technical support document for draft air emission permit

Technical Support Document, Permit Number: 01900055-101 of 11

Technical Support Document for

DRAFT Air Emission Permit No. 01900055-101 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: 3585 - Air-Conditioning & Warm Air Heating Equipment & Commercial & Industrial Refrigeration Equipment)

Tori Schneider 104 Peavey Rd Chaska, Minnesota 55318

Super Radiator Coils - Chaska 104 Peavey Rd Chaska, MN 55318

Contact: Tori Schneider Phone: 952-446-7102

1.2 Facility description

Super Radiator Coils (SRC) manufactures heat exchangers across a broad range of sizes. There are three emission units at the facility; a degreaser and two small process boilers. The degreaser uses perchloroethylene solvent vapor to thoroughly clean finned tube coils. Perchloroethylene is a listed Hazardous Air Pollutant (HAP), making the degreaser an affected source under the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Halogenated Solvent Cleaning (40 CFR pt. 63, subp. T).

1.3 Description of the activities allowed by this permit action This permit action is a Part 70 Reissuance.

1.4 Facility emissions

Table 2. Total facility potential to emit summary

PM tpy

PM10 tpy

PM2.5 tpy

SO2 tpy

NOx tpy

CO tpy

CO2e tpy

VOC tpy

Single HAP tpy

All HAPs tpy

Total facility limited potential emissions

0.055 0.055 0.055 0.0043 0.72 0.60 869 0.040 98 98

Total facility actual emissions (2010)

-- -- -- -- -- -- * -- *

*Not reported in Minnesota emission inventory. Cells with ”—“ indicate the pollutant was not required to be reported at the time of last report. Table 3. Facility classification


Classification Major Synthetic minor/area Minor/Area New Source Review X Part 70 X Part 63 X

1.5 Changes to permit

The permit does not authorize any specific modifications, however, the MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R. 7007.0800, the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action: · The permit has been updated to reflect current MPCA templates and standard citation formatting. · The EU, SV and CE identifiers have been updated to EQUI, STRU, and TREA to reflect MPCA’s current

permitting practice. · Completed submittal actions related to the installation and start-up of TREA 1 have been removed from

the permit. The facility was able to qualify the space housing the degreaser as a permanent total enclosure through a performance test. The notification is attached to this TSD as attachment 3.

· Requirements were added to EQUI 1 to align with the updated version of 40 CFR pt. 63, subp. T. This includes the facility-wide perchloroethylene limit of 4800 kg/year.

· Two boilers at the facility previously permitted as insignificant activities were added to the permit as EQUI 3 and 4. These two boilers became subject to 40 CFR pt. 63, subp. DDDDD in the time since the last permit action.

· Corrective action, Operation & Maintenance, and Equipment Replacement requirements were added to TREA 1 to ensure adequate monitoring to demonstrate compliance.

· HVAC equipment used to heat the facility were added to Appendix A of the permit as insignificant activities under Minn. R. 7007.1300(3)(I). Many of the units were added since the time of the last permit issuance. However, some have been in operation at the facility since 1998 and were mistakenly omitted from previous permit actions.

· A small cooling tower was added in July, 2016 and has been added to Appendix A of the permit as an insignificant activity under Minn. R. 7007.1300(3)(I).

2. Regulatory and/or statutory basis

2.1 New source review (NSR) SRC is a minor source under New Source Review because unrestricted emissions of criteria pollutants do not exceed 250 tons per year. No changes are authorized by this permit. The facility’s uncontrolled potential to emit for perchloroethylene exceeds 250 tpy. However, perchloroethylene is not considered a VOC under Minn. R. 7005.0100, subp. 45(X) and thus NSR does not apply.

2.2 Part 70 permit program

The facility is a major source under the Part 70 permit program.

2.3 New source performance standards (NSPS) The Permittee has stated that no New Source Performance Standards apply to the operations at this facility.

2.4 National emission standards for hazardous air pollutants (NESHAP) The facility is a major source of HAPs.


The Permittee operates a large batch vapor degreaser (EQUI 1) subject to 40 CFR pt. 63, subp. T–NESHAPs for Halogenated Solvent Cleaning. The Permittee has stated that EQUI 1 does not have a lip exhaust and therefore is not required to operate the control equipment in order to comply with 40 CFR pt. 63, subp. T. Additionally, the Permittee operates two small boilers; one to heat the degreaser solvent and the other to provide steam for purging the carbon adsorption system. These boilers are subject to 40 CFR pt. 63, subp. DDDDD – NESHAPs for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters. Under this standard, an existing source commenced construction prior to June 4, 2010. EQUI 3 is considered an existing source since construction was commenced 8/1/1998 while EQUI 4 is considered new since construction commenced 5/1/2015. The compliance date was January 31, 2016.

2.5 Compliance assurance monitoring (CAM)

CAM does not apply because the carbon adsorption unit (TREA 1) is not used to meet any emission limits, including the perchloroethylene limit in 40 CFR pt. 63, subp. T. The carbon adsorption unit is used only to meet modeling requirements – the background of which is detailed in the TSD from permit action 01900055-003.

2.6 Minnesota State Rules

Portions of the facility are subject to the following Minnesota Standards of Performance: · Minn. R. 7011.0515 Standards of Performance for New Indirect Heating Equipment · Minn. R. 7011.0610 Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment · Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment

Table 4. Regulatory overview of facility Subject item* Applicable regulations Rationale EQUI 1 - Degreaser 40 CFR pt. 63, subp. T

Minn. R. 7011.0715

NESHAP for Halogenated Solvent Cleaning. · EQUI 1 is a batch vapor solvent cleaning machine

using perchloroethylene in a concentration > 5% weight as a cleaning agent.

Standards of Performance for Post 1969 Industrial Process Equipment.

EQUI 3 and 4 - Boliers

40 CFR pt. 63, subp. DDDDD Minn. R. 7011.0515

NESHAP for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters.

· EQUI 3 and 4 are both institutional boilers located at a major source facility

Standards of Performance for Indirect Heating Equipment. Determination of applicable limit from rule:

· EQUI 3 was constructed in 1998, EQUI 4 was constructed in 2013;

· the facility is located within the Minneapolis-St. Paul Air Quality Control Region;

· both units have a capacity less than 250 MMBtu/hr; and

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


Subject item* Applicable regulations Rationale TREA 1 - 048-Activated Carbon Adsorption

Minn. Stat. Section 116.07, subd. 4a, Minn. R. 7007.0800, subp. 2

Use of carbon adsorption system required in order to meet Minnesota Department of Health benchmarks for ambient perchloroethylene concentrations. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act.

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

3. Technical information

3.1 Calculations of potential to emit (PTE) Attachment 1 to this TSD contains a facility PTE summary, as well as detailed spreadsheets and supporting information prepared by the MPCA and the Permittee.

EQUI 1, perchloroethylene: PTE for EQUI 1 was calculated as required by 40 CFR §63.465(e) with the method laid out by 40 CFR §63.465(e)(1). This calculation method specifies an emission rate for batch vapor cleaning machines, such as EQUI 1. EQUI 3 and 4: Emissions were calculated based on allowable fuels, maximum capacity and AP-42 emission factors Insignificant activities under Minn. R. 7007.1300(3)(I): For combustion equipment, emissions were calculated based on allowable fuels, maximum capacity and AP-42 emission factors. For the cooling tower, emissions were calculated using an equation from AP-42, Chapter 13.4. The equation takes into account a conservatively high estimate for dissolved solids in the cooling tower water and the estimated drift loss of the unit.

3.2 Installation of activated carbon adsorption system for perchloroethylene recovery As mentioned earlier in this TSD, the use of the carbon adsorption system is not required for the facility to comply with 40 CFR pt. 63, subp. T. However, in 2005 the MPCA required additional steps be taken to further reduce perchloroethylene emissions. This requirement stemmed from a nearby MPCA air toxics monitor recording perchloroethylene concentrations above Minnesota Department of Health (MDH) health benchmarks. MPCA staff then conducted preliminary dispersion modeling for 1-hour and annual ambient concentrations of perchloroethylene. The modeling results showed concentrations above MDH health benchmarks. The modeling was repeated to include operation of a carbon adsorption system and these modeling results showed concentrations well below MDH health benchmarks. Therefore, MPCA staff believe it may be necessary to operate the system to be protective of human health and the environment, so the permit requires its operation. A more detailed background surrounding the installation of the carbon adsorption system can be found in the TSD from permit action 01900055-003.

3.3 Monitoring


In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements.

In evaluating the monitoring included in the permit, the MPCA considered the following:

· the likelihood of the facility violating the applicable requirements; · whether add-on controls are necessary to meet the emission limits; · the variability of emissions over time; · the type of monitoring, process, maintenance, or control equipment data already available for the

emission unit; · the technical and economic feasibility of possible periodic monitoring methods; and · the kind of monitoring found on similar units elsewhere.

Table 5 summarizes the monitoring requirements.

Table 5. Monitoring

Subject Item* Requirement (basis)

What is the monitoring? Why is this monitoring adequate?

EQUI 1 Perchloroethylene <= 4800 kilograms per year 12-month rolling sum [40 CFR §63.471(b)(2)] Particulate Matter: Varies with airflow Opacity <= 20% [Minn. R. 7011.0715, subp. 1(A)]

Recordkeeping: Solvent additions/deletions log along with monthly solvent emissions calculations None

The monitoring required by the NESHAP is adequate to demonstrate continuous compliance with the applicable requirement. Batch vapor solvent cleaning processes are not reasonably expected to generate particulate matter; therefore, it is highly unlikely EQUI 1 could violate the applicable requirement.

EQUI 3 & 4 Particulate Matter <= 0.4 lb/MMbtu heat input Opacity <= 20% with exceptions [Minn. R. 7011.0515]

None The uncontrolled, potential PM emissions of EQUI 3 and EQUI 4 are 0.007 lb/MMBTU for each boiler, which is well below the rule limit. It is highly unlikely the limit could be violated. The Permittee can demonstrate the units will operate with emissions well below the limits by continuing to burn only natural gas


Subject Item* Requirement (basis)

What is the monitoring? Why is this monitoring adequate?

TREA 1 Control Efficiency for Perchloroethylene >= 60 percent. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2] [Minn R. 7007.0800, subp. 2]

Monthly recordkeeping: Perchloroethylene material balance O&M, Inspections, corrective actions

Daily tracking of the amount of perchloroethylene leaving the machine/recovered from the adsorption unit and performing an efficiency calculation is a reasonable method to track the unit’s operation efficiency. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance.

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

3.4 Insignificant activities Super Radiator Coils - Chaska has several operations that are classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix A to the permit. Emissions calculations for insignificant activities are also included in Attachment 2 of this TSD.

The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities. See Attachment 2 of this TSD for PTE information for the insignificant activities. Table 6. Insignificant activities

Insignificant activity General applicable emission limit Discussion

Blueprint copiers and photographic processes

PM, varies with airflow Opacity <= 20% (Minn. R. 7011.0715)

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

Brazing, soldering or welding equipment

PM, varies with airflow Opacity <= 20% (Minn. R. 7011.0715)

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


Insignificant activity General applicable emission limit Discussion

Individual emission units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than: (1) 4,000 pounds per year of carbon monoxide; (2) 2,000 pounds per year each of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, VOCs (including hazardous air pollutant-containing VOCs), and ozone; and (3) 1,000 tons per year of CO2e.

PM <= 0.4 lb/MMBTU Opacity ≤ 20% (with exceptions) (Minn. R. 7011.0610) PM, varies with airflow Opacity <= 20% (Minn. R 7011.0715)

There are 30 small, natural gas fired HVAC units used for building heat. Based on the fuels used and EPA published emissions factors, it is highly unlikely these units could violate the applicable requirements. Additionally, there is a small cooling tower. Based on emission calculations, it is highly unlikely this unit could violate the applicable requirements

3.5 Permit organization

In this permit, federal requirements from NESHAPs are included in two different formats. The requirements for 40 CFR pt. 63, subp. T are incorporated into the permit as individual permit requirements, which has historically been MPCA’s standard practice. However, the requirements for 40 CFR pt. 63, subp. DDDDD and the associated General Provisions in 40 CFR pt. 63, subp. A are included in a different way. For these rules, limits and submittal/actions are included individually in the permit like the other standards. For the remaining portions of the rule, a requirement in Section 5 of the permit lists the citations of all of the applicable parts of the standard along with a reference to the permit appendix where the full text of the standard is included. 40 CFR pt. 63, subp. DDDDD and 40 CFR pt. 63, subp. A are included in Appendices B and C, respectively.

3.6 Comments received

To be completed following the public notice and EPA review periods.

4. Permit fee assessment This permit action is the reissuance of an Individual Part 70; therefore, no application fees apply under Minn. R. 7002.0016, subp. 1.

5. Conclusion Based on the information provided by Super Radiator Coils - Chaska the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 01900055-101 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Derek Nelson (permit engineer)

Adriane Lenshek (peer reviewer) Curt Stock (compliance) Dan Dietrich (enforcement) Beckie Olson (permit writing assistant) Laurie O’Brien (administrative support)


TEMPO360 Activities: Part 70 Reissuance (IND20110001)

Attachments: 1. PTE summary and calculation spreadsheets 2. Subject item inventory and facility requirements 3. Total enclosure notification

Attachment 1 – PTE summary and calculation spreadsheets

Attachment 2 – Subject item inventory and facility requirements

Attachment 3 – Total enclosure notification

Attachment 1 – PTE summary and calculation spreadsheets

Potential To Emit SummarySuper Radiator Coils - ChaskaPermit 01900055-101

Heat Input(MMBtu/hr) (lb/hr) (tpy) (lb/hr) (tpy) (lb/hr) (tpy) (lb/hr) (tpy) (lb/hr) (tpy)

EQUI 3 Degreaser Boiler 1.046 1.03E-01 4.49E-01 8.61E-02 3.77E-01 5.64E-03 2.47E-02 7.79E-03 3.41E-02 6.15E-04 2.69E-03EQUI 4 Carbon Boiler 0.63 6.18E-02 2.71E-01 5.19E-02 2.27E-01 3.40E-03 1.49E-02 4.69E-03 2.06E-02 3.71E-04 1.62E-03

1.64E-01 7.20E-01 1.38E-01 6.05E-01 9.04E-03 3.96E-02 1.25E-02 5.47E-02 9.86E-04 4.32E-03

HAP Summary

Heat Input(MMBtu/hr) (lb/hr) (tpy) (lb/hr) (tpy)

EQUI 1 Degreaser N/A 22.35 97.90 22.35 97.90EQUI 3 Degreaser Boiler 1.046 0.00E+00 0.00E+00 1.93E-03 8.47E-03EQUI 4 Carbon Boiler 0.63 0.00E+00 0.00E+00 1.17E-03 5.10E-03

2.24E+01 9.79E+01 2.24E+01 9.79E+01Total Emissions

Unit description

Perchloroethylene Emissions (limited)

Total HAP Emissions (limited)

Unit Unit description

Total Emissions

Unit

Emission RateNOx CO VOC PM SO2

H = 8760 60%W = 1.95

0.40SAI = 13.01

PTE = H x W x SAI = Potential Perchloroethylene Emissions (kg/yr): 222,237Potential Perchloroethylene Emissions (tons/yr): 244.75Potential Perchloroethylene Emissions (lbs/hr): 56

Limited Potential Perchloroethylene Emissions (tons/yr): 97.90Limited Potential Perchloroethylene Emissions (lbs/hr): 22.35

H = W = SAI =

[1] PTE formula and variable "W" come directly from 40 CFR § 63.465(e)(1)

Super Radiator Coils

Perchloroethylene Potential Emission Calculations

hrs/yr

Vapor Degreaser EQUI 1

Permitted TREA 1 control efficiency

(lb/ft2)/hrm2

Potential Perchloroethylene Emissions

Hours of operationPotential to emit is calculated as described in 40 CFR § 63.465(e)(1)

Where: Working mode uncontrolled emissions rate = 1.95 Solvent/air interface (Surface Area)

(kg/m2)/hr[1]

(Btu/hr)

(MMCf/hr)

lbs/hr Tons/yr lbs/hr Tons/yr

NOx 100 1.03E-01 4.49E-01 6.18E-02 2.71E-01

CO 84 8.61E-02 3.77E-01 5.19E-02 2.27E-01

PM 7.6 7.79E-03 3.41E-02 4.69E-03 2.06E-02

PM10 7.6 7.79E-03 3.41E-02 4.69E-03 2.06E-02

PM2.5 7.6 7.79E-03 3.41E-02 4.69E-03 2.06E-02

SO2 0.6 6.15E-04 2.69E-03 3.71E-04 1.62E-03

VOC 5.5 5.64E-03 2.47E-02 3.40E-03 1.49E-02

Ammonia 3.2 3.28E-03 1.44E-02 1.98E-03 8.66E-03Total HAPs 1.89 1.93E-03 8.47E-03 1.17E-03 5.10E-03

HAPS

lbs/hr Tons/yr lbs/hr Tons/yr

POM 8.64E-05 8.86E-08 3.88E-07 5.34E-08 2.34E-07

Benzene 2.10E-03 2.15E-06 9.43E-06 1.30E-06 5.68E-06

Formaldehyde 7.50E-02 7.69E-05 3.37E-04 4.63E-05 2.03E-04

Hexane 1.80E+00 1.85E-03 8.08E-03 1.11E-03 4.87E-03

Naphthalene 6.10E-04 6.26E-07 2.74E-06 3.77E-07 1.65E-06

Toluene 3.40E-03 3.49E-06 1.53E-05 2.10E-06 9.20E-06

Arsenic 2.00E-04 2.05E-07 8.98E-07 1.24E-07 5.41E-07

Beryllium 1.20E-05 1.23E-08 5.39E-08 7.41E-09 3.25E-08

Cadmium 1.10E-03 1.13E-06 4.94E-06 6.79E-07 2.98E-06

Chromium 1.40E-03 1.44E-06 6.29E-06 8.65E-07 3.79E-06

Cobalt 8.40E-05 8.61E-08 3.77E-07 5.19E-08 2.27E-07

Manganese 3.80E-04 3.90E-07 1.71E-06 2.35E-07 1.03E-06

Mercury 2.60E-04 2.67E-07 1.17E-06 1.61E-07 7.03E-07

Nickel 2.10E-03 2.15E-06 9.43E-06 1.30E-06 5.68E-06

Selenium 2.40E-05 2.46E-08 1.08E-07 1.48E-08 6.49E-08

Total HAP 1.89E+00 1.93E-03 8.47E-03 1.17E-03 5.10E-03

POM

Acenaphthene 1.80E-06Acenaphthylene 1.80E-06Anthracene 2.40E-06Benz(a)anthracene 1.80E-06Benzo(a)pyrene 1.20E-06Benzo(b,k)fluoranthene 1.80E-06Benzo(g,h,i)perylene 1.20E-06Chrysene 1.80E-06Dibenzo(a,h)anthrancene 1.20E-067,12-Dimethylbenz(a)anthracene 1.60E-05Fluoranthene 3.00E-06Fluorene 2.80E-06Indeno(1,2,3-cd)pyrene 1.80E-062-Methylnaphthalene 2.40E-053-Methylchloranthrene 1.80E-06Phenanthrene 1.70E-05Pyrene 5.00E-06Total POM 8.64E-05

lbs/hr tons/yr lbs/hr tons/yr

CO2 120,000 1.23E+02 5.39E+02 7.41E+01 3.25E+02

CH4 2.3 2.36E-03 1.03E-02 1.42E-03 6.22E-03

N2O 2.2 2.26E-03 9.88E-03 1.36E-03 5.95E-03

CO2e[2] 120,713 123.79 542 74.56 327

[2] GWP: CH4 = 25, N2O = 298

Emission Factor

(lbs/MMCf)[1]

Potential Emissions Potential Emissions

PollutantEmission Factor

(lbs/MMCf)[1]

Pollutant

Greenhouse Gas Emissions

[1] Emission Factors are from AP-42 Chapter 1.4 "Natural Gas Combustion"

Potential Emissions Potential EmissionsEmission Factor

(lbs/MMCf)[1]Pollutant

Degreaser Boiler Carbon Boiler


(lbs/MMCf)[1]


Number of Units 1 1

Total Max Firing Rate1,046,000 630,000

0.00103 0.00062

Process Boilers - EQUI 3&4

Super Radiator Coils - Chaska

Emission Unit EQUI 3 - Degreaser Boiler EQUI 4 - Carbon Boiler

Natural Gas Emission Calculations

Super Radiator Coils - ChaskaNatural Gas Combustion Emission Calculations

Individual Max Firing Rate (Btu/hr)(Btu/hr)

(MMCf/hr)

lbs/hr tons/yr lbs/hr tons/yr lbs/hr tons/yr

NOx 100 0.01 0.04 0.01 0.05 0.01 0.05

CO 84 0.01 0.03 0.01 0.04 0.01 0.04PM 7.6 0.00 0.00 0.00 0.00 0.00 0.00

PM10/PM2.5 7.6 0.00 0.00 0.00 0.00 0.00 0.00

SO2 0.6 0.000 0.000 0.000 0.000 0.000 0.000

VOC 5.5 0.00 0.00 0.00 0.00 0.00 0.00

CO2 120,000 10.59 46 13.53 59 14.12 62

CH4 2.3 0.000 0.001 0.000 0.001 0.000 0.001

N2O 2.2 0.000 0.001 0.000 0.001 0.000 0.001

CO2e[2] 120,713 10.65 47 13.61 60 14.20 62

Ammonia 3.2 0.000 0.001 0.000 0.002 0.000 0.002Total HAPs 1.89 0.000 0.001 0.000 0.001 0.000 0.001

[2] GWP: CH4 = 25, N2O = 298

0.00012


Number of Units 190,000

1 1


(lbs/MMCf)[1]

Potential Emissions Potential Emissions Potential Emissions

0.00011Total Max Firing Rate

90,000

0.00009

115,000 120,000115,000 120,000

Emission Unit Office Roof Top Unit Office Roof Top Unit Office Roof Top Unit



(MMCf/hr)

NOx 100

CO 84PM 7.6

PM10/PM2.5 7.6

SO2 0.6

VOC 5.5

CO2 120,000

CH4 2.3

N2O 2.2

CO2e[2] 120,713

Ammonia 3.2Total HAPs 1.89

[2] GWP: CH4 = 25, N2O = 298


Number of Units


(lbs/MMCf)[1]

Total Max Firing Rate

Emission Unit


1.27E-02 5.58E-02 1.57E-02 6.87E-02 2.35E-02 1.03E-01

1.07E-02 4.69E-02 1.32E-02 5.77E-02 1.98E-02 8.66E-029.69E-04 4.24E-03 1.19E-03 5.22E-03 1.79E-03 7.83E-03

9.69E-04 4.24E-03 1.19E-03 5.22E-03 1.79E-03 7.83E-03

7.65E-05 3.35E-04 9.41E-05 4.12E-04 1.41E-04 6.18E-04

7.01E-04 3.07E-03 8.63E-04 3.78E-03 1.29E-03 5.67E-03

1.53E+01 6.70E+01 1.88E+01 8.24E+01 2.82E+01 1.24E+02

2.93E-04 1.28E-03 3.61E-04 1.58E-03 5.41E-04 2.37E-03

2.80E-04 1.23E-03 3.45E-04 1.51E-03 5.18E-04 2.27E-03

1.54E+01 6.74E+01 1.89E+01 8.29E+01 2.84E+01 1.24E+02

4.08E-04 1.79E-03 5.02E-04 2.20E-03 7.53E-04 3.30E-032.41E-04 1.06E-03 2.96E-04 1.30E-03 4.45E-04 1.95E-03

0.00016 0.00024

80,000 120,0002 2


130,000

0.00013

160,000 240,000

1

Potential Emissions

130,000

Phone Room Unit Phone Room UnitOffice Roof Top Unit



(MMCf/hr)

NOx 100

CO 84PM 7.6

PM10/PM2.5 7.6

SO2 0.6

VOC 5.5

CO2 120,000

CH4 2.3

N2O 2.2

CO2e[2] 120,713


[2] GWP: CH4 = 25, N2O = 298


Number of Units


(lbs/MMCf)[1]


Emission Unit


1.76E-01 7.73E-01 7.35E-02 3.22E-01 9.80E-03 4.29E-02

1.48E-01 6.49E-01 6.18E-02 2.71E-01 8.24E-03 3.61E-021.34E-02 5.87E-02 5.59E-03 2.45E-02 7.45E-04 3.26E-03

1.34E-02 5.87E-02 5.59E-03 2.45E-02 7.45E-04 3.26E-03

1.06E-03 4.64E-03 4.41E-04 1.93E-03 5.88E-05 2.58E-04

9.71E-03 4.25E-02 4.04E-03 1.77E-02 5.39E-04 2.36E-03

2.12E+02 9.28E+02 8.82E+01 3.86E+02 1.18E+01 5.15E+01

4.06E-03 1.78E-02 1.69E-03 7.41E-03 2.25E-04 9.88E-04

3.88E-03 1.70E-02 1.62E-03 7.09E-03 2.16E-04 9.45E-04

2.13E+02 9.33E+02 8.88E+01 3.89E+02 1.18E+01 5.18E+01

5.65E-03 2.47E-02 2.35E-03 1.03E-02 3.14E-04 1.37E-033.34E-03 1.46E-02 1.39E-03 6.09E-03 1.85E-04 8.12E-04

Shop Heater1

100,000

Potential Emissions

0.00176

1,800,000

15

Potential Emissions

6125,000

Potential Emissions

120,000750,000 100,000

0.00074 0.00010

Infrared Heaters - Production FloorInfrared Heaters - Production Floor



(MMCf/hr)

NOx 100

CO 84PM 7.6

PM10/PM2.5 7.6

SO2 0.6

VOC 5.5

CO2 120,000

CH4 2.3

N2O 2.2

CO2e[2] 120,713


[2] GWP: CH4 = 25, N2O = 298


Number of Units


(lbs/MMCf)[1]


Emission Unit

lbs/hr tons/yr

3.44E-01 1.51E+00

2.89E-01 1.26E+002.61E-02 1.14E-01

2.61E-02 1.14E-01

2.06E-03 9.03E-03

1.89E-02 8.28E-02

4.12E+02 1.81E+03

7.90E-03 3.46E-02

7.56E-03 3.31E-02

4.15E+02 1.82E+03

1.10E-02 4.82E-026.49E-03 2.84E-02

Total

Potential Emissions

Emission Unit

TDS[1]

(ppmw)

rH2O

(lbs/gal) hdrift (%)[2]

Potential Operating

Time

(hours/year)

Water Recirculation Rate

(gpm)

PTE PM/PM10

Emissions

(lbs/year)

Cooling Tower 2850 8.34 0.002 8760 370 92

PM/PM10 Emissions (tons/yr) 0.05

[1] Confirmed by facility to be maximum concentration

[2] Conservatively high estimated drift rate for a new cooling tower installed in July 2016.

Calculation Methodology:

Above formula obtained from EPA analysis titled "Particulate Emission Calculations - Pinal Power" https://yosemite.epa.gov/r9/air/epss.nsf/6924c72e5ea10d5e882561b100685e04/44841bd36885b15e882579f80062a144/$FILE/Cooling%20Tower%20Emission%20Calculations%20update.pdf

Cooling Tower Emissions

Super Radiator Coils

Where:E = Annual Emissions in pounds per year (lb/yr)V = Cooling tower circulating water rate (gal/min)TDS = Concentration of total dissolved solids in circulating water (ppmw)

hdrift = Drift loss of circulating water (%)

rH2O = Density of water: 8.34 lb/gal60 = Conversion from minutes to hoursOH = Annual operating hours (hours/year)

OHOH

drift 60

10010

TDS V E

26r

h

https://yosemite.epa.gov/r9/air/epss.nsf/6924c72e5ea10d5e882561b100685e04/44841bd36885b15e882579f80062a144/$FILE/Cooling Tower Emission Calculations update.pdf

Attachment 2 – Subject item inventory and facility requirements

Agency Interest Name Subject Item ID SI Designation and Description

Super Radiator Coils -Chaska

ACTV3NullAll IA's

AISI5158NullNull

EQUI1EU001Vapor Degreaser

EQUI3NullDegreaser Boiler

EQUI4NullCarbon Boiler

STRU1SV001Degreaser Vent

STRU2SV002Boiler Vent

STRU3NullBuilding 1

STRU4NullCarbon Boiler

TFAC101900055Super Radiator Coils - Chaska

TREA1CE001Activated Carbon Adsorption

List of SIs

Agency Interest: Super Radiator Coils - ChaskaAgency Interest ID: 5158Activity: IND20110001 (Part 70 Reissuance)

Details for:SI Category: NoneSI Type: All

Agency Interest Na.. Activity ID Subject Ite..Subject Item Type Description Subject Item ID SI Designation and Description Status Desc..Sub Attribute Description

Super Radiator Coils -Chaska

IND20110001 Activity Insignificant Air Emissions Activity ACTV3 NullAll IA's

Active /Existing

Minn. R. 7007.1300, subp.3(H)(4)

Minn. R. 7007.1300, subp.3(H)(5)

Minn. R. 7007.1300, subp. 3(I)

Insignificant air emissions activity

Agency Interest: Super Radiator Coils - ChaskaAgency Interest ID: 5158Activity: IND20110001 (Part 70 Reissuance)

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

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)

Equipment Boiler EQUI3 Null Degreaser Boiler Ammonia

Arsenic compounds

Benzene

Beryllium

Cadmium compounds

Carbon Dioxide

Carbon Dioxide Equivalent

Carbon Monoxide

Chromium compounds

Cobalt compounds

Formaldehyde

HAPs - Total

Hexane

Manganese compounds

Mercury

Methane

Naphthalene

Nickel compounds

Nitrogen Oxides

Nitrous Oxide

Particulate Matter

PM < 2.5 micron

PM < 10 micron

Polycyclic organic matter

Selenium compounds

Sulfur Dioxide

Toluene

Volatile Organic Compoun..

EQUI4 Null Carbon Boiler Ammonia

Arsenic compounds

Benzene

Beryllium

Cadmium compounds

Carbon Dioxide

Carbon Dioxide Equivalent

Carbon Monoxide

Chromium compounds

Cobalt compounds

Formaldehyde

HAPs - Total

Hexane

Manganese compounds

Mercury

Methane

Naphthalene

Nickel compounds

Nitrogen Oxides

Nitrous Oxide

Particulate Matter

PM < 2.5 micron

PM < 10 micron

Polycyclic organic matter

Selenium compounds

Sulfur Dioxide

0.02471.53e-050.002691.08e-073.88e-070.03410.03410.03410.009880.449

9.43e-062.74e-060.01031.17e-061.71e-06

8080.008470.0003373.77e-076.29e-060.377542539

4.94e-065.39e-089.43e-068.98e-070.0144

0.02471.53e-050.002691.08e-073.88e-070.03410.03410.03410.009880.449

9.43e-062.74e-060.01031.17e-061.71e-060.008080.008470.0003373.77e-076.29e-060.377542539

4.94e-065.39e-089.43e-068.98e-070.0144

0.005643.49e-060.0006152.46e-088.86e-080.007790.007790.007790.002260.103

2.15e-066.26e-070.002362.67e-073.9e-070.001850.001937.69e-058.61e-081.44e-060.0861124123

1.13e-061.23e-082.15e-062.05e-070.00328

6.49e-082.34e-070.02060.02060.02060.005950.271

5.68e-061.65e-060.006227.03e-071.03e-060.004870.0051

0.0002032.27e-073.79e-060.227327325

2.98e-063.25e-085.68e-065.41e-070.00866

6.49e-082.34e-070.02060.02060.02060.005950.271

5.68e-061.65e-060.006227.03e-071.03e-060.004870.0051

0.0002032.27e-073.79e-060.227327325

2.98e-063.25e-085.68e-065.41e-070.00866

1.48e-085.34e-080.004690.004690.004690.001360.06181.3e-063.77e-070.001421.61e-072.35e-070.001110.001174.63e-055.19e-088.65e-070.051975.674.1

6.79e-077.41e-091.3e-061.24e-070.00198

PTE by subject item

Agency Interest: NoneAgency Interest ID: 5158Activity: None (Part 70 Reissuance)

Details for:SI Category: EquipmentSI Type: All

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)

Equipment Boiler EQUI4 Null Carbon BoilerSelenium compounds

Sulfur Dioxide

Toluene

Volatile Organic Compoun..

Degreaser EQUI1 EU001 Vapor Degreaser HAPs - Single

HAPs - Total

Tetrachloroethylene (Per..

0.01499.2e-060.00162

0.01499.2e-060.00162

0.00342.1e-060.000371

989898

245245245

565656

PTE by subject item



Subject ItemCategoryDescription

Subject Item TypeDescription Subject Item ID SI Designation and Description Relationship

Related SubjectItem ID

Related Subject ItemType Description

Start Date (RelatedSubject Item)

End Date (RelatedSubject Item)

Equipment Boiler EQUI3NullDegreaser Boiler

sends to STRU2 Stack/Vent 6/9/2017 Null



Degreaser EQUI1 EU001Vapor Degreaser

is controlledby

TREA1048-Activated CarbonAdsorption

12/6/2006 Null


SI - SI relationships



Subject ItemTypeDescription Subject Item ID SI Designation and Description Manufacturer Model

Max DesignCapacity

Max DesignCapacityUnits(numerator)

Max DesignCapacity Units(denominator) Material

ConstructionStart Date

OperationStart Date

ModificationDate

Degreaser EQUI1EU001Vapor Degreaser

Detrex Corporation 1DEL-750-1s16.01 pounds hours Solvents 8/15/1998 8/15/1998 Null

Emission Units 1


Details for:SI Category: NoneSI Type: Degreaser

Subject Item TypeDescription Subject Item ID SI Designation and Description Manufacturer Model

Max DesignCapacity

Max DesignCapacity Units(numerator)

Max DesignCapacity Units(denominator) Material

ConstructionStart Date

OperationStart Date

ModificationDate

Boiler EQUI3NullDegreaser Boiler

Cleaver BrooksCB700-60,150ST

1.05million Britishthermal units

hours Heat 8/15/1998 8/15/1998 Null


Columbia CT-15 630000British thermalunits

hours Heat 5/1/2013 5/1/2013 Null

Emission Units 2


Details for:SI Category: EquipmentSI Type: Boiler

Subject Item TypeDescription Subject Item ID SI Designation and Description

FiringMethod Engine Use

EngineDisplacement

EngineDisplacementUnits

Subject toCSAPR?

ElectricGeneratingCapacity(MW)

Boiler EQUI3NullDegreaser Boiler

Not coalburning

Null Null Null N Null


Not coalburning

Null Null Null N Null

Emission Units 2 (continued)


Details for:SI Category: EquipmentSI Type: Boiler

Subject ItemTypeDescription Subject Item ID SI Designation and Description Height

Units(height) Length

Units(length) Width

Units(width)

Building STRU3NullBuilding 1

20 feet 314 feet 183 feet

Buildings, General


Details for:SI Category: StructureSI Type: Building

Subject ItemTypeDescription Subject Item ID SI Designation and 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 STRU1SV001Degreaser Vent

25 1.16 Null Null 2100 70 ManufacturerUpwards with no cap onstack/vent

STRU2SV002Boiler Vent

22 1 Null Null 501 500 ManufacturerUpwards with no cap onstack/vent

STRU4NullCarbon Boiler

28 0.67 Null Null 60 475 ManufacturerUpwards with a cap onstack/vent

Stack/Vent, General


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

Subject Item TypeDescription Subject Item ID SI Designation and Description Manufacturer Model

InstallationStart Date Pollutant Controlled

CaptureEfficiency(%)

Destruction CollectEfficiency (%)

Subject toCAM?

Large orOther PSEU?

EfficiencyBasis

Otheroperatingparameters?

Other operatingparametersdescription

048-ActivatedCarbon Adsorption

TREA1CE001Activated Carbon Adsorption

AMCEC Inc. 0497 6/1/2007Tetrachloroethylene(Perchloroethylene)

100 60 No Null Other No Null

Other Control Equipment


Details for:SI Category: TreatmentSI Type: 048-Activated Carbon Adsorption

Subject Item ID Seq. # Requirement Citation

TFAC 1(01900055) 1

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

TFAC 1(01900055) 3

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

This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. Minn. R. 7007.1800, (A)(2)

TFAC 1(01900055) 7

The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA.

Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1‐2, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9

TFAC 1(01900055) 8

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

TFAC 1(01900055) 9

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

Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 2

TFAC 1(01900055) 10

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

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

TFAC 1(01900055) 11

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

TFAC 1(01900055) 12

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

TFAC 1(01900055) 13

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

TFAC 1(01900055) 14

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

TFAC 1(01900055) 15 The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. Minn. R. 7007.0800, subp. 16TFAC 1(01900055) 16

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

TFAC 1(01900055) 17

Performance Test No fica ons and Submi als:

Performance Test No fica on and Plan: due 30 days before each Performance TestPerformance Test Pre‐test Mee ng: due 7 days before each Performance TestPerformance Test Report: due 45 days a er each Performance Test

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

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


TFAC 1(01900055) 18

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

TFAC 1(01900055) 19

Monitoring Equipment Calibra on ‐ The Permi ee shall either:1. Calibrate or replace required monitoring equipment every 12 months; or2. Calibrate at the frequency stated in the manufacturer's specifica ons.

For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. Minn. R. 7007.0800, subp. 4(D)

TFAC 1(01900055) 20

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

TFAC 1(01900055) 25

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

TFAC 1(01900055) 26

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

TFAC 1(01900055) 27

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

TFAC 1(01900055) 28

If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. These records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. Minn. R. 7007.1200, subp. 4

TFAC 1(01900055) 29

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Minn. R. 7019.1000, subp. 3

TFAC 1(01900055) 30

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24‐hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2.

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

TFAC 1(01900055) 31

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


TFAC 1(01900055) 32

Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written descrip on:

1. the cause of the devia on; 2. the exact dates of the period of the devia on, if the devia on has been corrected;3. whether or not the devia on has been corrected; 4. the an cipated me by which the devia on is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Minn. R. 7019.1000, subp. 1

TFAC 1(01900055) 33

The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and July The first semiannual report submitted by the Permittee shall cover the calendar half‐year in which the permit is issued. The first report of each calendar year covers January 1 ‐ June 30. The second report of each calendar year covers July 1 ‐ December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations.

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

TFAC 1(01900055) 35

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

Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3.

Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 ‐ 7007.1500

TFAC 1(01900055) 36

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

TFAC 1(01900055) 38

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

TFAC 1(01900055) 39

Emission 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

TFAC 1(01900055) 40 Emission Fees: due 30 days after receipt of an MPCA bill. Minn. R. 7002.0005‐7002.0095

EQUI 1(EU001) 7

The Permittee shall limit emissions of Tetrachloroethylene (Perchloroethylene) <= 4800 kilograms per year 12‐month rolling sum (10,582 pounds/yr) as determined using the procedures in 40 CFR Section 63.471(c).

40 CFR 63.471(b)(2), 40 CFR 63.471(b)(2), Table 1, Minn. R. 7011.7200

EQUI 1(EU001) 13 Opacity <= 20 percent opacity. Minn. R. 7011.0715, subp. 1(B)

EQUI 1(EU001) 14

Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0715, subp. 1(A)

EQUI 1(EU001) 15

Except during unplanned breakdowns and scheduled shutdowns for maintenance purposes, the Permittee shall vent emissions from EQUI 1 to TREA 1 at all times that EQUI 1 is in operation. The Permittee shall keep written records documenting any period of TREA 1's non‐operation when EQUI 1 is operating. The above two requirements are state only requirements.

Minn. R. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a

EQUI 1(EU001) 19

Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, but is not limited to:

(1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere; or(2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions.

40 CFR 63.4(b), Minn. R. 7011.7000


EQUI 1(EU001) 23

Proper Operation and Maintenance: At all times, including periods of startup, shutdown and malfunction, the Permittee shall operate and maintain the emission unit subject to the MACT standard and its associated air pollution control and monitoring equipment in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards.

40 CFR 63.6(e)(1)(i), Minn. R. 7011.7000

EQUI 1(EU001) 24 Malfunctions shall be corrected as soon as practicable after their occurrence.

40 CFR 63.6(e)(1)(ii), Minn. R. 7011.7000

EQUI 1(EU001) 26

Notwithstanding the allowance to reduce the frequency of reporting for periodic SSM reports under 40 CFR Section 63.10(d)(5)(i), any time an action taken by the Permittee during a startup or shutdown that caused the source to exceed any applicable emission limitation in the standard, or malfunction (including actions taken to correct a malfunction) is not consistent with the procedures specified in the facility's SSMP, the Permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan followed by a letter within 7 working days after the end of the event. The immediate report required shall consist of a telephone call (FAX) to the Administrator within 2 working days after commencing actions inconsistent with the plan, and it shall be followed by a letter delivered or postmarked within 7 working days after the end of the event. The report shall contain the information specified in 40 CFR Section 63.10(d)(5)(ii).

40 CFR 63.10(d)(5)(ii), Minn. R. 7019.0100, subp. 2(B)

EQUI 1(EU001) 27

After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, the Permittee who constructs a new affected source that is not major‐emitting or reconstructs an affected source that is not major‐emitting that is subject to such standard, or reconstructs a source such that the source becomes an affected source subject to the standard, must notify the Administrator of the intended construction or reconstruction. The notification must be submitted in accordance with the procedures in 40 CFR Section 63.9(b).

40 CFR 63.5(b)(4)& Minn. R. 7011.7000

EQUI 1(EU001) 30

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

40 CFR 63.5(b), Minn. R. 7011.7000

EQUI 1(EU001) 33

The provisions of 40 CFR pt. 63, subp. T apply to each individual batch vapor, in‐line vapor, in‐line cold, and batch cold solvent cleaning machine that uses any solvent containing methylene chloride (CAS No. 75‐09‐2), perchloroethylene (CAS No. 127‐18‐4), trichloroethylene (CAS No. 79‐01‐6), 1,1,1‐trichloroethane (CAS No. 71‐55‐6), carbon tetrachloride (CAS No. 56‐23‐5) or chloroform (CAS No. 67‐66‐3), or any combination of these halogenated HAP solvents, in a total concentration greater than 5 percent by weight, as a cleaning and/or drying agent. The concentration of these solvents may be determined using EPA test method 18, material safety data sheets, or engineering calculations. Wipe cleaning activities, such as using a rag containing halogenated solvent or a spray cleaner containing halogenated solvent are not covered under the provisions of 40 CFR pt. 63, subp. T.

40 CFR 63.460(a), Minn. R. 7011.7200

EQUI 1(EU001) 34

For the purposes of 40 CFR pt. 63, subp. T, affected facility means all solvent cleaning machines, except solvent cleaning machines used in the manufacture and maintenance of aerospace products, solvent cleaning machines used in the manufacture of narrow tubing, and continuous web cleaning machines, located at a major source that are subject to the facility‐wide limits in 40 CFR Section 63.471(b)(2).

40 CFR 63.460(i), 40 CFR 63.471(a), Minn. R. 7011.7200

EQUI 1(EU001) 35

Clean Liquid Solvent: The Permittee shall, on the first operating day of every month, ensure that each solvent cleaning machine system contains only clean liquid solvent. This includes, but is not limited to, fresh unused solvent, recycled solvent, and used solvent that has been cleaned of soiled materials. A fill line must be indicated during the first month the measurements are made. The solvent level within the machine must be returned to the same fill‐line each month, immediately prior to calculating monthly emissions as specified in 40 CFR Section 63.471(c)(2) and (3). The solvent cleaning machine does not have to be emptied and filled with fresh unused solvent prior to the calculations.

40 CFR 63.471(c)(1), Minn. R. 7011.7200

EQUI 1(EU001) 36

Solvent Additions/Deletions Log: The Permittee shall maintain a log of solvent additions and deletions for each solvent cleaning machine.

40 CFR 63.471(b)(1), Minn. R. 7011.7200


EQUI 1(EU001) 37

Monthly Solvent Emissions Equation: The Permittee shall, on the first operating day of the month, using the records of all solvent additions and deletions for the previous month, determine solvent emissions (Eunit) from each solvent cleaning machine using the following equa on:

Eunit= SAi ‐ LSRi – SSRi

Where:

Eunit = The total halogenated HAP solvent emissions from the solvent cleaning machine during the most recent month i, (kilograms of solvent per month)

SAi = The total amount of halogenated HAP liquid solvent added to the solvent cleaning machine during the most recent month i, (kilograms of solvent per month)

LSRi = The total amount of halogenated HAP liquid solvent removed from the solvent cleaning machine during the most recent month i, (kilograms of solvent per month)

SSRi = The total amount of halogenated HAP solvent removed from the solvent cleaning machine in solid waste, obtained as described in 40 CFR Section 63.471 (c)(3) of this section, during the most recent month i, (kilograms of solvent per month).

40 CFR 63.471(c)(2), Minn. R. 7011.7200

EQUI 1(EU001) 38

Solid Solvent Removed (SSR): The Permittee shall, on the first operating day of the month, determine SSRi by engineering calculations included in the compliance report.

40 CFR 63.471(c)(3), Minn. R. 7011.7200

EQUI 1(EU001) 39

12‐month rolling total (ETunit): The Permittee shall on the first operating day of the month, after 12 months of emissions data are available, determine the 12‐month rolling total emissions, ETunit, for the 12‐month period ending with the most recent month using the equa on below:

ETunit = Sum (Eunit), from j=1 to 12

Where:

ETunit = The total halogenated HAP solvent emissions over the preceding 12 months, (kilograms of solvent emissions per 12‐month period).Eunit = Halogenated HAP solvent emissions for each month (j) for the most recent 12 months, (kilograms of solvent per month).

40 CFR 63.471(c)(4), Minn. R. 7011.7200

EQUI 1(EU001) 40

12‐month rolling total (ETfacility): The Permittee shall on the first operating day of the month, after 12 months of emissions data are available, determine the 12‐month rolling total emissions for the facility, ETfacility, for the 12‐month period ending with the most recent month using the equation below:

ETfacility = Sum (ETunit), from j=1 to i

Where:

ETfacility = The total halogenated HAP solvent emissions over the preceding 12 months for all cleaning machines at the facility, (kilograms of solvent emissions per 12‐month period).ETunit = The total halogenated HAP solvent emissions over the preceding 12 months for each unit j, where i equals the total number of units at the facility, (kilograms of solvent emissions per 12‐month period).

40 CFR 63.471(c)(5), Minn. R. 7011.7200

EQUI 1(EU001) 41

The Permittee shall maintain records specified below either in electronic or written form for a period of 5 years:

(1) The dates and amounts of solvent that are added to each solvent cleaning machine.

(2) The solvent composition of wastes removed from each solvent cleaning machines as determined using the procedure described in 40 CFR Sec on 63.471(c)(3).(3) Calculation sheets showing how monthly emissions and the 12‐month rolling total emissions from each solvent cleaning machine were determined, and the results of all calculations.

40 CFR 63.471(e), Minn. R. 7011.7200

EQUI 1(EU001) 42

Exceedance: If the applicable facility‐wide emission limit presented in Table 1 of 40 CFR Section 63.471 (b)(2) is not met, an exceedance has occurred. All exceedances shall be reported as required in Sec. 63.468(h).

40 CFR 63.471(d), Minn. R. 7011.7200

EQUI 1(EU001) 44

The Permittee shall use the following control combination: Option 6‐ Freeboard refrigeration device, reduced room draft, and freeboard ratio of 1.0.

40 CFR 63.463(b)(2)(i), Minn. R. 7011.7200

EQUI 1(EU001) 45

The Permittee shall ensure that each cleaning machine be designed or operated to have a reduced room draft as described in 40 CFR Section 63.463(e)(2)(ii).

40 CFR 63.463(a)(1)(ii), Minn. R. 7011.7200


EQUI 1(EU001) 46

The Permi ee shall ensure that the solvent cleaning machine has a freeboard ra o of 1.0.

(This limit is more stringent than 40 CFR Section 63.463(a)(2), which also applies. The requirement states that the freeboard ratio must be 0.75 or greater.).

40 CFR 63.463(a)(2), 40 CFR 63.463(b)(2)(i), Minn. R. 7011.7200

EQUI 1(EU001) 47

Each cleaning machine shall have an automated parts handling system capable of moving parts or parts baskets at a speed of 3.4 meters per minute (11 feet per minute) or less from the initial loading of parts through removal of cleaned parts.

40 CFR 63.463(a)(3), Minn. R. 7011.7200

EQUI 1(EU001) 49

Each vapor cleaning machine shall be equipped with a device that shuts off the sump heat if the sump liquid solvent level drops to the sump heater coils.

40 CFR 63.463(a)(4), Minn. R. 7011.7200

EQUI 1(EU001) 50

Each vapor cleaning machine shall be equipped with a vapor level control device that shuts off the sump heat if the vapor level in the vapor cleaning machine rises above the height of the primary condenser.

40 CFR 63.463(a)(5), Minn. R. 7011.7200

EQUI 1(EU001) 51 Each vapor cleaning machine shall have a primary condenser.

40 CFR 63.463(a)(6), Minn. R. 7011.7200

EQUI 1(EU001) 52

The Permittee shall control air disturbances across the cleaning machine opening(s) by incorporating a reduced room draft as described in 40 CFR Section 63.463(e)(2)(ii).

40 CFR 63.463(d)(1)(ii), Minn. R. 7011.7200

EQUI 1(EU001) 53

The parts baskets or the parts being cleaned in an open‐top batch vapor cleaning machine shall not occupy more than 50 percent of the solvent/air interface area unless the parts baskets or parts are introduced at a speed of 0.9 meters per minute (3 feet per minute) or less.

40 CFR 63.463(d)(2), Minn. R. 7011.7200

EQUI 1(EU001) 54

The Permittee shall complete any spraying operations within the vapor zone or within a section of the solvent cleaning machine that is not directly exposed to the ambient air (i.e., a baffled or enclosed area of the solvent cleaning machine).

40 CFR 63.463(d)(3), Minn. R. 7011.7200

EQUI 1(EU001) 55

The Permittee shall orient parts so that the solvent drains from them freely. Parts having cavities or blind holes shall be tipped or rotated before being removed from any solvent cleaning machine unless an equally effective approach has been approved by the Administrator.

40 CFR 63.463(d)(4), Minn. R. 7011.7200

EQUI 1(EU001) 56

The Permittee shall not remove parts baskets or parts from any solvent cleaning machine until dripping has stopped.

40 CFR 63.463(d)(5), Minn. R. 7011.7200

EQUI 1(EU001) 57

During startup of each vapor cleaning machine, the Permittee shall turn on the primary condenser before the sump heater.

40 CFR 63.463(d)(6), Minn. R. 7011.7200

EQUI 1(EU001) 58

During shutdown of each vapor cleaning machine, the Permittee shall turn off the sump heater and allow the solvent vapor layer to collapse before the primary condenser is turned off.

40 CFR 63.463(d)(7), Minn. R. 7011.7200

EQUI 1(EU001) 60

When solvent is added or drained from any solvent cleaning machine, the Permittee shall transfer the solvent using threaded or other leakproof couplings and locate the end of the pipe in the solvent sump beneath the liquid solvent surface.

40 CFR 63.463(d)(8), Minn. R. 7011.7200

EQUI 1(EU001) 61

The Permittee shall maintain each solvent cleaning machine and associated controls as recommended by the manufacturers of the equipment or using alternative maintenance practices that have been demonstrated to the Commissioner's satisfaction to achieve the same or better results as those recommended by the manufacturer.

40 CFR 63.463(d)(9), Minn. R. 7011.7200

EQUI 1(EU001) 62

The Permittee shall complete and pass the applicable sections of the test of solvent cleaning procedures in appendix A to 40 CFR pt. 63, subp. T if requested during an inspection by the Administrator.

40 CFR 63.463(d)(10), Minn. R. 7011.7200

EQUI 1(EU001) 63

The Permittee shall collect and store waste solvent, still bottoms, and sump bottoms in closed containers. The closed containers may contain a device that would allow pressure relief, but would not allow liquid solvent to drain from the container.

40 CFR 63.463(d)(11), Minn. R. 7011.7200

EQUI 1(EU001) 64 The Permittee shall not clean sponges, fabric, wood, and paper products.

40 CFR 63.463(d)(12), Minn. R. 7011.7200

EQUI 1(EU001) 65

The Permittee shall ensure that the chilled air blanket temperature (in degrees F), measured at the center of the air blanket, is no greater than 30 percent of the solvent's boiling point.

An exceedance has occurred if the above requirement has not been met and is not corrected within 15 days of detection. Adjustments or repairs shall be made to the solvent cleaning system or control device to reestablish required levels. The parameter must be re‐measured immediately upon adjustment or repair and demonstrated to be within required limits.

40 CFR 63.463(e)(2)(i), 40 CFR 63.463(e)(3)(ii), Minn. R. 7011.7200


EQUI 1(EU001) 69

The Permittee shall ensure that the flow or movement of air across the top of the freeboard area of the solvent cleaning machine or within the solvent cleaning machine enclosure does not exceed 15.2 meters per minute (50 feet per minute) at any time as measured using the procedures in 40 CFR Sec on 63.466(d).

An exceedance has occurred if the above requirement has not been met and is not corrected within 15 days of detection. The Permittee shall make adjustments or repairs to the solvent cleaning system or control device to reestablish required levels. The parameter must be remeasured immediately upon adjustment or repair and demonstrated to be within required limits.

40 CFR 63.463(e)(2)(ii)(A), 40 CFR 63.463(e)(3)(ii), Minn. R. 7011.7200

EQUI 1(EU001) 70

The Permittee shall establish and maintain the operating conditions under which the wind speed was demonstrated to be 15.2 meters per minute (50 feet per minute) or less as described in 40 CFR Sec on 63.466(d).

An exceedance has occurred if the above requirement has not been met.

40 CFR 63.463(e)(2)(ii)(B), 40 CFR 63.463(e)(3)(i), Minn. R. 7011.7200

EQUI 1(EU001) 71

The Permittee shall determine the potential to emit from all solvent cleaning operations using the procedures described in 40 CFR Section 63.465(e)(1) through (3). A facility's total potential to emit is the sum of the HAP emissions from all solvent cleaning operations, plus all HAP emissions from other sources within the facility.

40 CFR 63.465(e), Minn. R. 7011.7200

EQUI 1(EU001) 72

The Permittee shall determine the potential to emit for each individual solvent cleaning using the following equa on:

PTEi = Hi * Wi * SAIi

Where:

PTEi = the poten al to emit for solvent cleaning machine i (kilograms of solvent per year).Hi = hours of operation for solvent cleaning machine i (hours per year) = 8760 hours per year, unless otherwise restricted by a Federally enforceable requirement.

Wi = the working mode uncontrolled emission rate (kilograms per square meter per hour) = 1.95 kilograms per square meter per hourSAIi = solvent/air interface area of solvent cleaning machine i (square meters).

40 CFR 63.465(e)(1), Minn. R. 7011.7200

EQUI 1(EU001) 73

Sum the PTEi for all solvent cleaning operations to obtain the total potential to emit for solvent cleaning operations at the facility.

40 CFR 63.465(e)(3), Minn. R. 7011.7200

EQUI 1(EU001) 75

The Permittee shall use a thermometer or thermocouple to measure the temperature at the center of the air blanket during the idling mode.

The temperature shall be monitored and the results recorded on a weekly basis.40 CFR 63.466(a)(1), Minn. R. 7011.7200

EQUI 1(EU001) 77

The Permi ee shall monitor the hoist speed as described below:

(1) Determine the hoist speed by measuring the time it takes for the hoist to travel a measured distance. The speed is equal to the distance in meters or feet divided by the time in minutes (meters or feet per minute, respec vely).

(2) The monitoring shall be conducted monthly. If after the first year, no exceedances of the hoist speed are measured, the Permi ee may begin monitoring the hoist speed quarterly.

(3) If an exceedance of the hoist speed occurs during quarterly monitoring, the monitoring frequency returns to monthly until another year of compliance without an exceedance is demonstrated.

(4) If the Permittee can demonstrate to the Administrator's satisfaction in the initial compliance report that the hoist cannot exceed a speed of 11 feet per minute (3.4 meters per minute), the required monitoring frequency is quarterly, including during the first year of compliance.

40 CFR 63.466(c), Minn. R. 7011.7200

EQUI 1(EU001) 78

The Permittee shall conduct an initial monitoring test and, thereafter, monthly monitoring tests of the wind speed within the enclosure using the procedure specified below:(i) Determine the direction of the wind current in the enclosure by slowly rotating a velometer inside the entrance to the enclosure un l the maximum speed is located.(ii) Record the maximum wind speed.

The Permittee shall conduct a monthly visual inspection of the enclosure to determine if it is free of cracks, holes and other defects.

40 CFR 63.463(e)(1), 40 CFR 63.466(d)(2), Minn. R. 7011.7200


EQUI 1(EU001) 79 The Permittee can use alternative monitoring procedures approved by the Administrator.

40 CFR 63.466(g), Minn. R. 7011.7200

EQUI 1(EU001) 80

The Permittee shall maintain the following records, in written or electronic form, for the lifetime of the machine:

‐ Owner's manuals, or if not available, written maintenance and operating procedures, for the solvent cleaning machine and control equipment. ‐ The date of installation for the solvent cleaning machine and all of its control devices. If the exact date of installation is not known, a letter certifying that the cleaning machine and its control devices were installed prior to, or on, November 29, 1993, or after November 29, 1993, may be subs tuted. ‐ Records of the initial performance test, including the idling emission rate and the values of monitoring parameters measured during the test.‐ Records of the halogenated HAP solvent content for each solvent used in the solvent cleaning machine subject to the provisions of 40 CFR pt. 63, subp. T.

40 CFR 63.467(a), Minn. R. 7011.7200

EQUI 1(EU001) 81

The Permittee shall maintain the following records, in written or electronic form, for a period of 5 years:

‐ The results of control device monitoring required under 40 CFR Sec on 63.466. ‐ Information on the actions taken to comply with 40 CFR Section 63.463(e) and 63.463(f). This information shall include records of written or verbal orders for replacement parts, a description of the repairs made, and additional monitoring conducted to demonstrate that monitored parameters have returned to accepted levels. ‐ Es mates of annual solvent consump on for each solvent cleaning machine.

‐ Records of the date and results of the weekly measurement of the halogenated HAP solvent concentration in the carbon adsorber exhaust required in 40 CFR Section 63.466(e).

40 CFR 63.467(b), Minn. R. 7011.7200

EQUI 1(EU001) 84

The Permittee shall submit an exceedance report: Due semiannually, by the 30th of January and July. The Permittee shall submit an exceedance report to the Commissioner semiannually except when, the Administrator determines on a case‐by‐case basis that more frequent reporting is necessary to accurately assess the compliance status of the source, or an exceedance occurs. Once an exceedance has occurred, the Permittee shall follow a quarterly reporting format until a request to reduce reporting frequency under 40 CFR Section 63.468(i) is approved. Exceedance reports shall be delivered or postmarked by the 30th day following the end of each calendar half or quarter, as appropriate.

40 CFR 63.463(e)(4), 40 CFR 63.463(f)(5), 40 CFR 63.468(h), Minn. R. 7011.7200

EQUI 1(EU001) 86

The Exceedance Report shall include: (1) Information on actions taken to comply with 40 CFR Section 63.463(e) and 63.463(f), including records of written or verbal orders for replacement parts, a description of the repairs made, and additional monitoring conducted to demonstrate that monitored parameters have returned to accepted levels. (2) If an exceedance has occurred, the reason for the exceedance and a description of the actions taken. (3) If no exceedances of a parameter have occurred, or if a piece of equipment has not been inoperative, out of control, repaired, or adjusted, such information shall be stated in the report.

40 CFR 63.468(h), Minn. R. 7011.7200

EQUI 1(EU001) 87

If the Permittee is required to submit an exceedance report on a quarterly (or more frequent) basis, the Permittee may reduce the frequency of reporting to semiannual if the conditions below are met:

(1) The source has demonstrated a full year of compliance without an exceedance.(2) The Permittee continues to comply with all relevant recordkeeping and monitoring requirements specified in 40 CFR pt. 63, subp. A (General Provisions) and in 40 CFR pt. 63, subp. T.(3) The Administrator does not object to a reduced frequency of reporting for the affected source as provided in 40 CFR Section 63.10(e)(3)(iii).

40 CFR 63.468(i), Minn. R. 7011.7200

EQUI 1(EU001) 88 The Permittee shall submit an annual report: Due annually, by the 1st of February.

40 CFR 63.648(f), Minn. R. 7011.7200


EQUI 1(EU001) 89

The annual report shall include the following:

(1) A signed statement from the Permittee stating that "All operators of solvent cleaning machines have received training on the proper operation of solvent cleaning machines and their control devices sufficient to pass the test in 40 CFR Sec on 63.463(d)(10)."(2) An estimate of the solvent consumption for each solvent cleaning machine during the reporting period.

40 CFR 63.468(f), Minn. R. 7011.7200

EQUI 334

Particulate Matter <= 0.4 pounds per million Btu heat input The potential to emit from the unit is 0.007 lb/MMBtu due to equipment design and allowable fuels. Minn. R. 7011.0515, subp. 1

EQUI 335

Opacity <= 20 percent opacity except for one six‐minute period per hour of not more than 60 percent opacity. Minn. R. 7011.0515, subp. 2

EQUI 338

The Permittee must comply with all applicable requirements of 40 CFR pt. 63, subp. DDDDD, as follows:

40 CFR Section 63.7485; 40 CFR Section 63.7490(a)(1);40 CFR Section 63.7490(d); 40 CFR Section 63.7499(l); 40 CFR Section 63.7500(a)(1); 40 CFR Section 63.7500(a)(3); 40 CFR Section 63.7500(e); 40 CFR Section 63.7500(f); 40 CFR Section 63.7505(a); 40 CFR Section 63.7515(d); 40 CFR Section 63.7540(a)(10)(i); 40 CFR Section 63.7540(a)(10)(ii); 40 CFR Section 63.7540(a)(10)(iii); 40 CFR Section 63.7540(a)(10)(iv); 40 CFR Section 63.7540(a)(10)(v); 40 CFR Section 63.7540(a)(10)(vi)(A); 40 CFR Section 63.7540(a)(10)(vi)(B); 40 CFR Section 63.7540(a)(10)(vi)(C); 40 CFR Section 63.7540(a)(12); 40 CFR Section 63.7540(a)(13); 40 CFR Section 63.7550(a);40 CFR Section 63.7550(b)(1);

40 CFR Section 63.7550(b)(2); 40 CFR Section 63.7550(b)(3);40 CFR Section 63.7550(b)(4); 40 CFR Section 63.7550(b)(5); 40 CFR Section 63.7550(c)(1);40 CFR Section 63.7550(c)(5)(i);40 CFR Section 63.7550(c)(5)(ii); 40 CFR Section 63.7550(c)(5)(iii);40 CFR Section 63.7550(c)(5)(xiv);40 CFR Section 63.7550(c)(5)(xvii); 40 CFR Section 63.7550(h)(3);40 CFR Section 63.7555(a)(1); 40 CFR Section 63.7560(a); 40 CFR Section 63.7560(b); 40 CFR Section 63.7560(c); 40 CFR Section 63.7565; 40 CFR Section 63.7575; 40 CFR pt. 63, subp. DDDDD, Table 3, Item 1, and Item 4; 40 CFR pt. 63, subp. DDDDD, Table 9, Item 1; and40 CFR pt. 63, subp. DDDDD, Table 10.

A copy of 40 CFR pt. 63, subp. DDDDD is included in Appendix B.

If the standard changes or upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3.

40 CFR 63. subp. DDDDD, Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150‐1500, Minn. R. 7011.7050


EQUI 339

The Permittee must comply with all applicable requirements of 40 CFR pt. 63, subp A, as follows:

40 CFR Section 63.1; 40 CFR Section 63.2; 40 CFR Section 63.3; 40 CFR Section 63.4; 40 CFR Section 63.5; 40 CFR Section 63.6(a); 40 CFR Section 63.6(b)(1)‐(b)(5); 40 CFR Section 63.6(b)(7); 40 CFR Section 63.6(c); 40 CFR Section 63.6(f)(2) and (f)(3); 40 CFR Section 63.6(g); 40 CFR Section 63.6(i); 40 CFR Section 63.6(j); 40 CFR Section 63.7(a)‐(d); 40 CFR Section 63.7(e)(2)‐(e)(9) and (f)‐(h); 40 CFR Section 63.8(a) and (b); 40 CFR Section 63.8(c)(1); 40 CFR Section 63.8(c)(1)(ii); 40 CFR Section 63.8(c)(2)‐(c)(9);

40 CFR Section 63.8(d)(1) and (2); 40 CFR Section 63.8(d)(3); 40 CFR Section 63.8(e); 40 CFR Section 63.8(f); 40 CFR Section 63.8(g); 40 CFR Section 63.9; 40 CFR Section 63.10(a); 40 CFR Section 63.10(b)(1); 40 CFR Section 63.10(b)(2)(i); 40 CFR Section 63.10(b)(2)(iii); 40 CFR Section 63.10(b)(2)(vi); 40 CFR Section 63.10(b)(2)(vii)‐(xiv); 40 CFR Section 63.10(c)(1)‐(9); 40 CFR Section 63.10(c)(12)‐(13); 40 CFR Section 63.10(d)(1)‐(2); 40 CFR Section 6¬¬3.10(d)(4); 40 CFR Section 63.10(e); 40 CFR Section 63.10(f); 40 CFR Section 63.12; and40 CFR Section 63.13‐63.16.

A copy of 40 CFR pt. 63, subp. A is included in Appendix C.


40 CFR 63. subp. A, 40 CFR 63.7565, Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150‐1500, Minn. R. 7011.7000, Minn. R. 7011.7050

EQUI 340

The Permittee must submit a compliance report every 5 years as specified in 40 CFR Section 63.7550(b)(1) through (4). The 5‐year compliance report must cover the period beginning on January 31, 2016, and ending on December 31 within 5 years after January 31, 2016. The first 5‐year compliance report must be postmarked or submitted no later than January 31. Each subsequent biennial compliance report must cover the applicable 5‐year period from January 1 to December 31. Each subsequent biennial compliance report must be postmarked or submitted no later than January 31.

The compliance report must contain the information specified in 40 CFR Section 63.7550(c)(5)(i)‐(iii), (xiv), and (xvii).

40 CFR 63.7550(b), 40 CFR 63.7550(c)(1), Minn. R. 7011.7050

EQUI 341 Permitted Fuel: Natural Gas only. Minn. R. 7007.0800, subp. 2

EQUI 41

Particulate Matter <= 0.4 pounds per million Btu heat input The potential to emit from the unit is 0.007 lb/MMBtu due to equipment design and allowable fuels. Minn. R. 7011.0515, subp. 1


EQUI 42

Opacity <= 20 percent opacity except for one six‐minute period per hour of not more than 60 percent opacity. Minn. R. 7011.0515, subp. 2

EQUI 45

The Permittee must comply with all applicable requirements of 40 CFR pt. 63, subp. DDDDD, as follows:

40 CFR Section 63.7485; 40 CFR Section 63.7490(a)(2); 40 CFR Section 63.7490(b);40 CFR Section 63.7499(l); 40 CFR Section 63.7500(a)(1); 40 CFR Section 63.7500(a)(3); 40 CFR Section 63.7500(e); 40 CFR Section 63.7500(f); 40 CFR Section 63.7505(a); 40 CFR Section 63.7510(g); 40 CFR Section 63.7515(d); 40 CFR Section 63.7540(a)(10)(i); 40 CFR Section 63.7540(a)(10)(ii); 40 CFR Section 63.7540(a)(10)(iii); 40 CFR Section 63.7540(a)(10)(iv); 40 CFR Section 63.7540(a)(10)(v); 40 CFR Section 63.7540(a)(10)(vi)(A); 40 CFR Section 63.7540(a)(10)(vi)(B); 40 CFR Section 63.7540(a)(10)(vi)(C); 40 CFR Section 63.7540(a)(12); 40 CFR Section 63.7540(a)(13); 40 CFR Section 63.7550(a);40 CFR Section 63.7550(b)(1);

40 CFR Section 63.7550(b)(2); 40 CFR Section 63.7550(b)(3);40 CFR Section 63.7550(b)(4); 40 CFR Section 63.7550(b)(5); 40 CFR Section 63.7550(c)(1);40 CFR Section 63.7550(c)(5)(i);40 CFR Section 63.7550(c)(5)(ii); 40 CFR Section 63.7550(c)(5)(iii);40 CFR Section 63.7550(c)(5)(xiv);40 CFR Section 63.7550(c)(5)(xvii); 40 CFR Section 63.7550(h)(3);40 CFR Section 63.7555(a)(1); 40 CFR Section 63.7560(a); 40 CFR Section 63.7560(b); 40 CFR Section 63.7560(c); 40 CFR Section 63.7565; 40 CFR Section 63.7575; 40 CFR pt. 63, subp. DDDDD, Table 3, Item 1; 40 CFR pt. 63, subp. DDDDD, Table 9, Item 1; and40 CFR pt. 63, subp. DDDDD, Table 10.

A copy of 40 CFR pt. 63, subp. DDDDD is included in Appendix B.


40 CFR 63. subp. DDDDD, Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150‐1500, Minn. R. 7011.7050


EQUI 46

The Permittee must comply with all applicable requirements of 40 CFR pt. 63, subp A, as follows:

40 CFR Section 63.1; 40 CFR Section 63.2; 40 CFR Section 63.3; 40 CFR Section 63.4; 40 CFR Section 63.5; 40 CFR Section 63.6(a); 40 CFR Section 63.6(b)(1)‐(b)(5); 40 CFR Section 63.6(b)(7); 40 CFR Section 63.6(c); 40 CFR Section 63.6(f)(2) and (f)(3); 40 CFR Section 63.6(g); 40 CFR Section 63.6(i); 40 CFR Section 63.6(j); 40 CFR Section 63.7(a)‐(d); 40 CFR Section 63.7(e)(2)‐(e)(9) and (f)‐(h); 40 CFR Section 63.8(a) and (b); 40 CFR Section 63.8(c)(1); 40 CFR Section 63.8(c)(1)(ii); 40 CFR Section 63.8(c)(2)‐(c)(9);

40 CFR Section 63.8(d)(1) and (2); 40 CFR Section 63.8(d)(3); 40 CFR Section 63.8(e); 40 CFR Section 63.8(f); 40 CFR Section 63.8(g); 40 CFR Section 63.9; 40 CFR Section 63.10(a); 40 CFR Section 63.10(b)(1); 40 CFR Section 63.10(b)(2)(i); 40 CFR Section 63.10(b)(2)(iii); 40 CFR Section 63.10(b)(2)(vi); 40 CFR Section 63.10(b)(2)(vii)‐(xiv); 40 CFR Section 63.10(c)(1)‐(9); 40 CFR Section 63.10(c)(12)‐(13); 40 CFR Section 63.10(d)(1)‐(2); 40 CFR Section 6¬¬3.10(d)(4); 40 CFR Section 63.10(e); 40 CFR Section 63.10(f); 40 CFR Section 63.12; and40 CFR Section 63.13‐63.16.

A copy of 40 CFR pt. 63, subp. A is included in Appendix C.


40 CFR 63. subp. A, 40 CFR 63.7565, Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150‐1500, Minn. R. 7011.7000, Minn. R. 7011.7050

EQUI 47

The Permittee must submit a compliance report biennially as specified in 40 CFR Section 63.7550(b)(1) through (4). The biennial compliance report must cover the period beginning on January 31, 2016, and ending on December 31 within 2 years after January 31, 2016. The first biennial compliance report must be postmarked or submitted no later than January 31. Each subsequent biennial compliance report must cover the applicable 2‐year period from January 1 to December 31. Each subsequent biennial compliance report must be postmarked or submitted no later than January 31.

The compliance report must contain the information specified in 40 CFR Section 63.7550(c)(5)(i)‐(iii), (xiv), and (xvii).

40 CFR 63.7550(b), 40 CFR 63.7550(c)(1), Minn. R. 7011.7050

EQUI 48 Permitted Fuel: Natural Gas only. Minn. R. 7007.0800, subp. 2

TREA 1(CE001) 1

The Permittee shall vent emissions from EQUI 1 to control equipment meeting the requirements of TREA 1 whenever EQUI 1 operates.

Minn. R. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a


TREA 1(CE001) 2

The Permittee shall operate and maintain the control equipment such that it achieves an overall Control Efficiency for Tetrachloroethylene (Perchloroethylene) >= 60 percent.

Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a

TREA 1(CE001) 3

On each day of operation, the Permittee shall record and maintain the total quantity of Tetrachloroethylene used in EQUI 1.

Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2

TREA 1(CE001) 4

On each day of operation, the Permittee shall record and maintain the total quantity of Tetrachloroethylene recovered from EQUI 1.


TREA 1(CE001) 5

The Permittee shall use a Material Balance as described below to demonstrate compliance with the required Control Efficiency.


TREA 1(CE001) 6

Monthly Recordkeeping ‐‐ Tetrachlorethylene Material Balance:

By the 15th of the month, the Permittee shall calculate and record the following:

1) The total Tetrachlorethylene used during the previous calendar month using daily usage records.

2) The total amount of Tetrachlorethylene recovered during the previous calendar month using daily records.

3) The percentage of Tetrachlorethylene recovered to determine Control Efficiency for the previous month, calculated by dividing the amount of Tetrachloroethylene recovered by the amount of Tetrachloroethylene used.


TREA 1(CE001) 8

Bypass Prohibited: The Permittee shall ensure that the carbon adsorber bed is not bypassed during desorption.


TREA 1(CE001) 9

If the Permittee replaces TREA 1, the replacement control must meet or exceed the control efficiency requirements of TREA 1 as well as comply with all other requirements of TREA 1. Prior to making such a 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 the Agency using Form CR‐05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. Minn. R. 7007.0800, subp. 2

TREA 1(CE001) 10

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

TREA 1(CE001) 11

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect TREA 1's components. The Permittee shall maintain a written record of these inspections.

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

TREA 1(CE001) 12

Corrective Actions: If the Carbon Adsorption Unit or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the unit. The Permittee shall keep a record of the type and date of any corrective action taken.

Minn. R. 7007.08, subp. 4, Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 5

TREA 1(CE001) 13

Regular Training: Regular training courses shall be held by in‐house personnel or through the use of outside expertise. The set of manuals provided as part of the initial training shall include manufacturer‐recommended maintenance procedures. Training shall be conducted annually, and at a minimum, include a review of these documents and confirmation of the original operating parameters. Training shall include written instructions and practical experience sessions on safety, inspection procedures, system monitoring equipment and procedures, routine maintenance procedures and recordkeeping.

Records of this training shall be kept on‐site.Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5


TREA 1(CE001) 14

If the Permittee replaces TREA 1 with a different model, initial training on the proper operation of the replacement unit shall be provided by the manufacturer upon installation. The manufacturer's initial training will include introductory training for facility operators and maintenance personnel. The manufacturer's field service technician or engineer will instruct the Permittee's personnel in methods for ensuring proper operation of the system components, checking and resetting system instrumenta on and controls, and performing simple troubleshoo ng.

Records of this training shall be kept on‐site.Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5

Attachment 3 – Total enclosure notification

technical support document for draft air emission permit

Documents