(b)(1). Whereappropriate, the records may be maintained as electronic spreadsheets or asa database. As specified in 40 CFR Section 63.10(b)(1), each record must bekept for 5 years following the date of each occurrence, measurement,maintenance, corrective action, report, or record. The record must be kepton site for at least 2 years after the date of each occurrence, measurement,maintenance, corrective action, report, or record according to 40 CFR Section63.10(b)(1). The remaining records may be kept off site for the remaining 3years. [40 CFR 63.4552(d), 40 CFR pt. 63, 4531, Minn. R. 7011.8130]



The Permittee shall submit a semiannual compliance report : Due by 31 daysafter end of each calendar half year following Permit Issuance. The reportshall contain the information specified in Semiannual Compliance ReportContent requirement under COMG 6. Each semiannual compliance reportmust cover the semiannual reporting period from January 1 through June 30or the semiannual reporting period from July 1 through December 31. Thisreport may be submitted with the Semiannual Deviations Report also listed inTable B of this permit. [40 CFR 63.4520(a)(1)(i),(ii),&(iv), Minn. R. 7011.8130]


Semiannual Compliance Report Content: The semiannual compliance reportmust contain the following information: i) Company name and address. ii)Statement by a responsible official with that official's name, title, andsignature, certifying the truth, accuracy, and completeness of the content ofthe report. iii) Date of report and beginning and ending dates of the reportingperiod. The reporting period is the 6 month period ending on June 30 orDecember 31. Note that the information reported for each of the 6 months inthe reporting period will be based on the last 12 months of data prior to thedate of each monthly calculation. iv) Identification of the compliance optionor options specified in 40 CFR Section 63.4491 that was used on each coatingoperation during the reporting period. If the compliance option was changedduring the reporting period, the report must contain beginning and endingdates for each option that was used; and v) The calculation results for eachrolling 12 month organic HAP emission rate during the 6 month reportingperiod. [40 CFR 63.4520(a)(3), Minn. R. 7011.8130]


If there were no deviations from the emissions limitations in 40 CFR Sections63.4490, 63.4492, and 63.4493 which apply, the semiannual compliancereport must contain a statement that there were no deviations from theemission limitations during the reporting period. [40 CFR 63.4520(a)(5), Minn.R. 7011.8130]


Deviation Report Requirements: If there was a deviation from the HAPemission limit, the semiannual compliance report must contain the followinginformation: i) The beginning and ending dates of each compliance periodduring which the 12 month organic HAP emission rate exceeded the HAPemission limit. ii) The calculations used to determine the 12 month organicHAP emission rate for the compliance period in which the deviation occurred.The Permittee must submit the calculations for Equations 1, 1A through 1C, 2,and 3 in Appendix B of this permit; and if applicable, the calculation used todetermine mass of organic HAP in waste materials according to 40 CFRSection 63.4551(e)(4). The Permittee does not need to submit backgrounddata supporting these calculations (e.g., information provided by materialssuppliers or manufacturers, or test reports). iii) A statement of the cause ofeach deviation. [40 CFR 63.4520(a)(6), Minn. R. 7011.8130]


After the effective date of any relevant standard promulgated by theAdministrator under 40 CFR pt. 63, equipment added (or a process change) toan affected source that is within the scope of the definition of affected sourceunder the relevant standard must be considered part of the affected sourceand subject to all provisions of the relevant standard established for thataffected source. [40 CFR 63.5(b)(6), Minn. R. 7011.7000]



Proper Operation and Maintenance. At all times, including periods of startup,shutdown, and malfunction, the Permittee shall operate and maintain theemission unit subject to the MACT standard and any associated air pollutioncontrol equipment and monitoring equipment, in a manner consistent withsafety and good air pollution control practices for minimizing emissions atleast to the levels required by any relevant standard and as detailed in 40 CFRSection 63.6(e)(1)(i) (iii). The Permittee shall correct malfunctions as soon aspracticable after their occurrence. [40 CFR pt. 63, 6(e)(1), Minn. R. 7011.7000]


Methods for determining compliance. The Administrator will determinecompliance, in part, based on conformance with operation and maintenancerequirements, review of records, and inspection of the source as specified in40 CFR Section 63.6(f)(2). [40 CFR 63.6(f)(2), Minn. R. 7011.7000]


Finding of compliance. The Administrator will make a finding concerning anaffected source's compliance with a non opacity emission standard uponobtaining all the compliance information required by the relevant standard.[40 CFR pt. 63, 6(f)(3), Minn. R. 7011.7000]


The Administrator may grant an extension of compliance with an emissionstandard, as specified in 40 CFR Section 63.6(i). Until an extension ofcompliance has been granted by the Administrator, the Permittee shallcomply with all applicable requirements of 40 CFR pt. 63, subp. A. [40 CFR63.6(i), Minn. R. 7011.7000]


Initial notification requirements apply to the Permittee when the Permittee’saffected source becomes subject to a relevant standard. [40 CFR 63.9(b)(1),Minn. R. 7019.0100]


Notification of compliance status. Each time a notification of compliancestatus is required under 40 CFR pt. 63, subp. A, the Permittee shall submit tothe MPCA a notification of compliance status containing the informationrequired by 40 CFR Section 63.9(h), signed by the responsible official whoshall certify its accuracy, attesting to whether the source has complied withthe relevant standard. The Permittee shall submit the notification ofcompliance status on the dates specified in 40 CFR Section 63.4510.Notifications may be combined as long as the due date requirement for eachnotification is met. [40 CFR 63.9(h), Minn. R. 7019.0100]


Notification of information change. Any change in the information alreadyprovided under 40 CFR Section 63.9 shall be provided to the Administrator inwriting within 15 calendar days after the change. [40 CFR 63.9(j), Minn. R.7019.0100]


The Permittee shall submit reports to the MPCA and shall send a copy of eachreport to the Administrator. [40 CFR 63.10(a), Minn. R. 7019.0100]


General recordkeeping requirements.. The Permittee shall maintain files of allinformation (including all reports and notifications) required by 40 CFR pt. 63in a form suitable and readily available for expeditious inspection and review.The files shall be retained for at least 5 years following the date of eachoccurrence, measurement, maintenance, corrective action, report, or record.At a minimum, the most recent 2 years of data must be retained on site. [40CFR 63.10(b)(1), Minn. R. 7019.0100, Minn. R. 7019.0100, subp. 2(B)]



General recordkeeping requirements. For each affected source, the Permitteeshall maintain the relevant records of all documents supporting initialnotifications and notifications of compliance status. [40 CFR 63.10(b)(2)(xiv),Minn. R. 7019.0100, subp. 2(B)]


Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e),the Permittee shall submit reports to the Administrator in accordance withthe reporting requirements in the relevant standard. Additional reportingrequirements are specified in 40 CFR Section 4520. [40 CFR 63.10(d)(1), Minn.R. 7019.0100]

1 COMG7 (GP005)Paint Filters

The Permittee shall submit a plan : Due 180 calendar days after PermitIssuance Date. The Permittee shall provide CAM plans for TREA1, TREA2,TREA3, TREA4, and TREA5 for control of Total Particulate Matter. The CAMplans shall be submitted according to the requirements in 40 CFR Section 64.4and shall fulfill the monitoring design criteria in 40 CFR Section 64.3. [40 CFR64.5(b), Corrective Action]


The Permitee was required to submit a plan : Due 180 calendar days before07/17/2006 (which was the expiration date of permit 06500002 001). ThePermittee was required to submit the information requested under 40 CFRSection 64.4 (CAM plans) for all Other pollutant specific emission units, aspart of the application for the Part 70 permit renewal. This requirement willbe fulfilled upon completion of Requirement ID #1055244 found in Section 7of this permit. [40 CFR 64.5(b)]


The Permittee shall operate and maintain control equipment such that itachieves a control efficiency for Total Particulate Matter >= 99 percentcontrol efficiency. [Minn. R. 7007.80, subp. 2, Minn. R. 7011.0070, subp. 1(A)]


The Permittee shall operate and maintain control equipment such that itachieves a control efficiency for PM < 10 micron >= 85 percent controlefficiency. [Minn. R. 7011.0070, subp. 1(A), Title I Condition: Avoid majorsource under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]


The Permittee shall operate and maintain control equipment such that itachieves a control efficiency for PM < 2.5 micron >= 85 percent controlefficiency. [Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major sourceunder 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]


The Permittee shall operate and maintain the panel filter in accordance withthe Operation and Maintenance (O & M) Plan. The Permittee shall keepcopies of the O & M Plan available onsite for use by staff and MPCA staff.[Minn. R. 7007.0800, subp. 14]


Daily Inspections: Once each operating day, the Permittee shall visuallyinspect the condition of each paint filter with respect to alignment,saturation, tears, holes and any other condition that may affect the filter'sperformance. The Permittee shall maintain a daily written record of filterinspections. [Minn. R. 7007.0800, subp. 4 5, Title I Condition: Avoid majorsource under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]


Periodic Inspections: At least once per calendar quarter, or more frequentlyas required by the manufacturing specifications, the Permittee shall inspectthe control equipment components. The Permittee shall maintain a writtenrecord of these inspections. [Minn. R. 7007.0800, subp. 14, Minn. R.7007.0800, subps. 4 5]


Paint FiltersCorrective Actions: The Permittee shall take corrective action as soon aspossible if the fabric filter or any of its components are found during theinspections to need repair. Corrective actions shall include completion ofnecessary repairs identified during the inspection, as applicable. Correctiveactions include, but are not limited to, those outlined in the O & M Plan forthe fabric filter. The Permittee shall keep a record of the type and date of anycorrective action taken for each filter. [Minn. R. 7007.0800, subp. 14, Minn. R.7007.0800, subp. 5]


Annual Hood Evaluation: The Permittee shall measure and record at leastonce every 12 months the fan rotation speed, fan power draw, or facevelocity of each hood, or other comparable air flow indication method asrequired by Minn. R. 7011.0072, subp. 4. The Permittee shall maintain a copyof the annual evaluation on site. [Minn. R. 7011.0072, subp. 4]


Initial Hood Certification and Evaluation: The control device hood mustconform to the requirements listed in Minn. R. 7011.0072, subp. 2(B), and thePermittee shall certify this as specified in Minn. R. 7011.0072, subps. 2 and 3.The Permittee shall maintain a copy of the evaluation and certification onsite. [Minn. R. 7011.0072, subps. 2 4]


The Permittee was required to submit a report : Due 180 calendar daysbefore 07/17/2006 (which was the expiration date for permit 06500002 001).In order to use a certified hood control efficiency value from Minn. R.7011.0070, subp. 1a, Table A, the Permittee must: 1) Arrange for a testingcompany to conduct a hood evaluation; 2) Document, on a form provided bythe commissioner, that the hood conforms to the design and operationpractices recommended in the manual incorporated by reference underMinn. R. 7011.0061; and 3) Must include with the permit application acertification statement, as specified in Minn. R. 7011.0072, Subp. 2(C). Thisrequirement will be fulfilled by completion of Requirement ID #1056026found in Section 7 of this permit. [Minn. R. 7007.0800, subp. 14, Minn. R.7007.0800, subps. 4 5, Minn. R. 7011.0072, subp. 2]


The Permittee shall submit a report : Due 14 calendar days after PermitIssuance Date. The Permittee shall submit a copy of the hood certification forthe hood of each control equipment unit in COMG 7, demonstrating that thehood has been evaluated and certified according to the requirements ofMinn. R. 7011.0072, subps. 2 and 3. [Corrective Action, Minn. R. 7007.0800,subp. 14, Minn. R. 7007.0800, subps. 4 5]

1 EQUI6 (EU002)Boiler 2

Total Particulate Matter <= 0.60 pounds per million Btu heat input 3 houraverage The PM potential to emit from the unit is 0.024 lb/MMBtu due toequipment design and allowable fuels. [Minn. R. 7011.0510, subp. 1]


Opacity <= 20 percent opacity except for one six minute period per hour ofnot more than 60 percent opacity. [Minn. R. 7011.0510, subp. 2]

3 EQUI6 (EU002)Boiler 2 Fuel types: natural gas or distillate oil only. [Minn. R. 7005.0100, subp. 35a]


The Permittee shall comply with all applicable requirements under 40 CFR pt.63, Subpart JJJJJJ: National Emission Standards for Hazardous Air Pollutantsfor Industrial, Commercial and Institutional Boilers Area Sources. [40 CFR63.11193]

Sequence # Subject Item Description5 EQUI6 (EU002)

Boiler 2For boilers located at existing major sources of HAP that limit their potentialto emit (e.g., take a permit limit) such that the existing major source becomesan area source, the Permittee must comply with the applicable provisions asspecified in 40 CFR Section 63.11210(i). Any such existing boiler at the existingsource must demonstrate compliance with 40 CFR pt. 63, subp. JJJJJJ upon theexisting major source commencing operation as an area source. [40 CFR63.11210(i)]


At all times the Permittee must operate and maintain the affected boiler in amanner consistent with safety and good air pollution control practices forminimizing emissions. The general duty to minimize emissions does notrequire the Permittee to make any further efforts to reduce emissions iflevels required by this standard have been achieved. Determination ofwhether such operation and maintenance procedures are being used will bebased on information available to the Administrator that may include, but isnot limited to, monitoring results, review of operation and maintenanceprocedures, review of operation and maintenance records, and inspection ofthe source. [40 CFR 63.11205(a)]


To demonstrate initial compliance the Permittee shall conduct an initialperformance tune up according to the requirements of 40 CFR Section63.11223(b). The Permittee shall submit a signed statement in theNotification of Compliance Status report that indicates that that the tune upwas conducted. [40 CFR 63.11201(b), 40 CFR 63.11214(b), 40 CFR pt. 63,subp. JJJJJJ(Table 2)]


To demonstrate continuous compliance, the Permittee shall conductperformance tune ups as specified in 40 CFR Section 63.11223(e) and belowand keep records as required in 40 CFR Section 63.11225(c). The Permitteemust conduct the tune up while burning the type of fuel (or fuels in the caseof boilers that routinely burn two types of fuels at the same time) thatprovided the majority of the heat input to the boiler over the 12 months priorto the tune up. [40 CFR 63.11201(b), 40 CFR 63.11223(a), 40 CFR pt. 63, subp.JJJJJJ(Table 2)]


The Permittee must conduct a tune up on EQUI6 every 5 years as specified inparagraphs 40 CFR Section 63.11223(b)(1) through (7). Each 5 year tune upmust be conducted no more than 61 months after the previous tune up. ThePermittee may delay the burner inspection specified in 40 CFR Section63.11223(b)(1) and inspection of the system controlling the air to fuel ratiospecified in 40 CFR Section 63.11223(b)(3) until the next scheduled unitshutdown. However, the Permittee must inspect each burner and systemcontrolling the air to fuel ratio at least once every 72 months. [40 CFR63.11223(e)]


Boiler 2The Permittee must conduct the initial tune up and all subsequent tune upsaccording to the following requirements: (1) As applicable, inspect theburner, and clean or replace any components of the burner as necessary. (2)Inspect the flame pattern, as applicable, and adjust the burner as necessaryto optimize the flame pattern. The adjustment should be consistent with themanufacturer's specifications, if available. (3) Inspect the system controllingthe air to fuel ratio, as applicable, and ensure that it is correctly calibratedand functioning properly. (4) Optimize total emissions of CO. Thisoptimization should be consistent with the manufacturer's specifications, ifavailable. (5) Measure the concentrations in the effluent stream of CO inparts per million, by volume, and oxygen in volume percent, before and afterthe adjustments are made (measurements may be either on a dry or wetbasis, as long as it is the same basis before and after the adjustments aremade). Measurements may be taken using a portable CO analyzer. [40 CFR63.11223(b)(1) (7)]


If the unit is not operating on the required date for a tune up, the tune upmust be conducted within 30 days of startup. [40 CFR 63.11223(b)(7)]


The Permittee shall maintain on site and submit, if requested by theAdministrator, a report of each tune up which contains the information in 40CFR Section 63.11223(b)(6)(i) through (iii). The required report contents are:(i) The concentrations of CO in the effluent stream in parts per million, byvolume, and oxygen in volume percent, measured at high fire or typicaloperating load, before and after the tune up of the boiler. (ii) A description ofany corrective actions taken as a part of the tune up of the boiler. (iii) Thetype and amount of fuel used over the 12 months prior to the tune up of theboiler, but only if the unit was physically and legally capable of using morethan one type of fuel during that period. Units sharing a fuel meter mayestimate the fuel use by each unit. [40 CFR 63.11223(b)(6)(i) (iii)]


As required in 40 CFR Section 63.10(b)(2)(xiv), the Permittee must keep acopy of each notification and report that was submitted to comply with thissubpart and all documentation supporting any Initial Notification orNotification of Compliance Status that the Permittee submitted. [40 CFR63.11225(c)(1)]


The Permittee must keep records to document conformance with theapplicable requirements 40 CFR Section 63.11214 and 63.11223 as specifiedin 40 CFR Section 63.11225(c)(2). These records must identify each boiler, thedate of tune up, the procedures followed for tune up, and the manufacturer'sspecifications to which the boiler was tuned. [40 CFR 63.11225(c)(2)(i)]


The Permittee must maintain records of the occurrence and duration of eachmalfunction of the boiler, as well as records of actions taken during periods ofmalfunction to minimize emissions in accordance with the general duty tominimize emissions in 40 CFR Section 11205(a), including corrective actions torestore the malfunctioning boiler to its normal or usual manner of operation.[40 CFR 63.11225(c)(4) (5)]


The Permittee’s records must be in a form suitable and readily available forexpeditious review. The Permittee shall keep each record for 5 yearsfollowing the date of each recorded action. The Permittee must keep eachrecord on site or be accessible from a central location by computer or othermeans that instantly provide access at the site for at least 2 years after thedate of each recorded action. The Permittee may keep the records off site forthe remaining 3 years. [40 CFR 63.11225(d)]


Boiler 2The Permittee must submit all of the notifications in 40 CFR Sections 63.7(b);63.8(e) and (f); 63.9(b) through (e), (g) and (h) that apply by the datesspecified in those sections except as specified in 40 CFR Section63.11225(a)(2) and (4). [40 CFR 63.11225(a)(1)]


The Permittee shall submit a notification : Due 30 calendar days after PermitIssuance Date. The Permittee must provide notice of the date when a permitlimit resulted in the source being subject to 40 CFR pt. 63, subp. JJJJJJ. Thenotification must identify: (1) The name of the owner or operator of theaffected source, the location of the source, the boiler(s) effected by thechange, and the date of the notice. (2) The date upon which the permit limitoccurred (date of permit issuance). [40 CFR 63.11210(i), 40 CFR 63.11225(g)]


The Permittee shall submit a notification : Due 120 calendar days after PermitIssuance Date. The Permittee shall submit the initial notification as prescribedin 40 CFR Section 63.9(b)(2). [40 CFR 63.11225(a)(2)]


The Permittee shall submit a notification of compliance status : Due 120calendar days after Permit Issuance Date. The Notification of ComplianceStatus must include the following information and certifications ofcompliance listed in Table A, as applicable, and be signed by a responsibleofficial. The notification must be submitted electronically using theCompliance and Emissions Data Reporting Interface (CEDRI) that is accessedthrough EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, ifthe reporting form specific to this subpart is not available in CEDRI at the timethat the report is due, the written Notification of Compliance Status must besubmitted to the Administrator at the appropriate address listed in 40 CFRSection 63.13. [40 CFR 63.11225(a)(4)]


Notification of Compliance Status Contents: (1) The Permittee shall includethe information required by 40 CFR Section 63.9(h)(2), except the informationlisted in 40 CFR Section 63.9(h)(2)(i)(B), (D), (E), and (F). (2) The Permitteeshall include the following statement: This facility complies with therequirements in 40 CFR Section 63.11223 to conduct a biennial or 5 yeartune up, as applicable, of each boiler. (3) For units that do not qualify for astatutory exemption as provided in section 129(g)(1) of the Clean Air Act thePermittee shall include the following statement: No secondary materials thatare solid waste were combusted in any affected unit. [40 CFR 63.11225(a)(4)]


Compliance Report: The Permittee shall prepare 5 year compliance report asspecified in 40 CFR Section 63.11225(b)(1) and (2). (1) Company name andaddress. (2) Statement by a responsible official, with the official's name, title,phone number, email address, and signature, certifying the truth, accuracyand completeness of the notification and a statement of whether the sourcehas complied with all the relevant standards and other requirements of thissubpart. The notification must include the following statements ofcompliance, as applicable, and signed by a responsible official: (i) This facilitycomplies with the requirements in 40 CFR Section 63.11223 to conduct abiennial or 5 year tune up, as applicable, of each boiler. (ii) For units that donot qualify for a statutory exemption as provided in section 129(g)(1) of theClean Air Act the Permittee shall include the following statement: Nosecondary materials that are solid waste were combusted in any affectedunit. [40 CFR 63.11225(b)]


Boiler 2Deviations in Compliance Report: If the source experiences any deviationsfrom the applicable requirements during the reporting period, include adescription of deviations, the time periods during which the deviationsoccurred, and the corrective actions taken. [40 CFR 63.11225(b)]


Circumvention: The Permittee shall not build, erect, install, or use any article,machine, equipment, or process to conceal an emission that would otherwiseconstitute noncompliance with a relevant standard. Such concealmentincludes, but is not limited to, use of diluents to achieve compliance with arelevant standard based on the concentration of a pollutant in the effluentdischarged to the atmosphere. [40 CFR 63.4(b), Minn. R. 7011.7000]


Notification of information change. Any change in the information alreadyprovided under 40 CFR Section 63.9 shall be provided to the Administrator inwriting within 15 calendar days after the change. [40 CFR 63.9(j), Minn. R.7019.0100]


The Permittee shall submit reports to the MPCA and shall send a copy of eachreport to the Administrator. [40 CFR 63.10(a), Minn. R. 7019.0100]


General recordkeeping requirements. The Permittee shall maintain files of allinformation (including all reports and notifications) required by 40 CFR pt. 63in a form suitable and readily available for expeditious inspection and review.The files shall be retained for at least 5 years following the date of eachoccurrence, measurement, maintenance, corrective action, report, or record.At a minimum, the most recent 2 years of data must be retained on site. [40CFR 63.10(b)(1), Minn. R. 7019.0100, Minn. R. 7019.0100, subp. 2(B)]

1 EQUI17 (EU007)Dryer/Oven Main

Total Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaustgas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. The PMPTE for this unit is 0.0022 grains/dry standard cubic foot due to equipmentdesign and allowable fuel. [Minn. R. 7011.0610, subp. 1(A)(1)]

2 EQUI17 (EU007)Dryer/Oven Main

Opacity <= 20 percent opacity except for one six minute period per hour ofnot more than 60 percent opacity. [Minn. R. 7011.0610, subp. 1(A)(2)]

3 EQUI17 (EU007)Dryer/Oven Main Fuel type: Natural gas only [Minn. R. 7005.0100, subp. 35a]

TSD Attachments Attachment 3: Filter Specifications for TREA12 – TREA16


STANDARD

SMARTMEDIA SM 30 IS COMPATIBLE WITH MOST AIR-DRY INDUSTRIALSOLVENT-BASED PAINTS AND COATINGS, INCLUDING AIR-DRY PRIMERS,ENAMELS, SEALERS, STAINS AND LACQUERS.

SM 30 S E R I E S

PAINT ARRESTORS

SmartMedia pads and blankets are compressed and vacuum-packed prior to shipping to save freight costsand storage space... then instantly return to their normal size for installation. SmartMedia is supplied in vacuum-packed 20" x 20" and 20" x 25" pads as well as popular-sized blankets.

The Filter With The Memory

SmartMedia®

FEWER FILTER CHANGESCompetitive paint-holding capacity

REDUCED WORK CHAMBER CLEAN UPLess run-off with many coatings

REDUCED BACK-SECTION MAINTENANCEUp to 4 times less penetration/scrim reinforced

REDUCED DISPOSAL COSTUltracompressibility/doubling not required

MINIMIZED PARTICULATE EMISSIONSPolyb™ and TotalTac® provide unmatched paint-dust retention

IMPROVED BOOTH VENTILATIONDesigned to depth load, not face load

BENEFITS

&Features

Vacuum-PackUS Patent # 6,209,724

▼▼

▼▼

▼▼

PolybTM andTotalTac®

make it possible!

SM 30 S E R I E S

PAINT ARRESTORS


SmartMedia®

Large-diameter fibers in the 1st layer (10 times bigger than in the 3rd layer) areloosely spaced, coiled and bundled for structural stability and to capture the largerpaint particles. Fibers in the 2nd layer are engineered to intercept the mid-sizedoverspray particles. The 3rd layer is a dense mat of single-strand, 21-micronfibers. It is especially effective at capturing and retaining small, dry particles.SM 30 has a scrim backing for dimensional stability, effectively adding a 4th layer.

Polyb conditions SmartMedia’s fibers, making them safer, softer and more user friendly; TotalTac, the first true 100%tackification process, arrests and holds dry paint particles, preventing their escape in the environment.

COMPARATIVE PERFORMANCE DATACharacteristics SmartMedia SM 30 Standard Expanded Paper

Avg. Arrestance Efficiency 99.08% 97.12%

Holding Capacity 2.4 lbs. 2.4 lbs.

Run-Off 2,900 grams 2,819 grams

Penetration 37.2 grams 115.3 grams

Pressure Drop (Initial/Final) .01/.07 in. of H2O .01/.11 in. of H2O

Test ConditionsFilter Size: 20" x 20" pads

Test Paint: High Solids Baking Enamel

Spray Rate: 138 gr./min.

Air Velocity: 150 FPM

Test Lab: LMS Technologies

Complete Test ReportsAvailable Upon Request.

SUPERIOR FIBERS CONTINUOUSLY IMPROVES ITS PRODUCTS. THEREFORE, SPECIFICATIONS ARE SUBJECT TO CHANGE WITHOUT NOTICE.

Illustrations: Microscopic view of filter layers as they load

STANDARD

PROGRESSIVELY DENSER LAYERSClean SmartMedia - Side View

Clean SmartMedia - Top View

Loaded SmartMedia - Side View

Loaded SmartMedia - Top View

Layers

2

3

1

Ph: 740-569-4175 Fax: 740-569-4632 E-mail: [email protected] Web: www.superiorfibers.com

P.O. Box 89, Bremen, OH 43107

SmartMedia®

a product of SUPERIOR FIBERS, INC.


Your Superior SmartMedia Distributor is:

©2002 Superior Fibers, Inc. Printed in USA SmartMedia, Polyb and TotalTac are Superior trademarks. Form SM 30

Fiber

Polyb

CoatingUS Patent # 6,136,058

TSD Attachments Attachment 4: Change of Ownership Request


Documents

Air Individual Permit Part 70 Reissuance for Imperial