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Technical Support Document, Permit Number: 03700280-101 of 5

Technical Support Document

For Draft Air Emission Permit No. 03700280-101

This technical support document (TSD) is intended for all parties interested in the draft 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 draft permit. 1. General information

1.1 Applicant and stationary source location:

Table 1. Applicant and source address

Applicant/Address

Stationary source/Address (SIC Code: 2048 - Prepared Feed and Feed Ingredients for Animals and Fowls, Except Dogs and Cats)

Reconserve of Minnesota Inc 13420 Court House Blvd Rosemount, Minnesota 55068-2553

Reconserve of Minnesota Inc 13420 Court House Blvd Rosemount, MN 55068-2553

Contact: Chris Frantz Phone: 612-419-6514

1.2 Facility description

The facility is an animal feed production plant which uses off specification or outdated bakery, dairy and other food production materials. The materials are mixed and dried into animal feed which is shipped in bulk. On occasion the dryer is also used to dry high-moisture wood by-products for sale or for later use as fuel. The facility consists of material handling equipment, a rotary dryer, control equipment, truck loading and unloading areas, storage tanks, and paved drive areas.

1.3 Description of the activities allowed by this permit action This permit action is a major amendment through mandatory reopening under Minn. R. 7007.1600, subp. 1(D). This permit includes revisions to assure compliance with the permit limits to avoid 40 CFR pt. 70, New Source Review, and 40 CFR pt. 63 major source by adding control efficiencies for control equipment. This permit action also rolls in an administrative amendment to change the facility name from Endres Processing, LLC to ReConserve of Minnesota Inc. This permit action does not authorize construction.

1.4 Description of notifications and applications included in this action Table 2. Notifications and applications included in this action

Date received Application/notification type and description 06/15/2018 Administrative Amendment (IND20180001)

1.5 Facility emissions:

Table 3. Facility classification


Classification Major Synthetic minor/area Minor/area PSD X Part 70 Permit Program X Part 63 NESHAP X

1.6 Changes to permit

• This permit has been updated to match MPCA’s current TEMPO language and guidance; • The facility name was updated from Endres Processing LLC to ReConserve of Minnesota Inc.; • The emission limits were moved from the total facility to their respective groups to match MPCA

guidance; • One-time testing submittals that were completed were removed from the permit; • EQUI 5, Generator, was removed from the facility on 1/1/2015; it was removed from the permit; • Performance test dates were updated and requirements moved from the group to individual unit; • EQUI 6 was added to the Indirect Heating Units Group, COMG 7, to reflect applicable requirements; • Industrial Process Equipment Rule requirements were added to TREA 15, Thermal Oxidizer; • FUGIs 1 and 4 had Industrial Process Equipment Rule requirements added; • FUGI 3 had Visible Air Emissions Rule requirements added; • COMG 9 – Fabric Filters and COMG 10 – Cyclones were removed, and requirements moved to

individual units, TREAs 8, 9, 10, 11, 12, 13, and 14, to match MPCA guidance; • Control efficiency requirements were added to TREAs 8, 9, 10, 11, 12, 13, and 14 to ensure

compliance with limits to avoid Part 70; • Citations were corrected on TREAs 8, 9, 10, 11, 12, 13, and 14 to cite the correct permitting

programs; and • Inapplicable requirements in the previous permit were discussed in the TSD instead of being

included in the main permit, per current guidance. 2. Regulatory and/or statutory basis

2.1 New source review (NSR)

The permit carries forward limits on the facility such that it is a minor source under New Source Review regulations. No changes are authorized by this permit.

2.2 Part 70 permit program The permit carries forward limits on the facility such that it is a nonmajor 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 permit carries forward limits on the facility such that it is an area source under the Part 70 permit program. Thus, no major source NESHAPs apply. In addition, the Permittee has stated that no area source NESHAPs apply to the facility. The facility is not subject to the requirements under 40 CFR pt. 63, subp. DDDDD (process heater MACT) because the facility is not a major source of hazardous air pollutants.

2.5 Regulatory and Monitoring Overview Table 4. Regulatory and monitoring overview of units affected by the permit amendment


Subject Item*

Applicable Regulations Rationale Requirement

What is the monitoring? Rationale

FUGIs 1, 4 - Loadouts

Minn. R. 7011.0715, subps. 1(A) &(B)

Standards of Performance for post-1969 Industrial Process Equipment. Equipment for which there is no other promulgated performance standard is subject to the opacity and PM limits in this rule. Construction of the unit was on or after July 9, 1969.

PM, Variable with airflow & Opacity <= 20%

None These loadouts are used to move large items and finished product, which generates negligible particulate matter.

FUGI 3 – Paved Roads

Minn. R. 7011.0110

Visible Emissions Rules apply to facilities for which a standard of performance has not been promulgated in another rule.

Opacity <= 20%

Corrective actions if visible emissions are observed.

These paved roads are used to access the loadouts by trucks. Trucks will be stopped or moving slowly, so no dust issues are anticipated.

TREAs 8 & 9 - Cyclones

40 CFR § 70.2 & Minn. R. 7007.0200

Part 70. Control efficiency and other operating parameter requirements to limit PM/PM10/PM2.5 PTE to avoid major source classification under Part 70. Permit specifies that replacement fabric filters must meet requirements of TREA being replaced.

PM/PM10/PM2.5 >= 50.0 percent control efficiency Pressure Drop >= 1.5 and <= 5.0 inches of water

Daily and periodic inspections, pressure drop, visible emissions, operation and maintenance, corrective actions, and recordkeeping.

Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance.

TREAs 10, 11, 12, 13 – Fabric Filters

40 CFR § 70.2 & Minn. R. 7007.0200

Part 70. Control efficiency and other operating parameter requirements to limit PM/PM10/PM2.5 PTE to avoid major source classification under Part 70. Permit specifies that replacement fabric filters must meet requirements of TREA being replaced.

PM10/PM2.5 >= 93.0 percent control efficiency PM >= 99.0 percent control efficiency Pressure Drop >= 3.5 and <= 6.5 inches of water

Daily and periodic inspections, pressure drop, visible emissions, operation and maintenance, corrective actions, and recordkeeping.

Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance.


Subject Item*

Applicable Regulations Rationale Requirement

What is the monitoring? Rationale

TREA 15 – Thermal Oxidizer

Minn. R. 7011.0715, subps. 1 & 2

Standards of Performance for post-1969 Industrial Process Equipment. Equipment for which there is no other promulgated performance standard is subject to the opacity and PM limits in this rule. Construction of the unit was on or after July 9, 1969.

PM, Variable with airflow & Opacity <= 20%

None This unit is temperature controlled above 1250 degrees F and does not burn any external fuel. Additionally, it acts as control equipment for EQUI 1, which complies with similar standards through use of control equipment.

*Location of the requirement in the permit (e.g. EQUI 1, STRU 2, etc.).

3. Technical information 3.1 Permit organization

This permit meets the MPCA Tempo Guidance for ordering and grouping of requirements as well as the use of permit appendices.

3.2 Inapplicable requirements moved to TSD

This permit action moves three inapplicable requirements from the main permit to the TSD. One is the negative applicability for 40 CFR pt. 63, subp. DDDDD discussed in Section 2.4 of this TSD. The other two were requirements reading: “Inapplicable Requirement: Minn. R. 7011.1201-1285 regarding waste combustors. The facility is defined as a "cofired facility" under Minn. R. 7011.1215 subp. 2 since it combusts primarily wood and is limited under this permit to burn less than 30% of refuse derived fuel or mixed municipal solid waste. The permit shield applies in accordance with Minn. R. 7007.1800, subp. (A)(2).” “Inapplicable Requirement: The facility is not subject to Minn. R. 7011.1000 regarding bulk agricultural facilities. The facility primarily receives already processed food by-products and liquid material and is not a dry bulk agricultural commodity facility. The permit shield applies in accordance with Minn. R. 7007.1800, subp. (A)(2).

3.3 Comments received This section will be completed once the referenced review period ends.

4. Permit fee assessment This permit is an MPCA-initiated reopening, with an administrative amendment rolled in. No additional points were assessed.

5. Conclusion


Based on the information provided by Reconserve of Minnesota Inc the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 03700280-101 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Benton Campbell (permit engineer)

Peggy Bartz (peer reviewer) Beckie Olson (permit writing assistant) Beckie Olson (data coordinator) Laurie O’Brien (administrative support)

TEMPO360 Activities: Permit Reopening (IND20200001)

Administrative Amendment (IND20180001) Attachments: 1. Subject item inventory and requirements report

AQ Permit SI Details Start PageThis workbook allows you to select any single AQ permitting activity at a single AgencyInterest. to view details about subject items (equipment, etc.) that are/were associated withthat permit activity. You have the option of viewing either the effective permit or otherpermit activities including past permits (issued or not) and permits currently being worked onthat have not yet been issued. Bear in mind that some facilities here may not have effectivepermits, so your selection may be limited to other permit activities.

You may also view SI details for an APPSET through the filter on the right. For both PERSETsand APPSETs, a specific document creation date and title description must be chosen. This is toselect a specific APPSET under activities with several of them.

AI and Activity selections on this dashboard will apply to all tabs in this workbook.

To print this report for your selected facility click the export arrow at the top center of thepage and choose PDF. Then selectLayout = 'Landscape'Content = 'Sheets in Workbook'Paper Size = 'Letter'Scaling = "At most 1 page wide'

If you are having issues with data not displaying, check your selection for "Agency InterestName" on this page. This should match the entry next to "AI Name" when you open yourPERSET or APPSET, which is not necessarily the same name that displays in Central File for afacility. If the wrong name is selected, no data will display in this report.

Agency Interest Name Master AI IdActivity Class Desc Activity Type Desc Activity Type Label Activity ID Title Desc Int Doc IdNumber ofRecords

Reconserve of Minnesota Inc 1465 Individual Permit Permit Reopening Permit Reopening IND2020000103700280-101 4066973 65 .

Showing Subject Item details for:

Agency Interest NameReconserve of Minnesota Inc

Document type(s)?APPSETPERSET

Show effective permit? (set to 'N' for appsets)Effective PermitsNon-effective Permits

Choose an activityEMI20160001EMI20170001EMI20180001EMI20190001

Select document creation date6/1/2020 90927 AM

Select document title03700280-101

Subject Item Category Description Subject Item Type Description

Agency Interest Conventional Site

Component Group Air Component Group

Equipment Coke Handling Equipment

Furnace

Kiln

Material Handling Equipment

Other Combustion

Silo/Bin

Fugitive Material Handling/Transfer/Storage

Paved Road

Structure Building

Stack/Vent

Total Facility Air Quality Total Facility

Treatment 007-Centrifugal Collector - High Efficiency

016-Fabric Filter - High Temp, T>250 Degrees F

018-Fabric Filter - Low Temp, T<180 Degrees F

131-Thermal Oxidizer

206-Dry Sorbent Injection

1

10

1

1

3

1

1

1

1

2

8

8

1

1

1

3

1

2

Overview of SI's (count) by type

Agency Interest: Reconserve of Minnesota IncAgency Interest ID: NoneActivity: IND20200001 (None)

Details for:SI Category: AllSI Type: All

Agency Interest Name Subject Item ID Subject Item Designation Subject Item Description

Reconserve ofMinnesota Inc

AISI1465 Null Null

COMG1 GP002Nitrogen Oxides (NOx)Group

COMG2 GP003 Sulfur Dioxide (SO2) Group

COMG3 GP004Particulate Matter (PM)Group

COMG4 GP006Carbon Monoxide (CO)Group

COMG5 GP007Volatile OrganicCompounds (VOC) Group

COMG6 GP008Hazardous Air Pollutants(HAP) Group

COMG7 GP001Indirect HeatingEquipment

COMG8 GP009 Material Handling

COMG11 GP005Particulate Matter < 10Micron (PM10) Group

COMG12 GP012Particulate Matter < 2.5Micron (PM2.5) Group

EQUI1 EU011Solid Fuel Burner w/Natural Gas-Fired Startup

EQUI2 EU012 Rotary Kiln Dryer

EQUI3 EU014Post Dryer MaterialsHandling

EQUI4 EU015Packaging MaterialsHandling

EQUI6 EU017 Comfort Heating

EQUI7 EU019 Petroleum Coke Handling

List of SIs

Agency Interest: Reconserve of Minnesota IncAgency Interest ID: 1465Activity: IND20200001 (Permit Reopening)

Details for:SI Category: NoneSI Type: All

Agency Interest Name Subject Item ID Subject Item Designation Subject Item DescriptionReconserve ofMinnesota Inc

EQUI6 EU017 Comfort Heating

EQUI7 EU019 Petroleum Coke Handling

EQUI14 EU013Sawdust/WoodBy-products Storage and ..

EQUI16 EU018Raw Material andSawdust/Wood By-produc..

FUGI1 FS004 Shipping (loadout)

FUGI3 FS002 Paved Roads

FUGI4 FS003 Pet Coke Receiving

STRU4 SV014Raw Material andSawdust/Wood By-produc..

STRU12 SV011 Burner and Dryer Stack

STRU13 SV012 Raw Material Receiving

STRU14 SV013Packaging MaterialStorage

STRU15 SV015Packaging Material andPost Dryer Handling Stack

STRU16 SV016 Emergency Dump Stack

STRU17 SV017 Not currently in use

STRU18 SV018 Not currently in use

STRU19 Null Production & Raw Storage

STRU20 Null Feed Storage

STRU21 Null Feed Loadout

List of SIs



Agency Interest Name Subject Item ID Subject Item Designation Subject Item DescriptionReconserve ofMinnesota Inc

STRU20 Null Feed Storage

STRU21 Null Feed Loadout

STRU22 Null Washbay

STRU23 Null Shop

STRU24 Null Office

STRU25 Null Office

STRU26 Null Receivings

TFAC3 03700280ReConserve of MinnesotaInc

TREA8 CE012Centrifugal Collector - HighEfficiency

TREA9 CE013Centrifugal Collector - HighEfficiency

TREA10 CE014Fabric Filter - LowTemperature, i.e., T<180 ..



TREA13 CE017Fabric Filter - HighTemperature, i.e., T>250 ..

TREA14 CE018 Dry Sorbent Injection

TREA15 CE019 Thermal Oxidizer

List of SIs



Reconserve of Minnesota IncCOMG1 GP002 Nitrogen Oxides (NOx)Group

1 Nitrogen Oxides <= 95 tons per year 12-month rolling sum.

Title I Condition: Avoid majorsource under 40 CFR52.21(b)(1)(i) and Minn. R.7007.3000, To avoid majorsource under 40 CFR 70.2 &Minn. R. 7007.0200

2 Calculate and record the 12-month Rolling Sum for each month by the 15th of the following month.


3

Calculate monthly Nitrogen Oxides (NOx) emissions based on fuel usage records and materialthroughput data and emission factors developed for each fuel combination (sawdust/RDF blend orsawdust/petroleum coke blend) from the most recent performance test of STRU 12. If emission factorsare not developed through performance testing the emission factors in this permit, which are based onU.S. EPA AP-42 published factors, shall take precedence. Monthly facility-wide NOx emissions shallalso be based on the operating hours of the generator and appropriate emission factors for thegenerator (either stack test data or U.S. EPA AP-42 emission factors). In addition, the facility-wide capmust include NOx emissions from natural gas combustion.


4

For each month by the 15th of the following month calculate and record the monthly NOx emissionsusing Equation 1:

EQUATION 1:NOx emissions = EF1s(A) + EF1rdf(B) + EF1pc(C) + EFng(E) + EFab(F)

EF1s = 7.84 (EQUI 1 emission factor for sawdust; lbs NOx/ton sawdust combusted)EF1rdf = 2 (EQUI 1 emission factor for RDF; lbs NOx/ton combusted)EF1pc = 14 (EQUI 1 emission factor for petroleum coke; lbs NOx/ton combusted)EFng = 100 (comfort heating emission factor for natural gas; lbs NOx/mmcf natural gas combusted)EFab = emission factor for MPCA-approved biomass fuel combusted based on most recent MPCA-appr..


6

Revision of Equation 1 Emission Factors: Equation 1 emission factors shall be revised for units that aretested based on the results of each performance test. The most recent performance test for eachpollutant shall be used to develop emission factors. The use of the updated emission factor shallcommence upon receipt of written MPCA notification that the performance test results were valid. Forthe interim period prior to receipt of written MPCA notification after the first performance test, usethe factors defined above for Equation 1 in this permit.


COMG2 GP003 Sulfur Dioxide (SO2)Group

1 Sulfur Dioxide <= 95 tons per year 12-month rolling sum.


2 Calculate and record the 12-month Rolling Sum for each month by the 15th of the following month.


3

Calculate monthly Sulfur Dioxide (SO2) emissions based on fuel usage records and materialthroughput data and emission factors developed for each fuel combination (sawdust/RDF blend orsawdust/petroleum coke blend) from the most recent performance test of STRU 12. If emission factorsare not developed through performance testing the emission factors in this permit, which are based onU.S. EPA AP-42 published factors, shall take precedence. Monthly facility-wide SO2 emissions shallalso be based on the operating hours of the generator and appropriate emission factors for thegenerator (either stack test data or U.S. EPA AP-42 emission factors). In addition, the facility-wide capmust include SO2 emissions from natural gas combustion.


4

For each month by the 15th of the following month calculate and record the monthly SO2 emissionsusing Equation 2.EQUATION 2:SO2 emissions = EF1s (A) + EF1rdf (B) + EF1pc(C) + EFng(E) + EFab(F)

EF1s = 0.2 (EQUI 1 emission factor for sawdust; lbs SO2/ton saw dust combusted)EF1rdf = 1.2 (EQUI 1 emission factor for RDF; lbs SO2/ton combusted)EF1pc = 19.5S where S is the sulfur content of the petroleum coke (EQUI 1 emission factor forpetroleum coke; lbs SO2/ton combusted)EFng = 0.6 lb SO2/MMcf natural gas combustedEFab = emission factor for MPCA-approved biomass fuel combusted based on most recent MPCA-appr..


7



COMG3 GP004 Particulate Matter (PM)Group

1 Particulate Matter <= 95 tons per year 12-month rolling sum.To avoid major source under40 CFR 70.2 & Minn. R.7007.0200

2 Calculate and record the 12-month Rolling Sum for each month by the 15th of the following month.To avoid major source under40 CFR 70.2 & Minn. R.7007.0200

3

Calculate monthly Total Particulate Matter (PM) emissions based on fuel usage records and materialthroughput data and emission factors developed for each fuel combination (sawdust/RDF blend orsawdust/petroleum coke/blend) from the most recent performance test of STRU 12. If emissionfactors are not developed through performance testing the emission factors in this permit, which arebased on U.S. EPA AP-42 published factors, shall take precedence. Monthly facility-wide PM emissionsshall also be based on the operating hours of the generator and appropriate emission factors for thegenerator (either stack test data or U.S. EPA AP-42 emission factors with application of pollutioncontrol as applicable). The PM emissions shall also include material handling and be based on emissionfactors and monthly throughput for the material handling processes. In addition, the facility-wide capmust include PM emissions from natural gas combustion.

To avoid major source under40 CFR 70.2 & Minn. R.7007.0200

5 For each month by the 15th of the following month calculate and record the monthly PM emissionsusing Equation 3.

EQUATION 3:PM emissions = EF1s(A) + EF1rdf(B) + EF1pc(C) + EF2(D) + EF3(E) + EF4(F)+ EF5(G) + EF8(I) + EF9(J) +EFng(K) + EFpl(L) + EFab(M) + 1.4

EF1s = 0.32 (EQUI 1 emission factor (EF) for sawdust; lbs PM/ton sawdust burned)EF1rdf = 0.73 (EQUI 1 EF for RDF; lbs PM/ton burned)EF1pc = 0.28 (EQUI 1 EF for petroleum coke; lbs PM/ton burned)EF2 = 0.036 (EQUI 2 EF for dryer material; lbs PM/ton dried)..


Requirements

Agency Interest: Reconserve of Minnesota IncAgency Interest ID: 1465Activity: (Permit Reopening)

Reconserve of Minnesota IncCOMG3 GP004 Particulate Matter (PM)Group

3

Calculate monthly Total Particulate Matter (PM) emissions based on fuel usage records and materialthroughput data and emission factors developed for each fuel combination (sawdust/RDF blend orsawdust/petroleum coke/blend) from the most recent performance test of STRU 12. If emissionfactors are not developed through performance testing the emission factors in this permit, which arebased on U.S. EPA AP-42 published factors, shall take precedence. Monthly facility-wide PM emissionsshall also be based on the operating hours of the generator and appropriate emission factors for thegenerator (either stack test data or U.S. EPA AP-42 emission factors with application of pollutioncontrol as applicable). The PM emissions shall also include material handling and be based on emissionfactors and monthly throughput for the material handling processes. In addition, the facility-wide capmust include PM emissions from natural gas combustion.


5

For each month by the 15th of the following month calculate and record the monthly PM emissionsusing Equation 3.

EQUATION 3:PM emissions = EF1s(A) + EF1rdf(B) + EF1pc(C) + EF2(D) + EF3(E) + EF4(F)+ EF5(G) + EF8(I) + EF9(J) +EFng(K) + EFpl(L) + EFab(M) + 1.4

EF1s = 0.32 (EQUI 1 emission factor (EF) for sawdust; lbs PM/ton sawdust burned)EF1rdf = 0.73 (EQUI 1 EF for RDF; lbs PM/ton burned)EF1pc = 0.28 (EQUI 1 EF for petroleum coke; lbs PM/ton burned)EF2 = 0.036 (EQUI 2 EF for dryer material; lbs PM/ton dried)..


8



COMG4 GP006 Carbon Monoxide (CO)Group

1 Carbon Monoxide <= 95 tons per year 12-month rolling sum.To avoid major source under40 CFR 70.2 & Minn. R.7007.0200


3

Calculate monthly Carbon Monoxide (CO) emissions based on fuel usage records and materialthroughput data and emission factors developed for each fuel combination (sawdust/RDF blend orsawdust/petroleum coke blend) from the most recent performance test of STRU 12. If emission factorsare not developed through performance testing the emission factors in this permit, which are based onU.S. EPA AP-42 published factors, shall take precedence. Monthly facility-wide CO emissions shall alsobe based on the operating hours of the generator and appropriate emission factors for the generator(either stack test data or U.S. EPA AP-42 emission factors). In addition, the facility-wide cap mustinclude CO emissions from natural gas combustion.


4

For each month by the 15th of the following month calculate and record the monthly CO emissionsusing Equation 5.

EQUATION 5:CO emissions = EF1s(A) + EF1rdf(B) + EF1pc(C) + EFng(E) + EFab(F)

EF1s = 0.96 (EQUI 1 emission factor for sawdust; lbs CO/ton saw dust combusted)EF1rdf = 2 (EQUI 1 emission factor for refuse derived fuel; lbs CO/ton combustedEF1pc = 0.06 (EQUI 1 emission factor for petroleum coke; lbs CO/ton combusted)EFng = 84 (emission factor for natural gas; lbs CO/mmcf natural gas combusted)EFab = emission factor for MPCA-approved biomass fuel combusted based on most recent MPCA-appr..


6



COMG5 GP007 Volatile OrganicCompounds (VOC) Group

1 Volatile Organic Compounds <= 95 tons per year 12-month rolling sum.To avoid major source under40 CFR 70.2 & Minn. R.7007.0200


3

Calculate monthly Volatile Organic Compounds (VOC) emissions based material throughput of dryerand emission factors developed for each fuel combination (sawdust/RDF blend or sawdust/petroleumcoke blend) from the most recent performance test of STRU 12. If emission factors are not developedthrough performance testing the emission factors in this permit, which are based on U.S. EPA AP-42published factors, shall take precedence. Monthly facility-wide VOC emissions shall also be based onthe operating hours of the generator and appropriate emission factors for the generator (either stacktest data or U.S. EPA AP-42 emission factors).


4

For each month by the 15th of the following month calculate and record the monthly VOC emissionsusing Equation 6.

EQUATION 6:VOC emissions = EF1s(A) + EF1rdf(B) + EF1pc(C) + EF2(D) + EFng(F) + EFab(G)

EF1s = 0.0272 (EQUI 1 emission factor for sawdust; lbs VOC/ton sawdust combusted)EF1rdf = 1.5 (EQUI 1 emission factor for RDF; lbs VOC/ton combusted)EF1pc = 0.007 (EQUI 1 emission factor for petroleum coke; lbs VOC/ton combusted)EF2 = 0.11 (EQUI 2 emission factor for dryer material; lbs VOC/ton dried)EFng = 5.5 lb/mmcf (emission factor for natural gas)..


6



COMG6 GP008 Hazardous Air Pollutants(HAP) Group

1 HAPs - Single <= 9.0 tons per year 12-month rolling sum.

Title I Condition: Avoid majorsource under 40 CFR 63.2, Toavoid major source under 40CFR 70.2 & Minn. R.7007.0200

2 HAPs - Total <= 24.0 tons per year 12-month rolling sum. Title I Condition: Avoid majorsource under 40 CFR 63.2, Toavoid major source under 40CFR 70.2 & Minn. R.7007.0200

Requirements


Reconserve of Minnesota IncCOMG6 GP008 Hazardous Air Pollutants(HAP) Group

1 HAPs - Single <= 9.0 tons per year 12-month rolling sum.


2 HAPs - Total <= 24.0 tons per year 12-month rolling sum.


3 Calculate and record the 12-month Rolling Sums for each month by the 15th of the following month.


4

Calculate monthly Hazardous Air Pollutants (HAP) emissions based on fuel usage records and materialthroughput of dryer and emission factors developed for each fuel combination (sawdust/RDF blend orsawdust/petroleum coke blend) from the most recent performance test of STRU 12. If emission factorsare not developed through performance testing the emission factors in Appendix A of this permit,which are based on U.S. EPA AP-42 published factors, shall take precedence. Monthly facility-wide HAPemissions shall also be based on the operating hours of the generator and appropriate emissionfactors for the generator (either stack test data or U.S. EPA AP-42 emission factors). The largest singleHAP from natural gas combustion is formaldehyde, therefore only the formaldehyde emissions fromnatural gas combustion needs to be included as part of this calculation. The remaining HAP emissionsfrom natural gas are considered negligible.


5

For each month by the 15th of the following month calculate and record the monthly HAP emissionsusing Equation 7.

EQUATION 7:HAP emissions = EF1s(A) + EF1rdf(B) + EF1pc(C) + EF2(D) + EFng(F) + EFab(G)

EF1s = EQUI 1 emission factor for sawdust;EF1rdf = EQUI 1 emission factor for RDF;EF1pc = EQUI 1 emission factor for petroleum coke;EF2 = EQUI 2 emission factor for dryer material;EFng = .075 (emission factor for natural gas; lbs formaldehyde/mmcf natural gas)..


7Repeat equation 7 for each individual HAP to determine compliance with the single HAP limit. Sum theresults for each individual HAP to determine the facility's total HAPs emission to determinecompliance with the total HAPs limit.


8



COMG7 GP001 Indirect HeatingEquipment

1Filterable Particulate Matter <= 0.4 pounds per million Btu heat input. The potential to emit from theunit is 0.03 lb/MMBtu due to equipment design and allowable fuels. This requirement appliesindividually to each subject item in this group.

Minn. R. 7011.0515, subp. 1

2Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percentopacity. This requirement applies individually to each subject item in this group.

Minn. R. 7011.0515, subp. 2

3Sulfur Dioxide <= 4.0 pounds per million Btu heat input. The potential to emit from the unit is 3.9lb/MMBtu due to equipment design and allowable fuels. This requirement applies individually to eachsubject item in this group.

Minn. R. 7011.0515, subp. 1

7Fuels Allowed: Natural gas; sawdust from untreated wood; petroleum coke; refuse derived fuel (RDF),as defined by Minn. R. 7035.0300, subp. 91; mixed municipal solid waste (MMSW) limited to packagingmaterial, plastics and paper; and MPCA-approved biomass fuels.

Minn. R. 7011.0551, subps.1-4, Title I Condition: Avoidmajor source under 40 CFR52.21(b)(1)(i) and Minn. R.7007.3000, Title I Condition:Avoid major source under 40CFR 63.2, To avoid majorsource under 40 CFR 70.2 &Minn. R. 7007.0200

8

Refuse Derived and Mixed Municipal Solid Waste Fuel Usage: less than or equal to 30 percent byweight using a 24-hour block average. The extraneous matter fraction of the primary sawdust fuelthat is included as part of the 30% limit is provided monthly by lab analysis and is used in thesubsequent month's determination of 24-hour block averages.

40 CFR 60.1020(g)(1), Minn.R. 7011.0551, subps. 1-4

9

Fuel Usage <= 10 percent by weight of sawdust shall consist of extraneous materials, such as resins,coatings, plastics and/or laminate remnants. The sawdust composition shall be determined using amonthly analysis of a composite sample of sawdust deliveries analyzed by stereomicroscopy(following the sampling and analysis protocol) or supplier certification. The protocol defines:-sawdust delivery sampling,-sample compositing,-analysis by stereomicroscopy,-separation of bound wood and laminate, and-reportingThe percentage of extraneous material present in the composite sample shall count towards theRDF/MMSW fuel usage limit for the following month.

Minn. R. 7011.0551, subp. 1-4

10Startup Fuel Usage: During startup of EQUI 1, use natural gas to achieve chamber operatingtemperature before the addition of other fuels.

Title I Condition: Avoid majorsource under 40 CFR52.21(b)(1)(i) and Minn. R.7007.3000, Title I Condition:Avoid major source under 40CFR 63.2, To avoid majorsource under 40 CFR 70.2 &Minn. R. 7007.0200

12 Obtain and retain on site fuel supplier certifications indicating the sulfur content of each petroleumcoke delivery.


Requirements


Reconserve of Minnesota IncCOMG7 GP001 Indirect HeatingEquipment

10Startup Fuel Usage: During startup of EQUI 1, use natural gas to achieve chamber operatingtemperature before the addition of other fuels.


12Obtain and retain on site fuel supplier certifications indicating the sulfur content of each petroleumcoke delivery.


13

Recordkeeping: Keep daily records of:- weight of sawdust combusted;- weight of RDF combusted (and calculate and record the percentage of RDF in the fuel mix by weight);and- weight of petroleum coke combusted.


14Quarterly Report: due 30 days after end of each calendar quarter and containing the date, weight ofrefuse-derived fuel, and the weight of each other fuel combusted each day during the quarter.

Minn. R. 7011.0551, subp. 4

15Bypass Event Recordkeeping: Record and maintain records of the time, date, duration, cause, andcorrective action of sorbent injection and fabric filter bypass events.

Minn. R. 7007.0800, subp. 5

27

Testing shall be performed for sawdust/RDF blend and sawdust/petroleum coke blend. To the extentthat petroleum coke is not in use as a fuel at the facility at the time of the initial performance testingrequired by this permit, the Permittee shall conduct testing within 90 days of the start of petroleumcoke use. The tested emission rates will establish the emission factors to be used to calculate themonthly and 12-month rolling sum of emissions. After the initial performance testing has beencompleted, additional testing for these parameters is not required unless the Permittee wants torevise an emission factor or operating condition, or unless requested by MPCA. Total PM and opacitywhich shall be tested based on MPCA guidance and the testing frequency plan.

Minn. R. 7017.2020, subp. 1,Title I Condition: Avoid majorsource under 40 CFR52.21(b)(1)(i) and Minn. R.7007.3000, Title I Condition:Avoid major source under 40CFR 63.2, To avoid majorsource under 40 CFR 70.2 &Minn. R. 7007.0200

30

Pre-Authorized Biomass Fuel Testing Authorization: The Permittee is pre-authorized to conduct testburns of the following biomass fuels:

agricultural crops;herbs, nuts, by-products or waste;vegetable oils, by-products or waste;crop field residue or field processing by-products;shells, husks, seed, dust, screenings and other agricultural by-products;cultivated grasses or grass by-products;wood, wood waste including wood processing by-products; andleaves...

Minn. R. 7007.0800, subp.2(A)

31Biomass Test Burn Notification: 3 days prior to the start of a test burn, the Permittee shall notify theMPCA in writing that the test burn is taking place. This written notification shall include the type ofmaterial being test burned.

Minn. Stat. 116.091, Minn.Stat. 115.04, Minn. Stat.116.07, subd. 9(b)

32

Any MPCA-approved biomass fuel must be accommodated with existing equipment at the facility. In nocase does this permit authorize the Permitteee to make any physical or operational changes thatwould trigger applicability of a New Source Performance Standard, a Maximum Achievable ControlTechnology Standard or Prevention of Significant Deterioration.

40 CFR 52.21, 40 CFR pt. 60,40 CFR pt. 63

33Biomass Fuel Testing Restrictions: Test burns shall be done in accordance with an MPCA-approved testplan and limited to no more than 14 days of operation and a test period not to exceed 90 days.

Minn. R. 7007.0800, subp.2(A)

34Biomass Fuel Testing Requirements: Test burns shall be conducted to measure emissions of PM, PM10,Opacity, CO, NOx, SO2, HCl, VOCs, HAPs and other chemicals of potential interest as determined by theMPCA for the purpose of developing emission factors.

Minn. R. 7007.0800, subp.2(A)

35

Biomass Fuel Testing Submittals: 30 days prior to testing of a biomass fuel, the Permittee shall submita written performance test notification and test plan. The test plan shall:1) meet the requirements of Minn. R. 7017.2030,2) describe which above pre-authorized category the fuels to be burned are part of, and3) include the type and estimated amount of fuels to be tested; operating parameters and anticipatedfuel mixes during the test; air pollutants and other chemicals of potential interest as determined bythe MPCA that will be measured during testing; results of the MPCA-approved analysis that was usedto determine that the material to be burned does not meet the definition of a hazardous waste; and, atesting schedule.

Minn. R. 7017.2018, Minn. R.7017.2030

36

Risk Assessment Screening Analysis: When burning treated seed or materials that may result inemissions of chemicals of potential interest as determined through the MPCA-approved test plan, thePermittee shall complete a Risk Assessment Screening Analysis. The Permittee shall use the emissionfactors developed during the above testing as input data for use of the MPCA's Risk AssessmentScreening Spreadsheet available at: http://www.pca.state.mn.us/air/aera-risk.html. The Permitteemay also choose to use a more refined dispersion model for the analysis.

The results of this analysis shall be included with the test report required below.

Minn. R. 7007.0800, subp.2(B)

37

Biomass Fuel Testing Notifications and Submittals:

Performance Test Pre-Test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report: Microfiche Copy or CD: due 105 days after each Performance Test.

The Notification, Test Plan, and Test report may be submitted in alternate format as allowed by Minn.R. 7017.2018.

Minn. R. 7017.2035, subp. 1,Minn. R. 7017.2035, subp. 2,Minn. R. 7017.2030, Minn. R.7017.2018

38 Authorization to Burn Biomass Fuels Tested Below Existing Permit Limits: Within 45 days ofcompletion of the biomass fuel test, the Permittee shall submit a written test report to the MPCA thatcharacterizes emissions from the tested biomass fuel. Specifically, the report will describe whetheruse of the fuel can be accomplished while the Permittee remains under existing permit limits forcriteria and hazardous air pollutants. Upon written approval from the MPCA, and receipt of theappropriate permit amendment when necessary where there may be an increase in criteria pollutantemissions in pounds per hour, the Permittee may commence use of the tested biomass fuel. For anytested biomass fuel where compliance with existing permit limits cannot be demonstrated during itsuse, the Permittee may not use such a fuel until it has complied with the permit amendmentrequirements in Minn. R. 7007.1150 through 7007.1500.

Minn. R. 7007.0800, subp.2(A)

Requirements


Reconserve of Minnesota IncCOMG7 GP001 Indirect HeatingEquipment

37

Biomass Fuel Testing Notifications and Submittals:

Performance Test Pre-Test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report: Microfiche Copy or CD: due 105 days after each Performance Test.

The Notification, Test Plan, and Test report may be submitted in alternate format as allowed by Minn.R. 7017.2018.

Minn. R. 7017.2035, subp. 1,Minn. R. 7017.2035, subp. 2,Minn. R. 7017.2030, Minn. R.7017.2018

38

Authorization to Burn Biomass Fuels Tested Below Existing Permit Limits: Within 45 days ofcompletion of the biomass fuel test, the Permittee shall submit a written test report to the MPCA thatcharacterizes emissions from the tested biomass fuel. Specifically, the report will describe whetheruse of the fuel can be accomplished while the Permittee remains under existing permit limits forcriteria and hazardous air pollutants. Upon written approval from the MPCA, and receipt of theappropriate permit amendment when necessary where there may be an increase in criteria pollutantemissions in pounds per hour, the Permittee may commence use of the tested biomass fuel. For anytested biomass fuel where compliance with existing permit limits cannot be demonstrated during itsuse, the Permittee may not use such a fuel until it has complied with the permit amendmentrequirements in Minn. R. 7007.1150 through 7007.1500.

Minn. R. 7007.0800, subp.2(A)

39

Sawdust and Wood by-products where stated in this permit shall meet the definition of CleanCellulosic Biomass as defined at 40 CFR Section 241.2.Clean cellulosic biomass means those residuals that are akin to traditional cellulosic biomass such asforest-derived biomass (e.g., green wood, forest thinnings, clean and unadultered bark, sawdust, trim,and tree harvesting residuals from logging and sawmill materials), corn stover and other biomasscrops used specifically for energy production (e.g., energy cane, other fast growing grasses), bagasseand other crop residues (e.g., peanut shells), wood collected from forest fire clearance activities, treesand clean wood found in disaster debris, clean biomass from land clearing operations, and cleanconstruction and demolition wood. These fuels are not secondary materials or solid wastes unlessdiscarded. Clean biomass is biomass that does not contain contaminants at concentrations notnormally associated with virgin biomass materials.

40 CFR 241.2, Minn. R.7007.0800, subp. 2(A)

COMG8 GP009 Material Handling 3680 Opacity <= 20 percent opacity.Minn. R. 7011.0715, subp.1(B)

3690Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to furtherreduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R.7011.0735.

Minn. R. 7011.0715, subp.1(A)

COMG11 GP005 Particulate Matter < 10Micron (PM10) Group

1 PM < 10 micron <= 95 tons per year 12-month rolling sum.To avoid major source under40 CFR 70.2 & Minn. R.7007.0200


3

Calculate monthly PM < 10 micron (PM10) emissions based on fuel usage records and materialthroughput data and emission factors developed for each fuel combination (sawdust/RDF blend orsawdust/petroleum coke blend) from the most recent performance test of STRU 12. If emission factorsare not developed through performance testing the emission factors in this permit, which are based onU.S. EPA AP-42 published factors, shall take precedence. Monthly facility-wide PM10 emissions shallalso be based on the operating hours of the generator and appropriate emission factors for thegenerator (either stack test data or U.S. EPA AP-42 emission factors with application of applicablepollution control efficiencies). The PM10 emissions shall also include material handling and be basedon emission factors and monthly throughput for the material handling processes. In addition, thefacility-wide cap must include PM10 emissions from natural gas combustion.


4

For each month by the 15th of the following month calculate and record the monthly PM10 emissionsusing Equation 4.

EQUATION 4:PM10 emissions = EF1s(A) + EF1rdf(B) + EF1pc(C) + EF2(D) + EF3(E) + EF4(F) + EF5(G) + EF8(I) + EF9(J)+ EFng(K) + EFpl(L) + EFab(M) + 0.3

EF1s = 0.29 (EQUI 1 emission factor (EF) for sawdust; lbs PM10/ton sawdust burned)EF1rdf = 0.365 (EQUI 1 EF for RDF; lbs PM10/ton burned)EF1pc = 0.22 (EQUI 1 EF for petroleum coke; lbs PM10/ton burned)EF2 = 0.018 (EQUI 2 EF for dryer material; lbs PM10/ton dried)..


8



COMG12 GP012 Particulate Matter < 2.5Micron (PM2.5) Group

1 PM < 2.5 micron <= 95 tons per year 12-month rolling sum.To avoid major source under40 CFR 70.2 & Minn. R.7007.0200

2 Calculate and record the 12-month Rolling Sums for each month by the 15th of the following month.To avoid major source under40 CFR 70.2 & Minn. R.7007.0200

3

Calculate monthly PM < 2.5 micron (PM2.5) emissions based on fuel usage records and materialthroughput data and emission factors developed for each fuel combination (sawdust/RDF blend orsawdust/petroleum coke blend) from the most recent performance test of STRU 12. If emission factorsare not developed through performance testing the emission factors in this permit, which are based onU.S. EPA AP-42 published factors, shall take precedence. Monthly facility-wide PM2.5 emissions shallalso be based on the operating hours of the generator and appropriate emission factors for thegenerator (either stack test data or U.S. EPA AP-42 emission factors with application of applicablepollution control efficiencies). The PM2.5 emissions shall also include material handling and be basedon emission factors and monthly throughput for the material handling processes. In addition, thefacility-wide cap must include PM2.5 emissions from natural gas combustion.


4

For each month by the 15th of the following month calculate and record the monthly PM2.5 emissionsusing Equation 8.

EQUATION 8:PM2.5 emissions = EF1s(A) + EF1rdf(B) + EF1pc(C) + EF2(D) + EF3(E) + EF4(F) + EF5(G) + EF8(I) +EF9(J) + EFng(K) + EFpl(L) + EFab(M) + 0.083

EF1s = 0.25 (EQUI 1 emission factor (EF) for sawdust; lbs PM2.5/ton sawdust burned)EF1rdf = 0.365 (EQUI 1 EF for RDF; lbs PM2.5/ton burned)EF1pc = 0.0015 (EQUI 1 EF for petroleum coke; lbs PM2.5/ton burned)EF2 = 0.0026 (EQUI 2 EF for dryer material; lbs PM2.5/ton dried)..


8 Revision of Equation 8 Emission Factors: Equation 8 emission factors shall be revised for units that aretested based on the results of each performance test. The most recent performance test for eachpollutant shall be used to develop emission factors. The use of the updated emission factor shallcommence upon receipt of written MPCA notification that the performance test results were valid. Forthe interim period prior to receipt of written MPCA notification after the first performance test, usethe factors defined above for Equation 8 in this permit.


Requirements


Reconserve of Minnesota IncCOMG12 GP012 Particulate Matter < 2.5Micron (PM2.5) Group

4

For each month by the 15th of the following month calculate and record the monthly PM2.5 emissionsusing Equation 8.

EQUATION 8:PM2.5 emissions = EF1s(A) + EF1rdf(B) + EF1pc(C) + EF2(D) + EF3(E) + EF4(F) + EF5(G) + EF8(I) +EF9(J) + EFng(K) + EFpl(L) + EFab(M) + 0.083

EF1s = 0.25 (EQUI 1 emission factor (EF) for sawdust; lbs PM2.5/ton sawdust burned)EF1rdf = 0.365 (EQUI 1 EF for RDF; lbs PM2.5/ton burned)EF1pc = 0.0015 (EQUI 1 EF for petroleum coke; lbs PM2.5/ton burned)EF2 = 0.0026 (EQUI 2 EF for dryer material; lbs PM2.5/ton dried)..


8



EQUI1 EU011 Solid Fuel Burner w/Natural Gas-FiredStartup

20020The Permittee shall vent emissions from EQUI 1 to control equipment meeting the requirements ofTREA 13, TREA 14 and TREA 15 whenever EQUI 1 operates.


20021

HCl: The Permittee shall conduct a performance test due before 04/17/2022 and every 60 monthsthereafter to measure emissions.

The first test is due by the date specified above and all subsequent tests shall be completed every 60months thereafter by the due date (month and day) and as described below. The performance testshall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operatingconditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 5 and 202, or othermethod approved by MPCA in the performance test plan approval.

Testing conducted during the 60 days prior to the performance test due date will not reset the testdue date for future testing as required by this permit or within a Notice of Compliance letter...


20030

PM < 10 micron: The Permittee shall conduct a performance test due before 04/17/2022 and every 60months thereafter to measure emissions.

The first test is due by the date specified above and all subsequent tests shall be completed every 60months thereafter by the due date (month and day) and as described below. The performance testshall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operatingconditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, orother method approved by MPCA in the performance test plan approval.


Minn. R. 7017.2020, subp. 1,To avoid major source under40 CFR 70.2 & Minn. R.7007.0200

20040

PM < 2.5 micron: The Permittee shall conduct a performance test due before 04/17/2022 and every 60months thereafter to measure emissions.

The first test is due by the date specified above and all subsequent tests shall be completed every 60months thereafter by the due date (month and day) and as described below. The performance testshall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operatingconditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, orother method approved by MPCA in the performance test plan approval.



20045

Particulate Matter: The Permittee shall conduct a performance test due before 04/17/2022 and every60 months thereafter to measure emissions.

The first test is due by the date specified above and all subsequent tests shall be completed every 60months thereafter by the due date (month and day) and as described below. The performance testshall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operatingconditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 5 and 202, or othermethod approved by MPCA in the performance test plan approval.



20050

Opacity: The Permittee shall conduct a performance test due before 04/17/2022 and every 60 monthsthereafter to measure opacity.

The first test is due by the date specified above and all subsequent tests shall be completed every 60months thereafter by the due date (month and day) and as described below. The performance testshall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operatingconditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 9, or other methodapproved by MPCA in the performance test plan approval.


Minn. R. 7017.2020, subp. 1

20060

Carbon Monoxide: The Permittee shall conduct a performance test due before 04/17/2022 and every60 months thereafter to measure emissions.

The first test is due by the date specified above and all subsequent tests shall be completed every 60months thereafter by the due date (month and day) and as described below. The performance testshall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operatingconditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 10, or othermethod approved by MPCA in the performance test plan approval.



20070

Nitrogen Oxides: The Permittee shall conduct a performance test due before 04/17/2022 and every 60months thereafter to measure emissions.

The first test is due by the date specified above and all subsequent tests shall be completed every 60months thereafter by the due date (month and day) and as described below. The performance testshall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operatingconditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 7E, or othermethod approved by MPCA in the performance test plan approval.


Minn. R. 7017.2020, subp. 1,Title I Condition: Avoid majorsource under 40 CFR52.21(b)(1)(i) and Minn. R.7007.3000, To avoid majorsource under 40 CFR 70.2 &Minn. R. 7007.0200

20080

Sulfur Dioxide: The Permittee shall conduct a performance test due before 04/17/2022 and every 60months thereafter to measure emissions.

The first test is due by the date specified above and all subsequent tests shall be completed every 60months thereafter by the due date (month and day) and as described below. The performance testshall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operatingconditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 6C, or othermethod approved by MPCA in the performance test plan approval.


Minn. R. 7017.2020, subp. 1,Title I Condition: Avoid majorsource under 40 CFR52.21(b)(1)(i) and Minn. R.7007.3000, To avoid majorsource under 40 CFR 70.2 &Minn. R. 7007.0200

21260

Volatile Organic Compounds: The Permittee shall conduct a performance test due before 04/17/2022and every 60 months thereafter to measure emissions.

The first test is due by the date specified above and all subsequent tests shall be completed every 60months thereafter by the due date (month and day) and as described below. The performance testshall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operatingconditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 25A, or othermethod approved by MPCA in the performance test plan approval.



21261

HAPs - Total: The Permittee shall conduct a performance test due before 04/17/2022 and every 60months thereafter to measure emissions. (Method 18 targeted to quantify as many of the following asfeasible: aldehydes (including acrolein, benzaldehyde, crotonaldehyde and gluteraldehyde), organicacids (including formic and acetic acid), nitrosamines, acrylamide and acrylonitrile).

The first test is due by the date specified above and all subsequent tests shall be completed every 60months thereafter by the due date (month and day) and as described below. The performance testshall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operatingconditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 18, 320, or othermethod approved by MPCA in the performance test plan approval...

Minn. R. 7017.2020, subp. 1,Title I Condition: Avoid majorsource under 40 CFR 63.2, Toavoid major source under 40CFR 70.2 & Minn. R.7007.0200

EQUI2 EU012 Rotary Kiln Dryer 20020The Permittee shall vent emissions from EQUI 2 to control equipment meeting the requirements ofTREA 8, TREA 13, TREA 14 and TREA 15 whenever EQUI 2 operates.


EQUI3 EU014 Post Dryer MaterialsHandling

20020 The Permittee shall vent emissions from EQUI 3 to control equipment meeting the requirements ofTREA 9 whenever EQUI 3 operates.


Requirements


Reconserve of Minnesota IncEQUI2 EU012 Rotary Kiln Dryer 20020

The Permittee shall vent emissions from EQUI 2 to control equipment meeting the requirements ofTREA 8, TREA 13, TREA 14 and TREA 15 whenever EQUI 2 operates.



20020The Permittee shall vent emissions from EQUI 3 to control equipment meeting the requirements ofTREA 9 whenever EQUI 3 operates.





EQUI14 EU013Sawdust/WoodBy-products Storage andHandling



EQUI16 EU018Raw Material andSawdust/WoodBy-products Storage



FUGI1 FS004 Shipping (loadout) 3680 Opacity <= 20 percent opacity.Minn. R. 7011.0715, subp.1(B)


Minn. R. 7011.0715, subp.1(A)

FUGI3 FS002 Paved Roads 2910 Opacity <= 20 percent opacity. Minn. R. 7011.0110

3200

The Permittee shall minimize or eliminate fugitive emissions from all paved surfaces. If fugitiveemissions from paved surfaces are observed, the Permittee shall record the date that fugitive dustwas observed, what corrective actions were taken, when the corrective actions were taken, andwhether the corrective actions eliminated the fugitive dust.

Minn. R. 7007.0800, subp.2(A), Minn. R. 7011.0150

3330 The facility shall take reasonable measure to prevent particulate matter from becoming airborne.Minn. R. 7007.0800, subp.2(A), Minn. R. 7011.0150

FUGI4 FS003 Pet Coke Receiving 3680 Opacity <= 20 percent opacity.Minn. R. 7011.0715, subp.1(B)


Minn. R. 7011.0715, subp.1(A)

TFAC3 03700280 ReConserve ofMinnesota Inc

1240

Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. ThePermittee shall comply with all requirements contained in Appendix A - Emission Factors ForHazardous Air Pollutants, Appendix B - Standard Operating Procedure for Composite SawdustSampling, Appendix C - Standard Operating Procedure for Composite Sawdust Analysis, and AppendixD - Manufacturer's Recommendations for Perlite Injection.

Minn. R. 7007.0800, subp.2(A) & (B)

1250

Daily record and for each month by the 15th of the following month calculate and record:

1) Tons of sawdust burned in EQUI 1;2) Tons of RDF burned in EQUI 1;3) Tons of petroleum coke burned in EQUI 1;4) MMCF natural gas burned facility-wide;5) Amount of raw product received and dried;6) Amount of sawdust or other wood by-products received and dried;7) Amount of sawdust, wood by-products, and raw materials conveyed to storage;8) Amount of petroleum coke received and its sulfur content; and9) Amount of other MPCA-approved biomass fuel burned...


1260 PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions ofthis permit shall be deemed compliance with the specific provision of the applicable requirementidentified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practicesfor applicable requirements, any person (including the Permittee) may also use other credible evidenceto establish compliance or noncompliance with applicable requirements.

This permit shall not alter or affect 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)

Requirements


Reconserve of Minnesota IncTFAC3 03700280 ReConserve ofMinnesota Inc

1250

Daily record and for each month by the 15th of the following month calculate and record:

1) Tons of sawdust burned in EQUI 1;2) Tons of RDF burned in EQUI 1;3) Tons of petroleum coke burned in EQUI 1;4) MMCF natural gas burned facility-wide;5) Amount of raw product received and dried;6) Amount of sawdust or other wood by-products received and dried;7) Amount of sawdust, wood by-products, and raw materials conveyed to storage;8) Amount of petroleum coke received and its sulfur content; and9) Amount of other MPCA-approved biomass fuel burned...


1260

PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions ofthis permit shall be deemed compliance with the specific provision of the applicable requirementidentified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practicesfor applicable requirements, any person (including the Permittee) may also use other credible evidenceto establish compliance or noncompliance with applicable requirements.

This permit shall not alter or affect 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)

1261

Keep on site and implement a written training procedure for all dryer system operators. This trainingwill cover all aspects of dryer operation and include training regarding start-up and shut-down ofequipment and the environmental requirements applicable to dryer equipment. All dryer operatorsmust comply with the written training procedure. This is a state only requirement and not enforceableby the EPA or citizens under the Clean Air Act.

Minn. R. 7007.0800, subp.2(A)

1262

Ash Testing: Conduct ash sampling at least quarterly in accordance with Minn. R.7035.2910 to form anannual composite sample. The Permittee shall analyze the annual composite sample in accordancewith Minn. R. 7035.2910, subp. 4, item A, tables 1 and 2. This is a state only requirement and notenforceable by EPA or citizens under the Clear Air Act.

Minn. R. 7035.2910, subp. 3

1380Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which wouldotherwise violate a federal or state air pollution control rule, without reducing the total amount ofpollutant emitted.

Minn. R. 7011.0020

1390Air Pollution Control Equipment: Operate all pollution control equipment whenever the correspondingprocess equipment and emission units are operated.

Minn. R. 7007.0800, subp.16(J), Minn. R. 7007.0800,subp. 2(A) & (B)

1400

Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance planfor all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollutioncontrol equipment and control practices and shall include a preventative maintenance program for theequipment and practices, a description of (the minimum but not necessarily the only) correctiveactions to be taken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for proper operation andmaintenance of the control equipment and practices, and the records kept to demonstrate planimplementation.

Minn. R. 7007.0800, subp. 14,Minn. R. 7007.0800, subp.16(J)

1410

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately takeall practical steps to modify operations to reduce the emission of any regulated air pollutant. TheCommissioner may require feasible and practical modifications in the operation to reduce emissions ofair pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency ofprocess or control equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4

1420Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any materialin a manner which may allow avoidable amounts of particulate matter to become airborne. Complywith all other requirements listed in Minn. R. 7011.0150.

Minn. R. 7011.0150

1430Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to7030.0080 at all times during the operation of any emission units. This is a state only requirement andis not enforceable by the EPA Administrator or citizens under the Clean Air Act.

Minn. R.7030.0010-7030.0080

1440Inspections: The Permittee shall comply with the inspection procedures and requirements as found inMinn. R. 7007.0800, subp. 9(A).

Minn. R. 7007.0800, subp.9(A)

1450 The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. Minn. R. 7007.0800, subp. 16

1460Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unlessotherwise noted in this permit.

Minn. R. ch. 7017

1470

Performance Test Notifications and Submittals:

Performance Test Notification and Plan: due 30 days before each Performance TestPerformance Test Pre-test Meeting: due seven days before each Performance TestPerformance Test Report: due 45 days after each Performance Test

The Notification, Test Plan, and Test Report must be submitted in a format specified by thecommissioner.

Minn. R. 7017.2017, Minn. R.7017.2030, subps. 1-4, Minn.R. 7017.2035, subps. 1-2

1480 Limits set as a result of a performance test (conducted before or after permit issuance) apply untilsuperseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval.Preliminary approval is based on formal review of a subsequent performance test on the same unit asspecified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendmentincorporating the change.

Minn. R. 7017.2025, subp. 3

Requirements



1470

Performance Test Notifications and Submittals:

Performance Test Notification and Plan: due 30 days before each Performance TestPerformance Test Pre-test Meeting: due seven days before each Performance TestPerformance Test Report: due 45 days after each Performance Test

The Notification, Test Plan, and Test Report must be submitted in a format specified by thecommissioner.

Minn. R. 7017.2017, Minn. R.7017.2030, subps. 1-4, Minn.R. 7017.2035, subps. 1-2

1480

Limits set as a result of a performance test (conducted before or after permit issuance) apply untilsuperseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval.Preliminary approval is based on formal review of a subsequent performance test on the same unit asspecified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendmentincorporating the change.

Minn. R. 7017.2025, subp. 3

1490

Monitoring Equipment Calibration - The Permittee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; or2. Calibrate at the 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 shall include the calibrationfrequencies, procedures, and manufacturer's specifications (if applicable) in the Operations andMaintenance Plan. Any requirements applying to continuous emission monitors are listed separatelyin this permit.

Minn. R. 7007.0800, subp.4(D)

1500

Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process orcontrol equipment connected to that process is not necessary during periods when the process isshutdown, or during checks of the monitoring systems, such as calibration checks and zero and spanadjustments. If monitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp.4(D)

1510

Recordkeeping: Retain all records at the stationary source, unless otherwise specified within thispermit, for five (5) years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, all originalrecordings for continuous monitoring instrumentation, and copies of all reports required by thepermit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A).

Minn. R. 7007.0800, subp.5(C)

1520Recordkeeping: 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)

1530

If the Permittee determines that no permit amendment or notification is required prior to making achange, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. Fornon-expiring permits, these records shall be kept for a period of five years from the date that thechange was made. The records shall be kept at the stationary source for the current calendar year ofoperation and may be kept at the stationary source or office of the stationary source for all otheryears. The records may be maintained in either electronic or paper format.

Minn. R. 7007.1200, subp. 4

1610

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdownof any control equipment or process equipment if the shutdown would cause any increase in theemissions of any regulated air pollutant. If the owner or operator does not have advance knowledge ofthe 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 theshutdown and the estimated duration. The owner or operator shall notify the Commissioner when theshutdown is over.

Minn. R. 7019.1000, subp. 3

1620

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than onehour duration of any control equipment or process equipment if the breakdown causes any increase inthe emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown wasdiscovered or reasonably should have been discovered by the owner or operator. However, notificationis 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 theCommissioner of the cause of the breakdown and the estimated duration. The owner or operator shallnotify the Commissioner when the breakdown is over.

Minn. R. 7019.1000, subp. 2

1630Notification of Deviations Endangering Human Health or the Environment: As soon as possible afterdiscovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of anydeviation from permit conditions which could endanger human health or the environment.

Minn. R. 7019.1000, subp. 1

1640

Notification of Deviations Endangering Human Health or the Environment Report: Within two workingdays of discovery, notify the Commissioner in writing of any deviation from permit conditions whichcould endanger human health or the environment. Include the following information in this writtendescription: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; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation.

Minn. R. 7019.1000, subp. 1

1650

The Permittee must submit a semiannual deviations report : Due semiannually, by the 30th of Januaryand July. The first semiannual report submitted by the Permittee must cover the calendar half-year inwhich the permit is issued. The first report of each calendar year covers January 1 - June 30. Thesecond report of each calendar year covers July 1 - December 31. Submit this on form DRF-2 (DeviationReporting Form). If no deviations have occurred, submit the signed report certifying that there wereno deviations.

Minn. R. 7007.0800, subp.6(B)(2)

1670

Application for Permit Amendment: If a permit amendment is needed, submit an application inaccordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal datesvary, depending on the type of amendment needed.

Upon adoption of a new or amended federal applicable requirement, and if there are three or moreyears remaining in the permit term, the Permittee shall file an application for an amendment withinnine 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 -7007.1500

1680

Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadlinein a permit by no more than 120 days, provided the proposed deadline extension meets therequirements 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 the MPCA does not haveauthority 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)

1700 The Permittee must submit a compliance certification : Due annually, by the 31st of January (for theprevious calendar year). Submit this on form CR-04 (Annual Compliance Certification Report). Thisreport covers all deviations experienced during the calendar year. If no deviations have occurred,submit the signed report certifying that there were no deviations.

Minn. R. 7007.0800, subp.6(D)

Requirements



1680

Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadlinein a permit by no more than 120 days, provided the proposed deadline extension meets therequirements 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 the MPCA does not haveauthority 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)

1700

The Permittee must submit a compliance certification : Due annually, by the 31st of January (for theprevious calendar year). Submit this on form CR-04 (Annual Compliance Certification Report). Thisreport covers all deviations experienced during the calendar year. If no deviations have occurred,submit the signed report certifying that there were no deviations.

Minn. R. 7007.0800, subp.6(D)

1703Within 15 days of a request from the Commissioner, the Permittee must provide a complete summaryof all performance tests required at the facility including the subject item, pollutant, most recent testdate (if applicable), and the date of the next test in an approved format.

Minn. R. 7007.0800, subp.16(L)

1730Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance.Submit in a format specified by the Commissioner.

Minn. R.7019.3000-7019.3100

1740 Emission Fees: due 30 days after receipt of an MPCA bill.Minn. R.7002.0005-7002.0085

TREA8 CE012 Centrifugal Collector -High Efficiency

17610

The Permittee shall vent emissions from EQUI 2 to control equipment meeting the requirements ofTREA 8 whenever EQUI 2 operates, and operate and maintain TREA 8 at all times that any emissionsare vented to TREA 8. The Permittee shall document periods of non-operation of the control equipmentTREA 8 whenever EQUI 2 is operating.


17615

If the Permittee replaces TREA 8, the replacement control must meet or exceed the control efficiencyrequirements of TREA 8 as well as comply with all other requirements of TREA 8. Prior to making sucha change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable.

If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to theAgency using Form CR-05. The notice must be received by the Agency seven working days prior to thecommencement/start of replacement.


18480The Permittee shall operate and maintain control equipment such that it achieves a control efficiencyfor Particulate Matter >= 50 percent control efficiency.


18490The Permittee shall operate and maintain control equipment such that it achieves a control efficiencyfor PM < 10 micron >= 50 percent control efficiency.


18500The Permittee shall operate and maintain control equipment such that it achieves a control efficiencyfor PM < 2.5 micron >= 50 percent control efficiency.


18501

Pressure Drop >= 1.5 and <= 5.0 inches of water, unless a new range is set pursuant to Minn. R.7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performancetest where compliance was demonstrated. The new range shall be implemented upon receipt of theNotice of Compliance letter granting preliminary approval. The range is final upon issuance of a permitamendment incorporating the change.

If the recorded pressure drop is outside the required range, the emissions during that time shall beconsidered uncontrolled until the pressure drop is once again within the required range. The period oftime for which the pressure drop is considered out of range shall be reported as a deviation. ThePermittee shall record the pressure drop at least once every 24 hours when in operation.


18502 Check the pressure drop once every 24 hours when in operation.Minn. R. 7007.0800, subp. 14,Minn. R. 7007.0800, subp.2(A)

18510The Permittee shall operate and maintain the fabric filter in accordance with the Operation andMaintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use bystaff and MPCA staff.

Minn. R. 7007.0800, subp. 14

18520Visible Emissions: The Permittee shall check the cyclone stack, STRU 12, for any visible emissions onceeach day of operation during daylight hours. During inclement weather, the Permittee shall read andrecord the pressure drop across the fabric filter, once each day of operation.

Minn. R. 7007.0800, subps.4-5, To avoid major sourceunder 40 CFR 70.2 & Minn. R.7007.0200

18540 Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date ofeach visible emission inspection and pressure drop reading, and whether or not any visible emissionswere observed, and whether or not the observed pressure drop was within the range specified in thispermit.


Requirements


Reconserve of Minnesota IncTREA8 CE012 Centrifugal Collector -High Efficiency

18520

Visible Emissions: The Permittee shall check the cyclone stack, STRU 12, for any visible emissions onceeach day of operation during daylight hours. During inclement weather, the Permittee shall read andrecord the pressure drop across the fabric filter, once each day of operation.


18540

Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date ofeach visible emission inspection and pressure drop reading, and whether or not any visible emissionswere observed, and whether or not the observed pressure drop was within the range specified in thispermit.


18550

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of thefollowing occur:- visible emissions are observed;- the recorded pressure drop is outside the required operating range; or- the fabric filter or any of its components are found during the inspections to need repair.Corrective actions shall return the pressure drop to within the permitted range, eliminate visibleemissions, and/or include completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for thefabric filter. The Permittee shall keep a record of the type and date of any corrective action taken foreach filter.

Minn. R. 7007.0800, subp. 14,Minn. R. 7007.0800, subp.2(A), Minn. R. 7007.0800,subp. 5

18560Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipmentfor measuring and recording pressure drop as required by this permit. The monitoring equipment mustbe installed, in use, and properly maintained when the monitored fabric filter is in operation.

Minn. R. 7007.0800, subp. 4

18565The Permittee shall calibrate or replace the pressure drop monitor at least once every 12 months andshall maintain a written record of any action resulting from the calibration.

Minn. R. 7007.0800, subp. 14,Minn. R. 7007.0800, subp. 4,Minn. R. 7007.0800, subp. 5

18570Periodic Inspections: At least once per calendar quarter, or more frequently as required by themanufacturing specifications, the Permittee shall inspect the control equipment components. ThePermittee shall maintain a written record of these inspections.


TREA9 CE013 Centrifugal Collector -High Efficiency

17610

The Permittee shall vent emissions from EQUI 3 to control equipment meeting the requirements ofTREA 9 whenever EQUI 3 operates, and operate and maintain TREA 9 at all times that any emissionsare vented to TREA 9. The Permittee shall document periods of non-operation of the control equipmentTREA 9 whenever EQUI 3 is operating.


17615

If the Permittee replaces TREA 9, the replacement control must meet or exceed the control efficiencyrequirements of TREA 9 as well as comply with all other requirements of TREA 9. Prior to making sucha change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable.









18501






Minn. R. 7007.0800, subp. 14

18520 Visible Emissions: The Permittee shall check the cyclone stack, STRU 12, for any visible emissions onceeach day of operation during daylight hours. During inclement weather, the Permittee shall read andrecord the pressure drop across the fabric filter, once each day of operation.


Requirements


Reconserve of Minnesota IncTREA9 CE013 Centrifugal Collector -High Efficiency

18510

The Permittee shall operate and maintain the fabric filter in accordance with the Operation andMaintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use bystaff and MPCA staff. Minn. R. 7007.0800, subp. 14

18520Visible Emissions: The Permittee shall check the cyclone stack, STRU 12, for any visible emissions onceeach day of operation during daylight hours. During inclement weather, the Permittee shall read andrecord the pressure drop across the fabric filter, once each day of operation.


18540



18550




Minn. R. 7007.0800, subp. 4





TREA10 CE014 Fabric Filter - LowTemperature, i.e., T<180Degrees F

17610

The Permittee shall vent emissions from EQUI 4 to control equipment meeting the requirements ofTREA 10 whenever EQUI 4 operates, and operate and maintain TREA 10 at all times that any emissionsare vented to TREA 10. The Permittee shall document periods of non-operation of the controlequipment TREA 10 whenever EQUI 4 is operating.


17615

If the Permittee replaces TREA 10, the replacement control must meet or exceed the control efficiencyrequirements of TREA 10, as well as comply with all other requirements of TREA 10. Prior to makingsuch a change, the Permittee shall apply for and obtain the appropriate permit amendment, asapplicable.









18501





18510 The Permittee shall operate and maintain the fabric filter in accordance with the Operation andMaintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use bystaff and MPCA staff.

Minn. R. 7007.0800, subp. 14

Requirements


Reconserve of Minnesota IncTREA10 CE014 Fabric Filter - LowTemperature, i.e., T<180Degrees F

18502 Check the pressure drop once every 24 hours when in operation.

Minn. R. 7007.0800, subp. 14,Minn. R. 7007.0800, subp.2(A)


Minn. R. 7007.0800, subp. 14

18520Visible Emissions: The Permittee shall check STRU 14 for any visible emissions once each day ofoperation during daylight hours. During inclement weather, the Permittee shall read and record thepressure drop across the fabric filter, once each day of operation.


18530

Pressure Drop: Recordkeeping. The Permittee shall record the time and date of each pressure dropreading and whether or not the recorded pressure drop was within the range specified in this permit.The Permittee shall read and record the pressure drop across the fabric filter, once each day ofoperation.

Minn. R. 7007.0800, subps.4-5

18540



18550




Minn. R. 7007.0800, subp. 4






17610

The Permittee shall vent emissions from EQUI 14 to control equipment meeting the requirements ofTREA 11 whenever EQUI 14 operates, and operate and maintain TREA 11 at all times that anyemissions are vented to TREA 11. The Permittee shall document periods of non-operation of thecontrol equipment TREA 11 whenever EQUI 14 is operating.


17615

If the Permittee replaces TREA 11, the replacement control must meet or exceed the control efficiencyrequirements of TREA 11 as well as comply with all other requirements of TREA 11. Prior to makingsuch a change, the Permittee shall apply for and obtain the appropriate permit amendment, asapplicable.









18501 Pressure Drop >= 3.5 and <= 6.5 inches of water, unless a new range is set pursuant to Minn. R.7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performancetest where compliance was demonstrated. The new range shall be implemented upon receipt of theNotice of Compliance letter granting preliminary approval. The range is final upon issuance of a permitamendment incorporating the change.



Requirements





18501






Minn. R. 7007.0800, subp. 14



18530


Minn. R. 7007.0800, subps.4-5

18540



18550




Minn. R. 7007.0800, subp. 4






17610

The Permittee shall vent emissions from EQUI 15 to control equipment meeting the requirements ofTREA 12 whenever EQUI 15 operates, and operate and maintain TREA 12 at all times that anyemissions are vented to TREA 12. The Permittee shall document periods of non-operation of thecontrol equipment TREA 12 whenever EQUI 15 is operating.


17615






18490 The Permittee shall operate and maintain control equipment such that it achieves a control efficiencyfor PM < 10 micron >= 93 percent control efficiency.


Requirements









18501






Minn. R. 7007.0800, subp. 14



18530


Minn. R. 7007.0800, subps.4-5

18540



18550




Minn. R. 7007.0800, subp. 4





TREA13 CE017 Fabric Filter - HighTemperature, i.e., T>250Degrees F

17610

The Permittee shall vent emissions from EQUI 1 and EQUI 2 to control equipment meeting therequirements of TREA 13 whenever EQUI 1 or EQUI 2 operates, and operate and maintain TREA 13 atall times that any emissions are vented to TREA 13. The Permittee shall document periods ofnon-operation of the control equipment TREA 13 whenever EQUI 1 or EQUI 2 is operating.


17615 If the Permittee replaces TREA 13, the replacement control must meet or exceed the control efficiencyrequirements of TREA 13 as well as comply with all other requirements of TREA 13. Prior to makingsuch a change, the Permittee shall apply for and obtain the appropriate permit amendment, asapplicable.



Requirements


Reconserve of Minnesota IncTREA13 CE017 Fabric Filter - HighTemperature, i.e., T>250Degrees F

17610

The Permittee shall vent emissions from EQUI 1 and EQUI 2 to control equipment meeting therequirements of TREA 13 whenever EQUI 1 or EQUI 2 operates, and operate and maintain TREA 13 atall times that any emissions are vented to TREA 13. The Permittee shall document periods ofnon-operation of the control equipment TREA 13 whenever EQUI 1 or EQUI 2 is operating.


17615










18501






Minn. R. 7007.0800, subp. 14



18530


Minn. R. 7007.0800, subps.4-5

18540



18550




Minn. R. 7007.0800, subp. 4



18570 Periodic Inspections: At least once per calendar quarter, or more frequently as required by themanufacturing specifications, the Permittee shall inspect the control equipment components. ThePermittee shall maintain a written record of these inspections.


Requirements


Reconserve of Minnesota IncTREA13 CE017 Fabric Filter - HighTemperature, i.e., T>250Degrees F





TREA14 CE018 Dry Sorbent Injection 1

The Permittee shall vent emissions from EQUI 1 and EQUI 2 to TREA 14 whenever EQUI 1 or EQUI 2operates, and operate and maintain TREA 14 at all times that any emissions are vented to TREA 14.The Permittee shall document periods of non-operation of the control equipment TREA 14 wheneverEQUI 1 or EQUI 2 is operating.


2




3

Trona Injection Rate: greater than or equal to 35.9 lbs/hr using a 3-Hour Rolling Average. Down time of15 or more minutes is not to be included as operating time

A new value may be set pursuant to Minn. R. 7017.2025, subp. 3, based on the value recorded duringthe most recent MPCA approved performance test where compliance was demonstrated. The type ofsorbent injection used shall remain consistent with the sorbent used for the most recent performancetest. The sorbent type may be changed if a new performance test is conducted within 90 days afterswitching to the new sorbent.

Minn. R. 7007.0800, subp. 14,Minn. R. 7007.0800, subp.2(A), Title I Condition: Avoidmajor source under 40 CFR52.21(b)(1)(i) and Minn. R.7007.3000, Title I Condition:Avoid major source under 40CFR 63.2, To avoid majorsource under 40 CFR 70.2 &Minn. R. 7007.0200

4

The sorbent injection rate shall be monitored using a weigh belt, weigh hopper, or hopper flowmeasurement device located in a position that provides a representative measurement of the totalsorbent injection rate. The monitor(s) shall be installed, calibrated and operated in accordance withthe manufacturer's specifications. Monitoring is required immediately upon each startup of TREA 14.

Minn. R. 7007.0800, subp. 4

5

Continuously collect the sorbent injection rate monitoring system data and reduce the data to 3-hourRolling Averages. Use all recorded readings except during monitoring malfunctions, associatedrepairs, out of control periods, or required quality assurance or control activities. Use all the datacollected during all other periods in assessing compliance. Any period for which the monitoring systemis out-of-control and data are not available for required calculations constitute a deviation from themonitoring requirement. Data collection to commence immediately upon each startup of TREA 14.

Minn. R. 7007.0800, subp. 4,Minn. R. 7007.0800, subp. 5

6Quarterly Inspections: At least once per calendar quarter, or more frequently as required by themanufacturing specifications, inspect the control equipment components. Maintain a written recordof these inspections.


7

Corrective Actions: If the sorbent injection rate is below the minimum specified by this permit or if thesorbent injection system or any of its components are found during the inspections to need repair,take corrective actions as soon as possible. Corrective actions shall return the sorbent injection rate toat least the permitted minimum and/or include completion of necessary repairs identified during theinspection, as applicable. Corrective actions include, but are not limited, to those outlined in the O&MPlan for the sorbent injection system. Keep a record of the type and date of any corrective actiontaken.


9Perlite Injection: The Permittee shall inject perlite during first cold start-up of TREA 14. Perlite mayalso be used to provide an initial coating for new bags. Perlite can improve bag life, but is not requiredfor the ePTFE membrane to be effective in removing particulate.

Minn. R. 7007.0800, subp.2(A)

10

The Permittee shall operate and maintain the perlite injection system in accordance with themanufacturer's recommendations included in Appendix D. However, the optimization of Perlite use isat the facility's discretion based on experience; therefore changes to the manufacturer'srecommendations can be made following written notification to the MPCA.

Minn. R. 7007.0800, subp. 14

13The Permittee shall operate and maintain the dry sorbent injection system in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan availableonsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14

TREA15 CE019 Thermal Oxidizer 3450Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percentopacity.

Minn. R. 7011.0610, subp.1(A)(2)


Minn. R. 7011.0610, subp.1(A)(1)

3512 Temperature >= 1250 degrees Fahrenheit 3-hour rolling average,at the combustion chamber outlet,unless a new limit is required to be set pursuant to Minn. R. 7017.2025, subp. 3. If a new minimum isrequired to be set it will be based on the values recorded during the most recent MPCA-approvedperformance test where compliance was demonstrated. The new limit shall be implemented uponreceipt of the Notice of Compliance letter granting preliminary approval. The limit is final uponissuance of a permit amendment incorporating the change. If the 3-hour rolling average temperatureis below the minimum temperature limit, the VOC emitted during that time shall be considereduncontrolled until the average temperature is above the minimum temperature limit. This shall bereported as a deviation.


Requirements


Reconserve of Minnesota IncTREA15 CE019 Thermal Oxidizer3460

Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to furtherreduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R.7011.0735.

Minn. R. 7011.0610, subp.1(A)(1)

3512

Temperature >= 1250 degrees Fahrenheit 3-hour rolling average,at the combustion chamber outlet,unless a new limit is required to be set pursuant to Minn. R. 7017.2025, subp. 3. If a new minimum isrequired to be set it will be based on the values recorded during the most recent MPCA-approvedperformance test where compliance was demonstrated. The new limit shall be implemented uponreceipt of the Notice of Compliance letter granting preliminary approval. The limit is final uponissuance of a permit amendment incorporating the change. If the 3-hour rolling average temperatureis below the minimum temperature limit, the VOC emitted during that time shall be considereduncontrolled until the average temperature is above the minimum temperature limit. This shall bereported as a deviation.


3517 Fuel type: Natural gas only, by design.Minn. R. 7005.0100, subp.35a

17610 The Permittee shall keep records of fuel purchases showing fuel types. Minn. R. 7007.0800, subp. 5

17615

The Permittee shall vent emissions from EQUI 1 and EQUI 2 to TREA 15 whenever EQUI 1 or EQUI 2operates, and operate and maintain TREA 15 at all times that any emissions are vented to TREA 15.The Permittee shall document periods of non-operation of the control equipment TREA 15 wheneverEQUI 1 or EQUI 2 is operating.


18730




18740The Permittee shall operate and maintain control equipment such that it achieves an overall controlefficiency for, Volatile Organic Compounds >= 90 percent control efficiency.


18750

Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring devicethat continuously indicates and records the combustion chamber temperature of the thermal oxidizer.The monitoring device shall have a margin of error less than the greater of +/- 0.75 percent of thetemperature being measured or +/- 4.5 degrees Fahrenheit. The recording device shall also calculatethe three-hour rolling average combustion chamber temperature. Recorded values outside the rangespecified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a.


18760Daily Monitoring: The Permittee shall physically verify the operation of the temperature recordingdevice at least once each operating day to verify that it is working and recording properly. ThePermittee shall maintain a written record of the daily verifications.


18770Monitoring Equipment: The Permittee shall install and maintain thermocouples to conducttemperature monitoring required by this permit. The monitoring equipment must be installed, in use,and properly maintained whenever operation of the monitored control equipment is required.


18780 The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperaturereadings and calculated three hour rolling average temperatures for the combustion chamber.

Minn. R. 7007.0800, subps.4-5, Title I Condition: Avoidmajor source under 40 CFR52.21(b)(1)(i) and Minn. R.7007.3000


18790Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12months and shall maintain a written record of the calibration and any action resulting from thecalibration.


18800

Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the controlequipment internal and external system components, including but not limited to the refractory, heatexchanger, and electrical systems. The Permittee shall maintain a written record of the inspection andany corrective actions taken resulting from the inspection.


18810 Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspectionof the control device that includes all operating systems of the control device. The Permittee shallmaintain a written record of the inspection and any action resulting from the inspection.


Requirements


Reconserve of Minnesota IncTREA15 CE019 Thermal Oxidizer18800

Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the controlequipment internal and external system components, including but not limited to the refractory, heatexchanger, and electrical systems. The Permittee shall maintain a written record of the inspection andany corrective actions taken resulting from the inspection.


18810Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspectionof the control device that includes all operating systems of the control device. The Permittee shallmaintain a written record of the inspection and any action resulting from the inspection.


18820

For periods when the thermal oxidizer is operated above the minimum combustion chambertemperature, the Permittee shall use either one of the following when completing calculations asrequired elsewhere in this permit:a. The control efficiency limit specified in this permit for this equipment (x%); orb. The control efficiency determined during the most recent MPCA approved performance test. If thetested efficiency is less than the efficiency limit in this permit, the Permittee must use the testedvalue in all calculations until the efficiency is demonstrated to be above the permit limit through a newtest.

Minn. R. 7007.0800, subps.4-5, Title I Condition: Avoidmajor source under 40 CFR52.21(b)(1)(i) and Minn. R.7007.3000

18830

Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermaloxidizer or any of its components are found during the inspections to need repair, the Permittee shalltake corrective action as soon as possible. Corrective actions shall return the temperature to at leastthe permitted minimum and/or include completion of necessary repairs identified during theinspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & MPlan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any correctiveaction taken.


For periods when the thermal oxidizer is operated above the minimum combustion chambertemperature, the Permittee shall use either one of the following when completing calculations asrequired elsewhere in this permit:

a. The overall control efficiency limit specified in this permit for this equipment (x%); or

b. The overall control efficiency determined during the most recent MPCA approved performance test.If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use thetested value in all calculations until the efficiency is demonstrated to be above the permit limitthrough a new test.


Requirements


Insignificant air emissions activity

Agency Interest: NoneAgency Interest ID: NoneActivity: None (None)

Details for:SI Category: NoneSI Type: Insignificant Air Emissions Activity

Agency Interest Name Subject Item ID Subject Item DesignationSubject Item Description Group Member ID (padded)

Reconserve ofMinnesota Inc

COMG1 GP002 Nitrogen Oxides (NOx)Group

EQUI1

EQUI2

EQUI6

COMG2 GP003 Sulfur Dioxide (SO2)Group

EQUI1

EQUI2

COMG3 GP004 Particulate Matter (PM)Group

EQUI1

EQUI2

EQUI3

EQUI4

EQUI7

EQUI14

EQUI16

COMG4 GP006 Carbon Monoxide (CO)Group

EQUI1

EQUI6

COMG5 GP007 Volatile OrganicCompounds (VOC) Group

EQUI1

EQUI2


EQUI1

Component Group (Members)

Agency Interest: Reconserve of Minnesota IncAgency Interest ID: 1465Activity: None (Permit Reopening)

Details for:SI Category: Component GroupSI Type: Air Component Group

Agency Interest Name Subject Item ID Subject Item DesignationSubject Item Description Group Member ID (padded)Reconserve ofMinnesota Inc

COMG5 GP007Volatile OrganicCompounds (VOC) Group EQUI2


EQUI1

EQUI2

EQUI6

COMG7 GP001 Indirect HeatingEquipment

EQUI1

EQUI2

EQUI6

EQUI7

COMG8 GP009 Material Handling EQUI3

EQUI4

EQUI7

EQUI14

EQUI16


EQUI1

EQUI2

EQUI3

EQUI4

EQUI7




Agency Interest Name Subject Item ID Subject Item DesignationSubject Item Description Group Member ID (padded)Reconserve ofMinnesota Inc


EQUI4

EQUI7

EQUI14

EQUI16

COMG12 GP012 Particulate Matter < 2.5Micron (PM2.5) Group

EQUI1

EQUI2

EQUI3

EQUI4

EQUI7

EQUI14

EQUI16




Subject ItemCategory Description

Subject Item TypeDescription Subject Item ID

Subject ItemDesignation Subject Item Description Pollutant

Potential (lbs/hr)

Unrestricted Potential

(tons/yr)

Potential Limited

(tons/yr)

Actual Emissions

(tons/yr)

Component Group Air Component Group COMG1 GP002 Nitrogen Oxides (NOx) Gr..Nitrogen Oxides

COMG2 GP003 Sulfur Dioxide (SO2) Gro..Sulfur Dioxide

COMG3 GP004 Particulate Matter (PM) ..Particulate Matter

COMG4 GP006 Carbon Monoxide (CO) Gr..Carbon Monoxide

COMG5 GP007 Volatile Organic Compou..Volatile Organic Compoun..


1,1,1-Trichloroethane

1,2-Dichloroethane

1,2-Dichloropropane

1,4-Dichlorobenzene (par..

2,4-Dinitrophenol

2,4,6-Trichlorophenol

4-Nitrophenol

Acetaldehyde

Acetophenone

Acrolein

Antimony compounds

Arsenic compounds

Benzene

Beryllium Compounds

Bis(2-ethylhexyl) phthalate

Bromomethane (Methyl b..

Cadmium compounds

Carbon Dioxide Equivalent

Carbon tetrachloride

Chlorine

Chlorobenzene (Monochlo..

Chloroform

Chloromethane

Chromium compounds

Cobalt compounds

Dichloromethane (Methyl..

Ethylbenzene

Formaldehyde

HAPs - Single

HAPs - Total

Hexane

Hydrochloric acid

Hydrogen Chloride

Lead

Lead Compounds

Manganese compounds

Mercury Compounds

Methane

Methyl ethyl ketone (MEK)

Naphthalene

Nickel compounds

Nitrous Oxide

Pentachlorophenol (PCP)

Phenol

Phosphorus

Polycyclic organic matter

Propionaldehyde

Propylene oxide

Selenium compounds

Styrene

Tetrachloroethylene (Per..

Toluene

Trichloroethylene (TCE)

Vinyl chloride (chloroethe..

Xylenes, Total

COMG11 GP005 Particulate Matter < 10 .. PM < 10 micron

COMG12 GP012 Particulate Matter < 2.5 ..PM < 2.5 micron

Equipment Coke HandlingEquipment

EQUI7 EU019 Petroleum Coke Handling Particulate Matter

PM < 2.5 micron

PM < 10 micron

9595959513.3

0.0134570.0004730.0007880.0429460.000999

4.160.00073703

0.1850.0016

0.014734790.001340.001341.34e-06

00.02349010.00257620.000142

00.01671120.42001630.01260.64.789

0.0773249

1.482250.0008150.00762

0.001713610.02686010.0006040.0007360.0008670.05190.00118

00.03004720.0003941.24e-06

0.0002895151.32169010.013008580.002081.4195228.41e-083.308472.89e-065.78e-074.73e-065.15e-050.0008670.0007620.000815

34.419.1

7.854.36

9595

000

0.060.010.14

0.0007370.0001120.00156

PTE by subject item

Agency Interest: NoneAgency Interest ID: 1465Activity: None (Permit Reopening)





Potential (lbs/hr)


(tons/yr)

Potential Limited

(tons/yr)

Actual Emissions

(tons/yr)

EquipmentCoke HandlingEquipment EQUI7 EU019 Petroleum Coke Handling

PM < 2.5 micron

PM < 10 micron

Furnace EQUI6 EU017 Comfort Heating 1,4-Dichlorobenzene (par..

Arsenic compounds

Benzene

Beryllium Compounds

Cadmium compounds

Carbon Dioxide


Carbon Monoxide

Chromium compounds

Cobalt compounds

Formaldehyde

Hexane

Manganese compounds

Mercury Compounds

Methane

Naphthalene

Nickel compounds

Nitrogen Oxides

Nitrous Oxide

Particulate Matter

PM < 2.5 micron

PM < 10 micron


Selenium compounds

Sulfur Dioxide

Toluene

Volatile Organic Compoun..

Kiln EQUI2 EU012 Rotary Kiln Dryer Acetaldehyde

Acrolein

Benzene

Carbon Monoxide

Formaldehyde

Hydrochloric acid

Nitrogen Oxides

Particulate Matter

PM < 2.5 micron

PM < 10 micron

Styrene


Material HandlingEquipment

EQUI3 EU014 Post Dryer MaterialsHandling

Particulate Matter

PM < 2.5 micron

PM < 10 micron

EQUI4 EU015 Packaging MaterialsHandling

Particulate Matter

PM < 2.5 micron

PM < 10 micron

EQUI14 EU013 Sawdust/WoodBy-products Storage andHandling

Particulate Matter

PM < 2.5 micron

PM < 10 micron

Other Combustion EQUI1 EU011 Solid Fuel Burner w/Natural Gas-Fired Startup

1,1,1-Trichloroethane

1,2-Dichloroethane

1,2-Dichloropropane

2,4-Dinitrophenol

2,4,6-Trichlorophenol

4-Nitrophenol

Acetaldehyde

Acetophenone

Acrolein

Antimony compounds

Arsenic compounds

Beryllium Compounds

Bis(2-ethylhexyl) phthalate

Bromomethane (Methyl b..

Cadmium compounds

Carbon Dioxide

000

0.060.010.14

0.0007370.0001120.00156

00000000

2.93000

1.990000000

5,023.135,018.21

00000

0.240.000146

0.031.03e-063.79e-06

0.330.330.332.934.29

9.01e-052.62e-05

1.991.12e-051.63e-050.07730.003223.61e-066.01e-05

3.615,023.135,018.214.72e-055.15e-079.01e-058.58e-065.15e-05

0.053.33e-050.006

2.35e-078.64e-070.0740.0740.0740.70.98

2.06e-055.98e-06

0.52.55e-063.72e-060.0176

0.0007358.23e-071.37e-05

0.821,1471,146

1.08e-051.18e-072.06e-051.96e-061.18e-05

000000000000

7.6654.16

11.38811.388157.6874.5

14.0161.357885.411.27021.3143.285

1.750.950.130.131.8173.20.3119.50.290.30.75

000

7.457.4513.36

0.850.851.53

000

0.150.150.31

0.001760.001760.00353

000

4.654.6514.19

0.05310.0530.16

0000000000000000

2870000

1340000000000000000

59,55159,130

000000000000000

0.00065744.8

0.0004730.0007880.0242

0.0009992,049.80.0007360.0016

0.00073194.681.5

0.001340.001341.34e-06157.7287128.80.02340.002550.000142

1340.01670.42

0.01260.64.780.116

0.0008150.007620.001710.0268

0.0006040.0007360.0008670.05190.00118157.759,55159,1300.03

0.0003941.24e-060.0002890.013

0.002080.105

8.41e-080.02182.89e-065.78e-074.73e-060.0008670.0007620.000815

0.000151.8

0.0001080.000180.005520.000228

2340.0001680.0003660.0001668

1.10.9

0.001620.0003063.06e-07

1.86629.4

0.0053520.0005823.24e-05

310.0038180.096

0.002880.1

1.0910.0264

0.0001860.001740.000390.0061160.0001380.0001680.0001980.011850.00027

3.613,59613,5000.007439e-05

2.82e-076.6e-050.003

0.0004740.024

1.98e-080.004986.6e-071.32e-071.08e-060.0001980.0001740.000186

PTE by subject item






Potential (lbs/hr)


(tons/yr)

Potential Limited

(tons/yr)

Actual Emissions

(tons/yr)

Equipment Other Combustion EQUI1 EU011 Solid Fuel Burner w/Natural Gas-Fired Startup

Cadmium compounds

Carbon Dioxide


Carbon Monoxide

Carbon tetrachloride

Chlorine

Chlorobenzene (Monochlo..

Chloroform

Chloromethane

Chromium compounds

Cobalt compounds

Dichloromethane (Methyl..

Ethylbenzene

Formaldehyde

Hydrogen Chloride

Lead

Lead Compounds

Manganese compounds

Mercury Compounds

Methane

Methyl ethyl ketone (MEK)

Naphthalene

Nickel compounds

Nitrogen Oxides

Nitrous Oxide

Particulate Matter

Pentachlorophenol (PCP)

Phenol

Phosphorus

PM < 2.5 micron

PM < 10 micron


Propionaldehyde

Selenium compounds

Sulfur Dioxide

Tetrachloroethylene (Per..

Toluene

Trichloroethylene (TCE)

Vinyl chloride (chloroethe..


Xylenes, Total

Silo/Bin EQUI16 EU018 Raw Material andSawdust/WoodBy-products Storage

Particulate Matter

PM < 2.5 micron

PM < 10 micron

Fugitive Material Handling/Transfer/Storage

FUGI1 FS004 Shipping (loadout) Particulate Matter

PM < 2.5 micron

PM < 10 micron

FUGI4 FS003 Pet Coke Receiving Particulate Matter

PM < 2.5 micron

PM < 10 micron

Paved Road FUGI3 FS002 Paved Roads Particulate Matter

PM < 2.5 micron

PM < 10 micron

0000000000000000

2870000

1340000000000000000

59,55159,130

000000000000000

0.00065744.8

0.0004730.0007880.0242

0.0009992,049.80.0007360.0016

0.00073194.681.5

0.001340.001341.34e-06157.7287128.80.02340.002550.000142

1340.01670.42

0.01260.64.780.116

0.0008150.007620.001710.0268

0.0006040.0007360.0008670.05190.00118157.759,55159,1300.03

0.0003941.24e-060.0002890.013

0.002080.105

8.41e-080.02182.89e-065.78e-074.73e-060.0008670.0007620.000815

0.000151.8

0.0001080.000180.005520.000228

2340.0001680.0003660.0001668

1.10.9

0.001620.0003063.06e-07

1.86629.4

0.0053520.0005823.24e-05

310.0038180.096

0.002880.1

1.0910.0264

0.0001860.001740.000390.0061160.0001380.0001680.0001980.011850.00027

3.613,59613,5000.007439e-05

2.82e-076.6e-050.003

0.0004740.024

1.98e-080.004986.6e-071.32e-071.08e-060.0001980.0001740.000186

000

0.50.091.97

0.005670.000990.0225

000

6.351.0718.83

1.450.2454.3

000

0.060.010.14

0.01470.002230.0312

000

3.470.8517.37

0.2220.05451.11

PTE by subject item



Subject ItemCategoryDescription


Subject ItemDesignation

Subject ItemDescription Relationship

Related SubjectItem ID % Flow

Related Subject ItemType Description

Start Date (RelatedSubject Item)

End Date (RelatedSubject Item)

Equipment Kiln EQUI2 EU012 Rotary KilnDryer

is controlledby

TREA8 100007-Centrifugal Collector- High Efficiency

9/22/2008 Null

TREA13 100016-Fabric Filter - HighTemp, T>250 Degrees F

9/22/2008 Null

TREA14 100 206-Dry Sorbent Injection9/22/2008 Null

TREA15 100 131-Thermal Oxidizer 9/22/2008 Null

sends to STRU12 100 Stack/Vent 12/5/2012 Null

STRU16 0 Stack/Vent 12/5/2012 Null

Material HandlingEquipment

EQUI3 EU014 Post DryerMaterialsHandling

is controlledby

TREA9 100007-Centrifugal Collector- High Efficiency

9/22/2008 Null


EQUI4 EU015 PackagingMaterialsHandling

is controlledby

TREA10 100018-Fabric Filter - LowTemp, T<180 Degrees F

12/5/2012 Null


EQUI14 EU013 Sawdust/WoodBy-productsStorage andHandling

is controlledby


12/5/2012 Null


Other Combustion EQUI1 EU011 Solid FuelBurner w/NaturalGas-FiredStartup

is controlledby


9/22/2008 Null


TREA15 100 131-Thermal Oxidizer 9/22/2008 Null


STRU16 0 Stack/Vent 12/5/2012 Null

Silo/Bin EQUI16 EU018 Raw MaterialandSawdust/WoodBy-products St..

is controlledby


12/5/2012 Null


Treatment 131-ThermalOxidizer

TREA15 CE019 ThermalOxidizer

is controlledin series by


9/22/2008 Null


SI - SI relationships



Aboveground Storage Tanks, General


Details for:SI Category: EquipmentSI Type: Aboveground Storage Tank

Underground Storage Tanks, General


Details for:SI Category: EquipmentSI Type: Underground Storage Tank System

Subject ItemTypeDescription Subject Item ID


Subject ItemDescription Manufacturer Model

Max DesignCapacity

Max DesignCapacityUnits(numerator)

Max DesignCapacity Units(denominator) Material

ConstructionStart Date

OperationStart Date

ModificationDate

CokeHandlingEquipment

EQUI7 EU019Petroleum CokeHandling

Various Various 20 tons hours Ash 2/6/1998 2/2/1998 Null

Furnace EQUI6 EU017 Comfort Heating Various Various 0.01million cubicfeet

hours Natural Gas 2/4/1998 2/1/1998 Null

MaterialHandlingEquipment


Various Various 50 tons hours Sawdust 2/2/1998 2/1/1998 Null


Various Various 1 tons hours Material 2/3/1998 2/1/1998 Null

EQUI14 EU013Sawdust/WoodBy-products Storageand Handling

Ronning Custom built18 tons hours Sawdust 2/1/1998 2/1/1998 Null

Silo/Bin EQUI16 EU018Raw Material andSawdust/WoodBy-products Storage

Various Various 18 tons hours Sawdust 2/5/1998 2/1/1998 Null

Emission Units 1


Details for:SI Category: NoneSI Type: Coke Handling Equipment, Furnace, Material Handling Equipment and 1 more




Max DesignCapacity

Max DesignCapacity Units(numerator)

Max DesignCapacity Units(denominator) Material

ConstructionStart Date

OperationStart Date

ModificationDate

Kiln EQUI2 EU012Rotary KilnDryer

Ronning Custom built60 tons hours Material 6/1/2008 6/1/2008 Null

Other Combustion EQUI1 EU011Solid FuelBurner w/ N..

Onix Corporation Custom built60million Britishthermal units

hours Heat 7/1/2005 7/1/2005 Null

Emission Units 2


Details for:SI Category: EquipmentSI Type: Kiln & Other Combustion


Subject ItemDesignation Subject Item Description

FiringMethod Engine Use

EngineDisplacement

EngineDisplacementUnits

Subject toCSAPR?

ElectricGeneratingCapacity(MW)

Kiln EQUI2 EU012 Rotary Kiln DryerNot coalburning

Null Null Null Null Null

Other Combustion EQUI1 EU011Solid Fuel Burner w/Natural Gas-Fired Startup

Not coalburning

Null Null Null Null Null

Emission Units 2 (continued)


Details for:SI Category: EquipmentSI Type: Kiln & Other Combustion

CEMs/COM, General


Details for:SI Category: EquipmentSI Type: Continuous Emission Monitor & Continuous Opacity Monitor

Parametric Mon, General


Details for:SI Category: EquipmentSI Type: Parametric Monitor

Data Acquisition System, General


Details for:SI Category: EquipmentSI Type: Data Acquisition System



Subject ItemDescription Install Year Pollutants Emitted

Material Handling/Transfer/Storage

FUGI1 FS004 Shipping(loadout)

1997 Particulate Matter

PM < 2.5 micron

PM < 10 micron

FUGI4 FS003 Pet CokeReceiving

1997 Particulate Matter

PM < 2.5 micron

PM < 10 micron

Paved Road FUGI3 FS002 Paved Roads1997 Particulate Matter

PM < 2.5 micron

PM < 10 micron

Fugitive Sources


Details for:SI Category: FugitiveSI Type: Material Handling/Transfer/Storage & Paved Road



Subject ItemDescription Height

Units(height) Length

Units(length) Width

Units(width)

Building STRU19 NullProduction &Raw Storage

44 feet 223 feet 119 feet

STRU20 Null Feed Storage43 feet 99 feet 81 feet

STRU21 NullFeedLoadout

41 feet 72 feet 24 feet

STRU22 Null Washbay 31 feet 78 feet 33 feet

STRU23 Null Shop 31 feet 56 feet 81 feet

STRU24 Null Office 31 feet 53 feet 81 feet

STRU25 Null Office 12 feet 39 feet 10 feet

STRU26 Null Receivings 40 feet 90 feet 23 feet

Buildings, General


Details for:SI Category: StructureSI Type: Building


Subject ItemDesignation Subject Item Description

Stack Height(feet)

StackDiameter(feet)

Stack Length(feet)

Stack Width(feet)

Stack Flow Rate(cubic ft/min)

DischargeTemperature(°F)

Flow Rate/TempInformationSource Discharge Direction

Stack/Vent STRU4 SV014Raw Material andSawdust/Wood By-produc..

40 Null 1.17 1.33 12000 70 Manufacturer Horizontally

STRU12 SV011 Burner and Dryer Stack 50 7 Null Null 65800 400 Test dataUpwards with no cap onstack/vent

STRU13 SV012 Raw Material Receiving 15 Null 1.17 1.33 10500 70 ManufacturerUpwards with no cap onstack/vent

STRU14 SV013Packaging MaterialStorage

25 1.17 Null Null 5800 100 Test dataUpwards with no cap onstack/vent

STRU15 SV015Packaging Material andPost Dryer Handling Stack

47 4.4 Null Null 20000 130 ManufacturerUpwards with no cap onstack/vent

STRU16 SV016 Emergency Dump Stack 40 3 Null Null 112000 1600 ManufacturerUpwards with no cap onstack/vent

STRU17 SV017 Not currently in use 18 1 Null Null 5200 700 ManufacturerUpwards with no cap onstack/vent

STRU18 SV018 Not currently in use 18 1 Null Null 5200 700 ManufacturerUpwards with no cap onstack/vent

Stack/Vent, General


Details for:SI Category: StructureSI Type: Stack/Vent

Scrubbers, General


Details for:SI Category: TreatmentSI Type: 001-Wet Scrubber - High Efficiency, 002-Wet Scrubber - MediumEfficiency, 003-Wet Scrubber - Low Efficiency and 12 more

Other Control Equipment


Details for:SI Category: TreatmentSI Type: 004-Gravity Collector - High Efficiency, 005-Gravity Collector -Medium Efficiency, 006-Gravity Collector - Low Efficiency and 55 more




InstallationStart Date

PollutantControlled

CaptureEfficiency(%)

DestructionCollectEfficiency(%)

Subject toCAM?

Large orOther PSEU?

EfficiencyBasis

CycloneMinimumPressureDrop (in. of ..

CycloneMaximumPressureDrop (in. of ..

007-CentrifugalCollector -HighEfficiency

TREA8 CE012 CentrifugalCollector -HighEfficiency

ParrEngineering

Custom 1/1/2000ParticulateMatter

100 90 No NullMfr/Vendordata

1.5 5

PM < 2.5micron


1.5 5

PM < 10micron


1.5 5

TREA9 CE013 CentrifugalCollector -HighEfficiency

ParrEngineering

Custom 1/1/2000ParticulateMatter


1.5 5

PM < 2.5micron


1.5 5

PM < 10micron


1.5 5

Collectors-Cyclones, General


Details for:SI Category: TreatmentSI Type: 007-Centrifugal Collector - High Efficiency

Electrostatic Precipitators, General


Details for:SI Category: TreatmentSI Type: 010-Electrostatic Precipitator - High Efficiency, 011-ElectrostaticPrecipitator - Med Efficiency, 012-Electrostatic Precipitator - Low Efficiencyand 1 more




InstallationStart Date

PollutantControlled

CaptureEfficiency(%)

DestructionCollectEfficiency(%)

Subject toCAM?

Large orOther PSEU?

EfficiencyBasis

Fabric FilterMinimumPressureDrop (in. of ..

Fabric FilterMaximumPressureDrop (in. of ..

Bag leakdetector inuse?

016-FabricFilter - HighTemp, T>250Degrees F

TREA13 CE017 Fabric Filter -HighTemperatur..

Century Custom 6/23/2006ParticulateMatter


3.5 6.5 No

PM < 2.5micron


3.5 6.5 No

PM < 10micron


3.5 6.5 No

018-FabricFilter - LowTemp, T<180Degrees F

TREA10 CE014 Fabric Filter -LowTemperatur..

IAC 100 BAG 6/23/2006ParticulateMatter


3.5 6.5 No

PM < 2.5micron


3.5 6.5 No

PM < 10micron


3.5 6.5 No


Camil Farr GS16 6/23/2006ParticulateMatter


3.5 6.5 No

PM < 2.5micron


3.5 6.5 No

PM < 10micron


3.5 6.5 No


Camil Farr CK66 6/23/2006ParticulateMatter


3.5 6.5 No

PM < 2.5micron


3.5 6.5 No

PM < 10micron


3.5 6.5 No

Fabric Filters, General


Details for:SI Category: TreatmentSI Type: 016-Fabric Filter - High Temp, T>250 Degrees F & 018-Fabric Filter - Low Temp, T<180 Degrees F

Catalytic Oxidizers, General


Details for:SI Category: TreatmentSI Type: 019-Catalytic Afterburner, 020-Catalytic Afterburner with HeatExchanger, 109-Catalytic Oxidizer

Oxidation Catalyst, General


Details for:SI Category: TreatmentSI Type: 312-Oxidation Catalyst

131-Thermal Oxidizer, TREA15CE019Thermal Oxidizer

OnixCorporation

Custom 12/5/2012Volatile OrganicCompounds


75 1400 1250 1800 0.9

Direct Flame Afterburners, General


Details for:SI Category: TreatmentSI Type: 131-Thermal Oxidizer

.. Injection, TREA14 CE018.. Acrison 98668 12/5/2012 Hydrochlori..100 99 No Null Test data Trona 120 pounds per ..37.8 pounds per ..

Injections Systems, General


Details for:SI Category: TreatmentSI Type: 206-Dry Sorbent Injection

Condensers, General


Details for:SI Category: TreatmentSI Type: 047-Vapor Recyc Sys-Condensers, Hoods, Othr Enclos, 072-Tubeand Shell Condenser, 073-Refrigerated Condenser and 1 more

Wet Separators, General


Details for:SI Category: TreatmentSI Type: 057-Dynamic Separator (Wet) & 085-Wet Cyclonic Separator - WetCyclone

Catalytic Converter, General


Details for:SI Category: TreatmentSI Type: 203-Catalytic Converter

Confidential Information

Agency Interest: Reconserve of Minnesota IncAgency Interest ID: NoneActivity: IND20200001 (None)


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