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MPCA Air Quality Permits Guide

Part 1 Defining Your Facility

Prepared by: Air Quality Staff

Minnesota Control Agency

520 Lafayette St. Paul, MN 55155

 March 1994 Revised September 1998

Printed on paper containing at least 20 percent fibers from paper recycled from consumers. Part 1 Acknowledgments March 1994 version: Author: Barbara Conti

Contributors: Lori Bartels Leo Raudys Dick Cordes Kathy Seeburger Bernadette Halverson Toni Stevens Julie Hendricks Mark Strange Mary Hoffman Phyllis Strong Barb Loida Neesha Wolf MPCA Air Quality Division Minnesota Office of the Attorney General

Project Manager: Leo Raudys

Editor: Valerie Williams, VKW Consulting

Graphic Design and Layout: Dick Garrison, Garrison Design (March 1994 version only)

Additional assistance provided Rust Environment & Infrastructure by: 1998 revision: Coordinator: Toni Volkmeier

Contributors: Peggy Bartz Bonnie Nelson

The MPCA would also like to thank the following individuals and organizations for provided advice and assistance during initial development of this document: MPCA Small Business Compliance Advisory Council William R. McMurtry, Honeywell, Inc. Tim Casey, HDR Engineering, Inc. Mike Medina, Unisys Karl DeWahl, Minnesota Technical Assistance Program Craig Moody, University of Minnesota Duane Dittberner, Unisys Mark Sytsma, Woodcraft Industries, Inc. James N. Friedman, Interpoll Laboratories, Inc. Mike Valentine, Braun Intertec Stephen F. Haselmann, Waldorf Corporation Lee Walz, DeZurik Elizabeth Henderson, Wenck Associates, Inc. Richard Svanda, Jostens Gary Kaziukewicz, Waldorf Corporation Paul Kramer, Rahr Malting Company Richard T. Kennealy, Jr., United Defense, L.P. Ahto Niemioja, Braun Intertec Allan Kremer, Hennepin Energy Resource Company Mary Sands, DPRA Incorporated Mary Kruger, Department of Trade and Economic Development Richard D. Lowe, American Engineering Testing, Inc. Gary J. Nierengarten, Frigidaire Company - Freezer Products Michael K. Vennewitz, Capsule Environmental Engineering, Inc. Bill Wall, ENSR Consulting and Engineering Table of Contents

Preface To The Guide...... v Focus Of Part 1 ...... vii 1.0 What Is A Permit?...... 1-1 2.0 What Air Are Regulated By The MPCA?...... 2-1 2.1 Criteria pollutants...... 2-1 2.2 Volatile Organic Compounds (VOCs) ...... 2-2 2.3 Hazardous Air Pollutants (HAPs) ...... 2-4 2.4 Other regulated pollutants ...... 2-4 3.0 Steps For Completing A Permit Application ...... 3-1 4.0 How Is Your Facility Defined? ...... 4-1 4.1 What are your emission points? ...... 4-1 4.2 What are your emission units? ...... 4-2 4.3 How should you describe your operations?...... 4-3 5.0 What Is Potential To Emit (PTE)?...... 5-1 5.1 How do you calculate Potential to Emit (PTE)? ...... 5-1 5.1.1 What references can you use to calculate PTE?...... 5-2 5.1.2 Examples of potential emissions calculations...... 5-3 5.1.3 What is the next step after calculating the PTE of your emission units? ... 5-8 5.1.4 What about fugitive emissions? ...... 5-9 5.1.5 What if your PTE is below the thresholds?...... 5-10 5.2 Do you need any other emissions data? ...... 5-11 5.2.1 What are your actual emissions?...... 5-11 5.3 How can you limit your Potential to Emit (PTE)? ...... 5-12 5.3.1 What about your control equipment? ...... 5-12 5.3.2 What if you do not want to be subject to federal regulations? ...... 5-12 5.3.2.1 What are acceptable options for synthetic minor limits? ...... 5-13 6.0 What Rules And Regulations Apply To You? ...... 6-1 6.1 What are the federal regulations?...... 6-1 6.1.1 National Ambient Air Quality Standards (NAAQS)...... 6-1 6.1.1.1 State Implementation Plan ...... 6-2 6.1.2 National Emission Standards for Hazardous Air Pollutants (NESHAPs)...... 6-2 6.1.3 New Source Review (NSR)...... 6-3 6.1.3.1 Does NSR apply to your facility?...... 6-4 6.1.3.2 What is required for NSR?...... 6-5 6.1.4 New Source Performance Standards (NSPS)...... 6-6 6.1.4.1 An example of an NSPS...... 6-7

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page i 6.1.5 ...... 6-7 6.1.6 Stratospheric protection...... 6-7 6.1.7 Compliance assurance monitoring ...... 6-8 6.2 What are the Minnesota rules?...... 6-8 6.2.1 Air Quality permit rule...... 6-9 6.2.2 Environmental review program...... 6-9 6.2.3 Standards of performance for stationary sources ...... 6-10 6.2.4 Emission inventory and air quality emission fees ...... 6-10 6.2.5 Performance testing for emissions ...... 6-11

7.0 How Do You Maintain Flexibility In Your Operations?...... 7-1 7.1 What is operational flexibility?...... 7-1 7.1.1 Alternative operating scenarios...... 7-1 7.1.2 Emission trading...... 7-2

8.0 What If You Have Confidential Material In An Application? ...... 8-1 9.0 What Is In A Complete Permit Application?...... 9-1 9.1 Why is a "complete" application important?...... 9-1 9.2 When were complete permit applications due?...... 9-2 9.3 What happens to your application at the MPCA? ...... 9-3 10.0 Case Study -- Blue Ox Woodworks...... 10-1 10.1 History of Blue Ox Woodworks...... 10-1 10.2 Blue Ox Woodworks Emission Unit Information...... 10-2 10.2.1 Boilers ...... 10-2 10.2.2 Milling operations ...... 10-3 10.2.3 Painting operations...... 10-6 10.2.4 Diesel generator...... 10-7 10.2.5 Fugitive dust emissions ...... 10-7 10.2.6 Insignificant activities ...... 10-7 10.3 Blue Ox Woodworks emission calculations...... 10-7 10.3.1 Wood boiler #1 calculations...... 10-8 10.3.2 New boiler #2 calculations...... 10-9 10.3.3 Milling equipment calculations...... 10-11 10.3.4 Painting equipment calculations...... 10-11 10.3.5 Diesel generator calculations...... 10-19 10.3.6 Summary of all potential to emit calculations...... 10-19 10.3.7 Proposed permit conditions and operating limits...... 10-20

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page ii FIGURES Figure 1-1 What Type of Air Emission Permit Do You Need?...... 1-2 Figure 3-1 The Permit Application Process...... 3-1 Figure 9-1 Process to Issue an Air Emission Permit for a Total Facility...... 9-4

TABLES Table 2-1 Chemicals Not Considered Volatile Organic Compounds (VOCs) ...... 2-2 Table 2-2 188 Hazardous Air Pollutants ...... 2-5 Table 5-1 Methods for Calculating Emissions ...... 5-4 Table 5-2 Emission Thresholds Requiring a Permit...... 5-9 Table 5-3 Types of Facilities That Include Fugitive Emissions in PTE...... 5-10 Table 6-1 Nonattainment Areas in Minnesota...... 6-2 Table 6-2 Sources that are Major for NSR if PTE Exceeds 100 Tons Per Year ...... 6-5 Table 6-3 Minnesota's Air Quality Rules Relating to Air Emission Facilities...... 6-8 Table 9-1 Summary of Information to be Included in an Application...... 9-2 Table 9-2 Due Dates for Facility Air Emission Permit Applications ...... 9-2

APPENDIX 1 Appendix 1-A Activities Not Required to be Listed in Your Application...... 1A-1 Appendix 1-B Insignificant Activities Required to be Listed in Your Application..... 1B-1

APPENDIX 2 Appendix 2-A List of References and Ordering Information...... 2A-1

APPENDIX 3 Appendix 3-A Nonattainment Area Maps ...... 3A-1

APPENDIX 4 Appendix 4-A Mandatory EAW Categories ...... 4A-1 Appendix 4-B Mandatory EIS Categories ...... 4B-1

APPENDIX 5 Appendix 5-A Application Forms for Blue Ox Woodworks ...... 5A-1

APPENDIX 6 Appendix 6-A Fact Sheet: Control Equipment Standards ...... 6A-1 ACRONYMS GLOSSARY

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page iii

PREFACE TO THE GUIDE The MPCA Air Quality Permits Guide is a three-part document intended to help you learn whether you need an air emission permit. If you do need one, the Guide will help you fill out an application.

Part 1: Defining Your Facility shows how to describe your equipment and quantify its emissions. After defining your facility, you may or may not need to apply for a permit. Part 2: Determining Compliance tells you how to prepare the compliance portion of your air emission permit application. Part 3: Making Changes explains what air quality rules and regulations apply when making changes at your facility and how the change affects your air emission permit. If you have not already done so, you may find it helpful to read MPCA's booklet, Getting Started, as a first step. It introduces you to Minnesota's air quality permit program and offers an overview of the permit application process. Please take your time going through each part of the Guide. Do not expect to read all three parts in one day. You will find some things that do not apply to your facility. For this reason, you probably will not need to read every section in detail. To help you define key terms, each part of the Guide contains a glossary and an acronym list. A case study at the end of each part of the Guide provides examples of how a fictitious facility, Blue Ox Woodworks, completed an air emission permit application. To answer your questions for help, phone numbers are given in the Focus section of each part. In addition, ordering information is offered in the Appendix of Part 1 should you want copies of the air quality rules and regulations. IMPORTANT NOTE: The MPCA has tried to make the Air Quality Permits Guide as complete as possible, however, it is not a substitute for the rules and regulations themselves. The Guide will be revised periodically, but it will not be updated each time a specific requirement is revised or added. It is your responsibility to find out which requirements apply to your facility.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page v

FOCUS OF PART 1 Welcome to Part 1: Defining Your Facility of the MPCA Air Quality Permits Guide. The Guide is an introduction to the Minnesota Pollution Control Agency (MPCA) and its Air Quality (AQ) rules. Under the MPCA rules, your facility may need an air emission permit. The Guide will help you find out whether your facility needs a permit and offers direction for completing a permit application. Part 1 helps you: • Define your sources of air emissions • Calculate your air emissions • Determine what rules apply • Assemble your descriptions and calculations for an application (if one is needed) If you have questions about the material covered in Part 1, you are welcome to call any of these numbers for help. You may also write to the MPCA for information. MPCA Air Permit Technical Advisor Responds to questions about rules or applying for 1-800-MinnAir (1-800-646-6247) or air emissions permits (651) 282-5844

MPCA Air Permit Document Coordinator Can send a copy of the Air Quality Permitting (651) 282-5843 Rules, application forms, fact sheets.

MPCA Small Business Technical Helps business with fewer than 100 employees to Assistance Program understand the air quality rules and complete (651) 282-5847 or 1-800-657-3938 permit applications

Training Registration Provides information on available classes and 1-800-571-7227 training sessions

Air Quality Small Business Ombudsman Provides confidential assistance to small (651) 297-8615 or 1-800-985-4247 businesses; helps to resolve complaints and disputes

Minnesota Technical Assistance Program Assists with (MnTAP), a nonregulatory assistance program located at the University of Minnesota (612) 627-4646 or 1-800-247-0015

TTY Teletypewriter for persons with (651) 282-5332 or 1-800-657-3864 hearing impairment

Minnesota Pollution Control Agency Mailing Address Air Quality Permit Technical Advisor 520 Lafayette Road St. Paul, Minnesota 55155

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page vii

1.0 WHAT IS A PERMIT? A permit is a regulatory document that is legally enforceable. An air emission permit spells out the process equipment and air pollution control equipment you have and the rules or regulations that apply to your facility. Your air emission permit also includes operational requirements, emission limits, and monitoring requirements for your facility. A Part 70 permit is a type of air emission permit that the MPCA issues to implement certain federal requirements. "Part 70" is a section in the Code of Federal Regulations for the Protection of the Environment. Because of the requirements set by the federal Clean Air Act Amendments of 1990, all states are now required to have Part 70 permit programs. Your facility is a Part 70 source if its potential to emit air pollutants meets or exceeds specific emission thresholds. A Part 70 permit is valid for five years, then it must be renewed. A state permit is issued to facilities that have the potential to emit smaller amounts of air pollutants than Part 70 sources. State permits generally do not expire. Requirements for showing compliance under state permits may be less extensive than for Part 70 permits. You may also qualify for a general permit. General permits cover a group of similar facilities, such as asphalt plants or aggregate producers. A general permit requires less individual processing by the MPCA than a permit developed to meet unique requirements for your facility. Because of this, a general permit may be quicker to obtain. A general permit can be written as either a state permit or a Part 70 permit. A fourth type of permit is a registration permit. Registration permits are simple, one-page permits for some facilities whose actual emissions are low, and which are not subject to complex federal regulations. Typical facilities qualifying for a registration permit include auto body shops and schools operating boilers for heat. Refer to the Registration Permit Handbook, available from the Permit Document Coordinator, for more detailed information on registration permits. Figure 1-1 illustrates the process for deciding what type of permit your facility needs. Other sections of Part 1 will define the types of permits and provide overall direction for completing the permit application. Section 10.0, a case study created by the MPCA, offers an overview of the permit application process from the applicant's viewpoint.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 1-1 Figure 1-1 What Type of Air Emission Permit Do You Need?

A facility located in Minnesota, emitting any air at any rate

ß No

Calculate Potential To Emit (PTE) Part 70 Individual or General Permit

ß No Ý Is your PTE of any criteria pollutant ≥100 Yes tons per year (tpy)? Is your PTE of any one Þ Facility is required to obtain a Part 70 HAP ≥ 10 tpy? Is your PTE of any Permit combinations of HAPs ≥ 25 tpy?

ß No ß Optional Can the source take permit limits to ß No qualify for a Federally Enforceable (Synthetic Minor) State Permit? ß No ßYes ß No ßYes

Is a unit at the facility subject to a 40 CFR part 60 or 61 Requirement, or a SIP* Þ Required Permit? Yes Facility is required to obtain a State ß No Permit

Does facility have a PTE of ≥25 tpy of PM10? Yes ≥ 50 tpy of SO2? ≥ 0.5 tpy of Lead? Þ ≥ 100 tpy of VOC?

ß No ßYes No Permit Required (Source must still State Individual or comply with all applicable standards.) General or Registration Permit

* State Implementation Plan (applies to 25 facilities statewide)

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 1-2 2.0 WHAT AIR POLLUTANTS ARE REGULATED BY THE MPCA?

2.1 Criteria pollutants The MPCA regulates many air pollutants. Some of the regulated pollutants are called criteria pollutants. Before these pollutants are allowed in the ambient air, they must meet certain human health-based or welfare-based criteria. Ambient air is the air to which the general public might be exposed. The following is a list of the criteria pollutants and why they are regulated.

• Sulfur dioxide (SO2) contributes to acid rain pollution and is a respiratory irritant.

• Nitrogen oxides (NOx) is a respiratory irritant. NOx also contributes to acid rain and produces .

• Small particulate matter (PM10 – particulate matter less than 10 microns in size) can be inhaled, causing irritation or respiratory illness. • Carbon monoxide (CO) decreases the ability of the blood to carry oxygen. • Lead (Pb) can cause anemia, brain damage and nervous system damage.

• Ozone (O3) is a respiratory irritant. Ground level ozone, a component of smog, is formed by reactions among volatile organic compounds, nitrogen oxides and sunlight.

2.2 Volatile Organic Compounds (VOCs) Most facilities do not emit ozone directly. Volatile organic compounds (VOCs) contribute to ozone formation and are calculated instead of ozone for your facility's emissions. Some VOCs are toxic also. VOCs are found in solvents, coatings or lubricants. The definition of volatile organic compounds is very broad. Volatile organic compounds are defined as any organic (carbon) compounds which participate in atmospheric photochemical (smog-forming) reactions. This means any organic compound other than those specified by the Environmental Protection Agency (EPA) as having minor photochemical reactivity. Table 2-1 (next page) lists the chemicals that are not considered VOCs. A list of chemicals not considered VOCs can also be found at Minn. R. 7005.0100, subp. 45.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 2-1 Table 2-1 CHEMICALS NOT CONSIDERED VOLATILE ORGANIC COMPOUNDS (VOCs)

A. ; B. ethane; C. 1,1,1-trichloroethane (methyl chloroform); D. 1,1,2-trichloro-1,2,2-trifluoroethane (CFC-113a); E. methylene chloride (dichloromethane); F. trichlorofluoromethane (CFC-11); G. dichlorodifluoromethane (CFC-12); H. chlorodifluoromethane (HCFC-22); I. trifluoromethane (HFC-23b); J. 1,2-dichloro-1,1,2,2-tetrafluoroethane (CFC-114); K. chloropentafluoroethane (CFC-115); L. 1,1,1-trifluoro-2,2-dichloroethane (HCFC-123c); M. 1,1,1,2-tetrafluoroethane (HFC-134ad); N. 1,1-dichloro-1-fluoroethane (HCFC-141b); O. 1-chloro-1,1-difluoroethane (HCFC-142b); P. 2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124); Q. pentafluoroethane (HFC-125); R. 1,1,2,2-tetrafluoroethane (HFC-134); S. 1,1,1-trifluoroethane (HFC-143a); T. 1,1-difluoroethane (HFC-152a); U. parachlorobenzotrifluoride (PCBTF); V. cyclic, branched, or linear completely methylated siloxanes; W. acetone; X. perchloroethylene (tetrachloroethylene); Y. 3,3-dichloro-1,1,1,2,2-pentafluoropropane (HCFC-225ca); Z. 1,3-dichloro-1,1,2,2,3-pentafluoropropane (HCFC-225cb); AA. 1,1,1,2,3,4,4,5,5,5-decafluoropentane (HFC 43-10mee); BB. perfluorocarbon compounds which fall into these classes: (1) cyclic, branched, or linear completely fluorinated alkanes; (2) cyclic, branched, or linear completely fluorinated ethers with no unsaturations; (3) cyclic, branched, or linear completely fluorinated tertiary amines with no unsaturations; and (4) sulfur-containing perfluorocarbons with no unsaturations and with sulfur bonds only to carbon and fluorine;

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 2-2 Table 2-1, continued CHEMICALS NOT CONSIDERED VOLATILE ORGANIC COMPOUNDS (VOCs)

CC. difluoromethane (HFC-32); DD. ethylfluoride (HFC-161); EE. 1,1,1,3,3,3-hexafluoropropane (HFC-236fa); FF. 1,1,2,2,3-pentafluoropentane (HFC-245ca); GG. 1,1,2,3,3-pentafluoropropane (HFC-245ea); HH. 1,1,1,3,4-pentafluoropentane (HFC-245eb); II. 1,1,1,3,3-pentafluoropentane (HFC-245fa); JJ. 1,1,1,2,3,3-hexafluoropropane (HFC-236ea); KK. 1,1,1,3,3-pentafluorobutane (HFC-365mfc); LL. chlorofluoromethane (HCFC-31); MM. 1,2-dichloro-1,1,2-trifluoroethane (HCFC-123a); NN. 1 chloro-1-fluoroethane (HCFC-151a); OO. 1,1,1,2,2,3,3,4,4-nonafluoro-4-methoxy-butane; PP. 2-(difluoromethoxymethyl)-1,1,1,2,3,3,3-heptafluoropropane; QQ. 1-ethoxy-1,1,2,2,3,3,4,4,4-nonafluorobutane; RR. 2-(ethoxydifluoromethyl)-1,1,1,2,3,3,3-heptafluoropropane; SS. methyl acetate TT. any other compound listed in table 1, as amended, of the United States Environmental Protection Agency's Recommended Policy on Control of Volatile Organic Compounds, Federal Register, volume 42, page 35314, July 8, 1977; or UU. any other compound determined by the United States Environmental Protection Agency to be negligibly photochemically reactive, upon publication of the determination in the Federal Register. a CFC = b FC = c HCFC = hydro-chlorofluorocarbon d HFC = hydro-fluorocarbon

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 2-3 2.3 Hazardous Air Pollutants

Most hazardous air pollutants are also regulated as volatile organic compounds and PM10, but the definition of hazardous air pollutants (HAPs) is more chemically specific. Hazardous air pollutants can also be metals. The 1990 Clean Air Act Amendments listed 189 HAPs (the list has been amended since then). These are included in the Minnesota permit rule as regulated pollutants with toxic health effects. As of the date of this document, there are 188 listed HAPs. Table 2.2 lists the chemicals and their Chemical Abstracts Services (CAS) numbers. The CAS number is a specific identifier used to confirm a chemical identity. This is very useful for chemicals with more than one common name. For example, methyl chloroform and 1,1,1 trichlorethane are both names for the same chemical. The CAS number is 71-55-6, the same number for either name. Product material safety data sheets usually provide both a name and a CAS number.

2.4 Other regulated pollutants The criteria pollutants, volatile organic compounds and the hazardous air pollutants comprise most of the regulated pollutants you will include in your air emission permit application. Another pollutant you must include is total particulate matter (liquid or solid particles such as dust, smoke, mist, fumes or smog). Particulate matter is sometimes called total suspended or TSP. Certain regulations also cover other pollutants. For example, sulfuric acid mist is regulated in a program called New Source Review (see Section 6.1.3). Other air quality programs add to the list of regulated pollutants. Accidental release provisions in the Clean Air Act Amendments cover some additional air pollutants (see Form GI-09[G]). Stratospheric ozone protection regulations cover the phase-out of chemicals that deplete the in the upper atmosphere. Regulations also include the maintenance and repair of equipment containing certain ozone depleting materials. Be aware that if you replace a regulated ozone depleting material (, for example) with a material containing a volatile organic compound, you may need a permit to authorize the change in your operations.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 2-4 Table 2-2 188 HAZARDOUS AIR POLLUTANTS

75070 Acetaldehyde 60117 Dimethyl aminoazobenzene 60355 Acetamide 119937 3,3-Dimethyl benzidine 75058 Acetonitrile 79447 Dimethyl carbamoyl chloride 98862 Acetophenone 68122 Dimethyl formamide 53963 2-Acetylaminofluorene 57147 1,1 Dimethyl hydrazine 107028 Acrolein 131113 Dimethyl phthalate 79061 Acrylamide 77781 Dimethyl Sulfate 79107 Acrylic acid 534521 4,6-Dintro-o-cresol, and salts 107131 Acrylonitrile 51285 2,4-Dinitrophenol 107051 Allyl chloride 121142 2,4-Dinitrotoluene 92671 4-Aminobiphenyl 123911 1,4-Dioxane (1.4-Diethyleneoxide) 62533 Aniline 122667 1,2-Diphenylhydrazine 90040 o-Anisidine 1332214 Asbestos 106898 Epichlorohydrin (1-Chloro-2,3-epoxypropane) 106887 1,2-Epoxybutane 71432 140885 Ethyl acrylate 92875 Benzidine 100414 Ethyl benzene 98077 Benzotrichloride 51796 Ethyl carbamate (Urethane) 100447 Benzyl chloride 75003 Ethyl chloride (Chloroethane) 92524 Biphenyl 106934 Ethylene dibromide (Dibromoethane) 117817 Bis (2-ethylhexyl) phthalate (DEHP) 107062 Ethylene dichloride (1,2- Dichloroethane) 542881 Bis (chloromethyl) ether 107211 Ethylene glycol 75252 Bromoform 151564 Ethylene imine (Aziridine) 106990 1,3-Butadiene 75218 Ethylene oxide 96457 Ethylene thiourea 156627 Calcium cyanamide 75343 Ethylidene dichloride (1,1-Dichloroethane) 133062 Captan 63252 Carbaryl 50000 Formaldehyde 75150 Carbon disulfide 56235 Carbon tetrachloride 76448 Heptacholor 463581 Carbonyl sulfide 118741 Hexachlorobenzene 120809 Catechol 87683 Hexachlorobutadiene 133904 Chloramben 77474 Hexachlorocyclopentadiene 57749 Chlordane 67721 Hexachloroethane 7782505 Chlorine 822060 Hexamethylene-1,6-diisocyanate 79118 Chloroacetic acid 680319 Hexamethylphosphoramide 532274 2-Chloroacetophenone 110543 Hexane 108907 Chlorobenzene 302012 Hydrazine 510156 Chlorobenzilate 7647010 Hydrochloric acid 67663 Chloroform 7664393 Hydrogen flouride (hydrofluoric acid) 107302 Chloromethyl methyl ether 123319 Hydroquinone 126998 Chloroprene 1319773 Cresols/Cresylic acid (isomers and mixture) 78591 Isophorone 95487 0-Cresol 108394 m-Cresol 58899 Lindane (all isomers) 106445 p-Cresol 98828 Cumene 108316 Maleic anhydride 67561 Methanol 94757 2,4-D, salts and esters 72435 Methoxychlor 3547044 DDE 74839 Methyl bromide (Bromomethane) 334883 Diazomethane 74873 Methyl chloride (Choromethane) 132649 Dibenzofurans 71556 Methyl chloroform (1,1,1-Trichloroethane) 96128 1,2-Dibromo-3-chloropropane 78933 Methyl ethyl ketone (2-Butanone) 84742 Dibutylphthalate 60344 Methyl hydrazine 106467 1,4-Dichlorobenzene(p) 74884 Methyl iodide (Iodomethane) 91941 3,3'-Dichlorobenzidene 108101 Methyl isobutyl ketone (Hexone) 111444 Dichloroethyl ether (Bis(2-chloroethyl)either) 624839 Methyl isocyanate 542756 1,3-Dichloropropene 80626 Methyl methacrylate 62737 Dichlorvos 1634044 Methyl tert butyl ether 111422 Diethanolamine 101144 4,4-Methylene bis (2-chloroaniline) 121697 N,N-Diethyl aniline (N,N- Dimethylaniline) 75092 Methylene chloride (Dichloromethane) 64675 Diethyl sulfate 119904 3,3-Dimethoxybenzidine

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 2-5 Table 2-2, continued

108883 Toluene 101688 Methlene diphenyl diisocyanate (MDI) 95807 2,4-Toluene diamine 101779 4,4'-methylenedianiline 584849 2,4-Toluene diisocyanate 95534 o-Toluidine 91203 Naphthalene 8001352 Toxaphene (chlorinated camphene) 98953 Nitrobenzene 120821 1,2,4-Trichlorobenzene 92933 4-Nitrobiphenyl 79005 1,1,2-Trichloroethane 100027 4-Nitrophenol 79016 79469 2-Nitropropane 95954 2,4,5-Trichlorophenol 684935 N-Nitroso-N-methylurea 88062 2,4,6-Trichlorophenol 62759 N-Nitrosodimethylamine 121448 Triethylamine 59892 N-Nitosomorpholine 1582098 Trifluralin 540841 2,2,4-Trimethylpentane 56382 Parathion 82688 Pentachloronitrobenzene (Quintobenzene) 108054 Vinyl acetate 87865 Pentachlorophenol 593602 Vinyl bromide 108952 Phenol 75014 Vinyl chloride 106503 p-Phenylenediamine 75354 Vinylidene chloride (1,1-Dichloroethylene) 75445 Phosgene 7803512 Phosphine 1330207 Xylenes (isomers and mixtures) 7723140 Phosphorus 95476 o-Xylenes 85449 Phthalic anhydride 108383 m-Xylenes 1336363 Polychlorinated biphenyls (aroclors) 106423 p-Xylenes 1120714 1,3-Propane sultone 57578 beta-Propiolactone 123386 Propionaldehyde COMPOUNDS 114261 Propoxur (Baygon) 78875 Propylene dichloride (1,2-Dichloropropane) 0 Antimony compounds 75569 Propylene oxide 0 Arsenic compounds (inorganic including arsine) 75558 1,2-Propylenimine (2-Methyl aziridine) 0 Beryllium compounds 0 Cadmium compounds 91225 Quinoline 0 Chromium compounds 106514 Quinone 0 Cobalt compounds 0 Coke oven emissions 100425 Styrene 0 Cyanide compounds 96093 Styrene Oxide 0 Glycol ethers 0 Lead compounds 1746016 2,3,7,8-Tetrachlorodibenzo-p-dioxin 0 Manganese compounds 79345 1,1,2,2-Tetrachloroethane 0 compounds 127184 Tetrachloroethylene (Perchloroethylene) 0 Mineral fibers 7550450 Titanium tetrachloride 0 Nickel compounds 0 Polycyclic organic matter 0 Radionuclides 0 Selenium compounds

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 2-6 3.0 STEPS FOR COMPLETING A PERMIT APPLICATION Figure 3-1 shows the process to follow when you apply for an air emission permit. The rest of Part 1 and Part 2 will take you through this process. Figure 3-1 The Permit Application Process

Review Part 1 and become familiar with the forms and attachments. ß Identify the property boundaries and activities included in your facility. Gather and review existing information you may have. ß Identify all emission sources. ß Compile detailed stack/vent information. ß Compile pollution control equipment information. ß Prepare detailed emission source data. ß Calculate potential emissions or PTE from each of your sources. ß Review potential to emit from your facility and evaluate whether a permit is needed based on potential emission levels. If not, see whether a permit is required because of National Emissions Standards for Hazardous Air Pollutants (NESHAPs) or New Source Performance Standards (NSPS). If a permit is required, continue with the application, otherwise stop. ß Calculate actual emissions from your sources, if needed. ß Complete the necessary forms to describe your facility, sources and emissions. ß Identify all requirements that apply to your facility. ß Go to Part 2: Determining Compliance to develop the compliance information needed to complete your application. ß Review permit application for completeness and accuracy. ß Submit your application to the MPCA.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 3-1

4.0 HOW IS YOUR FACILITY DEFINED? Your permit application will "define your facility" by detailing the facility's location and equipment. A facility may have a fixed location, like a factory or school. A facility can also be movable, like a portable asphalt plant. A facility includes all buildings or structures on connected or adjacent pieces of property that are under common ownership or control. Operations across the street from one another, however, may also be part of the same facility. Also, some facilities may have supporting operations on site with different owners. In this situation, your air emission permit would cover all of your facilities as a single source. The major Standard Industrial Classification (SIC) code also helps to define what is part of a facility. The SIC code is a four digit number used to identify industries. The first two digits are the "major group" of a facility. For example, major group 20 is "Food and Kindred Products." The last two digits of the SIC code identify the specific type of facility. Food products that have 43 as the last two digits, for instance, are Cereal Breakfast Foods manufacturing (SIC code 2043). A list of common SIC code categories is found in Getting Started. The Standard Industrial Classification Manual contains all the SIC codes. All emission units in the same major group SIC code (the first two digits) are considered part of the same facility. There are times when sources having different major SIC codes may be part of the same facility. In that case, use the SIC code that is the main one for your operations. An example of a facility that has more than one SIC code is a plant that both makes and prints on cardboard boxes. Its primary SIC code is 2653, Corrugated and Solid Fiber Boxes. Since the company does some of its own printing on site, its secondary SIC code is 2754, Commercial Printing, Gravure.

4.1 What are your emission points? An emission point is where emissions are released into the atmosphere. An emission point may be a stack, a wall vent, the general building ventilation exhaust, or a window. Your permit application will need to identify the emission points at your facility. Stacks are the easiest emission points to identify. Use a systematic approach to identify all stacks and roof vents and locate them on a drawing. It is helpful if each emission point is labeled with a sturdy tag or marking. Labels should be weatherproof so that the stack identity is clearly and permanently displayed. Note whether a stack has a rain cap, sampling ports or monitoring devices. Note any unusual odors, visible emissions or deposited materials by the stacks.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 4-1 After you have finished making a list of your stacks, walk around the outside and through the inside of the building. You may find vents other than the roof stacks, such as wall vents or exhaust fans. Also look for operations that exhaust into the building. Any emission units or sources that exhaust into the building must be included in your emission calculations. After this survey, you should have found all of your emission points. Describe each stack or vent on Form GI-04, Stack/Vent information. Also note if there is pollution control equipment at any emission point. If you have monitoring equipment for the control equipment at the emission point, be sure to describe it. Monitoring equipment examples are temperature gauges, gauges and flow meters. Complete Form GI-05A to describe your control equipment. Using your survey notes of outside and inside stacks or vents, place all your emission points on a facility or section layout diagram. This information will be helpful as you begin to complete the permit application forms. Your application must include information describing the location of your emission points. Form GI-03 is a facility and stack/vent diagram form that you could also use. An example diagram is included in the Blue Ox case study (Section 10.0). IMPORTANT NOTE: Even though some of your operations do not have a stack or vent, their process emissions will exhaust into the atmosphere through building ventilation or escape through doors or windows. These types of emissions must be included in your calculations. Operations that do not have a specific stack or vent are still considered emission units (see Section 4.2). Do not confuse this type of emission with "fugitive" emissions. Sections 4.2 and Section 5.1.4 provide more information on fugitive emissions.

4.2 What are your emission units? An emission unit is any piece of equipment or any process that emits pollutants into the air. They are the sources that emit pollutants to the air through your stacks and vents. For each stack or vent in your facility survey, list all the equipment and operations that vent at each emission point. Be sure to include any sources not located in your main building. If you have a standby generator, storage silo or other source located on your property, but away from the main building, it is still part of the facility. You may also have equipment or processes that you do not operate anymore. If these sources are still able to operate, they are considered emission units. You must include them in your application. Complete Form GI-05B, Emission Unit Description, for each emission unit other than storage tanks. Use form GI-05C for information related to tanks. Air emissions that cannot reasonably exhaust through a stack or a building structure are fugitive emissions. Examples of fugitive emissions include dust blowing from rock and coal piles and on unpaved . Volatile organic compound emissions from outdoor leaking valves or

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 4-2 flanges are also fugitive emissions. Printing emissions at a print shop, on the other hand, are not fugitive emissions because they could be collected and emitted from a stack or vent. Note any sources of fugitive emissions in your application (use Form GI-05D, Fugitive Emission Source Description). After surveying your facility, you should have found all of your emission points and units. Not every unit must be included in your application. Appendix 1-A provides a list and description of the activities or sources you may exclude from an application. Excluded activities include fuel combustion for food preparation (e.g., an employee cafeteria), maintenance activities and clerical activities. There is also a second group of similar sources that you must include in your application. For these sources, you may not have to calculate the emissions unless it would increase your potential emissions enough to make your facility subject to different requirements. Appendix 1-B shows the sources for which you must include at least a description in your application.

4.3 How should you describe your operations? Your permit application should describe how your raw materials, processes, products and emissions are related. Diagrams are a useful tool for describing operations and their relationships in a clear and efficient way. A process flow diagram form (Form GI-02) can be used for this purpose. An example of a process flow diagram is included in the Blue Ox case study (Section 10.0). At this point, begin to think about your operations as a whole and work toward more detailed descriptions and process flow diagrams. Start with a rough sketch of your overall operations. Show the raw materials used, the process steps, and the finished products. After you have sketched the overall operations, do the same for specific processes. All emission points identified on the walk-through of your facility should also be on these process flow diagrams.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 4-3

5.0 WHAT IS POTENTIAL TO EMIT (PTE)? Now that you have a list of all your emission points and units, you are ready to look at your air emissions. The potential to emit (PTE) from your facility is one of the most important parts of your permit application. Primarily, it helps you determine what federal rules and regulations apply to your facility. For most facilities, PTE is the basis for deciding whether a permit is needed. Potential to emit is the maximum amount of air emissions a unit or facility can possibly produce in a year. PTE gives the MPCA a uniform way to assess all types of facilities. In addition, PTE helps to classify types of modifications at a facility (refer to Part 3: Making Changes for details). This is the definition of PTE that Minnesota uses for most facilities (Minnesota Rules 7005.0100, subp. 35a):

"PTE is the maximum capacity while operating at the maximum hours of operation of an emissions unit, emission facility, or stationary source to emit a pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the source to emit a pollutant, including air pollution control equipment and restrictions on hours of operation or on the type, or amount of material combusted, or stored, or processed shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable..."

5.1 How do you calculate Potential to Emit (PTE)? Calculate your PTE using these assumptions: • The emission unit operates continuously. This means it runs 24 hours per day, 365 days per year. This amounts to 8,760 hours per year. • The emission unit operates at its physical and operational design capacity. This means the absolute maximum performance the emission unit or source can achieve. • The material with the most emissions is processed or used 100% of the time (e.g., for volatile organic compound calculations, assume the coating with the highest solvent content is used 100% of the time; for particulate matter calculations, assume the coating with the highest solid content is used 100% of the time.).

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-1 • The emission unit is uncontrolled. This means any pollution control equipment cannot be counted as reducing emissions while calculating potential to emit. Using the previous assumptions gives your unrestricted PTE. In most cases, this is what determines if an air emissions permit is needed. Once you’ve determined that an air emissions permit is needed, it may be possible to consider pollution control equipment when determining what type of permit is required. If the control equipment can be considered “listed control equipment” under Minn. R. 7011/0060 - 7011/0080, it may be used to calculate emissions for the type of permit. Potential to emit (PTE) calculations can include certain process limitations or bottlenecks. A bottleneck is an activity or process that restricts the capacity of other operations. As a result of a bottleneck, PTE may be reduced. The following examples illustrate bottlenecks that can and cannot be used in emissions calculations. Example A –– A grain facility has a dryer with a capacity of 50,000 bushels per hour (bu/hr). The facility has only one gallery conveyor for loading the dryer. The conveyor has a 40,000 bu/hr capacity. Since the conveyor physically limits the amount of grain that can be dried, it is a bottleneck. 40,000 bu/hr is used to calculate PTE for the dryer. Example B –– A spray booth has two spray guns and one compressor. The operator can spray either varnish or paint. The operator sprays these coatings separately to make the desired product. This is not considered a bottleneck. Because the compressor is large enough to allow both guns to run at the same time, the PTE calculation must assume both guns are used. If you want to use a bottleneck limitation in calculating your PTE, describe how it affects your process and emissions. You should also show it on your process flow diagrams. Please note that if you subsequently make a change that eliminates or reduces the bottleneck, you may have to amend your permit, or obtain one if you don’t already have one. If removing the bottleneck would cause an increase in potential emissions, the increase may be considered a modification to your facility. IMPORTANT NOTE: Heatset web offset presses and wafer board dryers must calculate the emissions of PM10 (condensable) emissions that result from their volatile organic compound usage. Other volatile organic compound emission sources will be required to calculate PM10 emissions as emission factors or other data become available.

5.1.1 What references can you use to calculate PTE? The potential to emit must be calculated separately for each regulated pollutant from each emission unit. You may use the EC series of forms for the different types of emission units or operations.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-2 Show your work for your PTE calculations! Part of the MPCA's review of your application includes checking how you came up with your PTE. If you use a computer spreadsheet, show a sample calculation or the formulas used as part of your application. Table 5-1 (next page) gives methods for calculating emissions. Appendix 2-A lists reference documents that might assist you. Remember that excluded activities, as listed in Appendix 1-A and 1-B, may not need emission calculations unless the additional emissions would cause your facility to be subject to different requirements.

5.1.2 Examples of Potential Emissions Calculations Example A –– Potential Emissions Calculations Using EMISSION FACTORS. If you use emission factors, pay attention to two things. First, make sure the factor you use is appropriate for your process. For example, three sets of emission factors are available for -fired boilers depending on their firing rate. To select the right factor, you need to know the size of your burner. Second, pay close attention to the units used with the emission factor. Make sure your process data agree with the units in the emission factor. The emission unit is a natural gas-fired boiler rated at 12 million Btu per hour, or 8,600 lb of steam per hour. NOx potential emissions will be calculated using an emission factor.

Heating value of natural gas = 1050 Btu/cubic foot

Annual operating hours = (365 days/year) (24 hours/day) = 8,760 hours/year

Hourly maximum fuel use = 12 million Btu/hr = 12,000 cubic feet/hour 1000 Btu/cubic foot

NOx Emission Factor from AP-42 = 100 pounds of NOx emitted per million cubic feet of natural gas burned

Annual potential emissions of NOx:

hours cubic feet of fuel million cubic feet of fuel 8760 ×=12,000 105. 12 year hour year

million cubic feet of fuel pounds of NOx pounds of NOx 105., 12 ×=100 10 512 year million cubic feet of fuel year

pounds 10, 512 year tons = 5. 26 pounds 2, 000 year ton

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-3 Table 5-1 METHODS FOR CALCULATING EMISSIONS

1. Emission Emission factors exist for many types of emission units and processes. An emission factor is an factors average emission value from industry data. It relates an activity or process to the quantity of a pollutant released into the atmosphere. Factors are usually expressed as the weight of pollutant released per volume or weight of the activity. You may need to know your process capacity or design rating to use an emission factor. An example of an emission factor is 0.0001 lb of NOx per cubic foot of natural gas burned. Emission factors for pollutants can be found in EPA publications such as AP-42**. If you need more information, AIRS**, , the FIRE*** database, and Toxic Air Pollutant Emission Factors may also be useful. These documents contain emission factors for many source classification codes. These factors are intended for use as default values if a facility lacks other emission data. Ordering information is in Appendix 2-A. If you do have data specific to your operations (e.g. from stack testing), use that instead of an emission factor from a book or database.

2. Mass Mass balance relies on the idea that what goes in must come out. Materials entering a process balances equal materials leaving, either through the product, recycled material, air emissions, wastewater, or solid or . Detailed records are needed. To find the amount of air emissions, you must accurately define these quantities: the amount of raw materials fed to production, the amount used in the product, and the amount lost to the non-air waste stream. Analyzing purchasing records, production records, product specifications and hazardous waste records may be helpful.

3. Performance If you have performance test data or data from a continuous emissions monitor for your facility, it test data must be used in place of emission factors. If you use actual operating or test data (from your own or a similar source), they must have been taken at the maximum possible emission rate. The test data must be correlated to the operating conditions.

4. Minnesota Regardless of your PTE, the limits listed in the Minnesota rules (primarily the Minnesota rules Standards of Performance for Stationary Sources) cannot be exceeded. You can use the rule values to calculate your "allowable" emissions from an emission unit. If your PTE is greater than the allowable emissions under the rule, the allowable emissions are used as your PTE because the rules do not let you emit more than the allowable amount. If your emissions unit cannot meet the state rule limit, you will have to add control equipment or modify operations so that the limit is met. Only if you have no other source of emissions data for calculating the PTE for an emission unit, can the allowable emissions be used as the PTE for that unit.

5. Federal New Source Performance Standards must not be exceeded. These emission limits are used to New Source calculate "allowable" emissions. The allowable emissions are then used as the PTE for the Performance emission unit. Standards limits

* AP-42, Compilation of Air Pollutant Emission Factors ** AIRS Facility Subsystem Source Classification Codes and Emission Factor Listing for Criteria Air Pollutants *** FIRE, Factor Information Retrieval System

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-4 Example B –– Potential Emissions Calculations Using MASS BALANCE. You can use a mass balance calculation to determine emissions from an individual process or series of process steps. The mass balance approach assumes that what goes into a process step equals what comes out. To use a mass balance, be certain that you know how the products and process behave. For example, at what temperature does your compound evaporate? Is any solvent retained in a hardened resin? These characteristics affect how much of your compound is emitted. In this example, the emission unit is one spray gun. The gun capacity is 5 gallons per hour. Primer, paint and varnish are used at this emission unit. Mineral spirits are used for cleaning. To calculate the PTE of volatile organic compounds from spray coating, assume the coating with the highest solvent content is used continuously. To calculate the PTE of particulate matter from coating, assume the highest solid content coating is used continuously. Although there is a wall filter on the booth for particulate matter, this control efficiency is not used in determining if a permit is needed. The transfer efficiency of the spray gun is 75% (taken from Table 1, Form PE-07). This means 75% of the coating adheres to the part and 25% is overspray. The overspray is released to the ambient air.

White Paint Sealer Wipe Stain Primer Mineral Spirits (varnish)

Density (lb/gal) 9.85 8.06 7.54 9.87 7.2 Percent VOC 75% 69% 96% 57% 100% content by weight Percent solid 25% 31% 4% 43% 0% content by weight VOC Content 7.39 5.56 7.24 5.64 7.2 (lb/gal) Calculated from density and percent VOC by weight Solids Content 2.46 2.5 0.3 4.23 0 (lb/gal) Calculated from density and percent solid by weight

Particulate Matter Emissions Annual potential emissions of particulate matter from spray coating are calculated as follows:

gallons pounds of solid pounds of solid 5 ××=423... 0 25 over spray 5 29 hour gallon hour

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-5 pounds of solid hours 1 ton tons 529., ××8 760 =23 . 16 hour year 2000 pounds year

Volatile Organic Compound Emissions Annual potential emissions of volatile organic compounds from spray coating are calculated as follows: gallons pounds of VOC pounds of VOC 5 ×=7 .39 36.95 hour gallon hour

pounds of VOC hours 1 ton tons 36 .95 ××8, 760 =161.84 hour year 2000 pounds year

Last year, the company used 800 gallons of mineral spirits and the plant operated 4,000 hours. For this calculation, those numbers will be scaled up, since there is not a "rated capacity" for cleaning, as there is for the spray gun. The usage of cleaning solvent is variable. For the purposes of establishing PTE, a margin for error will be factored into the calculation. An additional 30% was selected as an adequate margin for their operations. Annual potential emissions of volatile organic compounds from cleaning are calculated as follows: gallons 800 year gallons = 02. hours hour 4000 year

gallons pounds of VOC pounds of VOC 02.. ×=72 144 . hour gallon hour

pounds of VOC hours 1 ton tons 1.44 ××8, 760 =6.31 hour year 2000 pounds year

tons tons 6... 31 ×=13 820 year year

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-6 Hazardous Air Pollutant Emissions In addition to calculating your overall VOC emissions, you must also calculate the emissions of any individual hazardous air pollutant (HAP) from the list of HAPs. For the painting operation described in Example B, a review of the material safety data sheets showed what hazardous air pollutants are in the coatings. Only the paint, sealer and stain contain any chemicals that are hazardous air pollutants. The hazardous air pollutants are formaldehyde, toluene, methyl ethyl ketone, methyl isobutyl ketone, and xylene.

White Paint Sealer Wipe Stain

Density (lb/gal) 9.85 8.06 7.54 Percent Xylene content by weight 13% 30% 27% Percent Toluene content by weight 15% 31%3% 7% Percent Formaldehyde content by weight 0.2% 0.25% 0 Percent Methyl Ethyl Ketone content by 5% 2% 0 weight Percent Methyl Isobutyl Ketone content by 8% 0 6% weight Xylene Content (lb/gal) Calculated from 1.28 2.42 2.04 density and percent xylene by weight Toluene Content (lb/gal) Calculated from 1.48 0.24 0.53 density and percent toluene by weight Formaldehyde Content (lb/gal) Calculated 0.02 0.02 0 from density and percent formaldehyde by weight Methyl Ethyl Ketone Content (lb/gal) 0.49 0.16 0 Calculated from density and percent methyl ethyl ketone by weight Methyl Isobutyl Ketone Content (lb/gal) 0.79 00.45 Calculated from density and percent methyl isobutyl ketone by weight For each hazardous air pollutant, take the highest content in pounds per gallon and calculate the uncontrolled potential to emit from one spray gun. Annual potential emissions of xylene from spray coating is calculated as follows:

gallons pounds of xylene pounds of xylene 5 ×=242.. 12 1 hour gallon hour

pounds of xylene hours 1 ton tons 12., 1 ××8760 =53 . 0 hour year 2000 pounds year

The other pollutants were calculated similarly. The totals are summarized.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-7 Pollutant Potential to Emit (tons per year)

Xylene 53.0 Toluene 32.41 Formaldehyde 0.44 Methyl Ethyl Ketone 10.73 Methyl Isobutyl Ketone 17.30

IMPORTANT NOTE: In your emission calculations, you must calculate the maximum potential emission rate of each hazardous air pollutant you use. This means you must examine all materials that contain hazardous air pollutants, not just your maximum content of volatile organic compound material.

5.1.3 What is the next step after calculating the PTE of your emission units? Once you have found the potential to emit (PTE) from each individual emission unit, find the total PTE for each pollutant emitted by your facility. To obtain the total PTE for each pollutant, add the PTE from all the individual emission units. Once you have the total facility PTE for each pollutant, compare each of your totals to the thresholds for permits. Table 5-2 lists all the emission thresholds. If your total facility PTE for any one pollutant is above the level in Table 5-2, a permit is required. If you are building a new facility and the potential emissions meet or exceed the thresholds in Table 5-2, a permit is required before you start construction. If you meet or exceed a threshold for Part 70, your facility is called a "major" source for Part 70.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-8 Table 5-2 EMISSION THRESHOLDS REQUIRING A PERMIT

Permit Common Sources Type of Pollutant Permitting Threshold Type of Each Pollutant

Particulate Matter (PM) 100 tons/year State Dusty activities such as grain handling, milling, sand and gravel operations

PM10 (Particulate Matter less 25 tons/year State Fuel combustion, dusty than 10 microns) activities such as grain 100 tons/year Part 70 handling.

Volatile Organic Compounds 100 tons/year excluding Part 70 Solvent cleaning, painting, (VOCs) fugitive emissions (unless listed fuel storage and transfer in Table 5-3)

100 tons/year including State fugitive emissions

Carbon Monoxide (CO) 100 tons/year Part 70 Fuel combustion

Nitrogen Oxides (NOx) 100 tons/year Part 70 Fuel combustion

Sulfur Dioxide (SO2) 50 tons/year State Fuel combustion

100 tons/year Part 70

Lead (Pb) 0.5 tons/year State Wave soldering, and recycling 10 tons/year Part 70

Hazardous Air Pollutants (HAPs) Part 70 Solvent cleaning, painting, Any single HAP 10 tons/year fuel storage and transfer Any combination of HAPs 25 tons/year (both numbers include fugitive emissions)

5.1.4 What about fugitive emissions? If you have fugitive emissions, your permit application must have information on them, just as it would for stack emissions. However, fugitive emissions are only added to PTE in certain cases. If your facility is one of those listed in Table 5-3, you will add the PTE from fugitive emissions to the PTE from your emission points to determine if you need a Part 70 permit. Also, if your PTE is below state thresholds and you have fugitive emissions, add the PTE from the fugitive emissions to the PTE from your emission points. Your total facility PTE, including fugitive emissions, may trigger the need for a state permit for your facility.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-9 Table 5-3 TYPES OF FACILITIES THAT INCLUDE FUGITIVE EMISSIONS IN PTE

Coal Cleaning Plants-With Thermal Dryers Kraft Pulp Mills (2611, 2621)

Portland Plants (3241) Primary Zinc Smelters (3339)

Iron and Steel Mills (332X) Primary Aluminum Ore Reduction Plants (3334)

Primary Copper Smelters (3331) Municipal Incinerators Capable of Charging More Than 250 Tons of Refuse per Day

Hydrofluoric, Sulfuric, or Nitric Acid Plants (2819, Petroleum Refineries (2911) 2873, 2899)

Lime Plants (3274, 1422) Phosphate Rock Processing Plants (1475)

Coke Oven Batteries (3312) Sulfur Recovery Plants (2819)

Carbon Black Plants (Furnace Process, 2895) Primary Lead Smelters (3339)

Fuel Conversion Plants Sintering Plants*

Secondary Metal Production Plants Chemical Process Plants (28XX) (332X, 334X, 336X)

Fossil-Fuel Boilers (or combination Petroleum Storage & Transfer Units, Total thereof) totaling more than 250 MMBtu/hr Storage Capacity over 300,000 Barrels

Taconite Ore Processing Plants (1011) Glass Fiber Processing Plants

Charcoal Production Plants (2819, 2861) -Fired Steam Electric Plants of more than 250 MMBtu/hr

All other stationary source categories regulated by a standard promulgated under section 111 (New Source Performance Standards) or 112 (Hazardous Air Pollutants) of the Act (Clean Air Act, as amended), but only with respect to those air pollutants that have been regulated for that category

*Processing of fine materials into coarser lumps (performed primarily on ores).

5.1.5 What if your PTE is below the thresholds? If your potential emissions are below all the thresholds listed in Table 5-2, you may not have to submit a permit application. You should keep records showing your calculations and decisions. Also, keep track of any future increases in emissions in case your total facility PTE ever exceeds a threshold. If it does, you will have to obtain a permit. You should calculate emissions increases before you start construction. Certain changes require the permit to be issued for construction to begin (refer to Part 3: Making Changes). Even if your emissions are below all the thresholds listed in Table 5-2, you may still need a permit. If an emission unit or facility is subject to any federal New Source Performance Standard (NSPS)*, you will need a state permit just for the unit covered by the NSPS. Certain

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-10 National Emission Standard for Hazardous Air Pollutants (NESHAPs) cause a facility to need a state permit. These NESHAPs are the ones listed in Form GI-09(A)**. More information about these two regulations is in Section 6.1.2 and 6.1.4. Minnesota's rules regarding waste combustors require a permit for some waste combustors whose emissions are below the threshold levels in Table 5-2. * except: 40 CFR 60 Subp. AAA, New residential wood heaters; 40 CFR 60 Subp. JJJ, Petroleum Dry Cleaners; 40 CFR 60 Subp. Kb, Volatile Organic Liquid Storage Vessels, if all vessels have capacity less than 75 m3; 40 CFR 60 Subp. Dc, Small Industrial-Commercial-Institutional Steam Generating Units, if all are only capable of burning natural gas or propane. **except for 40 CFR 61 Subp. M, Asbestos section 61.145 Standard for Demolition and Renovation

5.2 Do you need any other emissions data? 5.2.1 What are your actual emissions? Your actual emissions for the previous year may have to be part of your permit application. Actual emissions are the emissions to the air that result from your actual material usage and actual hours of operation. For some facilities, a federal program called New Source Review (NSR) will apply (see Section 6.1.3). In NSR, the actual emissions data for operations now and in the past may be important. If you filed an annual Emission Inventory Report (Section 6.2.4) with the MPCA in the previous year, you do not have to submit actual emissions data with your application. If you have not submitted an annual Emission Inventory Report, you may not know your actual air emissions. The same methods used to calculate PTE can be used to find your actual emissions. You have several tools at your facility to help you calculate actual emissions. These reports will help you define your material usage: • Purchasing records • Production records • Fuel usage records • Hazardous waste manifests (for solvents, inks, paints or other materials) • Material safety data sheets (MSDSs) • Toxic Release Inventory reports Information collected from these sources should help to define your actual emissions. The mass balance approach (Section 5.1.2) is also useful for calculating actual emissions. For example, suppose you are using an organic cleaning solvent that is disposed as a hazardous waste. To calculate the portion that evaporated (your volatile organic compound emissions), you need to

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-11 know how much solvent went into the process and subtract the amount that went out as hazardous waste.

5.3 How can you limit your Potential to Emit (PTE)? 5.3.1 What about your air pollution control equipment? The “Control Equipment Rule” (Minn. R. 7011.0060 - 7011.0080) allows you to count the effects of some control equipment toward limiting your PTE. However, not all types of control equipment can be counted, and it can’t be used to reduce PTE to below permitting thresholds or to avoid permitting. Refer to the rule for more information, or to the fact sheet called “Control Equipment Performance Standards.”

5.3.2 What if you do not want to be subject to federal regulations? Suppose your potential to emit exceeds a threshold for a Part 70 permit for either criteria or hazardous air pollutants. Perhaps your PTE exceeds the thresholds for a major source in the New Source Review (NSR) regulations (see Section 6.1.3). However, your actual emissions are below the thresholds. You can then choose to have a synthetic minor permit. Your permit application for a synthetic minor permit must comply with all the requirements of a major source. Your facility does not become a synthetic minor facility until the permit is issued. The synthetic minor permit contains operating and emission limits. By accepting permit conditions that limit what you are allowed to emit, your PTE is redefined. Your allowable emissions in your permit become your PTE. If your actual emissions already exceed the thresholds for New Source Review, you cannot have a synthetic minor permit for your total facility. Refer to Part 3: Making Changes for information on synthetic minor modifications. A synthetic minor permit or amendment has benefits. For example, suppose you receive a synthetic minor state permit, instead of a Part 70 permit. Most state permits will not expire and you would be exempt from compliance assurance monitoring (CAM) requirements (see Section 6.1.7). You may also avoid environmental review (see Section 6.2.2). In addition, a synthetic minor permit for New Source Review (NSR) has some advantages. A synthetic minor permit for NSR may give you more flexibility for future changes. You also save both time and money with a simpler application process. Remember that if you receive a synthetic minor permit, you must perform sufficient record keeping and monitoring to show you are meeting the permit limits. The following discussion introduces you to what goes into your proposal for synthetic minor limits.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-12 5.3.2.1 What are acceptable options for synthetic minor limits? Acceptable permit conditions for a synthetic minor permit set specific limits for specific pollutants. Your permit cannot be written as, "do not exceed 99 tons per year of CO" –– that is too vague to be enforced. A permit limit for a synthetic minor must be enforceable. Enforceability means: • The limit is in a permit that was issued under an EPA approved program and that had a public comment period. • The limit is enforceable in a practical way (practically enforceable). Practically enforceable limits may be: • Production limits –– restrictions on the amount of a final product that can be manufactured or produced at a facility or process line. • Operational limits –– restrictions on how a source is run. These include limits on the hours of operation, fuel use, raw material type and usage, and the operation of pollution control equipment. • Emission limits –– these are acceptable if they are on a quantifiable, production basis. Examples are: pounds of pollutant/million Btu heat input or pounds of pollutant/unit of product. Emission limits are often linked to operational limits (e.g., a limit on the amount of fuel burned). You must be able to show that you comply with all your limits or requirements at any time. To show this, you may use some or all of these methods: • Record keeping such as production throughput and hours of operation • Continuous emission monitoring (CEM) data • Stack test data • Material analysis such as Material Safety Data Sheets (MSDSs), supplier certification, or laboratory analysis results If you choose to limit your hours of operation, your PTE must be calculated using the maximum design capacity for all the hours allowed by the permit. Be aware that putting a limit on the hours of operation may be more restrictive for you than other operating limits. However, you can also use a combination of types of limits, such as hours of operation with material usage. For many sources, the time period associated with a production or material usage limit may be proposed in any of several ways. It could be a straight monthly limit (i.e., not to exceed 500 hours per month). It could be an annual limit where you calculate the total over the previous 12

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-13 months (called a 12-month rolling sum). It could be one where you calculate the daily average over the previous 365 days (called a 365-day rolling average). Either of the rolling limits will give you a bit more operating flexibility than a monthly limit. Low months will allow you to have high months and still not exceed your limit. For some facilities (often those that are more complex than most or those that have an NSR requirement), a 30- or 365-day rolling average may be necessary. If you propose a rolling average or rolling sum for a new unit, you must provide a way to show that you comply with your limits during the first 12 months of operation. This could be a formula as shown in the following example. It could be a temporary monthly limit. If you are requesting new limits on an existing source, you have the option of using existing operating data in the rolling period. This would eliminate the need for a special limit for the first 12 months. Example –– This is a new installation of a stand-by diesel generator set. The unrestricted potential to emit would make the facility subject to both Part 70 and NSR. The limits keep potential emissions less than 100 tons per year. By accepting limits, the facility would not be considered a major source for both programs. In addition, the requirement for an Environmental Assessment Worksheet is avoided (see Section 6.2.2).

Pollutant Limitation

Nitrogen Oxides (NOx) (limited Not to exceed 300 hours of operation in each calendar year to less than 100 tons per year) Annual hours of operation shall be calculated monthly, based upon a 12-month rolling sum.

For the first 12 months of operation, the following formula shall be used:

Hn < 27.27 + 22.73n

Where: Hn = the total number of hours of operation through month n

n = number of months of unit operation

Where did that formula come from? It was set up to keep the total number of hours of operation for the first year less than or equal to 300 hours. The company decided that having 50 hours in the first month was more than enough for a stand-by generator set, even if an emergency did occur. That meant that for the rest of the year, there were 250 hours available. Those 250 hours had to be spread out over the next 11 months; i.e., 250 ÷ 11 = 22.73 hours. The first term of the formula is then (50 - 22.73) = 27.27. There is nothing magic about picking 50 hours for the first

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-14 month. If 30 hours were enough for the first month, the formula could use 30. If more hours were needed in the first month, the formula could use more hours. IMPORTANT NOTE: Make sure you can live with the limits in your synthetic minor permit. Suppose that in the future you want to modify your facility or permit and would then exceed the synthetic minor limits. At that time, you may have to address the requirements you avoided when you received a synthetic minor permit. Those requirements could include the installation of control equipment, computer modeling of the emissions, or environmental review, among others. If you do not comply with your synthetic minor limits, your permit may be a sham permit and you may be subject to enforcement action. This is because the objective of a synthetic minor permit is to simplify the permit process for sources whose actual emissions are minor. It is not for sources to circumvent major source requirements, if those requirements apply to them.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5-15

6.0 WHAT RULES AND REGULATIONS APPLY TO YOU? Some federal and state air quality rules and regulations apply to specific emission units. Some apply to the entire facility. This section is a brief introduction to what the MPCA calls "applicable requirements." Requirements Form GI-09 will help you define all the rules and regulations that apply to you in the permit application. Refer to Part 2 for the rules and regulations that relate to completing the compliance portion of your application. Federal regulations are found in the Code of Federal Regulations (CFR). Title 40 of the CFR covers the protection of the environment. Air quality regulations are in parts 50 to 99 of Title 40. If you see a reference to 40 CFR 61.01, it means the Code of Federal Regulations, Title 40, Part 61, Section 01. MPCA Air Quality rules are in Minnesota Rules, Chapters 7002 to 7030. Copies of federal and state regulations are at the MPCA library, county law libraries, university or college libraries, and some public libraries. The MPCA can also provide assistance in obtaining specific rules. You can also order copies of the Minnesota Rules or the CFR. See Appendix 2-A for a list of the rule publications and where to order them.

6.1 What are the federal regulations? Whether your facility needs a permit or not, remember that you still have to comply with the federal regulations.

6.1.1 National Ambient Air Quality Standards (NAAQS) The National Ambient Air Quality Standards (NAAQS) set the maximum concentrations of pollutants allowed in the ambient air. The pollutants for which the standards are developed are the criteria pollutants (PM10, PM2.5, SO2, NOX, CO, lead, and ozone). Minnesota also has a state standard for hydrogen sulfide. Primary and secondary standards exist for each of the pollutants. Primary standards protect public health, while secondary standards protect public welfare. Public welfare includes economic and environmental effects such as damage to plants or buildings. The NAAQS are found in Part 50 of the Code of Federal Regulations. If the National Ambient Air Quality Standards are met in a given area (e.g., a county), then the area is an attainment area. A nonattainment area is where the level of a criteria pollutant in the air exceeds the NAAQS for a pollutant. Nonattainment areas in Minnesota are shown in Table 6-1 and Appendix 3-A. Your location affects your facility's status for New Source Review (see Section 6.1.3 and Part 3 of the Guide).

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 6-1 Table 6-1 NONATTAINMENT AREAS IN MINNESOTA

Type of Pollutant Counties classified as nonattainment or as having nonattainment areas

Particulate Matter Less Portions of Ramsey County along the Mississippi River than 10 Microns (PM10)

Sulfur Dioxide (SO2) Portions of Olmsted County (Rochester area)

Carbon Monoxide (CO) Anoka, Hennepin and Ramsey Counties; Portions of Carver, Dakota, Scott, Washington and Wright Counties

If your facility requires a Part 70 permit, you will also have to show compliance with NAAQS.

Current MPCA policy is to required this for all facilities that have potential emissions of PM10,

SO2, or NOX exceeding 100 tons per year. Other facilities may also have to conduct modeling in certain instances. If this applies to your facility, your permit will require you to conduct dispersion modeling of your potential emissions. Dispersion modeling uses a computer program in which facility and emissions data are used to estimate pollutant concentrations. Estimated concentrations at various locations in the surrounding area are compared to the standards. The modeling requirement must be completed within the first five-year term of a Part 70 permit. You may submit your modeling with your initial application if you wish. Dispersion modeling is discussed further in Part 2, Section 2.5.4.1.

6.1.1.1 State Implementation Plan The MPCA has negotiated emission limits and other conditions with approximately 25 facilities. These conditions were needed to meet the NAAQS in the area around these facilities. The MPCA submitted these conditions to the EPA as part of Minnesota's State Implementation Plan (SIP). Once approved by the EPA, these SIP conditions have the effect of a federal regulation.

6.1.2 National Emission Standards for Hazardous Air Pollutants (NESHAPs) The NESHAPs rules are in 40 CFR Parts 61, 63 and 68. Part 61 has standards for nine hazardous air pollutants when they are emitted from specific source types. The nine hazardous air pollutants are: radon, beryllium, mercury, vinyl chloride, radionuclides, benzene, asbestos, inorganic arsenic and volatile hazardous air pollutants. Form GI-09(B) lists the source types. Part 63 contains a list of hazardous air pollutants [see Table A in Form GI-09(A)]. Some of the hazardous air pollutants overlap with the nine listed in Part 61. These chemicals include components of common solvents and heavy metals like cadmium. For sources that emit these hazardous air pollutants, the EPA is developing Maximum Achievable Control Technology

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 6-2 (MACT) standards. MACT standards are being developed for new major sources and also for existing sources of hazardous air pollutants. The standards apply to source categories, such as halogenated solvent cleaning equipment or wood treatment. A facility may be subject to a MACT standard but not required to have a permit. MACT standards will be established based on current technology. A MACT standard can be an emission rate, a product substitution, a work practice, or a control technology requirement. When setting the standards, the EPA can consider factors such as cost, energy use, waste disposal and . Once a MACT standard is in effect, an existing source has up to three years to comply. If your facility has opted to participate in the federal Early Reductions Program, you may have up to six years to comply with MACT. A new source must comply with MACT upon start-up. Table B in Form GI-09(A) contains the list of source categories for which MACT standards are developed or planned and the dates they are expected to be in effect. Please note that if a MACT standard is promulgated that applies to your facility, you must comply with it regardless of your permit status at that time. Some MACT standards are not due to be promulgated until the year 2000. If your facility becomes subject to any of these requirements, you will need to comply with the new rules. You can track these regulations and others that may be proposed in the Federal Register, The Minnesota State Register, and through updates in the MPCA's Air Mail newsletter. Part 68 of the Code of Federal Regulations concerns the prevention of accidental releases. It applies to specific chemicals, but only if a facility uses, handles, processes or stores more than a threshold amount of the chemical. Form GI-09(G) lists the chemicals in this regulation and the threshold amounts. However, these requirements are not permit requirements. Be aware that if this part of the regulation applies to you, you are required to write a management plan for the prevention of accidental releases that covers hazard assessment, pollution prevention, and emergency response issues for your facility.

6.1.3 New Source Review New Source Review (NSR) regulations are federal regulations that Minnesota administers through its permits. NSR regulations are in Parts 51 Appendix S and Section 52.21 of Title 40 of the Code of Federal Regulations. The present NSR regulations have been in effect since 1980. The goal of NSR is to allow economic growth while protecting air quality. These pollutants are currently regulated by the NSR program:

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 6-3 Carbon Monoxide (CO) Ozone ( and VOCs)

Sulfur Dioxide (SO2) Sulfuric acid mist PM and Total Particulate Matter (PM) 10 Total reduced sulfur compounds (TRS) Municipal waste combustor acid gases and metals Nitrogen Oxides (NOx) Lead (Pb) Fluorides

PM2.5 will be regulated in the future. Within NSR, two related programs are based on your location. One is called Prevention of Significant Deterioration (PSD), which is the part of the NSR program that applies to facilities located in attainment areas. The other program is Nonattainment Area New Source Review for areas where one or more National Ambient Air Quality Standards (NAAQS) are exceeded. Many similarities exist between PSD and Nonattainment Area review. The NSR program also provides special protection to geographic areas with special scenic or recreational values. These locations are called "Class I" areas. In Minnesota, the Boundary Waters Canoe Area and Voyageurs National Park are Class I areas. In Wisconsin, the Rainbow Lakes Wilderness Area is a Class I area that may be affected by Minnesota facilities.

6.1.3.1 Does NSR apply to your facility? Your facility could be a "major source" and require a Part 70 permit. That does not necessarily mean your facility is a major source for NSR. NSR applies to facilities whose emissions meet or exceed the thresholds in the NSR regulations. The major source threshold for NSR is a potential to emit 100 tons per year if either of these criteria applies: • Your facility is one of the 28 types listed in Table 6-2. The numbers in parentheses are the typical SIC codes for the source type. (Note: For these 28 sources, count fugitive emissions in your potential to emit to determine if your facility is "major.") • Your facility is located in a nonattainment area (see Section 6.1.1). "Nonattainment Area" review is triggered only if your facility's potential emissions of the nonattainment pollutant in the nonattainment area exceeds 100 tons per year. If neither of these criteria applies to you, then the threshold for facilities defined as a "major" source is 250 tons per year.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 6-4 Table 6-2 SOURCES THAT ARE MAJOR FOR NSR IF PTE EXCEEDS 100 TONS PER YEAR

Coal Cleaning Plants-With Thermal Dryers Kraft Pulp Mills (2611, 2621)

Portland Cement Plants (3241) Primary Zinc Smelters (3339)

Iron and Steel Mills (332X) Primary Aluminum Ore Reduction Plants (3334)

Primary Copper Smelters (3331) Municipal Incinerators Capable of Charging More Than 250 Tons of Refuse/Day

Hydrofluoric Acid Plants (2819, 2899) Sulfuric Acid Plants (2819)

Nitric Acid Plants (2873) Petroleum Refineries (2911)

Lime Plants (3274, 1422) Phosphate Rock Processing Plants (1475)

Coke Oven Batteries (3312) Sulfur Recovery Plants (2819)

Carbon Black Plants (Furnace Process, 2895) Primary Lead Smelters (3339)

Fuel Conversion Plants Sintering* Plants

Secondary Metal Production Plants (332X, Chemical Process Plants (28XX) 334X, 336X)

Fossil-Fuel Boilers (or combination Petroleum Storage & Transfer Units, Total thereof) totaling more than 250 MMBtu/hr Storage Capacity over 300,000 Barrels

Taconite Ore Processing Plants (1011) Glass Fiber Processing Plants

Charcoal Production Plants (2819, 2861) Fossil Fuel-Fired Steam Electric Plants of More Than 250 MMBtu/hr

*Processing of fine materials into coarser lumps (performed primarily on ores).

New Source Review is a pre-construction review program. This means you must wait until your permit is issued before starting to construct a "major" new facility or modification. If you are constructing a new facility with a potential to emit that is major according to the above definition, New Source Review must be performed. If you have an existing facility with a potential to emit that is major, New Source Review may apply if you wish to modify your facility. For future changes under New Source Review, refer to Part 3, Section 2.2.1.

6.1.3.2 What is required for NSR? If you have to perform a New Source Review for your project, it will include these items:

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 6-5 • Analysis for each pollutant to show whether PSD or nonattainment review applies • Environmental review by the Environmental Quality Board (see Section 6.2.2) • Public participation during a comment period • Review by the National Park Service or Forest Service if a Class I area is nearby • Analysis of the proposed emission rate or control technology • Ambient air monitoring (for some facilities) • Computer modeling to analyze impacts on air quality, visibility, soils and vegetation NSR requires that you look at ways to minimize your emissions. In a nonattainment area review, you must have the Lowest Achievable Emission Rate (LAER). LAER does not account for things like cost –– it is strictly a technical determination of what the smallest emission rate is for your emission unit. For Prevention of Significant Deterioration (PSD) reviews in attainment areas, Best Available Control Technology (BACT) must be applied. BACT is not necessarily a type of pollution control equipment, although the name implies it. A BACT study gives an emission rate, and it does consider cost, along with other factors. If you can achieve the emission rate with something like good process control, then good process control is BACT. You may have the option of obtaining a synthetic minor permit to restrict your emissions to less than threshold levels for New Source Review. If you do, the requirements of NSR are avoided. You may take permit conditions to restrict emissions from a new facility to less than 100 tons per year or 250 tons per year. If your existing facility has always had actual emissions below NSR thresholds, then you may also be able to receive a synthetic minor permit. You may also obtain a synthetic minor permit amendment for a modification. Please note that whether your facility is a major source or a synthetic minor source, you may not begin construction until a permit is issued.

6.1.4 New Source Performance Standards (NSPS) New Source Performance Standards (NSPS) exist so that new emission sources emit less pollution than old sources. You can find complete information on NSPS in Part 60 of the Code of Federal Regulations. Sources subject to NSPS have to follow all the general requirements in Part 60.1 - 60.29. Each NSPS applies only to defined sources that construct, modify or reconstruct after the date a particular NSPS was proposed. Part 60 defines the type and size of unit or facility for each NSPS. Emission limits, monitoring requirements, testing methods and reporting requirements are also part of most New Source Performance Standards. Form GI- 09(D) provides a list of emission sources subject to NSPS.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 6-6 When looking at NSPS, modification has a specific meaning. Modification means a physical or operational change to your facility that results in an increase in the emission rate of a regulated pollutant. Routine maintenance and repair is not considered a modification. Neither would an increase in the hours of operation because the potential emission rate (i.e., lb/hr) would not change. Reconstruction may be a modification and is defined for NSPS. Reconstruction is the significant replacement of existing components to an emission source (i.e., the cost of repair is greater than 50% of the cost of replacing the entire emission source).

6.1.4.1 An example of an NSPS Suppose you have an oil-fired boiler rated at 30 million Btu/hr and built after June 9, 1989. A New Source Performance Standard applies to your boiler: Subpart Dc – Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. This NSPS sets a SO2 limit for your boiler. The SO2 limit is 0.5 lb of SO2/million BTU of heat input or a sulfur content limit for the fuel oil of 0.5% by weight. If you choose the sulfur content limit, you would show that you comply with the requirement by fuel sampling or supplier certification. You would keep records of your fuel reports and report each quarter. If you opted for the other SO2 limit, you would need a SO2 emissions monitor on your stack. For an oil burning boiler, there is no particulate matter (PM) limit, however, it may not emit gases that have more than 20% opacity. Opacity is a measure of the visible emissions, such as smoke or dust, from a stack exhaust.

6.1.5 Acid Rain The acid rain program generally applies to power utilities with a generating capacity of more than 25 megawatts. It may apply to you if your facility combusts fossil fuel and generates electricity for wholesale or retail sale. The acid rain program requirements are in Parts 72, 73, 75, 77, and 78 of Title 40 of the Code of Federal Regulations. See Form GI-09(E) for further information.

6.1.6 Stratospheric Ozone Protection Because certain chemicals may cause a depletion of the ozone layer, the 1990 Clean Air Act Amendments has phased out their production. A list of ozone depleting chemicals is included in Form GI-09(F), Table D. Most of the chemicals are chlorofluorocarbons (often referred to as Freons®). Other affected compounds include 1,1,1-trichloroethane and carbon tetrachloride. If your facility manufactures, sells, distributes or uses any of the chemicals, this rule applies to you. If so, you will also need to identify any replacement chemical(s) in your permit application. These regulations are in Part 82 of Title 40 of the Code of Federal Regulations. The Environmental Protection Agency has a Stratospheric Ozone Hotline. The telephone

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 6-7 number is 1-800-296-1996 and it is available Monday through Friday, from 9:00 am to 3:00 pm Central Standard Time. Note that if you replace an ozone depleting chemical with a VOC containing compound, you may need a permit to authorize the change in your operations.

6.1.7 Compliance Assurance Monitoring Compliance Assurance Monitoring requirements apply to facilities that operate emission control devices subject to federally enforceable regulations promulgated prior to 1990. These regulations are not limited to EPA regulations, but include any regulation that pertains to the Part 70 operating permit rule. This includes New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAPs), and Minnesota Rules contained in the State Implementation Plan. Periodic monitoring applies to those facilities and units that are not subject to enhanced monitoring. The MPCA has guidance on what it will accept as periodic monitoring. This guidance is attached to Form CD-01, Compliance Plan. You can find more information on monitoring and compliance in Part 2 of the Guide.

6.2 What are the Minnesota rules? Whether your facility needs a permit or not, you still have to comply with the state rules. Table 6-3 lists the Minnesota rules related to air emission facilities. The Minnesota Air Quality Rules were renumbered as listed in The Minnesota State Register dated August 23, 1993. If you have difficulty locating a specific rule, contact the Permit Information Specialist, whose phone number is in Focus Section of Part 1.

Table 6-3 MINNESOTA'S AIR QUALITY RULES RELATING TO AIR EMISSION FACILITIES

Chapter Title

7002 Fees 7005 Air Quality Definitions and Abbreviations 7007 Air Emission Permits 7009 Ambient Air Quality Standards 7011 Standards of Performance for Stationary Sources 7017 Monitoring and Testing Requirements 7019 Notification, Reporting, and Emission Inventory Requirements 7030 Pollution Control

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 6-8 6.2.1 Air Quality Permit Rule Minnesota Rules Chapter 7007 contains the requirements for air emission permits. Even though this Guide introduces many sections of the permit rule, you should become familiar with the rule itself. Again, you can obtain a copy of the rule from the Permit Information Coordinator (see the Focus Section in Part 1 for the phone number). Copies of the rule can also be ordered from the Minnesota Print Communications Division (see Appendix 2-A for ordering information).

6.2.2 Environmental Review Program The and Review function of the MPCA conducts environmental reviews of projects with the potential for significant environmental effects. If your new facility or modification has potential air emissions of 100 tons per year or more, EQB review is required. EQB review is also required for projects that fall in certain "mandatory" categories. The mandatory category lists are in Appendix 4. Some government units (e.g., a city) may request environmental review even if it is not mandatory. Citizens can also petition for environmental review. An Environmental Assessment Worksheet (EAW) is the first step in environmental review. An EAW consists of a series of questions about your project. You will have to answer questions related to land use, impacts on plants and animals, air pollution and . An EAW determines if an Environmental Impact Statement (EIS) should be done. Typically, an EAW takes up to six months to complete, including a 30-day public comment period. If an EIS is required, the EIS will contain more detailed information. An EIS considers alternatives to the proposed project and explores methods for reducing adverse environmental effects. An EIS typically takes over a year to complete, including two public comment periods. If you obtain a permit that restricts your potential emissions to less than 100 tons per year, environmental review may be avoided. If you have another modification, however, environmental review may be required at that time even if the increase in potential emissions from the project is less than 100 tons per year. The rules governing environmental review are found in Minnesota Rules Chapter 4410.

6.2.3 Standards of performance for stationary sources Minnesota has performance standards for about 50 emission units or facility types. Many of these are the same as federal New Source Performance Standards. Look at Form GI-09(I) for the titles and where you can find each standard in Minnesota Rules Chapter 7011. For example, there are rules for fossil fuel-fired, indirect heating equipment (e.g., boilers). The indirect heating equipment rules have emission limits based on the size of the unit, its location, and the

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 6-9 type of fuel burned. These limits cover particulate matter, opacity, sulfur dioxide, and nitrogen oxides. There are also different standards based on the age of the equipment. One Minnesota standard that you can choose to have apply to your facility is for control equipment (Minn. R. 7011.0060 - 7011.0080). This rule only applies if you choose to use the listed efficiencies in the rule to determine what type of air emissions permit (or permit amendment) you need. If you choose to be subject to this rule, then you must meet all the conditions of the rule -- the recordkeeping, monitoring, and operation and maintenance requirements listed in the rule. These requirements will be added to your permit when it is issued. There are limitations on when the rule can be used when making modifications. Refer to Part 3: Making Changes for more information on modifications.

6.2.4 Emission inventory and air quality emission fees If your facility is subject to the air permit rule, you must also file an annual Emission Inventory. This inventory details the actual emissions from the facility based on records of material use and total production. You must sign a certification that says your inventory is true, accurate and complete to the best of your knowledge. Air quality fees are based on the amount of actual emissions reported in your inventory. These rules are found in Chapters 7002 and 7019. The MPCA mails the forms for your inventory in January of each year. The completed inventories are due in April. If you are required to pay emission fees, but you do not submit an inventory of your actual emissions, your fees will be based on your facility's potential to emit. Since your potential emissions may be greater than your actual emissions, it is important that you submit your emission inventory on time.

6.2.5 Performance testing for emissions Sometimes performance tests will be needed to measure your emissions or control equipment efficiency. Performance testing helps you know if emission limits and control equipment efficiencies in your permit are being met. Testing must follow the procedures outlined in Minnesota Rules Chapter 7017. The rule requires a process or unit to operate at its highest emission rate for testing. If the highest emission rate operating condition is not known, testing would be conducted at the maximum process rate. You may elect to conduct testing under some other condition. If approved by the MPCA, the other testing conditions will then be part of your permit. Refer to Section 2.7 in Part 2 of the Guide for more detailed information on performance testing.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 6-10 7.0 HOW DO YOU MAINTAIN FLEXIBILITY IN YOUR OPERATIONS? The air permit rule has some provisions that allow you to build flexibility into your permit. For example, permit limits can be somewhat flexible. For example, a limit can specify material usage for a group of emission points, such as paint usage for a group of spray booths. In this case, a group or overall limit may be more flexible for you than limits for each individual emission point. In addition, modifications (changes that may cause an increase in emissions) allow you to make some changes before a permit or amendment is issued. Part 3 of the Guide describes the different types of modifications and when you may make the changes.

7.1 What is operational flexibility? Specific provisions are outlined in the air permit rule for operational flexibility. When you apply for a permit, you would request this flexibility and propose specific language to include in your permit.

7.1.1 Alternative operating scenarios After you have an air emission permit for your total facility, your operations may change. You may have frequent operational changes or changes with short time tables. These changes may cause you to need a permit amendment. Applying for and waiting for an amendment may be inconvenient or even hurt your business. If you can foresee the various modes of operation that you may need, they can be included in your facility's air emission permit. If so, you would not need to amend a permit when you switch between operating modes. In your application, you must describe each operating mode. Each mode is an alternative operating scenario. Each scenario must have its own calculations and methods of monitoring and record keeping. The monitoring and record keeping must be specific enough to verify your compliance status at all times. When you switch between scenarios, you must record related data. These include the date, time, duration and production totals for each change of scenario. Section 2.10.2 in Part 2 discusses record keeping and reporting in greater detail. An example of an alternative operating scenario is a boiler that uses natural gas as its primary fuel, and fuel oil as a backup fuel. Different record keeping and monitoring would be done when fuel oil is used than when gas is used. For instance, the sulfur content of the fuel oil would be tracked while using oil, but not when using gas. Another example is a printing press with control equipment for volatile organic compounds. Both solvent-based inks and water-based inks are used. When water-based inks are used, the control equipment may not have to be run at all. If the control equipment does run, it most

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 7-1 likely would be at a different temperature and efficiency than when solvent-based inks are used. Both operating scenarios should be addressed in the permit application.

7.1.2 Emission trading Emission trading may apply to your facility. Emission trading is another way to avoid delays when making changes within your facility. Emission trading applies to the emissions of a single pollutant and is facility-specific. The facility will typically have an emission cap on a group of sources or the total facility, rather than limits for each emission point. The cap can be a synthetic minor permit limit. Trading allows you to exchange emission increases with emission decreases that occur within your facility. The cap and any other emission limits must not be exceeded. Emission trades are not allowed if they would be a modification as defined in New Source Review, New Source Performance Standards, or National Emissions Standards for Hazardous Air Pollutants. When you wish to make a trade, the MPCA must be notified at least seven working days in advance. To use emission trading, request it in your permit application. You must also propose your monitoring and record keeping methods to quantify the emission trades. Be aware that the monitoring and record keeping must be done the same way every time a trade is made. Options for monitoring and quantifying the trades range from simple to complex as shown by these examples: • Fuel use or material usage records • Calculations based on acceptable engineering estimation techniques • Measurement of emissions, process parameters, control equipment parameters, and material data performed on a periodic basis • Results of operations and maintenance programs, work plans, leak detection programs, and dust control programs • Continuous monitoring systems for process or control equipment parameters, or for emissions

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 7-2 8.0 WHAT IF YOU HAVE CONFIDENTIAL MATERIAL IN AN APPLICATION? Your permit application will contain detailed information about your facility. You may wish to keep some of that material confidential. Normally, everything submitted to the MPCA is available to the public. The Minnesota Data Practices Act allows some kinds of data, such as trade secrets or sales figures, to be kept confidential. Facility data related to emissions may not be kept confidential. For the MPCA to treat information in your application as confidential, you must submit a written request to the MPCA using Form CR-03. This request should identify what specific data in your application is confidential. You must state the reason for keeping the data confidential and certify that the material is confidential. The two legal provisions most likely to apply to permit applications protect the following kinds of data: • Data furnished to the agency that relates to (a) sales figures, (b) processes or methods of production unique to the owner or operator, OR (c) information which would tend to affect adversely the competitive position of said owner or operator. (Minn. Stat § 116.075, subd. 2) • Data including a formula, pattern, compilation, program, device, method, technique or process (1) that was supplied by the affected individual or organization, (2) that is the subject of efforts by the individual or organization that are reasonable under the circumstances to maintain its secrecy, AND (3) that derives independent economic value, actual or potential, from not being generally known to, and not being readily ascertainable by proper means by, other persons who can obtain economic value from its disclosure or use. (Minn. Stat. § 13.37, subd. 1(b)) However, even if the information falls under one of the above categories, if it is considered emissions data (defined in 40 CFR § 2.301), then the information is considered public. Both the Clean Air Act and Environmental Protection Agency (EPA) regulations require that “emission data” submitted to the MPCA under Title V or Minnesota’s State Implementation Plan must be available to the public. In addition, EPA has issued guidance on what type of information it generally considers to be emission data (Federal Register Vol. 56, No. 35; February 21, 1991). Please note that only specific data within an application can be considered confidential, not the entire application or permit. The MPCA staff will review your request and reply in writing. If your request is approved, the confidential material is kept in a separate, locked file at the MPCA.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 8-1 Once a piece of information has been approved as confidential, you must submit another copy of your application with the confidential data removed. That copy will be for the public file. If you send the MPCA any other documents that contain the confidential data, you must label it and request confidential status again. It is your responsibility to properly label (approved) data as confidential. The MPCA staff will not sort documents for data that may be confidential, but are not labeled. If you do not request and receive approval to have material treated as confidential, please take note! Stamping the word "Confidential" on a document will not cause the MPCA to treat it as confidential. For material to be treated as confidential, you must submit a written request for confidentiality and the MPCA must approve your request. The MPCA can agree to keep your data confidential. However, if the EPA requests the information from the MPCA, the agency must provide it. The material will not be treated as confidential by the EPA unless you request that the EPA does so. Requests for the EPA to keep data confidential are governed by Part 2 of Title 40 of the Code of Federal Regulations. Requests to EPA for confidentiality should be made to: Chief, Grants Management and Program Evaluation Section EPA Region V 77 West Jackson Blvd. Chicago, Illinois 60604

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 8-2 9.0 WHAT IS IN A COMPLETE PERMIT APPLICATION? A complete permit application contains information about your emission sources and your facility. It is the starting point for your permit. Your application should include the facility and emissions data you have collected based on the suggestions offered in Sections 2 through 5 of Part 1 of the Guide. The MPCA has developed standard forms you must use when you apply for a permit. The Blue Ox Woodworks case study (Section 10) has examples of completed forms (Appendix 5-A). These forms list the information needed by the MPCA to write a permit for your facility. If a question on a form is not applicable or the information is not available, note that by the question. If you find that a form does not apply to your facility, do not submit it. Table 9-1 shows the information you must supply in an application. The Application Forms Master List can serve as a table of contents for your application. This form can also be used as a checklist while you prepare your application. It will help to monitor those portions of the application you have completed. Your application will also cover compliance issues. After you decide what air permit rules apply to your facility, you must determine whether you comply with them. Your application should outline how you will correct any situations where your facility does not comply at the time you submit the application. Also, you must submit a plan for keeping your facility in compliance once the permit is issued. Part 2: Determining Compliance helps you work through the compliance issues for your application. Your application must certify that the information is complete and correct to the best of your knowledge. This certification must be signed by a responsible official. The signer can be a president, general partner or a ranking elected official. Other qualified people are listed in Minnesota Rule Chapter 7007.0100, subpart 21. The person signing an application is responsible for its contents, regardless of who prepared it.

9.1 Why is a "complete" application important? The process to obtain a permit will not continue until your permit application is complete. A permit application that is "right the first time" will save time. If a permit engineer has to request additional information, your permit could be delayed. By filing a timely and complete application, you may also benefit from the "application shield." Section 5.3.1 in Part 2 of the Guide explains when the application shield applies.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 9-1 Table 9-1 SUMMARY OF INFORMATION TO BE INCLUDED IN AN APPLICATION Type of Information Typical Information to be Provided

Identifying Information Facility location and mailing address. Contact persons. Genera process and products description. Application Certification. Facility layout and stack locations.

Process and Products Description Detailed process schematic flow diagrams.

Detailed Emissions Related Information Detailed stack or vent information. Detailed emissions unit information. Emission data.

List of All Applicable Requirements Identification of all rules that apply to the facility.

Compliance Requirements A compliance certification statement for all requirements that apply. A compliance plan to provide for long-term compliance with all rules that apply. A compliance schedule to correct any noncompliance

9.2 When were complete permit applications due? Due dates for complete permit applications were based on SIC codes (see Section 4.0). Table 9-2 shows the due dates for air emission permit applications for your entire facility. If you did not submit a timely application, this may affect your ability to utilize the modification provisions, described in Part 3: Making Changes.

Table 9-2 DUE DATES FOR FACILITY AIR EMISSION PERMIT APPLICATIONS

SIC Code Range Application Due Date

0000 to 2399, excluding 1422, 1423, 1429, 1442, 1446, 2041, and 2048 January 15, 1995

2400 to 2999 and 4953, excluding 2951 and 2952 April 15, 1995

3000 to 4499 June 15, 1995

4500 to 5099, excluding 4953 September 15, 1995

5100 to 8199 December 15, 1995

1422, 1423, 1429, 1442, 1446, 2041, 2048, 2951, 2952, and 8200 to 9999 February 15, 1996

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 9-2 9.3 What happens to your application at the MPCA? Figure 9-1 is a flowchart showing the steps of the process to issue an air emission permit for your facility. After you submit a permit application, the MPCA performs two reviews. During the first review, the administrative completeness review, the MPCA checks that your application is signed, uses the MPCA's forms, and has no obvious omissions. The second review is the technical completeness review. This is when the MPCA permit engineer analyzes the content and technical details of your application. The PTE calculations will be reviewed and rule citations checked, among other things. Within 60 days, the MPCA may send a letter telling you if your application is not complete. If the application is not complete, the MPCA will explain what must be added or revised to complete the application. Once the application is complete, the process of issuing your permit starts. PLEASE NOTE THAT IF YOUR APPLICATION IS NOT COMPLETE, THE PROCESS STOPS AND YOUR PERMIT WILL BE DELAYED. A complete permit application allows the MPCA permit engineer to continue the process and draft your permit. The permit engineer may then contact you to discuss your application, ask questions, and request other necessary information. The permit engineer also can answer your questions regarding your permit. Drafts of facility permits and some amendments must have a public notice. The public notice announces that the MPCA intends to issue your permit and will accept comments from the public on the draft permit. The public comment period lasts 30 days. If a facility is within 50 miles of a state border, the neighboring state also reviews the draft permit. The permit engineer replies to public comments with a letter. The draft permit may have to be revised based on public comments. Occasionally, the comments indicate a need for more analysis or more public participation. These comments are often those that bring to the MPCA's attention the extent of public concern over a project, that call into question whether rules were properly followed, or if the right data were used. Public meetings or contested case hearings may be held to resolve such issues. The EPA reviews draft air emission permits. For state permits, the EPA review period is 30 days, and occurs at the same time as the public comment period. For Part 70 permits, the EPA has 45 days to comment. This 45-day comment period occurs after the 30-day public comment period. If the EPA has comments that require changes to your draft permit, then your draft permit will be revised. If no comments arise that require changes to the draft permit, your permit is issued. In general, the MPCA will either issue or deny your permit within 18 months from the time your application has passed the technical completeness review.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 9-3 Figure 9.1 Process to Issue an Air Emission Permit for a Total Facility

Complete application package received ß

Acknowledgment sent by support staff Þ Within 7 days of receipt of application ß

Completeness determination Þ Within 60 days of receipt of application ß Draft permit written by permit engineer, reviewed by Air Quality staff, and revised as necessary ß Draft permit reviewed by applicant, possibly revised by permit engineer ß Draft permit placed on public notice for 30 days ß Address comments received during notice period ßßßß If a Part 70 permit, the State or Synthetic Minor EPA gets an additional permit can be issued 45 days to review ß Resolve all of EPA’s comments and concerns ß Part 70 permit can be issued

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 9-4 10.0 CASE STUDY -- BLUE OX WOODWORKS A case study has been assembled to show how the concepts in Part 1 fit together. A fictional facility, Blue Ox Woodworks, has been created by the MPCA. This case study will be used in each Part of the Guide. The concepts presented here will show how the forms were completed for the Blue Ox Woodworks' permit application.

10.1 History of Blue Ox Woodworks Otto Walder started Blue Ox Woodworks, a small millwork shop, in 1954. Otto saw a need to provide good quality trim and other milled goods to his neighbors in Central Minnesota. A former dairy farmer, Otto named his new company in memory of his favorite ox, Babe. The original milling operations included saws, planers, shapers, routers and sanders. As much as 20% of the wood was being thrown away as waste, so Otto and his employees began collecting the scrap wood from these operations and burning it in the boiler to heat the building. Much of the scrap collected during the summer is stored outside until it is needed. In 1966, Blue Ox Woodworks added three baghouses to the facility to collect the sawdust generated by the various operations. The sawdust was also burned in the boiler. Otto installed a diesel generator to provide backup electricity in case of power disruptions. In the later 1960s and the early 1970s, Otto replaced all of the original equipment and then added to it. Blue Ox Woodworks' production rose and fell over the years, but the maximum production rate was 460,000 board feet per year. He sold the milled wood directly to construction companies, window manufacturers, and to other small companies who stain, coat, prime and paint the wood before selling it in retail outlets. In the mid-1980s, Otto's daughter, Phyllis, became the day-to-day head of operations at the Blue Ox plant. Phyllis saw an opportunity to increase profits by finishing the millwork internally. In 1988, she installed a spray booth. To handle the variety of coatings, Blue Ox Woodworks installed four spray guns in the booth. Only two of the four guns are ever used at once, so the compressor was sized for two guns. Wall filters in the booth control particulate emissions. A steam-heated dryer is used to dry the finished coating. Solvent vapors from the spray booth and the dryer are directed to and then burned in a thermal oxidizer. When her dad retired in 1990, Phyllis became Blue Ox Woodworks' owner and operator. The plant began to utilize its raw material much more efficiently, and as a result, there was not always enough wood waste to fuel the boiler, particularly in the winter months. In 1991, Phyllis installed a new boiler as a backup, fueled primarily by natural gas, but also able to burn distillate or residual oil.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-1 Blue Ox Woodworks now operates two eight-hour shifts per day, five days a week. The plant shuts down for two weeks in December every year. 1997 was a record production year for Blue Ox Woodworks. However, Phyllis was concerned about her limited paint spray booth capacity. Phyllis plans to add an additional spray booth and compressor identical to the current system sometime in 1999. The following information lists emission units at Blue Ox Woodworks. Section 10.3 also includes potential to emit calculations for the facility. You may want to review Appendix 5-A which includes completed facility description and calculation forms for Blue Ox Woodworks.

10.2 Blue Ox Woodworks Emission Unit Information

Blue Ox Woodworks, Inc.

Owner: Phyllis Walder Address: 11 Green Lane Clear Sky (Dry Rock County), Minnesota 55000 Telephone Number (218) 555-0011 [Fax]: [(218) 555-0012] Name of Firm: Blue Ox Woodworks, Inc. SIC Code: 2431 (Millwork) Previous permits: None Number of Employees 28 Size of Property 5 acres (buildings are located at least 1/4 mile from nearest residence or public roadway)

10.2.1 Boilers Blue Ox Woodworks currently operates a wood-fired boiler (rated at 7.2 million Btu per hour) and a natural gas/oil-fired boiler (rated at 11.5 million Btu per hour). Blue Ox installed the wood-fired boiler when the original building was built in 1954. The wood-fired boiler burns scrap wood and sawdust from the milling operations and creates steam to heat the building and operate the cure oven. The natural gas/oil-fired boiler was installed in 1991 and serves primarily as a backup.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-2 Boiler No. 1: Manufacturer: Bunyan Boilers, Inc. Date installed: 1954 Rated heat input 7.2 million Btu per hour Fuel: Wood, sawdust Firing Method: Stoker Stack Parameters: Height: 50 feet Inside exit diameter: 1.5 feet Exhaust flow rate, acfm: 14,400 @ 300 °F

Boiler No. 2: Manufacturer: Superior Boilers Date Installed: 1991 Rated Heat Input: 11.5 million Btu per hour Fuel: Natural gas, distillate oil, residual oil Stack Parameters: 50 feet Inside exit diameter: 1.5 feet Exhaust flow rate, acfm: 15,300 @ 300 °F

Note: No emissions from storage tanks for diesel fuel and distillate and residual oils.

10.2.2 Milling operations Blue Ox Woodworks operates several milling lines: a saw line, a molding line, a planing line, and a sanding line. The saw line consists of a cutoff saw, two table saws, a resaw, and a ripsaw. The molding line has four molders; the planing line has three planers. The sanding line includes five sanders. Emissions from the milling lines flow through one of three bag filters. Each has an air-to-cloth ratio of 8:1. The rated air flows are 20,000, 40,000 and 65,000 acfm (@ 70 °F). All existing milling equipment was installed between 1969 and 1975. (All of the original equipment was replaced.) The bag filters were also installed during this time.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-3 Saw line: Molding Line: Cutoff Saw: Molder: Manufacturer: Norske Manufacturer: Buzzsaw Date installed: 1974 Date installed: 1973

Resaw: Molder: Manufacturer: Lakeland Manufacturer: Buzzsaw Date installed: 1969 Date installed: 1974

Table Saw: Molder: Manufacturer: Lakeland Manufacturer: Buzzsaw Date installed: 1971 Date installed: 1976

Table Saw: Molder: Manufacturer: Buzzsaw Manufacturer: Buzzsaw Date installed: 1974 Date installed: 1976

Ripsaw: Manufacturer: Ripley Date installed: 1974

Planing line: Sanding Line:

Planer: Sander: Manufacturer: Spruce Goose Manufacturer: Loon Date installed: 1972 Date installed: 1971

Planer: Sander: Manufacturer: Spruce Goose Manufacturer: Loon Date installed: 1972 Date installed: 1974

Planer: Sander: Manufacturer: Spruce Goose Manufacturer: Loon Date installed: 1975 Date installed: 1974

Sander: Manufacturer: Loon Date installed: 1976

Sander: Manufacturer: Loon Date installed: 1976

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-4 Baghouse No. 1 Manufacturer: Ladyslipper Date installed: 1966 Model: 143 AB 94 Air to cloth ratio: 8:1 Flow rate, acfm: 65,000 @ 70 ºF Manufacturer's recommended pressure drop: 2 - 4 inches water column (W.C.) Stack Parameters: Height 24 feet Inside exit diameter: 2.0 feet by 8 feet Flow rate, acfm: 65,000 @ 70 ºF Baghouse No. 2 Manufacturer: Ladyslipper Date installed: 1972 Model: 143 AB 94 Air to cloth ratio: 8:1 Flow rate, acfm: 40,000 @ 70 ºF Manufacturer's recommended pressure drop: 2 - 4 inches W.C. Stack Parameters: Height 24 feet Inside exit diameter: 2.0 feet by 8 feet Flow rate, acfm: 40,000 @ 70 ºF Baghouse No. 3 Manufacturer: Ladyslipper Date installed: 1975 Model: 143 AB 94 Air to cloth ratio: 8:1 Flow rate, acfm: 25,000 @ 70 ºF Manufacturer's recommended pressure drop: 2 - 4 inches W.C. Stack Parameters: Height 24 feet Inside exit diameter: 2.0 feet by 8 feet Flow rate, acfm: 25,000 @ 70 ºF

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-5 10.2.3 Painting operations The spray booth contains four guns, only two of which can operate simultaneously. (The compressor for the booth will only produce enough pressure for two guns.) The process is airless spray so the transfer efficiency is 45 percent. Each gun is rated at 5 gallons per hour. The coating process uses white paint, sealer, wipe stain, basecoat, and mineral spirits for cleanup. They also use a proprietary paint and stain identified as “paint 1A” and “stain 2A.” The properties of these materials are shown in a table in Section 10.3.4. The booth is equipped with wall filters capable of collecting 90 percent of captured particulate emissions. [The booth is a hood-type design, so not all emissions are captured; 80% of the total particulate matter is captured.] Sixty percent (60%) of the Volatile Organic Compound (VOC) emissions flow to a thermal oxidizer that destroys 90 percent of the VOCs it receives. The remaining 40% of the VOC emissions escape into the atmosphere. The thermal oxidizer combusts 5 million Btu per hour of natural gas.

Spray Booth: Wall Filter: Manufacturer: Blizzard Manufacturer: Northwind Filters Date installed: 1988 Date Installed: 1988 Control Efficiency: 72% PM10 (80% is captured, 90% of that is collected) Spray Guns: Manufacturer: Blizzard Cure Oven: Date installed: 1988 Manufacturer: Great Lakes Ovens Number of guns: 4 Date installed: 1988 Maximum flow rate: 5 gal/hr Operating temperature: 350 °F

Thermal Oxidizer: (Control equipment for spray booth and cure oven.) The control and capture efficiency for thermal oxidizer are based on the manufacturer's guarantee. Manufacturer: Inferno Control Systems Date installed: 1988 Fuel: Natural Gas Rating: 5 million Btu/hr Control efficiency (VOCs): 90 percent (VOCs) Capture efficiency 60 percent (VOCs) (spray booth & oven VOCs) Operating temperature, combustion chamber: 1400 °F Volume, combustion chamber: 525 cubic feet Residence time: 0.75 seconds

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-6 Stack Parameters: Height: 45 feet Inside exit diameter: 2.5 feet Exhaust flow rate, acfm: 25,000 @ 650 °F

Painting Cleanup: Blue Ox Woodworks uses mineral spirits to clean up guns and other equipment after painting.

10.2.4 Diesel generator The diesel generator, installed in 1966, produces 225 horsepower of electrical output. It is used as an emergency generator, and typically operates less than 90 hours per year. Manufacturer: Powerhouse Date installed: 1966 Rated electrical output: 225 horsepower Fuel: Diesel

10.2.5 Fugitive dust emissions No fugitive emissions result from woodchip storage piles. The sawdust from the baghouses is stored in an enclosed silo so there are no fugitive emissions.

10.2.6 Insignificant activities • The facility was painted during the last year. • A copier and a laser printer are used in the office portion of the facility. • There are some bathroom vents. • The employees park in a gravel parking lot.

10.3 Blue Ox Woodworks Emission Calculations General Notes: Blue Ox Woodworks has been operating out of compliance with Minnesota's state particulate rule, Standards of Performance for Indirect Heating Equipment (Minnesota Rules 7011.0500 - 7011.0550). To correct the situation, Phyllis is proposing to remove the wood-fired boiler and operate only with the gas/oil-fired boiler. Blue Ox will also propose synthetic minor limits, so they can be issued a non-expiring state permit.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-7 10.3.1 Wood boiler #1 calculations Rated heat input: 7.2 MMBtu/hour Heat content of wood: 8.0 MMBtu/ton

• AP-42 emission factors for wood boilers in pounds per ton of wood:

PM PM10 SO2 NOX VOC CO Pb 8.80 7.90 0.01 1.50 0.22 13.60 0.00

• Sample calculation (PM): (Note: "tpy" = tons per year)

MMBtu 1 ton of wood lbs PM 1 ton PM hours 7..2 ××88 ××=8760 34 . 6 9 tpy hour 8 MMBtu ton of wood 2000 lbs PM year

• Potential emissions based on AP-42, in tpy:

PM PM10 SO2 NOX VOC CO Pb 34.69 31.14 0.04 5.91 0.87 53.61 0.00

• Allowed PM emissions based on Minnesota Rules (7011.0545) PM limit, 0.6 lb/MMBtu:

lbs PM MMBtu hours 1 ton PM 06.. ×××72 8760 =18 . 92 tpy MMBtu hour year 2000 lbs PM

• Potential Emissions including State Rule limitations:

PM PM10 SO2 NOX VOC CO Pb 18.92 18.92 0.04 5.91 0.87 53.61 0.00

• 1997 Actual Emissions: (Based on 184 tons of wood waste burned, 204 hours of operation.)

PM PM10 SO2 NOX VOC CO Pb 0.81 0.71 0.01 0.14 0.02 1.25 0.00

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-8 10.3.2 New boiler #2 calculations Rated heat input: 11.5 MMBtu/hour Gas: 1000 Btu/cubic foot Distillate: 140,000 Btu/gal, 1% sulfur Residual: 150,000 Btu/gal, 2% sulfur

NATURAL GAS CALCULATIONS • AP-42 emission factors for natural gas, in pounds per million cubic feet (MMcf):

PM PM10 SO2 NOX VOC CO Pb HAPs* 7.6 7.6 0.60 100.0 5.5 84.0 0.0005 1.89 *Total HAPs; itemization of which pollutants are emitted is included in Appendix 5-A, Form EC-13C. • Sample Calculation (PM):

MMBtu 1 MMcf lb PM hours 1 ton 11.5 ××××=7.6 8760 0.383 tpy hour 1000 MMBtu MMcf year 2000 lb

• Potential emissions for natural gas based on AP-42:

PM PM10 SO2 NOX VOC CO Pb HAPs 0.383 0.383 0.03 5.04 0.28 4.23 0.00 0.095

• 1997 Actual Emissions (based on 28.8 MMcf of natural gas used):

PM PM10 SO2 NOX VOC CO Pb HAPs 0.109 0.109 0.009 1.44 0.079 1.21 0.00 0.027

RESIDUAL OIL CALCULATIONS • AP-42 Emission Factors for residual oil in lb/1000 gallons:

PM PM10 SO2 NOX VOC CO Pb HAPs* 9S + 3.2 8S + 2.7 159S 55.00 0.28 5.00 0.0042 0.156 *Total HAPs; itemization of which pollutants are emitted is included in Appendix 5-A, Form EC-13C.

• AP-42 Emission Factors corrected for 4% sulfur:

PM PM10 SO2 NOX VOC CO Pb HAPs 39.2 34.7 636 55.00 0.28 5.00 0.0042 0.156

• Sample Calculation (PM):

MMBtu 1 gallon Btu lb PM hours 1 ton 11.5 ××1,000,000 ×××=39.2 8760 13.16 tpy hour 150,000 Btu MMBtu gallon year 2000 lb

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-9 • Potential emissions for residual oil based on AP-42:

PM PM10 SO2 NOX VOC CO Pb HAPs 13.18 11.65 213.6 18.47 0.094 1.68 0.001 0.057

• 1997 Actual Emissions: 0 (no residual oil used in 1993)

DISTILLATE OIL CALCULATIONS • AP-42 emission factors for distillate oil in lb/1000 gallons:

PM PM10 SO2 NOX VOC CO Pb HAPs* 2.00 1.00 144S 20.00 0.20 5.00 0.0004 0.082 *Total HAPs; itemization of which pollutants are emitted are included in Appendix 5-A, Form EC-13C. • AP-42 emission factors corrected for 1% sulfur:

PM PM10 SO2 NOX VOC CO Pb HAPs 2.00 1.00 144 20.00 0.20 5.00 0.0004 0.082

• Sample Calculation (PM):

MMBtu 1 gallon Btu lb PM hours 1 ton 11.5 ××1,000,000 ×××=2 8760 0.72 tpy hour 140,000 Btu MMBtu gallon year 2000 lb

• Potential emissions for distillate oil based on AP-42:

PM PM10 SO2 NOX VOC CO Pb HAPs 0.72 0.36 51.77 7.20 0.07 1.80 0.00 0.130

• 1997 Actual Emissions: 0 (no distillate oil burned in 1993)

Overall potential emissions for boiler #2, based on worst case fuels:

PM PM10 SO2 NOX VOC CO Pb HAPs 13.18 11.65 213.6 18.47 0.28 4.23 0.001 0.130

• Allowed PM emissions based on Minnesota Rules 7011.0545 (PM limit = 0.4 lb/MMBtu):

lb PM MMBtu hours 1 ton 0.4 ×××=11.5 8760 20.15 tpy MMBtu hour year 2000 lb

This results in allowed PM emissions of 20.15 tpy, which Blue Ox is well below.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-10 10.3.3 Milling equipment calculations • Potential PM Emissions based on baghouse manufacturer’s guarantee (Option 3 on Form EC-11, assumption is that all PM is PM10): Guaranteed emission rate = 0.02 gr/dscf for each baghouse dscf grains min 1 lb 1 ton SV #3: 35,000 ××0.02 525,600 ××=26.3 tpy min dscf year 7000 grains 2000 lb

• Allowed PM emissions based on Minnesota Industrial Process Equipment Rule limits (Minn. R. 7011.0700-7011.0735):

Stack Flow Limit at max. flow Allowed Annual Emissions SV#3: 35,000 dscfm 0.059 gr/dscf 77.99 tpy SV#4: 30,000 dscfm 0.062 gr/dscf 70.27 tpy SV#5: 25,000 dscfm 0.066 gr/dscf 62.13 tpy

• Sample calculation of Allowed Emissions (SV #5):

dscf grains min 1 lb 1 ton 25,000 ××0.066 525,600 ××=62.1 tpy min dscf year 7000 grains 2000 lb • 1997 actual emissions (SV#3, #4, and #5 combined): PM: 17.45 tpy PM10: 17.45 tpy

10.3.4 Painting equipment calculations Spray Booth Parameters: • 4 spray guns, 5 gallons per hour each • Transfer efficiency of airless spray (Y) = 45% • Thermal oxidizer destruction efficiency = 90% • Wall filter control efficiency = 90% • PM Capture efficiency = 80% • VOC Capture efficiency = 60% There is one spray booth at the facility. The booth is used to spray stain and varnish, as well as primer (basecoat) and paint. There are 4 guns in booth; however, only 2 guns can be used at a time due to compressors. The potential emissions are the highest emission rates for VOC and particulates given the coatings available.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-11 White Wipe Paint Sealer Stain Basecoat Paint 1A Stain 2A Coating reference number 12 3 4 5 6 Density (lb/gal) 9.85 8.06 7.54 9.14 7.5 7.3 VOC content (lb/gal) 7.39 5.56 7.24 5.64 5.1 6.0 Solid content (lb/gal) 2.46 2.5 0.3 3.5 2.4 1.3 1997 usage (gals) 4000 5200 2000 1000 1200 500 HAPs content (lb/gal) Methyl ethyl ketone 0.528 0 0 0 0.492 0 Methyl isobutyl ketone 0 0.377 0.140 0 0.82 0 Toluene 0.025 0.377 0.365 0 1.312 0 Xylene 0 1.885 1.46 0 0.902 0 Total Volatile HAPs 0.553 2.64 1.97 0 3.53 0 Cadmium Compounds 0.014 0 0 0.019 0 0.022 Lead Compounds 0.006 0 0 0.008 0 0 Total PM HAPs 0.02 0 0 0.027 0 0.022

Phyllis looked at using the Minnesota control equipment performance standard (Minn. R. 7011.0060 - 7011.0080) for the thermal oxidizer and spray filters. The control efficiencies listed in the rule are 57% overall reduction for VOC (includes both capture and control) and 74% overall reduction for PM. The equipment currently obtains 54% overall reduction for VOC and 72% for PM. Phyllis doesn’t think it would be reasonable to make improvements to the efficiencies at this time, or to spend the money to do performance tests as required by the rule, so she decided not to use the Minnesota performance standard in her permit application. (Applicability of this particular standard is at the discretion of the applicant - it can be used to the applicant’s benefit if all conditions can be met. See also the fact sheet entitled “Control Equipment Standards,” attached in Appendix 6-A.)

CALCULATIONS • VOC (before controls):

gal hour lb VOC 1 ton 2 guns×× 5 8760 ×X × =uncontrolled VOC, tpy hour year gal 2000 lb

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-12 Coating No. 1 VOC PTE = 323.68 tons per year Coating No. 2 VOC PTE = 243.53 tons per year Coating No. 3 VOC PTE = 317.11 tons per year Coating No. 4 VOC PTE = 247.03 tons per year Coating No. 5 VOC PTE = 223.38 tons per year Coating No. 6 VOC PTE = 262.80 tons per year

• VOC (after controls) (Assume 60% capture efficiency and 90% destruction efficiency)

Coating No. 1 VOC PTE = 148.89 tons per year Coating No. 2 VOC PTE = 112.02 tons per year Coating No. 3 VOC PTE = 145.87 tons per year Coating No. 4 VOC PTE = 113.63 tons per year Coating No. 5 VOC PTE = 102.75 tons per year Coating No. 6 VOC PTE = 120.89 tons per year Controlled PTE, coating operations = 148.89 tons per year (occurs when Coating No. 1 is used 100% of the time.)

• PM (before controls):

gal hour lb PM 1 ton 2 guns×× 5 8760 ×X × ×−=()1Y uncontrolled PM, tpy hour year gal 2000 lb

Coating No. 1 PM PTE = 59.26 tons per year Coating No. 2 PM PTE = 60.23 tons per year Coating No. 3 PM PTE = 7.23 tons per year Coating No. 4 PM PTE = 84.32 tons per year Coating No. 5 PM PTE = 57.82 tons per year Coating No. 6 PM PTE = 31.32 tons per year

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-13 • PM (after controls): (Assume 80% capture efficiency and 90% control efficiency)

Coating No. 1 PM PTE = 16.59 tons per year Coating No. 2 PM PTE = 16.86 tons per year Coating No. 3 PM PTE = 2.02 tons per year Coating No. 4 PM PTE = 23.61 tons per year Coating No. 5 PM PTE = 16.19 tons per year Coating No. 6 PM PTE = 8.77 tons per year Controlled PTE, coating operations = 23.61 tons per year (occurs when Coating No. 4 is used 100% of the time.) • PM allowed by State Rules: At exhaust flow rate of 10,000 actual cubic feet per minute and exhaust temperature of 300 °F, allowed PM is 0.1 gr/dscf, or 5.95 lb/hr, or 26.08 tons per year.

Hazardous Air Pollutant Emissions • Methyl Ethyl Ketone (MEK) (before controls):

gal hour lb MEK 1 ton 2 guns×× 5 8760 ×X × =uncontrolled MEK, tpy hour year gal 2000 lb

Coating No. 1 MEK PTE = 23.13 tons per year Coating No. 5 MEK PTE = 21.55 tons per year

• MEK (after controls): (Assume 60% capture efficiency and 90% destruction efficiency)

Coating No. 1 MEK PTE = 10.64 tons per year Coating No. 5 MEK PTE = 9.91 tons per year Controlled PTE, coating operations = 10.64 tons per year (occurs when Coating No. 1 is used 100% of the time.)

• Methyl Isobutyl Ketone (MIbK) (before controls): gal hour lb MIbK 1 ton 2 guns×× 5 8760 ×X × =uncontrolled MIbK, tpy hour year gal 2000 lb

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-14 Coating No. 2 MIbK PTE = 16.51 tons per year Coating No. 3 MIbK PTE = 6.39 tons per year Coating No. 5 MIbK PTE = 35.92 tons per year

• MIbK (after controls): (Assume 60% capture efficiency and 90% destruction efficiency)

Coating No. 2 MIbK PTE = 7.60 tons per year Coating No. 3 MIbK PTE = 2.94 tons per year Coating No. 5 MIbK PTE = 16.52 tons per year Controlled PTE, coating operations = 16.52 tons per year (occurs when Coating No. 5 is used 100% of the time.)

• Toluene (before controls): gal hour lb toluene 1 ton 2 guns×× 5 8760 ×X × =uncontrolled toluene, tpy hour year gal 2000 lb

Coating No. 1 Toluene PTE = 37.58 tons per year Coating No. 2 Toluene PTE = 16.51 tons per year Coating No. 3 Toluene PTE = 15.99 tons per year Coating No. 5 Toluene PTE = 57.47 tons per year

• Toluene (after controls): (Assume 60% capture efficiency and 90% destruction efficiency)

Coating No. 1 Toluene PTE = 17.29 tons per year Coating No. 2 Toluene PTE = 7.60 tons per year Coating No. 3 Toluene PTE = 7.35 tons per year Coating No. 5 Toluene PTE = 26.43 tons per year Controlled PTE, coating operations = 26.43 tons per year (occurs when Coating No. 5 is used 100% of the time.)

• Xylene (before controls): gal hour lb xylene 1 ton 2 guns×× 5 8760 ×X × =uncontrolled xylene, tpy hour year gal 2000 lb

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-15 Coating No. 2 Xylene PTE = 82.56 tons per year Coating No. 3 Xylene PTE = 63.95 tons per year Coating No. 5 Xylene PTE = 39.51 tons per year

• Xylene (after controls): (Assume 60% capture efficiency and 90% destruction efficiency)

Coating No. 2 Xylene PTE = 37.98 tons per year Coating No. 3 Xylene PTE = 29.42 tons per year Coating No. 5 Xylene PTE = 18.17 tons per year Controlled PTE, coating operations = 37.98 tons per year (occurs when Coating No. 2 is used 100% of the time.)

• Cadmium (Cd) compounds (before controls): gal hour lb Cd compounds 1 ton 2 guns×× 5 8760 ×X × ×−=()1Y uncontrolled Cd compounds, tpy hour year gal 2000 lb

Coating No. 1 Cd compound PTE = 0.60 tons per year Coating No. 4 Cd compound PTE = 0.84 tons per year Coating No. 6 Cd compound PTE = 0.96 tons per year

• Cd compounds (after controls): (Assume 80% capture efficiency and 90% control efficiency)

Coating No. 1 Cd compound PTE = 0.17 tons per year Coating No. 4 Cd compound PTE = 0.24 tons per year Coating No. 6 Cd compound PTE = 0.27 tons per year Controlled PTE, coating operations = 0.27 tons per year (occurs when Coating No. 6 is used 100% of the time.)

• Lead (Pb) compounds (before controls): gal hour lb Pb compounds 1 ton 2 guns×× 5 8760 ×X × ×−=()1Y uncontrolled Pb compounds, tpy hour year gal 2000 lb

Coating No. 1 Pb compound PTE = 0.24 tons per year Coating No. 4 Pb compound PTE = 0.36 tons per year

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-16 • Pb compounds (after controls): (Assume 80% capture efficiency and 90% control efficiency)

Coating No. 1 Pb compound PTE = 0.07 tons per year Coating No. 4 Pb compound PTE = 0.10 tons per year Controlled PTE, coating operations = 0.10 tons per year (occurs when Coating No. 4 is used 100% of the time.)

• Total HAPs = Total volatile HAPs + Total PM HAPs (before controls): gal hour lb vol. HAPs 1 ton 2 guns×× 5 8760 ×X × =uncontrolled vol HAPs, tpy hour year gal 2000 lb

gal hour lb PM HSPs 1 ton 2 guns×× 5 8760 ×X ××−=(1 Y) uncontrolled PM HAPs, tpy hour year gal 2000 lb

Uncontrolled Uncontrolled PM Total Uncontrolled Coating Volatile HAPs HAPs HAPs 1 60.71 0.84 61.55 tons per year 2 115.59 0 115.59 tons per year 3 86.33 0 86.33 tons per year 4 0 1.2 1.2 tons per year 5 154.44 0 154.44 tons per year 6 0 0.96 0.96 tons per year

• Total HAPs = Total volatile HAPs + Total PM HAPs (after controls): (Assume 60% capture efficiency and 90% destruction efficiency for volatile HAPs)

(Assume 80% capture efficiency and 90% control efficiency for PM HAPs)

Controlled Controlled Total Controlled Coating Volatile HAPs PM HAPs HAPs 1 27.93 0.24 28.17 tons per year 2 53.17 0 53.17 tons per year 3 39.71 0 39.71 tons per year 4 0 0.34 0.34 tons per year 5 71.04 0 71.04 tons per year 6 0 0.27 0.27 tons per year Controlled Total HAP PTE, coating operations = 71.04 tons per year (occurs when Coating No. 5 is used 100% of the time.)

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-17 • 1997 Actual Emissions for Painting/Coating (based on actual usage): Pollutant Tons/year PM/PM10 4.27 VOC 27.53 MEK 0.62 MIbK 0.74 Toluene 1.77 Xylenes 3.18 Cd Compounds 0.02 Lead Compounds 0.01 Total HAPs 6.34

Thermal Oxidizer • Capacity = 5 MMBtu/hour • Fuel = Natural gas • AP-42 Emission Factors for natural gas in pounds per MMcf:

PM PM10 SO2 NOX VOC CO Pb 7.6 7.6 0.60 100 5.5 84 0.0005

• Sample Calculation (PM):

MMBtu 1 MMcf lb PM hours 1 ton 5 ××××=7.6 8760 0.166 tpy hour 1000 MMBtu MMcf year 2000 lb

• Potential emissions for oxidizer based on AP-42:

PM PM10 SO2 NOX VOC CO Pb 0.166 0.166 0.013 2.19 0.12 1.84 0.00

• 1997 Actual Emissions for Oxidizer (based on 11 MMcf natural gas usage):

PM PM10 SO2 NOX VOC CO Pb 0.042 0.042 0.003 0.55 0.03 0.462 0.00

Clean-up Materials (Mineral Spirits) Since Blue Ox reclaims the solvent used for cleanup, it is difficult to determine exactly what the potential emissions are. By looking at records of how much mineral spirits they purchase in a year and how much they ship out as waste, they can calculate how much is allowed to evaporate in a year. That number can then be scaled up to what it might be if they really operated 8760 hours per year. In 1997, Blue Ox operated 4000 hours, and used the most mineral spirits they ever had: 800 gallons. By multiplying 800 gallons per 4000 hours by 8760 hours per year, and doubling their

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-18 answer as a safety factor (assuming that they could conceivably use the mineral spirits at twice their normal rate if they weren’t careful), they came up with a quantity of mineral spirits per year. Density of mineral spirits = 7.2 pounds per gallon VOC content = 100% = 7.2 pounds per gallon 800 gallons hours pounds VOC 1 ton ××2 8760 ×7.2 × =12.61 tpy 4000 hours year gallon 2000 pounds

10.3.5 Diesel generator calculations This is an emergency generator. By authority of an EPA guidance memo dated September 6, 1995, Blue Ox (or any operator of an emergency generator meeting the requirements of the memo) can assume 500 hours of operation when calculating unrestricted PTE. This is because designed for emergency use are typically not designed for and not capable of running 8760 hours per year. Rated Heat Input = 2.1 MMBtu/hour • AP-42 emission factors, in pounds per MMBtu:

PM PM10 SO2 NOX VOC CO Pb 0.31 0.31 0.29 4.41 0.36 0.95 0.00

• Sample calculation (PM):

MMBtu pounds hours 1 ton 2.1 ×××=0.31 500 0.2 tpy hour MMBtu year 2000 pounds

• Potential emissions based on AP-42 emission factors, in tons per year:

PM PM10 SO2 NOX VOC CO Pb 0.2 0.2 0.152 2.32 0.189 0.5 0.00

• 1997 Actual Emissions, based on 90 hours of operation:

PM PM10 SO2 NOX VOC CO Pb 0.028 0.028 0.026 0.393 0.032 0.085 0.00

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-19 10.3.6 Summary of all potential to emit calculations • Total uncontrolled total PTE, in tons per year:

PM PM10 SO2 NOX VOC CO Pb 400.4 398.8 213.8 28.9 337.7 60.2 0.00

Cd Pb Total MEK MIbK Toluene Xylene compounds compounds HAP 23.1 35.9 57.5 82.6 1.0 0.4 154.6

• Total controlled total PTE:

PM PM10 SO2 NOX VOC CO Pb 65.0 63.5 213.8 28.9 162.9 60.2 0.00

Cd Pb Total MEK MIbK Toluene Xylene compounds compounds HAP 10.6 16.5 26.4 38.0 0.3 0.1 71.2

• 1997 actual emissions:

PM PM10 SO2 NOX VOC CO Pb 11.5 11.4 0.05 2.4 37.1 3.0 0.00

Cd Pb Total MEK MIbK Toluene Xylene compounds compounds HAP 2.4 3.8 6.0 8.6 0.06 0.02 16.2

10.3.7 Proposed permit conditions and operating limits Wood Boiler: Will be removed Gas/Oil Boiler: To comply with NSPS (40 CFR 60, Subpart Dc), Blue Ox will burn only natural gas and distillate oil. The oil will contain a maximum of 0.5 weight percent sulfur. No limit on distillate oil usage is required. • AP-42 distillate oil emission factors (lbs/1000 gallons) corrected for 0.5% sulfur:

PM PM10 SO2 NOX VOC CO Pb HAPs* 2.00 1.00 144S 20.00 0.20 5.00 0.0004 0.082 *Total HAPs; itemization of which pollutants are emitted are included in Appendix 5-A, Form EC-13C.

• Distillate oil limited PTE:

PM PM10 SO2 NOX VOC CO Pb HAPs 0.72 0.36 25.9 7.20 0.07 1.80 0.0001 0.13

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-20 Spray Booth Limits: Þ Limited to 185 tons/year of VOC usage, assuming 54% overall control. Basis: To keep the source under 100 tpy for VOC, this is the amount that can be used given the allowable VOC emissions from the boilers and the clean-up solvent. Þ Limited to 52 tons/year of Total HAP usage, assuming 54% overall control of volatile HAPs. Basis: To keep the source under 25 tpy for total HAPs. Þ Limited to 20 tons/year of individual HAP usage, assuming 54% overall control of volatile HAPs. Basis: To keep the source under 10 tpy for each individual HAP. Clean-Up Solvent: Þ Limited to 10 tons/year VOC use (no control) Basis: Blue Ox commits to this being the absolute maximum they would ever use.

TOTAL LIMITED EMISSIONS:

PM PM10 SO2 NOX VOC CO Pb 33.6 33.3 26.1 11.7 95.7 6.6 0.00

Cd Pb Total MEK MIbK Toluene Xylene compounds compounds HAP 9.0 9.0 9.0 9.0 9.0 9.0 24.1

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 10-21

Appendix 1-A Activities NOT Required To Be Listed In Your Application Minn. Rules Part 7007.1300, subp. 2

A. Fuel use: 1. production of hot water for on-site personal use not related to any industrial process; 2. fuel use related to food preparation by a restaurant or cafeteria; and 3. fuel burning equipment with a capacity less than 30,000 BTU/hour, but only if the combined total capacity of all fuel burning equipment at the stationary source with a capacity less 30,000 Btu per hour is less than or equal to 500,000 BTU/hour. B. Plant upkeep: 1. routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source, such as: painting buildings, retarring roofs, paving parking lots, but excluding use of spray paint equipment. 2. routine maintenance of buildings, grounds, and equipment; 3. use of vacuum cleaning systems and equipment for portable steam cleaning; 4. clerical activities such as operating copy machines and document printers, except operation of such units on a commercial basis; 5. janitorial activities; and 6. sampling connections used exclusively to withdraw materials for laboratory analysis and testing. C. Fabrication operations: 1. equipment used for the inspection of metal products; 2. equipment used exclusively for forging, pressing, drawing, spinning, or extruding cold metals; 3. equipment used exclusively to mill or grind coatings and molding compounds where all materials charged are in paste form; and 4. mixers, blenders, roll mills, or calendars for rubber or plastics for which no materials in powder are added and in which no organic solvents, diluents, or thinners are used. D. Processing operations: 1. closed tumblers used for cleaning or deburring metal products without abrasive blasting; 2. equipment for washing or drying fabricated glass or metal products, if no VOCs are used in the process, and no gas, oil, or solid fuel is burned; 3. equipment venting particulate matter (PM) or particulate matter less than 10 microns (PM-10) inside a building provided that emissions from the equipment: (a) are vented inside of the building 100% of the time; and

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 1A - 1 (b) do not use air filtering systems used to control indoor air emissions; and 4. blast cleaning operations using suspension of abrasive in water. E. Storage tanks: 1. pressurized storage tanks for anhydrous ammonia, liquid petroleum gas (LPG), liquid natural gas (LNG), or natural gas; 2. storage tanks holding lubricating oils; 3. above and below ground fuel oil storage tanks with a combined total tankage capacity of less than 100,000 gallons; and 4. gasoline storage tanks with a combined total tankage capacity of less than 2000 gallons. F. Drain, waste, and vent piping: 1. stacks or vents to prevent escape of sewer gases through plumbing traps, not including stacks and vents associated with processing at plants; 2. sewer maintenance access covers and shafts; 3. sludge and septage landspreading sites; 4. sludge loadout pumping operations for publicly owned treatment works with a design flow less than 5,000,000 gallons per day; and 5. odor control systems on components of publicly owned treatment works collection systems. G. Residential activities: typical emissions from residential structures, not including the following: 1. fuel burning equipment with a total capacity of 500,000 Btu/hour or greater; and 2. emergency backup generators. H. Recreational activities: use of the following for recreational purposes: 1. fireplaces; 2. barbecue pits and cookers; and 3. kerosene fuel use. I. Health care activities: activities and equipment directly associated with the diagnosis, care, and treatment of patients in medical or veterinary facilities or offices, not including support activities such as power plants, heating plants, emergency generators, incinerators, or other units affected by applicable requirements as defined in Minn. R. 7007.0100, subp. 7.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 1A - 2 J. Miscellaneous: 1. safety devices, such as fire extinguishers, if associated with a permitted emission source, but not including sources of continuous emissions; 2. flares to indicate danger to the public; 3. vehicle exhaust emissions from the operation of mobile sources at a stationary source; 4. purging of natural gas lines; 5. natural draft hoods, natural draft ventilation, comfort air conditioning, or comfort ventilating systems not designed or used to remove air contaminants generated by, or released from specific units of equipment; 6. funeral home embalming processes and associated ventilation systems; and 7. use of consumer products, including hazardous substances as that term is defined in the Federal Hazardous Substances Act, where the product is used at academic and health care institutions in the same manner as normal consumer use. K. Demonstration project conducted by a teaching institution where the sole purpose of a demonstration project is to provide an actual functional example of a process unit operation to the students or other interested persons, where actual operating hours of each emissions unit must not exceed a total of 350 hours in a calendar year and where the emissions unit is not used to dispose of waste materials.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 1A - 3

Appendix 1-B Insignificant Activities REQUIRED To Be Listed In Your Application Minn. Rules Part 7007.1300, subp. 3 The activities described below must be listed in your permit application. Under Minn. R. 7007.0500, subp. 2(C)(2), the MPCA may require you to submit calculations of emissions from these emission units. You must calculate emissions from these emission units and include them in your permit application if any of the following are true:

1) the emissions units are subject to additional requirements under Section 114(a)(3) of the Clean Air Act; 2) the emissions units are subject to Hazardous Air Pollutant requirements under Section 112 of the Clean Air Act; 3) the emissions units are part of a Title I modification; or 4) if accounted for, the emissions units make the stationary source subject to a part 70 permit.

A. Fuel use: space heaters fueled by, kerosene, natural gas, or propane. A space heater is a heating unit that is not connected to piping or ducting to distribute the heat. B. Furnaces, boilers, and incinerators: 1. infrared electric ovens; and 2. fuel burning equipment with a capacity less than 500,000 Btu/hour but only if the total combined capacity of all fuel burning equipment at the stationary source with a capacity less than 500,000 Btu per hour is less than or equal to 2,000,000 Btu/hour. C. Fabrication operations: equipment used exclusively for forging, pressing, drawing, spinning, or extruding hot metals. D. Processing operations: 1. open tumblers with a batch capacity of 1,000 pounds or less; and 2. Equipment venting particulate matter (PM) or particulate matter less than 10 microns (PM-10) inside a building, provided that emissions from the equipment are: a) filtered through an air cleaning system; and b) vented inside of the building 100% of the time. E. Storage tanks: 1. gasoline storage tanks with a combined total tankage capacity of not more than 10,000 gallons; and

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 1B - 1 2. non-hazardous air pollutant VOC storage tanks with a combined total tankage capacity of not more than 10,000 gallons of non-hazardous air pollutant VOCs and with a vapor pressure of not more than 1.0 psia at 60 degrees Fahrenheit. F. Cleaning operations: commercial laundries, not including dry cleaners and industrial launderers. G. Emissions from a laboratory as defined in this item: "Laboratory" means a place or activity devoted to experimental study or teaching in any science, or to the testing and analysis of drugs, chemicals, chemical compounds or other substances, or similar activities, provided that the activities described in this sentence are conducted on a laboratory scale. Activities are conducted on a laboratory scale if the containers used for reactions, transfers, and other handling of substances are designed to be easily and safely manipulated by one person. If a facility manufactures or produces products for profit in any quantity, it may not be considered to be a laboratory under this item. Support activities necessary to the operation of the laboratory are considered to be part of the laboratory. Support activities do not include the provision of power to the laboratory from sources that provide power to multiple projects or from sources which would otherwise require permitting, such as boilers that provide power to an entire facility. H. Miscellaneous: 1. total usage of less than 200 gallons of VOC (including hazardous air pollutant- containing VOC) combined in any consecutive 12 months period at a stationary source, where gallons of VOC equals volume percentage of VOC multiplied by the gallons of VOC-containing material, except that if the owner or operator ships VOC off-site for recycling, the amount recycled may be subtracted from the amount of VOC used. "Recycling" means the reclamation or reuse, as defined in part 7045.0020, of a VOC. If the owner or operator ships VOC off-site for recycling, the owner or operator shall keep records of the amount of material shipped off-site for recycling and the calculations done to determine the amount to subtract. Records may be MSDS, invoices, shipping papers, or hazardous waste manifests; 2. equipment used exclusively for packaging lubricants or grease; 3. equipment used for hydraulic or hydrostatic testing; 4. brazing, soldering or welding equipment; 5. blueprint copiers and photographic processes; 6. equipment used exclusively for melting or application of wax; 7. nonasbestos equipment used exclusively for bonding lining to brake shoes; and 8. cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners. I. Individual emissions units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than: 1. 4,000 lbs/year of carbon monoxide; and

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 1B - 2 2. 2,000 lbs/year each of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, volatile organic compounds (including hazardous air pollutant-containing VOC), and ozone. J. Fugitive Emissions from roads and parking lots except from a stationary source applying for an Option D registration permit under Minn. R. 7007.1130. K. Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source, such as spray painting of buildings, machinery, vehicles, and other supporting equipment.

The following Insignificant Activities are required to be listed only for Part 70 applications:

If a facility is applying for a part 70 permit, emissions units with potential emissions less than the following limits must be included in a part 70 permit application unless they are on the Insignificant Activities Not Required to be Listed list. If you are applying for any type of state permit (including an individual state permit, a state general permit, or a state registration permit) or an amendment to a state permit, this section does not apply.

The MPCA may require you to submit calculations of emissions from these emission units. You must calculate emissions of these activities in accordance with the criteria provided at the beginning of the Insignificant Activities Required to be Listed list.

A. 5.7 lbs/hr of carbon monoxide; B. potential emissions of 2.28 lbs/hr or actual emissions of one ton per year for nitrogen oxides, sulfur dioxide, particulate matter, particulate matter less than ten microns, and volatile organic compounds; and C. for hazardous air pollutants, emissions units with: 1. potential emissions of 25 percent or less of the hazardous air pollutant thresholds listed in Minn. R 7007.1300, subp. 5; or 2. combined HAP actual emissions of one ton per year unless the emissions unit emits one or more of the following HAPs: carbon tetrachloride; 1,2-dibromo-3-chloropropane; ethylene dibromide; hexachlorobenzene; polycyclic organic matter; antimony compounds; arsenic compounds, including inorganic arsine; cadmium compounds; chromium compounds; lead compounds; manganese compounds; mercury compounds; nickel compounds; selenium compounds; 2,3,7,8-tetrachlorodibenzo-p-dioxin; or dibenzofuran. If the emissions unit emits one or more of the HAPs listed in this subitem, the emissions unit is not an insignificant activity under this subitem.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 1B - 3

APPENDIX 2-A List Of References and Ordering Information

Air Pollution Engineering Manual Air and Association. 1992. Air and Waste Management Association Publications Department P.O. Box 2861 Pittsburgh, PA 15230 Telephone: 412-232-3444

Air Quality Permits A Handbook for Regulators and Industry State and Territorial Air Pollution Program Administrators and the Association of Local Air Pollution Control Officials. Washington, D.C. 1991

Code of Federal Regulations (CFR) Protection of Environment - Section 40, Parts 1-99 July 1996 Revision National Technical and Information Service 5285 Port Royal Road Springfield, Virginia 22161 Telephone: 703-487-4650 FAX: 703-321-8547 Also available via the Internet at the following address: http://earth1.epa.gov/epacfr40/chapt-I.info/subch-C/40P0060/

EPA Policy Memos and Guidances 3 volume set For sale by: Air and Waste Management Association Publications Department P.O. Box 2861 Pittsburgh, PA 15230 Telephone: 412-232-3444 Many EPA memos and Guidance Documents are also available via the Internet at the following address: http://www.epa.gov/ttn/

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 2A - 1 Minnesota Rules, Parts 4410, 7002, 7005, 7007, 7009, 7011, 7017, 7019, 7021, 7030 For sale by: Print Communication Division Department of Administration 117 University Avenue St. Paul, Minnesota 55055 Telephone: 651-297-3000 or 1-800-652-9747 Also available via the Internet at the following address: http://www.pca.state.mn.us/air/air_mnrules.html

New Source Review Workshop Manual: Prevention of Significant Deterioration and Nonattainment Area Permitting - Draft October 1990. U.S. Environmental Protection Agency Office of Air Quality Planning and Standards For sale by: Air and Waste Management Association Publications Department P.O. Box 2861 Pittsburgh, PA 15230 Telephone: 412-232-3444

Standard Industrial Classification (SIC) Manual Executive Office of the President Office of Management and Budget [Although the SIC codes were replaced in 1997 by the North American Industry Classification, SIC codes are still referenced in some rules. Copies of the SIC Manual may be available from: National Technical and Information Service 5285 Port Royal Road Springfield, Virginia 22161 Telephone: 703-487-4650 FAX: 703-321-8547)

U.S. EPA Public Information Center PM-211B 401 M Street SW Washington, DC 20460 Telephone: 202-260-7751 FAX: 202-260-6257 Also available at local libraries. EPA’s Internet address is: http://www.epa.gov

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 2A - 2 EPA Emission Factor References

AIRS Facility Subsystem Source Classification Codes and Emission Factor List for Criteria Air Pollutants EPA #450/4-90-003 AIRS information is also available via the Internet through the following address: http://www.epa.gov/ttn/direct.html

AP-42 Compilation of Air Pollutant Emission Factors Volume I. Stationary Point and Area Sources 5th Edition AP-42, including all supplements, is also available via the Internet at the following address: http://www.epa.gov/ttn/chief/ap42.html AP-42 and its supplements compile emission factors and descriptions of the activities that product criteria pollutant emissions for most stationary point and area sources.. The emissions data in the AP-42 document have been gathered from source tests, material balance studies, and engineering estimates. Volume II of AP-42 contains information on mobile source emissions.

Air Toxics Emission Factor References

Toxic Air Pollutant Emission Factors - A compilation for Selected Air Toxic Compounds and Sources EPA-450/2-88-006a. VOC Species Manual, Vol. 1: Volatile Organic Compound Species Profiles EPA 450/2-90-0012. These reports contain emission factors and chemical speciation profiles for various sources of VOC and PM emissions. Each profile lists the elements or compounds identified as being emitted by a source category or process according to the weight percent of each compound as a function of total VOC or PM emissions. Each individual pollutant specification factor within a profile can be multiplied against a VOC or PM emission rate for a source of interest to produce an estimate of air toxic emissions.

Locating and Estimating Emissions ... Series These reports are the products of the EPA's ongoing effort to compile and publish information on toxic pollutants and the source categories for which these emissions have been characterized. These reports are pollutant or source specific. The documents in the series are listed below, and are available via the Internet at the following address: http://www.epa.gov/ttn/chief/ap42etc.html#LE

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 2A - 3 Arsenic Formaldehyde Benzene Methyl chloroform 1,3-Butadiene Methyl ethyl ketone Cadmium Methylene chloride Chlorobenzenes Polycyclic Organic Matter (POM) Chromium Styrene Cyanide Toluene Dioxins and furans Vinylidene Chloride Epichlorohydrin Xylene Ethylene Oxide

Order NTIS Documents from:

National Technical Information Services U.S. Department of Commerce 5285 Port Royal Road Springfield, VA 22161 Telephone: 703-487-4650 FAX: 703-321-8547

Newly published material is sometimes not available from NTIS but can be ordered from: Superintendent of Documents U.S. Government Printing Office Washington, D.C. 20402-9375 Telephone: 202-783-3238 Internet Address: http://www.gpo.gov/

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 2A - 4 Appendix 3-A Nonattainment Area Maps

Carbon Monoxide Nonattainment Area Seven County Metropolitan Area and Wright County

(Map not available)

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 3A - 1 Appendix 3-A Nonattainment Area Maps

PM10 Nonattainment Area Twin Cities Area

(Map not available)

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 3A - 2 Appendix 4-A

Mandatory EAW Categories Minnesota Rules 4410.4300

The categories listed below all have threshold sizes or emissions that make an EAW mandatory.

1) Meets or exceeds thresholds given for categories listed below (unless a threshold for EIS is met or exceeded, in which case an EIS must be prepared) 2) Nuclear fuels and nuclear waste 3) Electric generating facilities 4) Petroleum refineries 5) Fuel conversion facilities 6) Transmission lines 7) Pipelines 8) Transfer facilities 9) Underground storage 10) Storage facilities 11) Metallic mineral and processing 12) Nonmetallic mineral mining 13) Paper or pulp processing mills 14) Industrial, commercial, and institutional facilities 15) Air Pollution 16) Hazardous Waste 17) Solid waste 18) Wastewater systems 19) Residential development 20) Campgrounds and RV parks 21) projects 22) projects 23) Barge fleeting 24) Water appropriation and impoundments 25) Marinas 26) Stream diversion 27) Wetlands and protected waters 28) Forestry 29) Animal feedlots 30) Natural areas 31) Historical places 32) Mixed residential and industrial-commercial projects 33) Communications towers 34) Sports or entertainment facilities 35) Release of genetically engineered organisms 36) Land use conversion, including golf courses

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 4A - 1

Appendix 4-B

Mandatory EIS Categories Minnesota Rules 4410.4400

The categories listed below all have threshold sizes or emissions that make an EIS mandatory.

1) Meets or exceeds thresholds given for categories listed below 2) Nuclear fuels and nuclear waste 3) Electric generating facilities 4) Petroleum refineries 5) Fuel conversion facilities 6) Transmission lines 7) Underground storage 8) Metallic mineral mining and processing 9) Nonmetallic mineral mining 10) Paper or pulp processing 11) Industrial, commercial, and institutional facilities 12) Hazardous waste 13) Solid waste 14) Residential development 15) Airport runway projects 16) Highway projects 17) Barge fleeting facilities 18) Water appropriation and impoundments 19) Marinas 20) Wetlands and protected waters 21) Mixed residential and industrial-commercial projects 22) Sports or entertainment facilities 23) Water diversions 24) Pipelines 25) of wastes containing PCBs

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 4B - 1

Appendix 5-A Application Forms For Blue Ox Woodworks

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 5A - 1

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-01 520 LAFAYETTE ROAD FACILITY INFORMATION ST. PAUL, MN 55155-4194 5/13/98

1a) AQ Facility ID No.: 99009999 1b) AQ File No.: 2) Facility Name: Blue Ox Woodworks, Inc. 3) Facility Location: Street Address: 11 Green Lane

City: Clear Sky State: MN ZIP Code: 55000 Mailing Address: same as above

City: State: ZIP Code: 4) Corporate/Company Owner: Name: Phyllis Walder Mailing Address: 11 Green Lane

City: Clear Sky State: MN ZIP Code: 55000 Owner Classification: Private Local Govt State Govt. Federal Govt. Utility 5) Corporate/Company Operator (if different than owner): Name: Mailing Address:

City: State: ZIP Code: 6) Co-permittee (if applicable): Name: Mailing Address:

City: State: ZIP Code: 7) Legally responsible official for this permit/facility: Mr/Ms: Phyllis Walder Phone: 218-555-0011 Title: Owner Fax: 218-555-0012 At (check one): Owner Address Operator Address Emission Facility Address Other (specify) 8) Contact person for this permit: Mr/Ms: Phyllis Walder Phone: 218-555-0011 Title: Owner Fax: 218-555-0012 At (check one): Owner Address Operator Address Emission Facility Address Other (specify) 9) All billings for annual fees should be addressed to: Mr/Ms: Phyllis Walder Phone: 218-555-0011 Title: Owner Fax: 218-555-0012 At (check one): Owner Address Operator Address Emission Facility Address Other (specify)

10) Standard Industrial Classification (SIC) Code and description for the facility: Primary: 2431 / Millwork Secondary (if applicable): / Tertiary (if applicable): /

11) Primary product produced (or activity performed) at the facility is: Millwork (painted or stained)

12) Facility is: Stationary Portable 13) Check the one that applies best to your facility: New facility planned or under construction (first permit application) Existing facility, applying for renewal of a total facility Air Quality operating permit issued by the MPCA Existing facility, and have never had a total facility operating permit, but have had another type of Air Quality permit issued by the MPCA Existing facility, but have never had a total facility operating permit or any other type of Air Quality permit issued by the MPCA

14) Check if the facility is in a non-attainment area for (check all that apply): PM10 SO2 CO Other (specify) The facility is located in an area which is in attainment or is unclassifiable for all ambient air standards

15) Is environmental review required (either an Environmental Assessment Worksheet (EAW) or an Environmental Impact Statement (EIS)) for this facility? Call the Minnesota Environmental Quality Board for more information (1-800-657- 3794, or 296-8253 in the Twin Cities metro area). Yes No Note: If you answered “Yes” to this question, you may also be required to perform a state air toxics review for your facility. Please call 1-800-MINN-AIR or (651)282-5844.

16) Are you required to submit a Toxics Release Inventory (Form R) under SARA Title 313 for this facility? Call the Minnesota Department of Public Safety, Emergency Response Commission for more information (651-297-7372). Yes No

17) Is this facility within 50 miles of another state or the Canadian border: Yes (specify which ones) No

18) Brief description of the facility or proposed facility to be permitted (attach additional sheet if necessary): Blue Ox Woodworks is a millwork facility that produces high quality finished trim and other milled goods. The emission sources currently on site are: one wood-fired boiler, one natural gas/oil fired boiler, a back up diesel generator, one spray booth, and a variety of milling equipment.

19) Are you proposing any alternative operating or emissions trading scenarios in this application (see Minn. R. 7007.0800, subp. 10 and 11)? Yes No If yes, attach a description of your proposal, including a statement on how the proposal will meet all applicable requirements (in particular, please address federal New Source Review requirements, if applicable). See Form GI- 09(C). MINNESOTA POLLUTION CONTROL PERMIT APPLICATION FORM GI-02 AGENCY PROCESS FLOW DIAGRAM AIR QUALITY 5/13/98 520 LAFAYETTE ROAD ST. PAUL, MN 55155-4194

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks 3) Flow Diagram:

SV005 Ventilation or air flow Product Flow CE004

Incoming Wood Planer #2 EU013

Planer #1 Ripsaw EU012 EU007 Planer #3 EU014 Table Saw Molder #4 EU006 EU011 SV003 To To CE002 CE004 CE004 Sander #1 Sander #3 Table Saw Molder #3 EU015 EU017 EU005 EU010

To Resaw Molder #2 To CE004 EU004 EU009 CE004 Sander #2 Sander #4 EU016 EU018

Cutoff Saw Molder #1 EU003 EU008 Sander #5 To EU019 CE004

SV004 CE003 Product to Paint Line (next page) SV006

CE001

CE005

Final Product Product from sanding Spray Booth Cure Oven EU020 EU021

Emergency Boiler #1 SV001 Generator SV007 EU001 heat for EU022 building

Boiler #2 SV002 EU002 heat for building

Ventilation or air flow Product Flow MINNESOTA POLLUTION CONTROL PERMIT APPLICATION FORM GI-03 AGENCY FACILITY AND STACK/VENT DIAGRAM AIR QUALITY 5/26/98 520 LAFAYETTE ROAD ST. PAUL, MN 55155-4194

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks 3) Facility and Stack/Vent Diagram:

Property boundary

Building 250 200 feet

flat roof: 15 ft above grade roof = 50 ft at peak, 30 ft at Flat roof = 10 ft edge SV007 SV005 SV006

Flat roof = 14 ft

SV004 SV001 100 feet

SV002

SV003

Flat roof = 15 ft

North

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-04 520 LAFAYETTE ROAD STACK/VENT INFORMATION ST. PAUL, MN 55155-4194 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks

3a) 3b) 3c) 3d) 3e) 3f) 3g) 3h) Height of Inside Diameter in ft. (left column only) Design Flow Exit Gas SV ID Operator’s Description Opening Rate/Temp Discharge No. or Rate at Exit Temperature Information Direction From (acfm) (° F) Length x Width in ft. Source Ground (both columns) (ft.)

001 Wood boiler exhaust 50.0 1.50 14,400 300 E U

002 Gas/oil boiler exhaust 50.0 1.50 15,300 300 E U

003 Saw Line 24.0 2.00 8.00 35,000 68 E U

004 Milling Line 24.0 2.00 8.00 30,000 68 E U

005 Sanding Line 24.0 2.00 8.00 25,000 68 E U

006 Spray booth exhaust 45.0 2.50 10,000 300 E U

007 Backup generator 11.0 1.00 1,500 250 E U

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-05A 520 LAFAYETTE ROAD POLLUTION CONTROL ST. PAUL, MN 55155-4194 EQUIPMENT INFORMATION 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks

3a) 3b) 3c) 3d) 3e) 3f) 3g) 3h) 3i) Control CE Description Manufacturer Model No. Pollutants Capture Destruct/ Afterburner Equip Type Controlled Efficiency Collect Combustion ID No. Code Efficiency Parameters 001 021 Thermal Oxidizer Inferno Control IF-1400 VOC 60 90 1400 F Systems

002 018 Low Temp Fabric Ladyslipper 143 AB 94 PM 100 99 Filter

PM10 100 99

003 018 Low Temp Fabric Ladyslipper 143 AB 94 PM 100 99 Filter

PM10 100 99

004 018 Low Temp Fabric Ladyslipper 143 AB 94 PM 100 99 Filter

PM10 100 99

005 058 Mat or panel filter Catchall C-150-A PM 80 90

PM10 80 90

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-05B 520 LAFAYETTE ROAD EMISSION UNIT INFORMATION, ST. PAUL, MN 55155-4194 PART 1 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks

3a) 3b) 3c) 3d) 3e) 3f) 3g)

Emis Control Unit ID SV ID Relation Equip Emission Unit Operator’s Description Manufacturer Model No. No. No(s). Type ID No.

001 001 (M)ain Wood-fired boiler Bunyan BUN-1

002 002 (M)ain Gas/Oil fired boiler Superior 1500S

003 003 (M)ain 002 Cutoff saw Norske NS001

004 003 (M)ain 002 Resaw Lakeland M-100

005 003 (M)ain 002 Table Saw #1 Lakeland M-500

006 003 (M)ain 002 Table Saw #2 Buzzsaw BZ-500

007 003 (M)ain 002 Ripsaw Ripley K-20

008 004 (M)ain 003 Molder #1 Buzzsaw BZ-150

009 004 (M)ain 003 Molder #2 Buzzsaw BZ-150

010 004 (M)ain 003 Molder #3 Buzzsaw BZ-155 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-05B 520 LAFAYETTE ROAD EMISSION UNIT INFORMATION, ST. PAUL, MN 55155-4194 PART 1 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks

3a) 3b) 3c) 3d) 3e) 3f) 3g)

Emis Control Unit ID SV ID Relation Equip Emission Unit Operator’s Description Manufacturer Model No. No. No(s). Type ID No.

011 004 (M)ain 003 Molder #4 Buzzsaw BZ-155

012 005 (M)ain 004 Planer #1 Spruce Goose SP1000

013 005 (M)ain 004 Planer #2 Spruce Goose SP1000

014 005 (M)ain 004 Planer #3 Spruce Goose SP1050

015 005 (M)ain 004 Sander #1 Loon TS100X

016 005 (M)ain 004 Sander #2 Loon TS100X

017 005 (M)ain 004 Sander #3 Loon TS100X

018 005 (M)ain 004 Sander #4 Loon TS100X

019 005 (M)ain 004 Sander #5 Loon TS100X

020 006 (M)ain 001 Spray Booth Blizzard 5000-B

005 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-05B 520 LAFAYETTE ROAD EMISSION UNIT INFORMATION, ST. PAUL, MN 55155-4194 PART 1 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks

3a) 3b) 3c) 3d) 3e) 3f) 3g)

Emis Control Unit ID SV ID Relation Equip Emission Unit Operator’s Description Manufacturer Model No. No. No(s). Type ID No.

021 006 (M)ain 005 Spray booth electric curing oven Great Lakes C500A

022 007 (M)ain Emergency Generator Powerhouse G1100 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-05B 520 LAFAYETTE ROAD EMISSION UNIT INFORMATION, ST. PAUL, MN 55155-4194 PART 2

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks

3a) 3h) 3i) 3j) 3k) 3l) 3m) 3n) 3o) 3p) Emis Maximum Maximum Maximum Commence Initial Startup Firing Method (coal- % Fuel for Bottle-neck? SIC Code Unit ID Design Design Capacity Fuel Input Construction Date burning units only) Space Heat F = facility No. Capacity Units (MMBTU) Date (MM/DD/YY) (boilers only) G = group of (MM/DD/YY) sources

001 7.2 1/1/54 100

002 11.5 1/1/91 100

003 1/1/74

004 1/1/69

005 1/1/71

006 1/1/74

007 1/1/74

008 1/1/73

009 1/1/74

010 1/1/76 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-05B 520 LAFAYETTE ROAD EMISSION UNIT INFORMATION, ST. PAUL, MN 55155-4194 PART 2

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks

3a) 3h) 3i) 3j) 3k) 3l) 3m) 3n) 3o) 3p) Emis Maximum Maximum Maximum Commence Initial Startup Firing Method (coal- % Fuel for Bottle-neck? SIC Code Unit ID Design Design Capacity Fuel Input Construction Date burning units only) Space Heat F = facility No. Capacity Units (MMBTU) Date (MM/DD/YY) (boilers only) G = group of (MM/DD/YY) sources

011 1/1/76

012 1/1/72

013 1/1/72

014 1/1/75

015 1/1/71

016 1/1/74

017 1/1/74

018 1/1/74

019 1/1/76

020 10 gal/hour 1/1/88 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-05B 520 LAFAYETTE ROAD EMISSION UNIT INFORMATION, ST. PAUL, MN 55155-4194 PART 2

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks

3a) 3h) 3i) 3j) 3k) 3l) 3m) 3n) 3o) 3p) Emis Maximum Maximum Maximum Commence Initial Startup Firing Method (coal- % Fuel for Bottle-neck? SIC Code Unit ID Design Design Capacity Fuel Input Construction Date burning units only) Space Heat F = facility No. Capacity Units (MMBTU) Date (MM/DD/YY) (boilers only) G = group of (MM/DD/YY) sources

021 1/1/88

022 175 kW 1/1/66

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM IA-01 520 LAFAYETTE ROAD INSIGNIFICANT ACTIVITIES ST. PAUL, MN 55155-4194 (REQUIRED TO BE LISTED) 5/26/98 1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks 3) Description of Activities:

7007.1300, subp. 3 (A) -- 5 space heaters fueled by propane 7007.1300, subp. 3 (H)(3) -- 2 blueprint copiers 7007.1300, subp. 3 (J) -- Fugitive Emissions from roads and parking lots

MINNESOTA POLLUTION CONTROL AGENCY PERMIT APPLICATION FORM EC-02 AIR QUALITY EXTERNAL COMBUSTION (BOILER) CALCULATION FORM 520 LAFAYETTE ROAD 5/27/98 ST. PAUL, MN 55155-4194

- Fill out this form for each boiler, or attach sheets with equivalent information. - Instructions begin on Page 6. - If the boiler emits Hazardous Air Pollutants (HAPs), fill out and attach Form EC-13C. 1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks 3) Emission Unit Identification 001 Number: 4) Stack/Vent Designation Number: 001 5) Maximum Rated Boiler Capacity: 7.2 million BTU/hr 6) Control Equipment: NA 7) Fuel Parameters

7a) 7b) 7c) 7d) 7e) Units Fuel Type % Sulfur % Ash Heat Value Units Fuel Consumption Rate wood 8000000 Btu/ton, Btu/gal, Btu/cf 0.90 ton/hr; gal/hr; cf/hr NA Btu/ton, Btu/gal, Btu/cf ton/hr; gal/hr; cf/hr Btu/ton, Btu/gal, Btu/cf ton/hr; gal/hr; cf/hr When calculating Potential Emissions, use items 8a, 8b, 8d, 8e, 8g, 8h, and 8i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 8a, 8b, 8c, 8f, 8g, and 8j.

8) Calculations Summary - Primary Fuel: 8a 8b 8c 8d 8e 8f 8g 8h 8i 8j Pollutant Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled lb/ton Fuel Use Emissions Emissions Efficiency Emissions Emissions Emissions (lbs/ton, lbs/gal, (tons, gallons, cf, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/cf, etc.) etc.) PM 8.8 184 7.92 34.7 0.81 0.00% 34.7 0.0 0.8

PM10 7.9 184 7.11 31.1 0.71 0.00% 31.1 0.0 0.7 SOx 0.01 184 0.01 0.0 0.0 0.00% 0.0 0.0 0.0 NOx 1.5 184 1.35 5.9 0.14 0.00% 5.9 0.0 0.1 VOC 0.22 184 0.20 0.9 0.02 0.00% 0.9 0.0 0.0 CO 13.6 184 12.24 53.6 1.25 0.00% 53.6 0.0 1.3 Lead 0 184 0.00 0.0 0 0.00% 0.0 0.0 0.0 When calculating Potential Emissions, use items 9a, 9b, 9d, 9e, 9g, 9h, and 9i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 9a, 9b, 9c, 9f, 9g, and 9j.

9) Calculations Summary - Back-up Fuel: 9a 9b 9c 9d 9e 9f 9g 9h 9i 9j Pollutant Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled Fuel Use Emissions Emissions Efficiency Emissions Emissions Emissions (lbs/ton, lbs/gal, (tons, gallons, cf, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/cf, etc.) etc.) PM

PM10 SOx NOx VOC CO Lead When calculating Potential Emissions, use items 10a, 10b, 10d, 10e, 10g, 10h, and 10i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 10a, 10b, 10c, 10f, 10g, and 10j.

10) Calculations Summary - Back-up Fuel: 10a 10b 10c 10d 10e 10f 10g 10h 10i 10j Pollutant Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled Fuel Use Emissions Emissions Efficiency Emissions Emissions Emissions (lbs/ton, lbs/gal, (tons, gallons, cf, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/cf, etc.) etc.) PM

PM10 SOx NOx VOC CO Lead 11) Worse-Case Potential-to-Emit Summary: (Ignore this item if filling out this form for a Registration Permit Option D) 11a) 11b) Before After Pollutant Operating Operating Limits: Limits: (tons/yr) (tons/yr) PM 34.7 0.0

PM10 31.1 0.0 SOx 0.0 0.0 NOx 5.9 0.0 VOC 0.9 0.0 CO 53.6 0.0 Lead 0.0 0.0

12) Operating Limitations, if applicable: (Ignore this item if filling out this form for a Registration Permit Option D) This boiler will be permanently shut down.

MINNESOTA POLLUTION CONTROL AGENCY PERMIT APPLICATION FORM EC-02 AIR QUALITY EXTERNAL COMBUSTION (BOILER) CALCULATION FORM 520 LAFAYETTE ROAD 5/27/98 ST. PAUL, MN 55155-4194

- Fill out this form for each boiler, or attach sheets with equivalent information. - Instructions begin on Page 6. - If the boiler emits Hazardous Air Pollutants (HAPs), fill out and attach Form EC-13C. 1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks 3) Emission Unit Identification 002 Number: 4) Stack/Vent Designation Number: 002 5) Maximum Rated Boiler Capacity: 11.5 million BTU/hr 6) Control Equipment: NA 7) Fuel Parameters

7a) 7b) 7c) 7d) 7e) Units Fuel Type % Sulfur % Ash Heat Value Units Fuel Consumption Rate natural gas 1000 Btu/ton, Btu/gal, Btu/cf 11500 ton/hr; gal/hr; cf/hr residual fuel oil 4.00% 150000 Btu/ton, Btu/gal, Btu/cf 76.67 ton/hr; gal/hr; cf/hr distillate oil 1.00% 140000 Btu/ton, Btu/gal, Btu/cf 82.14 ton/hr; gal/hr; cf/hr When calculating Potential Emissions, use items 8a, 8b, 8d, 8e, 8g, 8h, and 8i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 8a, 8b, 8c, 8f, 8g, and 8j.

8) Calculations Summary - Primary Fuel: Natural Gas 8a 8b 8c 8d 8e 8f 8g 8h 8i 8j Pollutant Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled lb/MMcf Fuel Use Emissions Emissions Efficiency Emissions Emissions Emissions (lbs/ton, lbs/gal, (tons, gallons, cf, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/cf, etc.) etc.) PM 7.6 28.8 0.087 0.383 0.109 0.00% 0.383 0.383 0.11

PM10 7.6 28.8 0.087 0.383 0.109 0.00% 0.383 0.383 0.11 SOx 0.6 28.8 0.0069 0.03 0.009 0.00% 0.03 0.03 0.009 NOx 100 28.8 1.15 5.037 1.44 0.00% 5.037 5.037 1.44 VOC 5.5 28.8 0.063 0.277 0.079 0.00% 0.277 0.277 0.079 CO 84 28.8 0.97 4.23 1.21 0.00% 4.23 4.23 1.2 Lead 0.0005 28.8 0.00000 0.000025 0.0 0.00% 0.000025 0.000025 0.0 6 When calculating Potential Emissions, use items 9a, 9b, 9d, 9e, 9g, 9h, and 9i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 9a, 9b, 9c, 9f, 9g, and 9j.

9) Calculations Summary - Back-up Fuel: Residual Oil, 4% sulfur 9a 9b 9c 9d 9e 9f 9g 9h 9i 9j Pollutant Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled lb/gal Fuel Use Emissions Emissions Efficiency Emissions Emissions Emissions (lbs/ton, lbs/gal, (tons, gallons, cf, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/cf, etc.) etc.) PM 0.0392 0 3.01 13.18 0 0 13.18 0 0

PM10 0.0347 0 2.66 11.65 0 0 11.65 0 0 SOx 0.636 0 48.76 213.6 0 0 213.6 0 0 NOx 0.055 0 4.217 18.47 0 0 18.47 0 0 VOC 0.00028 0 0.0215 0.094 0 0 0.094 0 0 CO 0.005 0 0.383 1.68 0 0 1.68 0 0 Lead 0.000004 0 0.00032 0.001 0 0 0.001 0 0 2 When calculating Potential Emissions, use items 10a, 10b, 10d, 10e, 10g, 10h, and 10i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 10a, 10b, 10c, 10f, 10g, and 10j.

10) Calculations Summary - Back-up Fuel: Distillate Oil, 1% sulfur 10a 10b 10c 10d 10e 10f 10g 10h 10i 10j Pollutant Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled lb/gal Fuel Use Emissions Emissions Efficiency Emissions Emissions Emissions (lbs/ton, lbs/gal, (tons, gallons, cf, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/cf, etc.) etc.) PM 0.002 0 0.164 0.718 0 0 0.718 0.718 0

PM10 0.001 0 0.082 0.359 0 0 0.359 0.359 0 SOx 0.144 0 11.82 51.77 0 0 51.77 25.90 0 NOx 0.020 0 1.643 7.196 0 0 7.196 7.196 0 VOC 0.00020 0 0.016 0.07 0 0 0.07 0.07 0 CO 0.005 0 0.411 1.80 0 0 1.80 1.80 0 Lead 0.000000 0 0.00003 0.000144 0 0 0.000144 0.000144 0 4 3 11) Worse-Case Potential-to-Emit Summary: (Ignore this item if filling out this form for a Registration Permit Option D) 11a) 11b) Before After Pollutant Operating Operating Limits: Limits: (tons/yr) (tons/yr) PM 13.18 0.718

PM10 11.65 0.40 SOx 213.6 25.90 NOx 18.47 7.196 VOC 0.277 0.277 CO 4.23 4.23 Lead 0.000144 0.000144

12) Operating Limitations, if applicable: (Ignore this item if filling out this form for a Registration Permit Option D) This boiler will burn only natural gas and distillate fuel oil (no residual fuel oil). The distillate oil will have a maximum sulfur content of 0.5 weight % to comply with 40 CFR pt. 60, subp. Dc.

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM EC-13C 520 LAFAYETTE ROAD HAZARDOUS AIR POLLUTANTS ST. PAUL, MN 55155-4194 CALCULATION FORM (FUEL COMBUSTION HAPS) 5/27/98

- Duplicate this form as necessary, or attach sheets with equivalent information. - Instructions begin on Page 6. 1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3) Emission Unit Identification Number: 002 4) Stack/Vent Designation Number: 002 5) Maximum Rated Equipment Capacity: 11.5 million BTU/hr 6) Control Equipment Designation Number: NA 7) Fuel Parameters

7a) 7b) 7c) 7d) 7e) Units Units Fuel Type % Sulfur % Ash Heat Value Fuel Consumption Rate natural gas 1000.00 Btu/ton, Btu/gal, Btu/cf 11500.00 tons/hr; gal/hr; cf/hr distillate fuel oil 1.0% 140000.00 Btu/ton, Btu/gal, Btu/cf 82.14 tons/hr; gal/hr; cf/hr residual fuel oil 4.0% 150000.00 Btu/ton, Btu/gal, Btu/cf 76.67 tons/hr; gal/hr; cf/hr When calculating Potential Emissions, use items 8a, 8b, 8d, 8e, 8g, 8h, and 8i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 8a, 8b, 8c, 8f, 8g, and 8j.

8) Calculations Summary - Primary Fuel: Natural Gas

8a 8b 8c 8d 8e 8f 8g 8h 8i 8j HAP Name Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Fuel Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled (CAS) (lbs/ton, Use Emissions Emissions Efficiency Emissions Emissions Emissions lbs/gal, (tons, gallons, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/MMcf, MMcf, etc.) etc.) benzene (71432) 0.00213 28.8 0.000024 0.0001 0.0000 0 0.0001 0.0001 0.0000 dichlorobenzene (106467) 0.0012 28.8 0.000014 0.00006 0.0000 0 0.00006 0.00006 0.0000 formaldehyde (50000) 0.075 28.8 0.00086 0.0038 0.0011 0 0.0038 0.0038 0.0011 hexane (110543) 1.80 28.8 0.0207 0.0907 0.0259 0 0.0907 0.0907 0.0259 naphthalene (91203) 0.00061 28.8 0.000007 0.00003 0.0000 0 0.00003 0.00003 0.0000 toluene (108883) 0.0034 28.8 0.000039 0.00017 0.0000 0 0.00017 0.00017 0.0000 POM (total) 0.000086 28.8 0.000001 0.000004 0.0000 0 0.000004 0.000004 0.0000 arsenic 0.0002 28.8 0.000002 0.00001 0.0000 0 0.00001 0.00001 0.0000 beryllium 0.000012 28.8 1.38E-8 6.04E-8 0.0000 0 6.04E-8 6.04E-8 0.0000 cadmium 0.0011 28.8 0.000013 0.00006 0.0000 0 0.00006 0.00006 0.0000 chromium 0.0014 28.8 0.000016 0.000071 0.0000 0 0.000071 0.000071 0.0000 manganese 0.00038 28.8 0.000004 0.000019 0.0000 0 0.000019 0.000019 0.0000 mercury 0.00026 28.8 0.000003 0.000013 0.0000 0 0.000013 0.000013 0.0000 nickel 0.0021 28.8 0.000024 0.00011 0.0000 0 0.00011 0.00011 0.0000 selenium 0.000024 28.8 2.76E-7 0.000001 0.0000 0 0.000001 0.000001 0.0000 Total HAP 1.8879 28.8 0.0217 0.0951 0.0272 0 0.0951 0.0951 0.0272 When calculating Potential Emissions, use items 9a, 9b, 9d, 9e, 9g, 9h, and 9i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 9a, 9b, 9c, 9f, 9g, and 9j.

9) Calculations Summary - Back-up Fuel: Distillate Oil

9a 9b 9c 9d 9e 9f 9g 9h 9i 9j HAP Name Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Fuel Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled (CAS) (lbs/ton, Use Emissions Emissions Efficiency Emissions Emissions Emissions lbs/gal, (tons, gallons, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/MMcf, MMcf, etc.) etc.) formaldehyde (50000) 0.061 0 0.0050 0.0219 0.0000 0 0.0219 0.0219 0.0000 POM (total) 0.0033 0 0.000271 0.0012 0.0000 0 0.0012 0.0012 0.0000 arsenic 0.000588 0 0.00021 0.0002 0.0000 0 0.0002 0.0002 0.0000 beryllium 0.00035 0 0.00013 0.00057 0.0000 0 0.00057 0.00057 0.0000 cadmium 0.0015 0 0.00054 0.00237 0.0000 0 0.00237 0.00237 0.0000 chromium 0.00938 0 0.00338 0.0148 0.0000 0 0.0148 0.0148 0.0000 manganese 0.00196 0 0.00071 0.0031 0.0000 0 0.0031 0.0031 0.0000 mercury 0.00042 0 0.00015 0.00066 0.0000 0 0.00066 0.00066 0.0000 nickel 0.00252 0 0.00091 0.00399 0.0000 0 0.00399 0.00399 0.0000 lead 0.001246 0 0.000045 0.00020 0.0000 0 0.00020 0.00020 0.0000 total HAP 0.08226 0 0.0296 0.1292 0.0000 0 0.1296 0.1296 0.0000

When calculating Potential Emissions, use items 10a, 10b, 10d, 10e , 10g, 10h, and 10i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 10a, 10b, 10c, 10f, 10g, and 10j.

10) Calculations Summary - Back-up Fuel: Residual Oil

10a 10b 10c 10d 10e 10f 10g 10h 10i 10j HAP Name Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Fuel Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled (CAS) (lbs/ton, Use Emissions Emissions Efficiency Emissions Emissions Emissions lbs/gal, (tons, gallons, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/MMcf, MMcf, etc.) etc.) benzene (71432) 0.000214 0 0.000016 0.000072 0.0000 0 0.000072 0.0000 0.0000 ethylbenzene (100414) 0.0000636 0 0.000005 0.000022 0.0000 0 0.000022 0.0000 0.0000 formaldehyde (50000) 0.033 0 0.00253 0.0111 0.0000 0 0.0111 0.0000 0.0000 naphthalene (91203) 0.00113 0 0.000087 0.00038 0.0000 0 0.00038 0.0000 0.0000 1,1,1-trichloroethane (71556) 0.000236 0 0.000018 0.000079 0.0000 0 0.000079 0.0000 0.0000 toluene (108883) 0.0062 0 0.000475 0.00208 0.0000 0 0.00208 0.0000 0.0000 o-xylene (95476) 0.000109 0 0.000008 0.000035 0.0000 0 0.000035 0.0000 0.0000 POM (total) 0.0013 0 0.00010 0.000438 0.0000 0 0.000438 0.0000 0.0000 antimony 0.00525 0 0.00040 0.00175 0.0000 0 0.00175 0.0000 0.0000 arsenic 0.00132 0 0.00010 0.000438 0.0000 0 0.000438 0.0000 0.0000 beryllium 0.0000278 0 0.000002 0.000009 0.0000 0 0.000009 0.0000 0.0000 cadmium 0.000398 0 0.000031 0.000136 0.0000 0 0.000136 0.0000 0.0000 cobalt 0.00602 0 0.000462 0.00202 0.0000 0 0.00202 0.0000 0.0000 chromium 0.00109 0 0.000084 0.000368 0.0000 0 0.000368 0.0000 0.0000 manganese 0.0030 0 0.00023 0.00101 0.0000 0 0.00101 0.0000 0.0000 mercury 0.000113 0 0.000009 0.000495 0.0000 0 0.000495 0.0000 0.0000 10) Calculations Summary - Back-up Fuel: Residual Oil continued

10a 10b 10c 10d 10e 10f 10g 10h 10i 10j HAP Name Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Fuel Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled (CAS) (lbs/ton, Use Emissions Emissions Efficiency Emissions Emissions Emissions lbs/gal, (tons, gallons, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/MMcf, MMcf, etc.) etc.) Nickel 0.0845 0 0.006479 0.0284 0.0000 0 0.0284 0.0000 0.0000 Lead 0.00151 0 0.000116 0.00051 0.0000 0 0.00051 0.0000 0.0000 Phosphorous 0.00946 0 .000725 0.00318 0.0000 0 0.00318 0.0000 0.0000 Selenium 0.000683 0 0.000052 0.000229 0.0000 0 0.000229 0.0000 0.0000

Total HAP 0 0.01294 0.05669 0.0000 0 0.05669 0.0000 0.0000

11) Worst-Case Potential-to-Emit Summary: (Ignore this item if filling out this form for a Registration Permit Option D)

11a) 11b) 11a) 11b) Before After Before After HAP Name (CAS) Operating Operating HAP Name (CAS) Operating Operating Limits: Limits: Limits: Limits: (tons/yr) (tons/yr) (tons/yr) (tons/yr) benzene (71432) 0.0001 0.0001 chromium 0.0148 0.0148 ethylbenzene (100414) 0.000022 0 manganese 0.0031 0.0031 formaldehyde (50000) 0.0219 0.0219 mercury 0.00066 0.00066 hexane (110543) 0.0907 0.0907 Nickel 0.0284 0.00399 naphthalene (91203) 0.00038 0.00003 Lead 0.00051 0.00020 1,1,1-trichloroethane (71556) 0.000079 0 Phosphorous 0.00318 0 toluene (108883) 0.00208 0.00017 Selenium 0.000229 0.000001 o-xylene (95476) 0.000035 0 Total HAP 0.1296 0.1296 POM (total) 0.0012 0.0012 antimony 0.00175 0 arsenic 0.00038 0.0002 beryllium 0.00057 0.00057 cadmium 0.00237 0.00237 cobalt 0.00202 0

12) Operating Limitations, if applicable: (Ignore this item if filling out this form for a Registration Permit Option D) This boiler will burn only natural gas and distillate fuel oil (no residual oil). MINNESOTA POLLUTION CONTROL AGENCY PERMIT APPLICATION FORM EC-11 AIR QUALITY WOODWORKING OPERATIONS 520 LAFAYETTE ROAD CALCULATION FORM ST. PAUL, MN 55155-4194 6/8/98 - This form is used for calculating potential and actual particulate emissions from cutting, sanding, and other woodworking and milling operations. You must complete the Painting and/or Coating Operations Calculation Form (EC-07) if you paint, varnish or apply any finish to your products. Fill out one copy of this form for each stack/vent, unless information for multiple stacks is identical or if using Option 1 or 2 as described below. If using Option 1 or 2, fill out this form for the entire facility. - Instructions begin on Page 3. Items 1 - 5 and the calculation summary in the form below must be completed for all options. Not all of the other data fields need to be completed. - If an emission inventory is used for determining actual emissions, it is not necessary to provide information on the past year’s production and operation where requested below. - Duplicate this form as necessary, or attach sheets with equivalent information 1) AQ Facility ID No. (if known): 99009999 2) Facility Name: Blue Ox Woodworks 3) Emission Unit Identification Number(s): 003, 004, 005, 006, and 007 4) Stack/Vent Designation Number(s): 003 5) Pollution Control Equipment Identification Number(s) 002 Option 1 - Complete items 6 - 9 if basing emission calculations on the capacity of the entire facility, in board- feet per year. Then go on to item 16. 6) Maximum Capacity of Milling: Bd ft/yr 7) Past Year’s Actual Production: Bd ft 8) Waste Wood Percent of Total Wood: % 9) Density of Wood: lb/ft³ Option 2 - Complete items 10 and 11 if basing emission calculations on published emissions factors. Then go on to item 16. 10) Maximum Capacity of Milling tons logs processed/yr 11) Past Year’s Actual Production tons logs processed Option 3 - Complete items 12 - 14 if basing emission calculations on a vendor’s emission guarantee for a baghouse. Then go on to item 16. 12) Baghouse Vendor Guarantee, if applicable: 0.020 gr/dscf 13) Maximum Rated Capacity of Pollution Control Equipment Fan: 35,000 SCFM 14) Past Year’s Hours of Operation of the Baghouse: 2000 hrs Option 4 - Complete item 15 if basing emission calculations on emission factors for cyclone-controlled operations. Then go on to item 16. 15) Past Year’s Hours of Operation of the Cyclone: hrs

16) Calculation Summary (use for all options):

16a) 16b) 16c) 16d) 16e) 16f) 16g) Maximum Pollution Maximum Limited Pollutant Emission Actual Rate Uncontrolled Control Controlled Controlled Emissions Emissions Efficiency Emissions Emissions (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) PM 6.54 26.28 26.28 6.0

PM10 6.54 26.28 26.28 6.0

17) Operating Limitations, if applicable: (Ignore this item if using this form for Registration Permit Option D.) The control equipment operation will be enforceable with an emission limit of 0.02 gr/dscf or 6.54 lb/hr.

MINNESOTA POLLUTION CONTROL AGENCY PERMIT APPLICATION FORM EC-11 AIR QUALITY WOODWORKING OPERATIONS 520 LAFAYETTE ROAD CALCULATION FORM ST. PAUL, MN 55155-4194 6/8/98 - This form is used for calculating potential and actual particulate emissions from cutting, sanding, and other woodworking and milling operations. You must complete the Painting and/or Coating Operations Calculation Form (EC-07) if you paint, varnish or apply any finish to your products. Fill out one copy of this form for each stack/vent, unless information for multiple stacks is identical or if using Option 1 or 2 as described below. If using Option 1 or 2, fill out this form for the entire facility. - Instructions begin on Page 3. Items 1 - 5 and the calculation summary in the form below must be completed for all options. Not all of the other data fields need to be completed. - If an emission inventory is used for determining actual emissions, it is not necessary to provide information on the past year’s production and operation where requested below. - Duplicate this form as necessary, or attach sheets with equivalent information 1) AQ Facility ID No. (if known): 99009999 2) Facility Name: Blue Ox Woodworks 3) Emission Unit Identification Number(s): 008, 009, 010, and 011 4) Stack/Vent Designation Number(s): 004 5) Pollution Control Equipment Identification Number(s) 003 Option 1 - Complete items 6 - 9 if basing emission calculations on the capacity of the entire facility, in board- feet per year. Then go on to item 16. 6) Maximum Capacity of Milling: Bd ft/yr 7) Past Year’s Actual Production: Bd ft 8) Waste Wood Percent of Total Wood: % 9) Density of Wood: lb/ft³ Option 2 - Complete items 10 and 11 if basing emission calculations on published emissions factors. Then go on to item 16. 10) Maximum Capacity of Milling tons logs processed/yr 11) Past Year’s Actual Production tons logs processed Option 3 - Complete items 12 - 14 if basing emission calculations on a vendor’s emission guarantee for a baghouse. Then go on to item 16. 12) Baghouse Vendor Guarantee, if applicable: 0.020 gr/dscf 13) Maximum Rated Capacity of Pollution Control Equipment Fan: 30,000 SCFM 14) Past Year’s Hours of Operation of the Baghouse: 2200 hrs Option 4 - Complete item 15 if basing emission calculations on emission factors for cyclone-controlled operations. Then go on to item 16. 15) Past Year’s Hours of Operation of the Cyclone: hrs

16) Calculation Summary (use for all options):

16a) 16b) 16c) 16d) 16e) 16f) 16g) Maximum Pollution Maximum Limited Pollutant Emissio Actual n Uncontrolled Control Controlled Controlled Emissions Rate Emissions Efficiency Emissions Emissions (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) PM 5.24 22.98 22.98 5.77

PM10 5.24 22.98 22.98 5.77

17) Operating Limitations, if applicable: (Ignore this item if using this form for Registration Permit Option D.) The control equipment operation will be enforceable with an emission limit of 0.02 gr/dscf or 5.24 lb/hr.

MINNESOTA POLLUTION CONTROL AGENCY PERMIT APPLICATION FORM EC-11 AIR QUALITY WOODWORKING OPERATIONS 520 LAFAYETTE ROAD CALCULATION FORM ST. PAUL, MN 55155-4194 6/8/98 - This form is used for calculating potential and actual particulate emissions from cutting, sanding, and other woodworking and milling operations. You must complete the Painting and/or Coating Operations Calculation Form (EC-07) if you paint, varnish or apply any finish to your products. Fill out one copy of this form for each stack/vent, unless information for multiple stacks is identical or if using Option 1 or 2 as described below. If using Option 1 or 2, fill out this form for the entire facility. - Instructions begin on Page 3. Items 1 - 5 and the calculation summary in the form below must be completed for all options. Not all of the other data fields need to be completed. - If an emission inventory is used for determining actual emissions, it is not necessary to provide information on the past year’s production and operation where requested below. - Duplicate this form as necessary, or attach sheets with equivalent information 1) AQ Facility ID No. (if known): 99009999 2) Facility Name: Blue Ox Woodworks 3) Emission Unit Identification Number(s): 012, 013, 014, 015, 016, 017, 018, and 019 4) Stack/Vent Designation Number(s): 005 5) Pollution Control Equipment Identification Number(s) 004 Option 1 - Complete items 6 - 9 if basing emission calculations on the capacity of the entire facility, in board- feet per year. Then go on to item 16. 6) Maximum Capacity of Milling: Bd ft/yr 7) Past Year’s Actual Production: Bd ft 8) Waste Wood Percent of Total Wood: % 9) Density of Wood: lb/ft³ Option 2 - Complete items 10 and 11 if basing emission calculations on published emissions factors. Then go on to item 16. 10) Maximum Capacity of Milling tons logs processed/yr 11) Past Year’s Actual Production tons logs processed Option 3 - Complete items 12 - 14 if basing emission calculations on a vendor’s emission guarantee for a baghouse. Then go on to item 16. 12) Baghouse Vendor Guarantee, if applicable: 0.020 gr/dscf 13) Maximum Rated Capacity of Pollution Control Equipment Fan: 25,000 SCFM 14) Past Year’s Hours of Operation of the Baghouse: 2600 hrs Option 4 - Complete item 15 if basing emission calculations on emission factors for cyclone-controlled operations. Then go on to item 16. 15) Past Year’s Hours of Operation of the Cyclone: hrs

16) Calculation Summary (use for all options):

16a) 16b) 16c) 16d) 16e) 16f) 16g) Maximum Pollution Maximum Limited Pollutant Emissio Actual n Uncontrolled Control Controlled Controlled Emissions Rate Emissions Efficiency Emissions Emissions (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) PM 4.37 19.15 19.15 5.68

PM10 4.37 19.15 19.15 5.68

17) Operating Limitations, if applicable: (Ignore this item if using this form for Registration Permit Option D.) The control equipment operation will be enforceable with an emission limit of 0.02 gr/dscf or 4.37 lb/hr.

MINNESOTA POLLUTION CONTROL AGENCY PERMIT APPLICATION FORM AIR QUALITY EC-07 520 LAFAYETTE ROAD PAINTING/COATING OPERATIONS ST. PAUL, MN 55155-4194 CALCULATION 8/11/98 - Use this form to calculate emissions from painting and coating operations. - Attach sheets to show all calculations, and duplicate this form for each booth/operation or attach sheets with equivalent information. -Use the External Combustion (Ovens, Dryers, Furnaces, etc.) Calculation Form (EC-08) to calculate emissions from any fuel-fired curing ovens used in this process. - If the painting/coating operation emits Hazardous Air Pollutants (HAPs), fill out Forms EC-13A and/or EC-13B. - Instructions begin on Page 3. 1) AQ Facility ID No.: 9900999 2) Facility Name: Blue Ox Woodworks 3) Emission Unit Identification Number(s): 020 4) Stack/Vent Designation Number(s): 006 5) Control Equipment I.D. Number(s): 001 6) Application Method: Airless Spray 7) Number of Spray Ports in the Booth: 4 8) Oven Curing, if applicable: Number of Ovens: 1 Oven Fuels (if fuel fired): steam from boiler Total Maximum Rated Heat Input of Ovens: MMBTU/hr 9) Coating Information (attach additional pages if necessary):

9a) 9b) 9c) 9d) Identify Coating VOC Content Solid Content Density (lb/gal) (lb/gal) (lb/gal) 1 white paint 7.39 2.46 9.85 2 sealer 5.56 2.5 8.06 3 wipe stain 7.24 0.30 7.54 4 basecoat (primer) 5.64 3.5 9.14 5 Paint 1A 5.10 2.4 7.5 6 Paint 2A 6.0 1.3 7.3 7 8 10) Maximum Coating Application Rate: 10 gallons/hour 11) Minimum Transfer Efficiency (%): 45% 12) Potential-to-Emit and Maximum Hourly Allowable Emissions Calculations Summary:

12a) 12b) 12c) 12d) 12e) 12f) 12g) 12h) 12i) 12j) Maximum Maximum Maximum Pollution Maximum Hourly emission Limited Pollutant VOC Solids Emissions Control Controlled rate allowed by Controlled Content Content Efficiency Emissions State Rule or Emissions (overall) federal regulation (tons/yr) (lbs/gal) (lbs/gal) (lbs/hr) (tons/yr) (%) (lbs/hr) (tons/yr) (tons/yr)

PM/PM10 3.5 19.25 84.32 72% 5.39 23.61 5.95 17.68 VOC 7.39 73.9 323.6 54% 33.99 148.89 n/a 85 8

13) Operating Limitations, if applicable VOC usage limited to 185 tons per year

14) Actual Emissions Calculations Summary:

14a) 14b) 14c) 14d) 14e) 14f) 14g) 14h) Uncontrolled Uncontrolled VOC PM/PM10 Controlled Controlled Identify Annual VOC PM/PM10 Control Control VOC PM/PM10 Coating usage Emissions Emissions Efficiency Efficiency Emissions Emissions (Gallons) (lbs/yr) (lbs/yr) (%) (%) (tons/year) (tons/year) 1 white paint 4000 29560 9840 54% 72% 6.8 1.38 2 sealer 5200 28912 13000 54% 72% 14.0 1.82 3 wipe stain 2000 14480 600 54% 72% 3.33 0.084 4 primer 1000 5640 3500 54% 72% 1.30 0.49 5 Paint 1A 1200 6120 2880 54% 72% 1.41 0.40 6 Stain 2A 500 3000 650 54% 72% 0.69 0.091 7 8 15a) Total Uncontrolled VOC Emissions, lbs/year: 87712

15b) Total Uncontrolled PM/PM10 Emissions, lbs/year: 30470 16a) Total Controlled VOC Emissions, tons/year: 27.53

16b) Total Controlled PM/PM10 Emissions, tons/year: 4.27 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM EC-13A 520 LAFAYETTE ROAD HAZARDOUS AIR POLLUTANTS ST. PAUL, MN 55155-4194 CALCULATION FORM (VOLATILE HAPS) 5/27/98

- Duplicate this form as necessary, or attach sheets with equivalent information. - Instructions begin on Page 4. 1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3) Emission Unit Identification Number: 020 4) Stack/Vent Designation Number: 006 5) Control Equipment Designation Number: 001 Complete item 6 or 7, not both. 6) Calculations Summary using Material Content: Potential Emissions (Do not complete this table if using this form for Registration Permit Option D. Go to Actual Emissions Table in item 6.) 6a) 6b) 6c) 6d) 6e) 6f) 6g) 6h) Maximum HAP Maximum Maximum Maximum Pollution Maximum Limited Volatile HAP Name Content Material Usage Uncontrolled HAP Uncontrolled Control Controlled HAP Controlled HAP (CAS) Rate Emission Rate HAP Emissions Efficiency Emissions Emissions (lbs/gal) (gal/hr) (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr) Methyl Ethyl Ketone (78933) 0.528 10 5.28 23.13 54.00% 10.64 9.0 Methyl Isobutyl Ketone (108101) 0.82 10 8.20 35.92 54.00% 16.52 9.0 Toluene (108883) 1.312 10 13.12 57.47 54.00% 26.43 9.0 Xylene (1330207) 1.885 10 18.85 82.56 54.00% 37.98 9.0 Total HAP 3.526 10 35.26 154.44 54.00% 71.04 24

Actual Emissions 6a) 6i) 6j) 6k) 6l) 6f) 6m) Actual Actual Material Actual Actual Pollution Actual Volatile HAP Name HAP Usage Uncontrolled HAP Uncontrolled Control Controlled HAP (CAS) Content Rate Emission Rate HAP Emissions Efficiency Emissions (lbs/gal) (gal/hr) (lbs/hr) (tons/yr) (%) (tons/yr) Coating 1: Methyl Ethyl Ketone 0.528 10 5.28 1.06 54.00% 0.49 (78933) Coating 5: Methyl Ethyl Ketone 0.492 10 4.92 0.295 54.00% 0.14 (78933) Coating 2: Methyl Isobutyl Ketone 0.377 10 3.77 0.98 54.00% 0.45 (108101) Coating 3: Methyl Isobutyl Ketone 0.146 10 1.46 0.146 54.00% 0.07 (108101) Coating 5: Methyl Isobutyl Ketone 0.82 10 8.2 0.492 54.00% 0.23 (108101)

7) Calculations Summary using Emission Factors: Potential Emissions (Do not complete this table if using this form for Registration Permit Option D. Go to the Actual Emission Table in item 7.) 7a) 7b) 7c) 7d) 7e) 7f) 7g) 7h) Maximum Hourly Maximum Maximum Pollution Maximum Limited Volatile HAP Name Maximum Production or HAP Emission Uncontrolled Control Controlled Controlled (CAS) Emission Factor Material Use Rate HAP Efficiency HAP HAP Emissions Emissions Emissions (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr)

Actual Emissions 6a) 6i) 6j) 6k) 6l) 6f) 6m) Actual Actual Material Actual Actual Pollution Actual Volatile HAP Name HAP Usage Uncontrolled HAP Uncontrolled Control Controlled HAP (CAS) Content Rate Emission Rate HAP Emissions Efficiency Emissions (lbs/gal) (gal/hr) (lbs/hr) (tons/yr) (%) (tons/yr) Coating 1: Toluene (108883) 0.858 10 8.58 1.716 54.00% 0.79 Coating 2: Toluene (108883) 0.377 10 3.77 0.98 54.00% 0.45 Coating 3: Toluene (108883) 0.365 10 3.65 0.37 54.00% 0.17 Coating 5: Toluene (108883) 1.312 10 13.12 0.782 54.00% 0.36 Coating 2: Xylene (1330207) 1.885 10 18.85 4.89 54.00% 2.25 Coating 3: Xylene (1330207) 1.46 10 14.6 1.457 54.00% 0.67 Coating 5: Xylene (1330207) 0.902 10 9.02 0.54 54.00% 0.25 Total HAP 5.40

7) Calculations Summary using Emission Factors: Potential Emissions (Do not complete this table if using this form for Registration Permit Option D. Go to the Actual Emission Table in item 7.) 7a) 7b) 7c) 7d) 7e) 7f) 7g) 7h) Maximum Hourly Maximum Maximum Pollution Maximum Limited Volatile HAP Name Maximum Production or HAP Emission Uncontrolled Control Controlled Controlled (CAS) Emission Factor Material Use Rate HAP Efficiency HAP HAP Emissions Emissions Emissions (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr)

Actual Emissions 7a) 7i) 7j) 7k) 7l) 7f) 7m) Actual Actual Actual Pollution Actual Volatile HAP Name Actual Emission Hourly Production Uncontrolled HAP Uncontrolled Control Controlled HAP (CAS) Factor or Material Use Emission Rate HAP Emissions Efficiency Emissions (lbs/hr) (tons/yr) (%) (tons/yr)

8) Operating Limitations, if applicable: (Ignore this item if using the form for Registration Permit Option D). Limit HAP usage such that each individual HAP PTE is 9.0 tpy and combined HAP PTE is 24 tpy. Control HAP emissions with a thermal oxidizer that will achieve an overall control efficiency of 54% for each volatile HAP.

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM EC-13B 520 LAFAYETTE ROAD HAZARDOUS AIR POLLUTANTS ST. PAUL, MN 55155-4194 CALCULATION FORM (PARTICULATE HAPS) 5/27/98

- Duplicate this form as necessary, or attach sheets with equivalent information. - Instructions begin on Page 4. 1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3) Emission Unit Identification Number: 020 4) Stack/Vent Designation Number: 006 5) Control Equipment Designation Number: 005 6) Calculations Summary using HAP Content of Particulate Matter: (Use this table only if you do not have emission factors but know the weight fraction of HAPs in the particulate matter emitted from the emission unit): Potential Emissions (Do not complete this table if using this form for Registration Permit Option D. Go to Actual Emissions Table in item 6.) 6a) 6b) 6c) 6d) 6e) 6f) 6g) 6h) Maximum Maximum Maximum Maximum Pollution Maximum Limited Particulate HAP Name Weight Fraction Uncontrolled Uncontrolled Uncontrolled Control Controlled HAP Controlled HAP (CAS) HAP in PM PM Emission HAP Emission HAP Emissions Efficiency Emissions Emissions Emissions Rate Rate (lbs/hr) (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr)

Actual Emissions 6a) 6i) 6j) 6k) 6l) 6f) 6m) Actual Actual Actual Actual Pollution Actual Particulate HAP Name Weight Fraction Uncontrolled Uncontrolled Uncontrolled Control Controlled HAP (CAS) HAP in PM PM Emission HAP Emission HAP Emissions Efficiency Emissions Emissions Rate Rate (lbs/hr) (lbs/hr) (tons/yr) (%) (tons/yr)

7) Calculations Summary using Emission Factors: (Use this table if you have specific emission factors for the HAPs emitted by this type of emission unit in this industry): Potential Emissions (Do not complete this table if using this form for Registration Permit Option D. Go to the Actual Emission Table in item 7.) 7a) 7b) 7c) 7d) 7e) 7f) 7g) 7h) Maximum Hourly Maximum Maximum Pollution Maximum Limited Particulate HAP Name Maximum HAP Production or Uncontrolled Uncontrolled Control Controlled Controlled (CAS) Emission Factor Material Use HAP Emission HAP Efficiency HAP HAP Rate Emissions Emissions Emissions (lb/gallon) (gal/hour) (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr) Cadmium compounds 0.022 10 0.22 0.96 72.00% 0.27 0.27 Lead compounds 0.008 10 0.08 0.36 72.00% 0.10 0.10 Total PM 0.028 10 0.28 1.23 72.00% 0.34 0.34

Actual Emissions 7a) 7i) 7j) 7k) 7l) 7f) 7m) Actual HAP Actual Actual Actual Pollution Actual Particulate HAP Name Emission Factor Hourly Production Uncontrolled HAP Uncontrolled Control Controlled HAP (CAS) or Material Use Emission Rate HAP Emissions Efficiency Emissions (lb/gallon) (gal/hour) (lbs/hr) (tons/yr) (%) (tons/yr) Coating 1: Cadmium compounds 0.014 10 0.14 0.028 72.00% 0.01 Coating 4: Cadmium compounds 0.019 10 0.19 0.01 72.00% 0.00 Coating 6: Cadmium compounds 0.022 10 0.22 0.01 72.00% 0.00 Coating 1: Lead compounds 0.006 10 0.06 0.01 72.00% 0.00 Coating 4: Lead compounds 0.008 10 0.08 0.00 72.00% 0.00 Total PM HAP 0.01

8) Operating Limitations, if applicable: (Ignore this item if using this form for Registration Permit Option D.) Control particulate matter with wall filters with an overall control efficiency of 72 percent.

MINNESOTA POLLUTION CONTROL AGENCY PERMIT APPLICATION FORM EC-08 AIR QUALITY EXTERNAL COMBUSTION (OVENS, DRYERS, FURNACES 520 LAFAYETTE ROAD ETC.) CALCULATION FORM ST. PAUL, MN 55155-4194 5/27/98

- Fill out this form for each fuel burned in each external combustion unit, or attach sheets with equivalent information. - Instructions start on Page 6. - If the external combustion unit emits Hazardous Air Pollutants (HAPs), fill out and attach Form EC-13C. - If you operate a furnace, oven, or dryer for the purpose of heating a material inside (such as a foundry furnace for melting metals, or a sweat furnace for recovering metals from scrap, or a grain dryer for drying grain), you must also account for emissions from the material being heated/melted/dried. Use Form EC-16 for grain drying. Use Form EC-01 for others. 1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks 3) Emission Unit Identification Number: NA -- Thermal Oxidizer 4) Stack/Vent Designation Number: 006 5) Maximum Rated Burner Capacity: 5.0 million BTU/hr 6) Control Equipment: 001 7) Fuel Parameters

7a) 7b) 7c) 7d) 7e) Units Fuel Type % Sulfur % Ash Heat Value Units Fuel Consumption Rate natural gas 1000 Btu/ton, Btu/gal, Btu/cf 5000 ton/hr; gal/hr; cf/hr Btu/ton, Btu/gal, Btu/cf ton/hr; gal/hr; cf/hr Btu/ton, Btu/gal, Btu/cf ton/hr; gal/hr; cf/hr When calculating Potential Emissions, use items 8a, 8b, 8d, 8e, 8g, 8h, and 8i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 8a, 8b, 8c, 8f, 8g, and 8j.

8) Calculations Summary - Primary Fuel: 8a 8b 8c 8d 8e 8f 8g 8h 8i 8j Pollutant Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled lb/MMcf Fuel Use Emissions Emissions Efficiency Emissions Emissions Emissions (lbs/ton, lbs/gal, (tons, gallons, cf, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/cf, etc.) etc.) PM 7.6 11 MMcf 0.038 0.166 0.042 0 0.166 0.166 0.042

PM10 7.6 11 0.038 0.166 0.042 0 0.166 0.166 0.042 SOx 0.6 11 0.003 0.013 0.003 0 0.013 0.013 0.003 NOx 100 11 0.50 2.19 0.55 0 2.19 2.19 0.55 VOC 5.5 11 0.0275 0.120 0.030 0 0.120 0.120 0.030 CO 84 11 0.420 1.84 0.462 0 1.84 1.84 0.462 Lead 0.005 11 0.00002 0.0001 0.00003 0 0.0001 0.0001 0.00003 5 When calculating Potential Emissions, use items 9a, 9b, 9d, 9e, 9g, 9h, and 9i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 9a, 9b, 9c, 9f, 9g, and 9j.

9) Calculations Summary - Back-up Fuel: NA 9a 9b 9c 9d 9e 9f 9g 9h 9i 9j Pollutant Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled Fuel Use Emissions Emissions Efficiency Emissions Emissions Emissions (lbs/ton, lbs/gal, (tons, gallons, cf, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/cf, etc.) etc.) PM

PM10 SOx NOx VOC CO Lead When calculating Potential Emissions, use items 10a, 10b, 10d, 10e, 10g, 10h, and 10i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 10a, 10b, 10c, 10f, 10g, and 10j.

10) Calculations Summary - Back-up Fuel: NA 10a 10b 10c 10d 10e 10f 10g 10h 10i 10j Pollutant Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled Fuel Use Emissions Emissions Efficiency Emissions Emissions Emissions (lbs/ton, lbs/gal, (tons, gallons, cf, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/cf, etc.) etc.) PM

PM10 SOx NOx VOC CO Lead 11) Worse-Case Potential-to-Emit Summary: (Ignore this item if filling out this form for a Registration Permit Option D) 11a) 11b) Before After Pollutant Operating Operating Limits: Limits: (tons/yr) (tons/yr) PM 0.166 0.166

PM10 0.166 0.166 SOx 0.013 0.013 NOx 2.19 2.19 VOC 0.120 0.120 CO 1.84 1.84 Lead 0.0001 0.0001

12) Operating Limitations, if applicable: (Ignore this item if filling out this form for a Registration Permit Option D) None

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM EC-13C 520 LAFAYETTE ROAD HAZARDOUS AIR POLLUTANTS ST. PAUL, MN 55155-4194 CALCULATION FORM (FUEL COMBUSTION HAPS) 5/27/98

- Duplicate this form as necessary, or attach sheets with equivalent information. - Instructions begin on Page 6. 1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3) Emission Unit Identification Number: NA -- thermal oxidizer 4) Stack/Vent Designation Number: 006 5) Maximum Rated Equipment Capacity: 5.0 million BTU/hr 6) Control Equipment Designation Number: 001 7) Fuel Parameters

7a) 7b) 7c) 7d) 7e) Units Units Fuel Type % Sulfur % Ash Heat Value Fuel Consumption Rate natural gas 1000.00 Btu/ton, Btu/gal, Btu/cf 5000.00 tons/hr; gal/hr; cf/hr Btu/ton, Btu/gal, Btu/cf tons/hr; gal/hr; cf/hr Btu/ton, Btu/gal, Btu/cf tons/hr; gal/hr; cf/hr When calculating Potential Emissions, use items 8a, 8b, 8d, 8e, 8g, 8h, and 8i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 8a, 8b, 8c, 8f, 8g, and 8j.

8) Calculations Summary - Primary Fuel: Natural Gas

8a 8b 8c 8d 8e 8f 8g 8h 8i 8j HAP Name Emission Actual Annual Emission Maximum Actual Pollution Maximum Limited Actual Factor (lbs/ton, Fuel Use Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled (CAS) Emissions Emissions Efficiency Emissions Emissions Emissions lbs/gal, (tons, gallons, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/MMcf, etc.) MMcf, etc.) benzene (71432) 0.00213 11 0.000011 0.000048 0.0000 0 0.000048 0.000048 0.0000 dichlorobenzene (106467) 0.0012 11 0.000006 0.000026 0.0000 0 0.000026 0.000026 0.0000 formaldehyde (50000) 0.075 11 0.000374 0.000163 0.0004 0 0.000163 0.000163 0.0004 hexane (110543) 1.80 11 0.0090 0.0394 0.0099 0 0.0394 0.0394 0.0099 naphthalene (91203) 0.00061 11 0.000003 0.000013 0.0000 0 0.000013 0.000013 0.0000 toluene (108883) 0.0034 11 0.000017 0.000074 0.0000 0 0.000074 0.000074 0.0000 POM (total) 0.000086 11 4.3E-7 0.000002 0.0000 0 0.000002 0.000002 0.0000 arsenic 0.0002 11 0.000001 0.000004 0.0000 0 0.000004 0.000004 0.0000 beryllium 0.000012 11 6.0E-8 2.63E-7 0.0000 0 2.63E-7 2.63E-7 0.0000 cadmium 0.0011 11 0.000006 0.000024 0.0000 0 0.000024 0.000024 0.0000 chromium 0.0014 11 0.000007 0.000031 0.0000 0 0.000031 0.000031 0.0000 manganese 0.00038 11 0.000002 0.000008 0.0000 0 0.000008 0.000008 0.0000 mercury 0.00026 11 0.000001 0.000006 0.0000 0 0.000006 0.000006 0.0000 nickel 0.0021 11 0.000011 0.000046 0.0000 0 0.000046 0.000046 0.0000 selenium 0.000024 11 1.20E-7 0.000001 0.0000 0 0.000001 0.000001 0.0000 Total HAP 1.8879 11 0.00944 0.0413 0.0104 0 0.0413 0.0413 0.0104 When calculating Potential Emissions, use items 9a, 9b, 9d, 9e, 9g, 9h, and 9i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 9a, 9b, 9c, 9f, 9g, and 9j.

9) Calculations Summary - Back-up Fuel: NA

9a 9b 9c 9d 9e 9f 9g 9h 9i 9j HAP Name Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Fuel Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled (CAS) (lbs/ton, Use Emissions Emissions Efficiency Emissions Emissions Emissions lbs/gal, (tons, gallons, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/MMcf, MMcf, etc.) etc.)

When calculating Potential Emissions, use items 10a, 10b, 10d, 10e , 10g, 10h, and 10i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 10a, 10b, 10c, 10f, 10g, and 10j. 10) Calculations Summary - Back-up Fuel: NA 10a 10b 10c 10d 10e 10f 10g 10h 10i 10j HAP Name Emission Actual Emission Maximum Actual Pollution Maximum Limited Actual Factor Annual Fuel Rate Uncontrolled Uncontrolled Control Controlled Controlled Controlled (CAS) (lbs/ton, Use Emissions Emissions Efficiency Emissions Emissions Emissions lbs/gal, (tons, gallons, (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) lbs/MMcf, MMcf, etc.) etc.)

11) Worst-Case Potential-to-Emit Summary: (Ignore this item if filling out this form for a Registration Permit Option D) 11a) 11b) 11a) 11b) Before After Before After HAP Name (CAS) Operating Operating HAP Name (CAS) Operating Operating Limits: Limits: Limits: Limits: (tons/yr) (tons/yr) (tons/yr) (tons/yr) benzene (71432) 0.000048 0.000048 manganese 0.000008 0.000008 dichlorobenzene (106467) 0.000026 0.000026 mercury 0.000006 0.000006 formaldehyde (50000) 0.000163 0.000163 nickel 0.000046 0.000046 hexane (110543) 0.0394 0.0394 selenium 0.000001 0.000001 naphthalene (91203) 0.000013 0.000013 Total HAP 0.0413 0.0413 toluene (108883) 0.000074 0.000074 POM (total) 0.000002 0.000002 arsenic 0.000004 0.000004 beryllium 2.63E-7 2.63E-7 cadmium 0.000024 0.000024 chromium 0.000031 0.000031

12) Operating Limitations, if applicable: (Ignore this item if filling out this form for a Registration Permit Option D) None

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM EC-12 520 LAFAYETTE ROAD CLEAN-UP MATERIALS ST. PAUL, MN 55155-4194 CALCULATION FORM 5/27/98

- Duplicate this form as necessary, or attach sheets with equivalent information. - If the clean-up materials contain Hazardous Air Pollutants (HAPs), fill out and attach form EC-13A. - When calculating potential emissions, use items 3a, 3b, 3d, 3f, 3h, 3i, and 3j. [Note: You do not need to calculate PTE if using this form for Registration Permit Option D.] - When calculating actual emissions, use items 3a, 3c, 3e, 3g, 3h, and 3k. 1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks 3) Calculations Summary for Clean-up Materials: 3a 3b 3c 3d 3e 3f 3g 3h 3i 3j 3k Maximum Actual Maximum Actual Maximum Actual Pollution Maximum Limited Actual Clean-Up Materials Amount Amount VOC VOC Uncontrolled Uncontrolled Control Controlled Controlled Controlled Used Used Content Content Emissions Emissions Efficiency Emissions Emissions Emissions (gal/hr) (gal/yr) (lbs/gal) (lbs/gal) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) Mineral Spirits 0.4 500 7.20 7.00 12.6 1.8 0.00% 12.6 10.0 1.8

4) Operating Limitations, if applicable: (Ignore this item if filling out this form for Registration Permit Option D) Permit limit of 10 tons of VOC per year.

MINNESOTA POLLUTION CONTROL AGENCY PERMIT APPLICATION FORM EC-03 AIR QUALITY INTERNAL COMBUSTION 520 LAFAYETTE ROAD (SINGLE-FUEL) CALCULATION FORM ST. PAUL, MN 55155-4194 7/22/98

- Fill out this form for each fuel burned in each engine, or attach sheets with equivalent information. - If the engine emits Hazardous Air Pollutants (HAPs), fill out and attach form EC-13C. 1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3) Emission Unit Identification Number: 022 4) Stack/Vent Designation Number: 007 5) Control Equipment Identification Number: 6) Engine Type: Reciprocating Turbine Other: 7) Engine is Used For: Routine operational use Emergency or back-up use only 8) Rated Heat Input: 2.1 MMBtu/hr 9) Rated Mechanical Output: HP @ RPM 10) Fuel Type: Diesel @ 0.5 % Sulfur 11) Fuel Consumption Rate: 15 (gal/hr or cf/hr) 12) Calculations Summary: 12a) 12b) 12c) 12d) 12e) 12f) 12g) 12h) Maximum Pollution Maximum Limited Pollutant Emission Emission Actual Factor Rate Uncontrolled Control Controlled Controlled Emissions Emissions Efficiency Emissions Emissions (lbs/gal, lbs/cf) (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr) PM 0.31 0.65 0.2 0 0.2 0.2 0.028

PM10 0.31 0.65 0.2 0 0.2 0.2 0.028 SOx 0.29 0.61 0.152 0 0.152 0.152 0.026 NOx 4.41 9.26 2.32 0 2.32 2.32 0.393 VOC 0.36 0.756 0.189 0 0.189 0.189 0.032 CO 0.95 2.0 0.50 0 0.50 0.50 0.085 Lead 13) Operating Limitations, if applicable: This is an emergency generator and per EPA letter dated Sept. 6, 1995, can assume 500 hours of operation per year when doing PTE. No proposed limits.

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-07 520 LAFAYETTE ROAD FACILITY EMISSIONS SUMMARY ST. PAUL, MN 55155-4194 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3a) 3b) 3c) CAS#: CAS#: CAS#:

3d) Pollutant Name: Carbon Monoxide Pollutant Name: Lead compounds Pollutant Name: Nitrogen Oxides Emission Emission Source Source 3e) 3f) Type ID No. Potential Actual Potential Actual Potential Actual Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per yr Hr tpy tpy yr Hr tpy tpy yr Hr tpy tpy EU 001 12.24 53.6 0 1.25 0 0 0 0 1.35 5.9 0 0.14

EU 002 0.97 4.23 4.23 1.2 0.00 0.00051 0.0002 0.00 4.217 18.47 7.196 1.44

SV 003 0 0 0 0 0 0 0 0 0 0 0 0

SV 004 0 0 0 0 0 0 0 0 0 0 0 0

SV 005 0 0 0 0 0 0 0 0 0 0 0 0

SV 006 0.420 1.84 1.84 0.462 0.022 0.36 0.10 0.01 0.50 2.19 2.19 0.55

SV 007 2.0 0.50 0.50 0.085 0 0 0 0 9.26 2.32 2.32 0.393

FC

4) Potential Actual Potential Actual Potential Actual Total Unc Lim Yr Unc Lim Yr Unc Lim Yr Facility 60.2 6.6 3.0 0.36 0.10 0.010 28.9 11.7 2.5 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-07 520 LAFAYETTE ROAD FACILITY EMISSIONS SUMMARY ST. PAUL, MN 55155-4194 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3a) 3b) 3c) CAS#: CAS#: CAS#:

3d) Pollutant Name: Particulate Matter Pollutant Name: PM10 Pollutant Name: Sulfur Dioxides Emission Emission Source Source 3e) 3f) Type ID No. Potential Actual Potential Actual Potential Actual Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per yr Hr tpy tpy yr Hr tpy tpy yr Hr tpy tpy EU 001 4.32 18.92 0.0 0.81 4.32 18.92 0.0 0.71 0.01 0.04 0.0 0.0

EU 002 3.01 13.18 0.718 0.11 2.66 11.65 0.383 0.11 48.76 213.6 25.90 0.009

SV 003 6.54 26.3 26.3 6.0 6.54 26.3 26.3 6.0 0 0 0 0

SV 004 5.24 22.98 22.98 5.77 5.24 22.98 22.98 5.77 0 0 0 0

SV 005 4.37 19.15 19.15 5.68 4.37 19.15 19.15 5.68 0 0 0 0

SV 006 19.28 84.49 17.84 4.31 19.28 84.49 17.84 4.31 0.003 0.013 0.013 0.003

SV 007 0.65 0.20 0.20 0.028 0.65 0.20 0.20 0.028 0.61 0.152 0.152 0.026

FC

4) Potential Actual Potential Actual Potential Actual Total Unc Lim Yr Unc Lim Yr Unc Lim Yr Facility 185.2 87.2 22.7 183.7 86.9 22.6 213.8 26.1 0.05 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-07 520 LAFAYETTE ROAD FACILITY EMISSIONS SUMMARY ST. PAUL, MN 55155-4194 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3a) 3b) 3c) CAS#: CAS#: 106467 CAS#:

3d) Pollutant Name: VOC Pollutant Name: dichlorobenzene Pollutant Name: arsenic Emission Emission Source Source 3e) 3f) Type ID No. Potential Actual Potential Actual Potential Actual Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per yr Hr tpy tpy yr Hr tpy tpy yr Hr tpy tpy EU 001 0.20 0.87 0.0 0.02

EU 002 0.063 0.277 0.277 0.079 0.00006 0.00006 0 0.00038 0.0002 0

SV 003

SV 004

SV 005

SV 006 76.81 336.42 95.12 30.46

SV 007 0.756 0.189 0.189 0.032

FC

4) Potential Actual Potential Actual Potential Actual Total Unc Lim Yr Unc Lim Yr Unc Lim Yr Facility 337.8 95.6 30.6 0.00006 0.00006 0 0.0004 0.0002 0 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-07 520 LAFAYETTE ROAD FACILITY EMISSIONS SUMMARY ST. PAUL, MN 55155-4194 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3a) 3b) 3c) CAS#: 71432 CAS#: CAS#:

3d) Pollutant Name: benzene Pollutant Name: beryllium Pollutant Name: cadmium compounds Emission Emission Source Source 3e) 3f) Type ID No. Potential Actual Potential Actual Potential Actual Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per yr Hr tpy tpy yr Hr tpy tpy yr Hr tpy tpy EU 001

EU 002 0.0001 0.0001 0 0.00057 0.00057 0 0.00237 0.00237 0

SV 003

SV 004

SV 005

SV 006 0.062 0.96 0.27 0.02

SV 007

FC

4) Potential Actual Potential Actual Potential Actual Total Unc Lim Yr Unc Lim Yr Unc Lim Yr Facility 0.0001 0.0001 0 0.00057 0.00057 0 0.96 0.27 0.02 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-07 520 LAFAYETTE ROAD FACILITY EMISSIONS SUMMARY ST. PAUL, MN 55155-4194 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3a) 3b) 3c) CAS#: 100414 CAS#: 50000 CAS#: 110543

3d) Pollutant Name: ethylbenzene Pollutant Name: formaldehyde Pollutant Name: hexane Emission Emission Source Source 3e) 3f) Type ID No. Potential Actual Potential Actual Potential Actual Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per yr Hr tpy tpy yr Hr tpy tpy yr Hr tpy tpy EU 001

EU 002 0.00002 0.00 0 0.0219 0.0219 0.0011 0.0907 0.0907 0.0259

SV 003

SV 004

SV 005

SV 006

SV 007

FC

4) Potential Actual Potential Actual Potential Actual Total Unc Lim Yr Unc Lim Yr Unc Lim Yr Facility 0.00002 0 0 0.0219 0.0219 0.0011 0.0907 0.0907 0.0259 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-07 520 LAFAYETTE ROAD FACILITY EMISSIONS SUMMARY ST. PAUL, MN 55155-4194 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3a) 3b) 3c) CAS#: CAS#: CAS#: 78933

3d) Pollutant Name: Manganese Pollutant Name: mercury Pollutant Name: methyl ethyl ketone Emission Emission Source Source 3e) 3f) Type ID No. Potential Actual Potential Actual Potential Actual Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per yr Hr tpy tpy yr Hr tpy tpy yr Hr tpy tpy EU 001

EU 002 0.0031 0.0031 0 0.00066 0.00066 0

SV 003

SV 004

SV 005

SV 006

SV 007 5.27 23.1 9.0 0.62

FC

4) Potential Actual Potential Actual Potential Actual Total Unc Lim Yr Unc Lim Yr Unc Lim Yr Facility 0.0031 0.0031 0 0.00066 0.00066 0 23.1 9.0 0.62 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-07 520 LAFAYETTE ROAD FACILITY EMISSIONS SUMMARY ST. PAUL, MN 55155-4194 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3a) 3b) 3c) CAS#: 108101 CAS#: 91203 CAS#:

3d) Pollutant Name: methyl isobutyl Pollutant Name: Naphthalene Pollutant Name: nickel Emission Emission ketone Source Source 3e) 3f) Type ID No. Potential Actual Potential Actual Potential Actual Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per yr Hr tpy tpy yr Hr tpy tpy yr Hr tpy tpy EU 001

EU 002 0.00038 0.00003 0 0.0284 0.00399 0

SV 003

SV 004

SV 005

SV 006 3.77 35.92 9.0 .74

SV 007

FC

4) Potential Actual Potential Actual Potential Actual Total Unc Lim Yr Unc Lim Yr Unc Lim Yr Facility 35.9 9.0 0.74 0.00038 0.00003 0 0.0284 0.004 0 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-07 520 LAFAYETTE ROAD FACILITY EMISSIONS SUMMARY ST. PAUL, MN 55155-4194 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3a) 3b) 3c) CAS#: CAS#: CAS#:

3d) Pollutant Name: chromium Pollutant Name: Polycyclic Organic Pollutant Name: selenium Emission Emission Matter Source Source 3e) 3f) Type ID No. Potential Actual Potential Actual Potential Actual Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per yr Hr tpy tpy yr Hr tpy tpy yr Hr tpy tpy EU 001

EU 002 0.0148 0.0148 0.0000 0.0012 0.0012 0 0.00023 .000001 0

SV 003

SV 004

SV 005

SV 006

SV 007

FC

4) Potential Actual Potential Actual Potential Actual Total Unc Lim Yr Unc Lim Yr Unc Lim Yr Facility 0.0148 0.0148 0 0.0012 0.0012 0 0.00023 0.00001 0 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-07 520 LAFAYETTE ROAD FACILITY EMISSIONS SUMMARY ST. PAUL, MN 55155-4194 5/26/98

1) AQ Facility ID No.: 99009999 2) Facility Name: Blue Ox Woodworks, Inc. 3a) 3b) 3c) CAS#: 108883 CAS#: 1330207 CAS#:

3d) Pollutant Name: toluene Pollutant Name: xylene Pollutant Name: Total HAPs Emission Emission Source Source 3e) 3f) Type ID No. Potential Actual Potential Actual Potential Actual Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per Lbs per Unc Lim Tons per yr Hr tpy tpy yr Hr tpy tpy yr Hr tpy tpy EU 001

EU 002 0.00208 0.00017 0 0.1296 0.1296 0.0272

SV 003

SV 004

SV 005

SV 006 6.04 57.47 9.0 1.77 8.67 82.56 9.0 3.18 35.25 154.4 24 6.34

SV 007

FC

4) Potential Actual Potential Actual Potential Actual Total Unc Lim Yr Unc Lim Yr Unc Lim Yr Facility 57.47 9.0 1.77 82.56 9.0 3.18 154.57 24.13 6.37

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-09 520 LAFAYETTE ROAD REQUIREMENTS FORM ST. PAUL, MN 55155-4194 05/11/98

Federal and State Requirements

This packet of forms, GI-09 REQUIREMENTS, will help you to determine the federal and state requirements with which your facility must comply. Be advised that you must include any applicable requirement that may not be addressed in this part of the application.

The first section of this form asks questions to find out if your facility is subject to specific federal and state regulations. To assist you in filling out this form, there are nine attachments, forms GI-09A through GI-09I. This form will direct you to each of the attachments as necessary, which will help you determine if your facility is subject to these regulations. When you are directed to an attachment, complete it as required, but always return to this GI-09 REQUIREMENTS form.

1) National Emission Standards for Hazardous Air Pollutants for Source Categories (NESHAP for Source Categories, 40 CFR pt. 63)

1a) To determine if any requirements for the National Emission Standards for Hazardous Air Pollutants (NESHAPS) for Source Categories (40 CFR pt. 63) apply to your facility, you must complete attached form GI-09A REQUIREMENTS: NESHAP FOR SOURCE CATEGORIES (40 CFR pt. 63).

1b) After completing form GI-09A, check one of the following boxes: YES, my facility is currently subject to NESHAP for Source Categories requirements. NO, my facility is not currently subject to NESHAP for Source Categories requirements.

1c) After completing form GI-09A, check one of the following boxes: YES, my facility is subject to requirements of case-by-case MACT under Section 112(g)(2)(B). NO, my facility is not subject to requirements of case-by-case MACT under Section 112(g)(2)(B).

2) National Emission Standards for Hazardous Air Pollutants (NESHAP; 40 CFR pt. 61)

2a) To determine if any of the National Emission Standards for Hazardous Air Pollutants (NESHAP) (40 CFR pt. 61) apply to your facility, you must complete the attached form GI-09B REQUIREMENTS: NESHAP (40 CFR pt. 61).

2b) After completing item 2a, check one of the following boxes: YES, my facility is subject to NESHAP requirements. NO, my facility is not subject to NESHAP requirements. 3) New Source Review (NSR, New Source Review, 40 CFR pt. 52)

3a) Did you construct, make any physical change to (as defined in 40 CFR § 52.21) or change the method of operation of (as defined in 40 CFR § 52.21) your facility since August 7, 1980? YES. Go to form GI-09C REQUIREMENTS: NEW SOURCE REVIEW. NO. Go to question 3b and answer NO.

3b) After completing the above question (and form GI-09C if necessary) check one of the following boxes: YES, my facility is subject to NSR requirements. NO, my facility is not subject to NSR requirements until I make a qualifying change. UNKNOWN. You may only check this box if directed to do so from GI-09C REQUIREMENTS: NEW SOURCE REVIEW.

4) National Ambient Air Quality Standards; Increment and Visibility Requirements (1990 Clean Air Act, as amended, Sections 109 and 160-169(B))

4a) Did you answer NO to question 3b above or are you taking "synthetic minor" permit limitations which allow you to avoid having to submit a complete NSR application? YES, my facility is not subject to this requirement. NO, my facility is subject to this requirement. I must complete an analysis of ambient air, increment and visibility in my NSR application as prescribed by Sections 109 and 160-169(B) of the 1990 Clean Air Act Amendments.

5) Standards of Performance for New Stationary Sources (NSPS, New Source Performance Standards, 40 CFR pt. 60)

5a) Is your facility a Sulfuric Acid Plant? NO. YES, you may be subject to this regulation; complete the attached form GI-09D REQUIREMENTS: NSPS (you may skip question 5b).

5b) Have you constructed, modified (as defined in 40 CFR § 60.14), or reconstructed (as defined in 40 CFR § 60.15) your emission facility, or any portion thereof, after August 17, 1971? NO. YES, you may be subject to this regulation. Complete the attached form GI-09D REQUIREMENTS: NSPS.

5c) If you answered NO to questions 5a and 5b your facility is not subject to federal NSPS requirements. Answer “NO” to question 5d.

5d) After completing the above questions (and the attachment if necessary) check one of the following boxes: YES, my facility (or a portion of it) is subject to NSPS requirements. NO, my facility is not subject to NSPS requirements. 6) Acid Rain Program under Title IV (40 CFR pt. 72, 40 CFR pt. 73; and 1990 Clean Air Act, as amended, Sections 401-416)

6a) Is your facility one of the Phase I or Phase II units listed below? NO. Go to question 6b. YES. Go to question 6c and answer YES.

Austin Utilities: Northeast Station Interstate Power: Fox Lake Minnesota Power and Light: Clay Boswell M.L. Hibbard Syl Laskin Northern States Power: High Bridge Minnesota Valley Riverside Sherburne County Allen S. King Black Dog Na. 1 -- 7237 Future Base Otter Tail Power: Hoot Lake Rochester Public Utility: Silver Lake

6b) Does your facility combust fossil fuel and generate electricity for wholesale or retail sale, such as a cogeneration facility, a qualifying facility (as defined in the Federal Power Act), independent power producer, or solid waste incinerator? NO. Go to question 6c and answer NO. YES. Your facility may be subject to Acid Rain Requirements. Refer to the applicability definitions in 40 CFR § 72.6 to find out if they apply.

6c) After completing question 6a and 6b, are you subject to Acid Rain Requirements? NO, my facility is not subject to Acid Rain Requirements. YES, my facility is subject to Acid Rain Requirements. Refer to Form GI-09E REQUIREMENTS: ACID RAIN for more information about applying for an acid rain permit.

7) Stratospheric Ozone Protection (1990 Clean Air Act, as amended, Sections 601-618)

7a) To determine if this federal regulation applies to your facility, you must complete the attached form GI-09F REQUIREMENTS: STRATOSPHERIC OZONE.

7b) After completing form GI-09F REQUIREMENTS: STRATOSPHERIC OZONE, check one of the following boxes: YES, my facility is subject to this requirement. NO, my facility is not subject to this requirement. 8) RISK MANAGEMENT PROGRAMS FOR CHEMICAL ACCIDENTAL RELEASE PREVENTION (40 CFR pt. 68, Section 112(r) of the Clean Air Act Amendments)

8a) Section 112(r) of the Clean Air Act requires facilities that produce, process, store or use any of the substances listed in form GI-09G: RISK MANAGEMENT PROGRAMS FOR CHEMICAL ACCIDENTAL, RELEASE PREVENTION (40 CFR pt. 68), in amounts greater than the listed thresholds, to develop and implement a risk management plan for accidental releases.

8b) Determine if you produce, process, store or use any of the substances listed in form GI-09G: RISK MANAGEMENT PROGRAMS FOR CHEMICAL ACCIDENTAL, RELEASE PREVENTION, and check one of the following boxes: Yes, my facility does produce, process, store or use one or more of the substances listed in form GI-09G, in amounts exceeding the listed thresholds. No, my facility does not produce, process, store or use any of the substances listed in form GI-09G, in amounts exceeding the listed thresholds.

9) Compliance Assurance Monitoring (CAM, 40 CFR pt. 64)

9a) To determine if the CAM regulations apply to your facility, you must complete the attached form GI-09H REQUIREMENTS: CAM.

9b) After completing question 9a, above, check one of the following boxes: YES, my facility is subject to CAM requirements. NO, my facility is not subject to CAM requirements.

10) Federal Ozone Measures for the Control of Emissions from Certain Sources (1990 Clean Air Act, as amended, Section 183(e))

10a) As of April 30, 1998, no rules have been promulgated under the above section of the Clean Air Act. If your facility manufactures, processes, wholesale distributes or imports consumer or commercial products that emit volatile organic compounds, it may be subject to any rules that are adopted under § 183(e) requiring emission reductions. When the rules are promulgated, you must comply with them.

11) Minnesota State Air Quality Rules

11a) To determine which Minnesota State rules you may be subject to, go to form GI-09I REQUIREMENTS: STATE RULES.

11b) Whether permitted or not, every business and activity in Minnesota is subject to the rules listed in the following table: Title of the Rule Minnesota Rules (Chapter What the Content of the Rule is: or Part) Air Quality Emission Fees Part 7002.0025 - 7002.0095 Requires facilities to pay emission fees every year within 60 days of MPCA billing. Air Emission Permits Parts 7007.0050 - 7007.1850 Outlines when an air emission permit is required and procedures for obtaining one. Minnesota and National Ambient Part 7009.0010 - 7009.0080 No one is allowed to emit any of the limited pollutants Air Quality Standards in such a manner that ambient levels of the pollutant are higher than the maximum level. Applicability of Standards of Parts 7011.0010, and Indicates that facilities must comply with all Performance 7011.0050 applicable state air pollution rules. Circumvention Part 7011.0020 States that no one may conceal or dilute emissions which would otherwise violate a federal or state air pollution control rule. Emission Standards for Visible Air Part 7011.0100 - 7011.0120 Outlines restrictions against emitting opaque smoke Contaminants from facilities. Preventing Particulate Matter from Part 7011.0150 States that no person shall cause particulate matter to Becoming Airborne become airborne if it can be avoided with listed preventative measures. Continuous Monitors Part 7017.1000 Outlines requirements for continuous monitoring systems. Performance Tests Part 7017.2001 - 7017.2060 Outlines procedures and methods for emissions and performance testing if required. Notifications Part 7019.1000 Requires facilities to notify the MPCA of shutdowns and breakdowns. Reports Part 7019.2000 Requires specific records and reports from facilities with continuous monitoring systems. Emission Inventory Part 7019.3000 - 7019.3100 Requires facilities to submit an Emission Inventory Report by April 1 every year. Motor Vehicles Part 7023.0100 - 7023.0120 Outlines restrictions against emitting opaque smoke from motor vehicles, trains, boats, construction equipment and stationary internal combustion engines. Noise Pollution Control Part 7030.0010 - 7030.0080 Sets noise standards which cannot be exceeded.

12) You have completed the Applicable Requirements form.

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-09A 520 LAFAYETTE ROAD REQUIREMENTS: NESHAP ST. PAUL, MN 55155-4194 FOR SOURCE CATEGORIES (40 CFR pt. 63) 05/11/98

National Emission Standards for Hazardous Air Pollutants for source categories (NESHAP for Source Categories, 40 CFR pt. 63)

1) Read through Table A, the list of Hazardous Air Pollutants (HAP) and check one of the following: No, my facility does not currently emit any pollutants from the list, and therefore is not subject to the requirements for NESHAP for Source Categories. Go to question 7. Yes, my facility does emit one or more pollutants from the list. Go on to question 2a.

2a) Does your source have the potential to emit 10 tons per year or more of any single pollutant listed in Table A? Yes, my facility is a major source of HAP emissions. Go to question 3. No. Go to question 2b.

2b) Does your source have the potential to emit 25 tons per year or more of any combination of pollutants listed in Table A? Yes, my facility is a major source of HAP emissions. Go to question 3. No. Go to question 6.

3) If you answered yes to question 2a or 2b, it may be possible to avoid the requirements associated with being a major source of HAP emissions. If the actual emissions of HAPs from your facility will not exceed 10 tons per year of a single HAP or 25 tons per year of all HAPs combined during each of the next five years, you may propose federally enforceable permit conditions to limit your potential HAP emissions to less than 10 tons per year for each HAP and/or 25 tons per year for all HAPs combined. Do you want to accept permit limitations on HAPs to avoid being a major source of HAPs?

No. Go to question 4. Yes. Briefly describe the limitations you would be willing to accept and abide by in your permit so that your HAP emissions will not exceed 10 tons per year for each HAP and 25 tons per year for all HAPs combined (use separate sheet if needed). Description must include each of the HAP pollutants. Refer to the Application General Instructions for guidance in establishing these limitations, and include your proposed limit, monitoring, recordkeeping, and reporting on Form CD-01. Your facility may be subject to NESHAP for Source Categories requirements until you receive a federally enforceable permit limiting your facility’s HAP emissions to a nonmajor source. When you return to form GI-09 Requirements, you must answer “YES” to question 1b. To determine whether your facility is subject to NESHAP for nonmajor sources, go to question 6. Limit HAP usage at the spray booth (SV006) such that each individual HAP PTE is 9.0 tpy and combined HAP PTE is 24.0 tpy (for the spray booth). Control HAP emissions with a thermal oxidizer with an overall efficiency of 54%. 4) The attached Table B is a list of NESHAP for Source Categories and important dates associated with each of them. Does your facility have any equipment that fits any of the source categories listed?

No. Go to question 6. Yes. List all the source categories applicable to your facility, and the associated dates shown in Table B.

5) If you answered no to question 3 and yes to question 4, please read all applicable sections of 40 CFR pt. 63 to determine all applicable requirements in each of the NESHAP for Source Categories. When you return to form GI- 09 Requirements, you must answer “YES” to question 1b.

6) If your source has any equipment that belongs to the following area source categories, place a check in the box next to that category and read the specified NESHAP for Source Categories to determine all applicable requirements for area sources. The rules for these source categories may apply whether or not your facility is considered a major source for hazardous air pollutants. If you check one or more boxes below, you must answer “YES” to question 1b when you return to form GI-09 Requirements. Go on to question 7.

Hard and Decorative Chromium Electroplating (40 CFR pt. 63, subp. N) Chromium Anodizing Tanks (40 CFR pt. 63, subp. N) Ethylene Oxide Commercial Sterilization and Fumigation Operations (40 CFR pt. 63, subp. O) Perchloroethylene Dry Cleaning Facilities (40 CFR pt. 63, subp. M) Secondary Lead Smelting Facilities (40 CFR pt. 63, subp. X) Halogenated Solvent Degreasers (40 CFR pt. 63, subp. T)

7) Does this permit application seek authorization to construct or reconstruct a major source of HAP (10 tpy or more of any pollutant listed on Table A, or 25 tpy or more of any combination of pollutants listed in Table A)?

Yes. Go on to question 8. No. Return to form GI-09 Requirements and answer “NO” to question 1c.

8) Is your proposed project subject to any of the promulgated standards as listed in Table B?

Yes, my facility is subject to the preconstruction review requirements under its MACT standard and to the General Provisions of the MACT standard. Return to form GI-09 Requirements and answer “YES” to question 1b and “NO” to question 1c. No, my facility may be subject to preconstruction review requirements under section 112(g)(2)(B). Go to question 9. 9) If you answered “No” to question 8, it may be possible to avoid the section 112(g)(2)(B) requirement of performing a case-by-case MACT determination for your proposed project by proposing a federally enforceable permit conditions to limit your potential HAP emissions to less than 10 tons per year for each HAP and/or 25 tons per year for all HAPs combined from the new proposed project. Do you want to accept permit limitations on HAPs to avoid the section 112(g)(2)(B) requirement?

No. Go to question 10. Yes. Briefly describe the limitations you would be willing to accept and abide by in your permit so that your HAP emissions will not exceed 10 tons per year for each HAP and 25 tons per year for all HAPs combined (use separate sheet if needed). Description must include all the HAP pollutants. Refer to the Application General Instructions for guidance in establishing these limitations, and include your proposed limit, monitoring, recordkeeping, and reporting on Form CD-01. Your facility may be subject to NESHAP for Source Categories requirements until you receive a federally enforceable permit limiting your facility’s HAP emissions from the proposed project to below the major source thresholds. When you return to form GI-09 Requirements, you must answer “YES” to question 1c.

10) If you answered “No” to question 8 and “No” to question 9, please read 40 CFR § 63.43 to 63.44 to determine all applicable requirements, including application requirements for a case-by-case MACT determination and what is required for your facility when a subsequent MACT standard for your facility is promulgated. When you return to form GI-09 Requirements, you must answer “YES” to question 1c.

11) Return to form GI-09 Requirements, and answer questions 1b and 1c using the above information. TABLE A Hazardous Air Pollutants

A 121697 N,N-Diethyl aniline (N,N- Dimethylaniline) 64675 Diethyl sulfate 119904 3,3-Dimethoxybenzidine 75070 Acetaldehyde 60117 Dimethyl aminoazobenzene 60355 Acetamide 119937 3,3-Dimethyl benzidine 75058 Acetonitrile 79447 Dimethyl carbamoyl chloride 98862 Acetophenone 68122 Dimethyl formamide 53963 2-Acetylaminofluorene 57147 1,1 Dimethyl hydrazine 107028 Acrolein 131113 Dimethyl phthalate 79061 Acrylamide 77781 Dimethyl Sulfate 79107 Acrylic acid 534521 4,6-Dintro-o-cresol, and salts 107131 Acrylonitrile 51285 2,4-Dinitrophenol 107051 Allyl chloride 121142 2,4-Dinitrotoluene 92671 4-Aminobiphenyl 123911 1,4-Dioxane (1.4-Diethyleneoxide) 62533 Aniline 122667 1,2-Diphenylhydrazine 90040 o-Anisidine 1332214 Asbestos E B 106898 Epichlorohydin (1-Chloro-2,3-epoxypropane) 106887 1,2-Epoxybutane 71432 Benzene 140885 Ethyl acrylate 92875 Benzidine 100414 Ethyl benzene 98077 Benzotrichloride 51796 Ethyl carbamate (Urethane) 100447 Benzyl chloride 75003 Ethyl chloride (Chloroethane) 92524 Biphenyl 106934 Ethylene dibromide (Dibromoethane) 117817 Bis (2-ethylhexyl) phthalate (DEHP) 107062 Ethylene dichloride (1,2- Dichloroethane) 542881 Bis (chloromethyl) ether 107211 Ethylene glycol 75252 Bromoform 151564 Ethylene imine (Aziridine) 106990 1,3-Butadiene 75218 Ethylene oxide 96457 Ethylene thiourea C 75343 Ethylidene dichloride (1,1-Dichloroethane) 156627 Calcium cyanamide F 133062 Captan 63252 Carbaryl 50000 Formaldehyde 75150 Carbon disulfide 56235 Carbon tetrachloride 463581 Carbonyl sulfide H 120809 Catechol 133904 Chloramben 76448 Heptacholor 57749 Chlordane 118741 Hexachlorobenzene 778505 Chlorine 87683 Hexachlorobutadiene 79118 Chloroacetic acid 77474 Hexachlorocyclopentadiene 532274 2-Chloroacetophenone 67721 Hexachloroethane 108907 Chlorobenzene 822060 Hexamethylene-1,6-diisocyanate 510156 Chlorobenzilate 680319 Hexamethylphosphoramide 67663 Chloroform 110543 Hexane 107302 Chloromethyl methyl ether 302012 Hydrazine 126998 Chloroprene 7647010 Hydrochloric acid 1319773 Cresols/Cresylic acid (isomers and mixture) 7664393 Hydrogen flouride (hydrofluoric acid) 95487 0-Cresol 123319 Hydroquinone 108394 m-Cresol 106445 p-Cresol I 98828 Cumene 78591 Isophorone D

94757 2,4-D, salts and esters L 3547044 DDE 334883 Diazomethane 58899 Lindane (all isomers) 132649 Dibenzofurans 96128 1,2-Dibromo-3-chloropropane 84742 Dibutylphthalate 106467 1,4-Dichlorobenzene(p) 91941 3,3'-Dichlorobenzidene 111444 Dichloroethyl ether (Bis(2-chloroethyl)either) 542756 1,3-Dichloropropene 62737 Dichlorvos 111422 Diethanolamine TABLE A Hazardous Air Pollutants

M S

108316 Maleic anhydride 100425 Styrene 67561 Methanol 96093 Styrene Oxide 72435 Methozychlor 74839 Methyl bromide (Bromomethane) T 74873 Methyl chloride (Choromethane) 71556 Methyl chloroform (1,1,1-Trichloroethane) 1746016 2,3,7,8-Tetrachlorodibenzo-p-dioxin 78933 Methyl ethyl ketone (2-Butanone) 79345 1,1,2,2-Tetrachloroene 60344 Methyl hydrazine 127184 Tetrachloroethylene (Perchloroethylene) 74884 Methyl iodide (Iodomethane) 7550450 Titanium tetrachloride 108101 Methyl isobutyl ketone (Hexone) 108883 Toluene 624839 Methyl isocyanate 95807 2,4-Toluene diamine 80626 Methyl methacrylate 584849 2,4-Toluene diisocyanate 1634044 Methyl tert butyl ether 95534 o-Toluidine 101144 4,4-Methylene bis (2-chloroaniline) 8001352 Toxaphene (chlorinated camphene) 75092 Methylene chloride (Dichloromethane) 120821 1,2,4-Trichlorobenzene 101688 Methlene diphenyl diisocyanate (MDI) 79005 1,1,2-Trichloroethane 101779 4,4'-methylenedianiline 79016 Trichloroethylene 95954 2,4,5-Trichlorophenol N 88062 2,4,6-Trichlorophenol 121448 Triethylamine 1582098 Trifluralin 91203 Naphthalene 540841 2,2,4-Trimethylpentane 98953 Nitrobenzene 92933 4-Nitrobiphenyl V 100027 4-Nitrophenol 79469 2-Nitropropane 684935 N-Nitroso-N-methylurea 108054 Vinyl acetate 62759 N-Nitrosodimethylamine 593602 Vinyl bromide 59892 N-Nitosomorpholine 75014 Vinyl chloride 75354 Vinylidene chloride (1,1-Dichloroethylene) P X 56382 Parathion 82688 Pentachloronitrobenzene (Quintobenzene) 1330207 Xylenes (isomers and mixtures) 87865 Pentachlorophenol 95476 o-Xylenes 108952 Phenol 108383 m-Xylenes 106503 p-Phenylenediamine 106423 p-Xylenes 75445 Phosgene 7803512 Phosphine 7723140 Phosphorus COMPOUNDS 85449 Phthalic anhydride 1336363 Polychlorinated biphenyls (aroclors) 0 Antimony compounds 1120714 1,3-Propane sultone 0 Arsenic compounds (inorganic including arsine) 57578 beta-Propiolactone 0 Beryllium compounds 123386 Propionaldehyde 0 Cadmium compounds 114261 Propoxur (Baygon) 0 Chromium compounds 78875 Propylene dichloride (1,2-Dichloropropane) 0 Cobalt compounds 75569 Propylene oxide 0 Coke oven emissions 75558 1,2-Propylenimine (2-Methyl aziridine) 0 Cyanide compounds 0 Glycol ethers Q 0 Lead compounds 0 Manganese compounds 0 Mercury compounds 91225 Quinoline 0 Mineral fibers 106514 Quinone 0 Nickel compounds 0 Polycyclic organic matter 0 Radionuclides 0 Selenium compounds TABLE B SOURCE CATEGORIES

Rule Promulgation Date Compliance Date for Categories of Major Sources or Scheduled Existing Sources Promulgation Date* (if applicable) (*date subject to change) Acetyl resins production (Polymers & Resins III) 7/99 Acrylic fibers/modacrylic fibers production 12/98 Acrylonitrile-butadiene-styrene production (Polymers and Resins IV) 9/12/96 3/12/97 can filling facilities (may be delisted) 11/15/2000 Aerospace industries surface coating 9/1/95 9/1/98 Alkyd resins production (Miscellaneous organic NESHAP) 11/15/2000 Alumina processing 11/15/2000 Amino resins production (Polymers and Resins III) 7/99 Ammonium sulfate production 11/15/2000 Antimony oxides manufacturing 11/15/2000 Asphalt/coal tar application - metal pipes 11/15/2000 Asphalt concrete manufacturing 11/15/2000 Asphalt processing 8/99 Asphaltic roofing manufacturing 8/99 Auto and light duty surface coating 11/15/2000

Baker's yeast manufacturing 6/99 Benzyltrimethylammonium chloride production 11/15/2000 (Miscellaneous organic NESHAP) Boat manufacturing 12/2000 Butadiene dimers production (Manufacturing of Tetrahydrobenzaldehyde) 2/98 Butadiene-furfural cotrimer (R-11) production 11/15/2000 Butyl rubber production (Polymers and Resins I) 9/5/96 3/5/97

Captafol production ( Active Ingredient Production) 3/99 Captan production (Pesticide Active Ingredient Production) 3/99 Carboxymethylcellulose prod. 11/15/2000 (Miscellaneous Cellulose MACT) Carbonyl sulfide production 11/15/2000 (Miscellaneous organic NESHAP) Cellophane production 11/15/2000 (Miscellaneous Cellulose MACT) Cellulose ethers production 11/15/2000 (Miscellaneous Cellulose MACT) Cellulose food casing manufacturing 11/15/2000 (Miscellaneous Cellulose MACT) Chelating agents production 11/15/2000 (Miscellaneous organic NESHAP) Chlorinated paraffins production 11/15/2000 (Miscellaneous organic NESHAP) Rule Promulgation Date Compliance Date for Categories of Major Sources or Scheduled Existing Sources Promulgation Date (if applicable) 4-chloro-2-methylphenoxyacetic acid production (Pesticide Active Ingredient Production) 3/99 Chloroneb production (Pesticide Active Ingredient Production) 3/99 Chlorothalonil production (Pesticide Active Ingredient Production) 3/99 Chromic acid anodizing 1/25/95 1/25/97 Chromium refractories production 5/2000 Clay products manufacturing 11/15/2000 Coke by-product plants (see 40 CFR part 61, subp. L) n/a Coke ovens: charging, top side, and door leaks 10/27/93 11/15/93 Coke ovens: pushing, quenching and battery stacks 11/15/2000 Commercial dry cleaning (Perc) transfer machines 9/22/93 12/20/93 Commercial sterilization facilities 12/2/94 12/6/98 Cyanuric chloride production (Cyanide Chemical Production) 11/2000

2,4- salts and esters production (Pesticide Active Ingredient Production) 3/99 Dacthal production (Pesticide Active Ingredient Production) 3/99 Decorative chromium electroplating 1/25/95 1/25/98 4,6,-dinitro-o-cresol production (Pesticide Active Ingredient Production) 3/99 Dodecanedioic acid production 11/15/2000 Dry cleaning (Petroleum solvent) 11/15/2000

Engine test facilities 11/15/2000 Epichlorohydrin elastomers production (Polymers and Resins I) 9/5/96 3/5/97 Epoxy resins production (Polymers and Resins II) 3/8/95 3/3/98 Ethylene-propylene rubber production (Polymers and Resins I) 9/5/96 3/5/97 Ethylidene norbornene production (Miscellaneous organic NESHAP) 11/15/2000 Explosives production (Miscellaneous organic NESHAP) 11/15/2000 Ethylene Processes 11/99

Ferroalloys production 8/98 Flat wood paneling surface coating 11/15/2000 Flexible polyurethane foam production 6/98 Fume silica production 11/15/2000

Gasoline distribution 12/14/94 12/15/97

Halogenated solvent cleaners 12/2/94 12/2/97 Hard chromium electroplating 1/25/95 1/25/97 Rule Promulgation Date Compliance Date for Categories of Major Sources or Scheduled Existing Sources Promulgation Date (if applicable) Hazardous waste incineration 11/15/2000 Hydrazine production 11/15/2000 (Miscellaneous organic NESHAP) Hydrochloric acid production 11/15/2000 Hydrogen cyanide production 11/15/2000 (Cyanide Chemical Production) Hydrogen fluoride production 12/98 Hypalon production (Polymers and Resins I) 9/5/96 3/5/97

Industrial boilers 11/15/2000 (Industrial Combustion Coordinating Rule) Industrial dry cleaning (Perc) dry-to-dry machines 9/22/93 12/20/93 Industrial dry cleaning (Perc) transfer machines 9/22/93 12/20/93 Industrial process cooling towers 9/8/94 3/8/96 Institutional/commercial boilers 11/15/2000 (Industrial Combustion Coordinating Rule) Integrated iron and steel manufacturing 11/15/2000 Iron foundries 11/15/2000

Large appliance surface coating 11/15/2000 Lead acid battery manufacturing 11/15/2000 Lime manufacturing 11/15/2000

Magnetic tape surface coating 12/15/94 12/15/96 Maleic anhydride copolymers production 11/15/2000 (Miscellaneous organic NESHAP) Manufacture of paints, coating and adhesives 11/15/2000 (Miscellaneous organic NESHAP) Marine vessel unloading and loading 9/19/95 9/19/99 Metal can surface coating 11/15/2000 Metal coil surface coating 11/15/2000 Metal furniture surface coating 11/15/2000 Methylcellulose production 11/15/2000 (Miscellaneous Cellulose MACT) Methyl methacrylate-acrylonitrile-butadiene-styrene production 9/12/96 3/12/97 (Polymers and Resins IV) Methyl methacrylate-butadiene-styrene terpolymers production 9/12/96 3/12/97 (Polymers and Resins IV) production 4/98 Miscellaneous metal parts and products s.c. 11/15/2000

Neoprene production (Polymers and Resins I) 9/5/96 3/5/97 Nitrile butadiene rubber prod. (Polymers and Resins I) 9/5/96 3/5/97 Non-nylon polyamides production 3/8/95 3/3/98 (Polymers and Resins I)

Oil and natural gas production 4/98 Rule Promulgation Date Compliance Date for Categories of Major Sources or Scheduled Existing Sources Promulgation Date (if applicable) Organic liquids distribution (non-gasoline) 11/15/2000 Oxybisphenoxarsine (OBPA)/1,3-diisocyanate production 11/15/2000 (Miscellaneous organic NESHAP)

Paper and other webs surface coating 11/15/2000 Paint stripper users 11/15/2000 Petroleum refineries - catalytic cracking (fluid and other) units, catalytic reforming units, and sulfur plant units 11/98 Petroleum refineries - Other sources not distinctly listed 8/18/95 8/18/98 Pharmaceuticals production 4/98 Phenolic resins production 7/99 (Polymers and Resins I) Phosphate fertilizers production 2/98 Phosphoric acid manufacturing 2/98 Photographic chemicals production 11/15/2000 (Miscellaneous organic NESHAP) Phthalate plasticizers production 11/15/2000 (Miscellaneous organic NESHAP) Plastic parts and products surface coating 11/15/2000 Plywood/particle board manufacturing 11/15/2000 Polyether polyols production 9/98 Polybutadiene rubber production (Polymers and Resins I) 9/5/96 3/5/97 Polycarbonates production 9/12/96 3/12/97 (Polymers and Resins IV) Polyester resins production 11/15/2000 (Miscellaneous organic NESHAP) Polyethylene terephthalate production 9/12/96 3/12/97 (Polymers and Resins IV) Polymerized vinylidene chloride production 11/15/2000 (Miscellaneous organic NESHAP) Polymethyl methacrylate resins production 11/15/2000 (Miscellaneous organic NESHAP) Polystyrene production 9/12/96 3/12/97 (Polymers and Resins IV) Polysulfide rubber production (Polymers and Resins I) 9/5/96 3/5/97 Polyvinyl alcohol production 11/15/2000 (Miscellaneous organic NESHAP) Polyvinyl butyral production 11/15/2000 (Miscellaneous organic NESHAP) Polyvinyl chloride and copolymers production 11/15/2000 Portland cement manufacturing 9/98 Primary aluminum production 9/19/97 Primary copper smelting 6/98 Primary lead smelting 8/98 Primary magnesium refining 5/2000 Printing, coating, and dyeing of fabrics 11/15/2000 Printing/publishing surface coating 5/30/96 5/30/99 Process heaters 11/15/2000 (Industrial Combustion Coordinating Rule) Rule Promulgation Date Compliance Date for Categories of Major Sources or Scheduled Existing Sources Promulgation Date (if applicable) Publicly owned treatment works 5/98 Pulp and paper production (con-combust) 11/14/97 Pulp and paper production (combust) 7/98 Pulp and paper production (con-chemical) 11/97

Quaternary ammonium compounds production 11/15/2000

Rayon production 11/15/2000 (Miscellaneous Cellulose MACT) Reinforced plastic composites production 11/2000 Rocket engine test firing 11/15/2000 Rubber chemicals manufacturing 11/15/2000 (Miscellaneous organic NESHAP)

Secondary aluminum prod. 3/99 Secondary lead smelting 6/23/95 6/23/97 Semiconductor manufacturing 11/15/2000 sludge incineration 11/15/2000 Shipbuilding and ship repair surface coating 12/15/95 12/16/97 Site remediation 11/15/2000 Sodium cyanide production 11/15/2000 (Cyanide Chemical Production) Sodium pentachlorophenate production (Pesticide Active Ingredient Production) 3/99 Off-site Waste Treatment Facilities 7/1/96 7/10/99 Spandex production 11/15/2000 Stationary internal combustion engines 11/15/97 (Industrial Combustion Coordinating Rule) Stationary turbines 11/15/2000 (Industrial Combustion Coordinating Rule) Steel foundries 1/15/2000 Styrene-acrylonitrile production 9/12/96 3/12/97 (Polymers and Resins IV) Styrene-butadiene rubber and latex production (Polymers and Resins I) 9/5/96 3/5/97 Symmetrical tetrachloropyridine production 11/15/2000 (Miscellaneous organic NESHAP) Synthetic organic chemical manufacturing 4/22/94 10/24/94

Taconite iron ore processing 11/15/2000 production (Rubber Tire Production) 12/99 Tordon acid production (Pesticide Active Ingredient Production) 3/99

Uranium hexafluoride production 11/15/2000 Vegetable oil production 11/15/2000 Wood furniture surface coating 12/7/95 11/21/97, 12/7/98 Wool fiberglass manufacturing 3/98 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-09B 520 LAFAYETTE ROAD REQUIREMENTS: NESHAP ST. PAUL, MN 55155-4194 (40 CFR pt. 61) 05/11/98 National Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR pt. 61)

1) Part 61 NESHAPs were the regulations in existence before the 1990 Clean Air Act Amendments. They apply only to air emission sources listed in Table C (attached) that emit the pollutants listed. Table C contains:

- a pollutant; - a facility description; - a Minnesota Rules reference; - a Code of Federal Regulation 40 part 61 (40 CFR pt. 61) subpart reference.

2) Read through Table C. If your facility emits any of the listed pollutants, and your facility type, process or equipment matches those associated with the pollutant, a NESHAP may apply to you. To determine if a standard applies to your facility, refer to the corresponding 40 CFR pt. 61 subpart(s) and Minnesota Rules listed and read the requirements in detail.

3) After reviewing the NESHAP reference list and reading the corresponding 40 CFR pt. 61 subpart(s) check one of the following boxes: NO, my facility is not subject to NESHAP requirements. Return to form GI-09 Requirements, and answer “NO” to question 2b. YES, my facility (or a portion of it) is subject to NESHAP requirements. Answer “YES” to question 2b when you return to form GI-09 Requirements.

If you have determined that your facility must comply with federal NESHAP requirements, you are also subject to state NESHAP requirements. Minn. R. ch. 7011 lists Minnesota State NESHAP requirements.

4) Check and complete the following questions (4a, 4b, and 4c). Some NESHAPs apply to an entire mine, plant or shop. Others apply to specific units, like a reactor, valve or vessel. If you check 4c, you must complete a group of questions for each emission unit subject to a NESHAP. Attach additional pages as necessary to identify all emission units subject to NESHAP at your facility. Photocopy each 40 CFR pt. 61 subpart you have listed (except the Asbestos NESHAP), highlight the portions of the subpart that directly applies to your facility, and attach the copies to this application form.

4a) My business is only subject to the NESHAP for the Demolition and Renovation of Asbestos containing structures identified in 40 CFR § 61.145; I do not need an Air Emission Permit. I have contacted the MN Department of Health and the asbestos team at the MN Pollution Control Agency regarding any renovation or demolition projects and have obtained an asbestos abatement permit if necessary. (For more information refer to Minn. Rules 7007.0300, subp. 1.C.)

4b) My entire facility is subject to NESHAP requirements.

Describe Emission Facility Date of Facility Construction Applicable 40 CFR pt. 61 subparts(s) Applicable Minnesota State Rule Reference Has this Source Been Permitted Previously? NO YES, list Air Emission Permit Number 4c) My facility has one or more emission unit(s) subject to NESHAP requirements. Provide the information requested below for each unit that is subject to a NESHAP.

Describe Emission Equipment Emission Unit Number Stack/Vent Number Date of Original Equipment Installation (Month/Date/Year) Applicable 40 CFR pt. 61 subpart(s) Applicable Minnesota State Rule Reference Has this Unit Been Permitted Previously? NO YES, list Air Emission Permit Number

Describe Emission Equipment Emission Unit Number Stack/Vent Number Date of Original Equipment Installation (Month/Date/Year) Applicable 40 CFR pt. 61 subpart(s) Applicable Minnesota State Rule Reference Has this Unit Been Permitted Previously? NO YES, list Air Emission Permit Number

Describe Emission Equipment Emission Unit Number Stack/Vent Number Date of Original Equipment Installation (Month/Date/Year) Applicable 40 CFR pt. 61 subpart(s) Applicable Minnesota State Rule Reference Has this Unit Been Permitted Previously? NO YES, list Air Emission Permit Number

5) Return to form GI-09 Requirements, question 2b. TABLE C NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS

POLLUTANT FACILITY OR EMISSION UNIT TYPE MINN 40 CFR 61 RULES SUBPART RADON Underground Uranium Mines; Department of Energy Facilities; 7011.9960 B, Q, R, T, W Phosphorus Fertilizer Plants; and Facilities Processing or Disposing of Uranium Ore and

BERYLLIUM Beryllium Extraction Plants; Ceramic Plants, Foundries, 7011.9940 - C, D Incinerators, Propellant Plants, and Machine Shops that Process 7011.9945 Beryllium Containing Material; and Rocket Motor Firing Test Sites

MERCURY Mercury Ore Processing; Manufacturing Processes Using 7011.9950 - E Mercury Chloralkali Cells; and Sludge Incinerators 7011.9955

VINYL Ethylene Dichloride Manufacturing Via Oxygen, HCl and 7011.9980 F CHLORIDE Ethylene; Vinyl Chloride Manufacturing; and Polyvinyl Chloride Manufacturing

RADIO- Department of Energy; Nuclear Regulatory Commission 7011.9970 H, I, K NUCLIDES Licensed Facilities; Other Federal Facilities; and Elemental Phosphorus Plants

BENZENE Fugitive Process, Storage, and Transfer Equipment Leaks; Coke 7011.9930 J, L, Y, BB, By-Product Recovery Plants; Benzene Storage Vessels; Benzene FF Transfer Operations; and Benzene Waste Operations

ASBESTOS* Asbestos Mills; Roadway Surfacing with Asbestos Tailings; 7011.9920 - M Manufacture of Products Containing Asbestos; Demolition; 7011.9927 Renovation; and Spraying and Disposal of Asbestos Waste

INORGANIC Glass Manufacturer; Primary Copper Smelter; Arsenic Trioxide 7011.9910 N, O, P ARSENIC and Metallic Arsenic Production Facilities

VOLATILE Pumps, Compressors, Pressure Relief Devices, Connections, 7011.9990 V HAZARDOUS Valves, Lines, Flanges, Product Accumulator Vessels, etc. in AIR VHAP Service POLLUTANTS (As of 11/30/94 only vinyl chloride and benzene are regulated by (VHAP) 40 CFR 61, subp. V)

*If you are only subject to 40 CFR §61.145 (subp. M Standard for Demolition and Renovation), because you are doing asbestos abatement, you do not need a Minnesota Air Emission Permit, but you must contact the Minnesota Department of Health at (612) 627-5097 and the asbestos team at the Minnesota Pollution Control Agency at (651) 297-8685 before beginning any abatement activity.

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-09C 520 LAFAYETTE ROAD REQUIREMENTS: ST. PAUL, MN 55155-4194 NEW SOURCE REVIEW (40 CFR pt. 52) 05/11/98 New Source Review (NSR; 40 CFR pt. 52)

Throughout this form you are asked for the Potential to Emit (PTE) of your facility or of changes to your facility. The PTE values in most cases are defined as the maximum uncontrolled PTE of the emission facility. In some cases, PTE calculations may reflect factors such as control equipment or permit limitations, but ONLY if proof is given that such factors were provisions of a federally enforceable permit issued to the facility.

New Source Review (NSR) regulations may apply to modifications to existing facilities or for the construction of a new facility. There are two kinds of review: one for nonattainment areas and one for attainment areas. For a nonattainment pollutant, if the potential to emit is more than 100 tons per year, New Source Review could apply. For attainment areas, the threshold is 100 or 250 tons per year depending on the type of facility.

This form is rather complex, but addresses a complicated regulatory program. Each item is intended to assist you in the process of determining applicability as easily and quickly as possible. Items 1-3 will help you determine the threshold -- a federally established pollutant level -- for your facility. The next two items, 4 and 5, determine if, based on your current PTE, you are considered a major stationary source. If your facility is not a major source now, item 6 asks if it was major in the past. Item 7 determines if you can accept "synthetic minor" limitations, while item 8 requires you to specify what these limitations would be.

It may be possible for sources that were major to become synthetic minor facilities. Items 9-10 are basic criteria questions that need to be answered. Sources who wish to pursue this option will need to work closely with MPCA staff to determine if the facility does qualify for the synthetic minor status. Items 11, 12, and 13 determine if you constructed a major facility. Item 14 requires a description of each change (physical or operational) made at your facility after it actually began emitting pollutants at a rate higher than your threshold. A detailed description is required for each change, including dates and emission levels through today. If necessary and/or allowed, item 14f requires you to specify "synthetic minor" limitations for just the change. Item 14 must be filled out separately for each change made, requiring duplication of those two pages. Item 15 directs specific sources to contact the MPCA for further guidance. 1) Is your facility defined as one of the following, (Some SIC Code(s) applying to specific categories are given in parentheses):

Coal Cleaning Plants-With Thermal Dryers Kraft Pulp Mills (2611, 2621) Portland Cement Plants (3241) Primary Zinc Smelters (3339) Iron and Steel Mills (332X) Primary Aluminum Ore Reduction Plants (3334) Primary Copper Smelters (3331) Municipal Incinerators Capable of Charging More Than 250 Tons of Refuse per Day Hydrofluoric Acid Plants (2819, 2899) Sulfuric Acid Plants (2819) Nitric Acid Plants (2873) Petroleum Refineries (2911) Lime Plants (3274) Phosphate Rock Processing Plants (1475) Coke Oven Batteries (3312) Sulfur Recovery Plants (2819) Carbon Black Plants (Furnace Process, 2895) Primary Lead Smelters (3339) Fuel Conversion Plants Sintering Plants* Secondary Metal Production Plants (334X) Chemical Process Plants (28XX) Fossil-Fuel Boilers (or combination thereof) totaling Petroleum Storage & Transfer Units, Total Storage more than 250 MMBtu/hr Capacity over 300,000 Barrels Taconite Ore Processing Plants (1011) Glass Fiber Processing Plants Charcoal Production Plants (2819, 2861) Fossil Fuel-Fired Steam Electric Plants of more than 250 MMBtu/hr * Processing of fine grain materials into coarser lumps (performed primarily on ores).

NO, my facility is not classified as one of the 28 sources listed above. Go to item 2. YES, my facility is classified as one of the 28 sources listed above. An air emission source having PTE (potential to emit) more than 100 TPY (tons per year) of any single regulated pollutant is considered a major stationary source. For the rest of this form, 100 TPY is the threshold you must use in answering the questions. Go to item 4.

2) Is your facility located in a nonattainment area (see form GI-01 Facility Information, question 14)? NO. Go to item 3. YES. Check all of the following pollutants that apply:

PM10 SO2 CO

An air emission source having the potential to emit more than 100 TPY of any pollutant(s) checked above, or 250 TPY of any single regulated pollutant not checked above is considered a major stationary source. For the rest of this form, 100 TPY is the threshold for any pollutant(s) checked above, and 250 TPY is the threshold for the remaining regulated pollutants. You must use these values in answering the remaining questions. Go to item 4.

3) I answered NO to items 1 and 2; my facility is not one of the 28 sources listed and my facility is not located in a non- attainment area. An air emission source having the potential to emit of more than 250 TPY of any single regulated pollutant is considered a major stationary source. For the rest of this form, 250 TPY is the threshold you must use in answering the questions. 4) In the boxes below, enter the current PTE (in tons per year) of your entire facility under each regulated pollutant. (“Current PTE” means the PTE of your facility prior to receiving the permit for which you are now applying.)

PM (includes PM10 PM10)SO2 NOX VOC CO Pb Fluorides

183.7 185.2 213.8 28.9 337.7 60.2 0.4 0

Total Reduced reduced sulfur MWC MSW Ozone- Sulfuric sulfur compounds MWC MWC acid depleting Acid Mist H2S (includes (includes organics metals gases gases substances H2S) H2S)

000 0 0 00 0 0

5) Is the current PTE of your facility above the 100/250 TPY threshold for your facility, making your facility a major stationary source? YES. My facility is currently considered a major stationary source, go to question 7. NO. Go to question 6.

6) Since August 7, 1980, has the PTE of your facility ever exceeded your 100/250 TPY threshold value? YES. Go to question 7. NO. My facility is not subject to NSR until I make a qualifying change. Return to form GI-09 Requirements and answer “NO” to question 3b.

[Note: If you do not know what the PTE of your facility has been in the past, it is sufficient for the purposes of this question only to use the following formula to roughly estimate PTE:

(8760 hours/year) x (actual emissions of a pollutant for a given year in tons/year)/(the number of hours of operation for that year).

Again, this formula cannot be used for any other purpose. This is only a screening test, it does not represent the required PTE calculation method for air permitting.

7) Since August 7, 1980, have the actual emissions from your facility ever exceeded the 100/250 TPY threshold value for your facility? YES. Go to item 9. NO. My facility is allowed to accept federally enforceable permit limitations to limit potential emissions to less than a major source (below the threshold). Go to question 8. 8) The actual emissions from your facility have never exceeded the 100/250 TPY threshold established for your facility. Would you be willing to accept federally enforceable permit limitations to limit potential emissions from your facility to less than the 100/250 TPY threshold? NO. Go to item 11. YES. You are required to specify limitations (called synthetic minor limits) for your facility. These limitations will limit your air emissions. This will be dependent on your emission sources and can have some flexibility. Briefly describe what limitations you would be willing to accept and abide by. Refer to the Application General Instructions for guidance in establishing these limitations. Include the specific limits, monitoring, recordkeeping, and reporting on Form CD-01.

Will remove the wood-fired boiler. Will not burn residual oil in Boiler #2. Will not burn distillate oil exceeding 0.5% sulfur content. Will maintain a 54% control efficiency for VOCs at the spray booth. Will maintain a maximum grain loading at SV003, SV004, and SV005 of 0.02 gr/dscf, by always operating the baghouses.

(DUPLICATE THIS FORM OR ADD EXTRA PAGES AS NEEDED)

Return to form GI-09 Requirements, question 3b, and check Unknown.

9) Have you removed any equipment from your facility since the actual emissions exceeded the 100/250 TPY threshold? NO. Go to question 11. YES. Go to question 10.

10) Have the actual emissions from the facility remained under the 100/250 TPY threshold for the last two years? NO. Go to question 11. YES. It may be possible to obtain a synthetic minor permit for your facility. Complete the remaining items in this form and contact the MPCA for further guidance as listed in item 15.

11) Did you construct your facility after August 7, 1980? NO. Go to question 14. YES, construction on my facility began on (date) _. The PTE of my facility (in tons per year) when constructed was:

PM (includes PM10 PM10)SO2 NOX VOC CO Pb Fluorides

Total Reduced reduced sulfur MWC MSW Ozone- Sulfuric sulfur compounds MWC MWC acid landfill depleting Acid Mist H2S (includes (includes organics metals gases gases substances H2S) H2S)

12) Are any of the PTE values entered in question 11 greater than the 100/250 TPY threshold for your facility? NO. Go to question 14. YES. Go to question 13. 13) Have the actual emissions for the operations installed during the facility’s construction ever exceeded the 100/250 TPY threshold for any year after the construction date? NO. Go to question 14. YES. My facility was a major source when it was constructed. If a BACT/LAER analysis was not done at the time of construction, the facility may be subject to backward looking NSR (if the analysis was not done at the time of construction but has been done since, it may not be necessary to repeat it). Contact the Permit Technical Advisor at (651)282-5844 or (800)646-6247 for additional guidance. Go to question 14.

14) NSR groups changes made during the same budget or planning period as a single modification. This means that changes need to be grouped together based on budgeting or planning periods and evaluated as one modification to determine if NSR/PSD applies to the changes that have been made.

Items 14a through 14g need to be completed for each modification made at your facility, through the current date (include any modifications you are proposing in this application, too). Begin with the first modification after the PTE of your facility exceeded the 100/250 TPY threshold or the first modification made after August 7, 1980, whichever is later. DO NOT INCLUDE modifications which were authorized by a permit from the MPCA. Duplicate and add additional pages as necessary. (Note: if your facility was under the 100/250 TPY threshold and the first modification you made was over 100/250 TPY, provide the information listed in items 14a, b, c, d, e, and f on a separate sheet of paper.) If you have not modified your facility since meeting the 100/250 TPY threshold, go to form GI-09 Requirements, question 3b, and answer “NO.”

14a) Describe the physical change in or change in method of operation to your facility:

14b) In what year(s) did the modification occur? ______

14c) List the potential emissions increase (in tons per year) of each pollutant for this modification.

PM (includes PM10 PM10)SO2 NOX VOC CO Pb Fluorides

Total Reduced reduced sulfur MWC MSW Ozone- Sulfuric sulfur compounds MWC MWC acid landfill depleting Acid Mist H2S (includes (includes organics metals gases gases substances H2S) H2S)

14d) Are the values you entered in item 14c for this modification greater than the values listed in item 14e for each regulated pollutant? NO. This was a minor change, go to question 14g. YES. Go to question 14e.

14e) Beginning with the year entered in item 14b through the current date, did the actual emissions of regulated pollutants resulting only from this modification ever exceed the values listed in the following table? Threshold Pollutant Effective Date (tons/year) PM10 15 July 31, 1987 PM 25 August 7, 1980 SO2 40 August 7, 1980 NOX 40 August 7, 1980 VOC 40 August 7, 1980 CO 100 August 7, 1990 Pb 0.6 August 7, 1980 Fluorides 3 August 7, 1980 Sulfuric Acid Mist 7 August 7,. 1980 H2S 10 August 7, 1980 Total reduced sulfur 10 August 7, 1980 Reduced sulfur compounds 10 August 7, 1980 MWC organics 3.5 x 10-6 August 12, 1991 MWC metals 15 August 12, 1991 MWC acid gases 40 August 12, 1991 MSW landfill gases 50 March 12, 1996 Ozone depleting substances 100 March 19, 1998 (EPA memo)

YES. This modification is subject to backward looking NSR, unless a BACT/LAER analysis was done at the time of modification. (If analysis was not done at the time of modification, but has been done since then, it may not be necessary to repeat it.) Contact the Permit Technical Advisor at (651)282-5844 or (800)646-6247 for additional guidance. NO. Go to question 14f.

14f) The actual emissions from this modification have never exceeded the levels listed in item 14e. Are you willing to accept federally enforceable permit limitations to limit the potential emissions increase of the modification to less than those levels? NO. Go to item 14g. YES. You are required to specify limitations (called “synthetic minor” limits) for this change. These limits will limit your air emissions to below the levels listed in item 14e. This will be dependent on your emissions sources and can have some flexibility. Briefly describe what limitations you would be willing to accept and abide by. Refer to the Application General Instructions for guidance in establishing these limitations. Include the specific limits, monitoring, recordkeeping, and reporting on Form CD-01.

(DUPLICATE THIS FORM OR ADD EXTRA PAGES AS NEEDED)

Go to item 14g. 14g) Repeat item 14 until each non-permitted physical change or change in method of operation to your facility has been identified, duplicating item 14 as necessary. 15) It may be possible to accept synthetic minor permit limitations if your actuals have exceeded the threshold levels, if you have removed equipment and the actual emissions for the last two calendar years of operation have remained under the threshold levels. You should contact the MPCA for more guidance on whether your facility qualifies for synthetic minor limitations. If you have triggered NSR/PSD levels and cannot or choose not to accept synthetic minor limitations, you need to check YES to question 3b on Form GI-09 Requirements. If your facility has received permits for modifications or completed NSR/PSD reviews as requested by the MPCA, you should work with MPCA staff to determine the compliance status of your facility regarding NSR/PSD and establishing limits. MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-09D 520 LAFAYETTE ROAD REQUIREMENTS: NSPS (40 CFR pt. 60) ST. PAUL, MN 55155-4194 05/11/98

Standards of Performance for New Stationary Sources (NSPS, New Source Performance Standards, 40 CFR pt. 60)

1) NSPS are federal rules that define limits, testing and monitoring for certain specific emission units. These standards are proposed and promulgated in the Federal Register and published in the Code of Federal Regulations, title 40 part 60 (40 CFR pt. 60). Table D lists the standards promulgated through April 1998. Table D may not be complete if a new NSPS has been promulgated since this form was last revised. The table contains:

- a brief emission source description; - a corresponding 40 CFR pt. 60 subpart reference; - an effective date for all performance standards promulgated as of April 1998.

[Please note: the best way to keep up-to-date on NSPS regulations is through the EPA’s Web page (www.epa.gov) or the Federal Register since there can be a significant time lag between the date when a standard is proposed or promulgated and when it is finally published in the Code of Federal Regulations.]

2) Please read through the emission sources in Table D. If you have modified (as defined in 40 CFR § 60.14), reconstructed (as defined in 40 CFR § 60.15) or constructed the described emission source on or after the effective date listed in the table, your facility may be subject to the requirements of 40 CFR pt. 60. Generally, reconstruction means that the cost of a repair exceeds 50 percent of what it would cost to install a new emission unit. If you have had an extensive and expensive repair, it may count as a reconstruction.

If you know or suspect standards may apply to your facility you must refer to the corresponding 40 CFR pt. 60 subpart and read the requirements in detail to make a final determination. Note: the general provisions found in 40 CFR pt. 60, subp. A, apply to all facilities subject to any other NSPS requirements.

3) After you review the list of sources subject to NSPS and read any applicable 40 CFR pt. 60 subparts, check one of the following boxes: NO, my facility is not subject to NSPS. Return to Form GI-09 Requirements, and answer “NO” to question 5d. YES, my facility is subject to NSPS.

4) The following page lists information needed to identify your facility's emission sources subject to NSPS. Complete the group of questions for all emission equipment subject to NSPS, attaching additional pages if necessary. Photocopy each 40 CFR pt. 60 subpart you have listed and highlight the portions of each subpart that directly apply to your facility, including the general provisions found in Subpart A. Attach the copies to this application form.

The MPCA has reprinted Subpart A and some additional NSPS regulations from the Code of Federal Regulations. The available regulations are starred in Table D. To obtain copies, contact the Permit Document Coordinator at (651)282-5843.

5) Return to Form GI-09 Requirements, and answer “YES” to question 5d. Describe Emission Equipment Boiler Emission Unit Number 2 Stack/Vent Number 2 Date of Equipment Manufacture 3/1/91 (Month/Date/Year) Date of Equipment Installation 3/1/91 (Month/Date/Year) Date of Reconstruction (if applicable) na (Month/Date/Year) Date of Modification (if applicable) na (Month/Date/Year) Applicable 40 CFR pt. 60 subpart or Federal Register Reference Subpart Dc This source is also subject to the general provisions of 40 CFR pt. 60, subp. A. Has this Unit Been Permitted Previously? NO YES, list Air Emission Permit Number Have you attached a photocopied, highlighted version of the 40 CFR pt. 60 subpart? YES NO

Describe Emission Equipment Emission Unit Number Stack/Vent Number Date of Equipment Manufacture (Month/Date/Year) Date of Equipment Installation (Month/Date/Year) Date of Reconstruction (if applicable) (Month/Date/Year) Date of Modification (if applicable) (Month/Date/Year) Applicable 40 CFR pt. 60 subpart or Federal Register Reference This source is also subject to the general provisions of 40 CFR pt. 60, subp. A. Has this Unit Been Permitted Previously? NO YES, list Air Emission Permit Number Have you attached a photocopied, highlighted version of the 40 CFR pt. 60 subpart? YES NO

Describe Emission Equipment Emission Unit Number Stack/Vent Number Date of Equipment Manufacture (Month/Date/Year) Date of Equipment Installation (Month/Date/Year) Date of Reconstruction (if applicable) (Month/Date/Year) Date of Modification (if applicable) (Month/Date/Year) Applicable 40 CFR pt. 60 subpart or Federal Register Reference This source is also subject to the general provisions of 40 CFR pt. 60, subp. A. Has this Unit Been Permitted Previously? NO YES, list Air Emission Permit Number Have you attached a photocopied, highlighted version of the 40 CFR pt. 60 subpart? YES NO

DUPLICATE THIS FORM AS NEEDED TABLE D STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES

Performance standards promulgated as of April 30, 1998 Source categories subject to federal performance 40 CFR 60 Effective date constructed, modified or standards Subpart reconstructed Fossil-Fuel Fired Steam Generators >250 MMBtu D After: 08/17/71 Electric Utility Steam Generators >250 MMBtu Da After: 09/18/78 Industrial-Commercial-Institutional Steam Generators Db* After: 06/19/84 >100 MMBtu Small Industrial-Commercial-Institutional Steam Dc* After: 06/09/89 Generators >10 MMBtu but <100 MMBtu Incinerators E After: 08/17/71 Hospital/Medical/Infectious Waste Incinerators Ec, Ce Initial Construction Municipal Waste Combustors Ea, Eb, Initial Construction Ca, Cb Portland Cement Plants F After: 08/17/71 Nitric Acid Plants G After: 08/17/71 Sulfuric Acid Plants H,Cd Initial Construction Asphalt Concrete Plants I* After: 06/11/73 Petroleum Refineries J After: 06/11/73 Storage Vessels for Petroleum Liquids K*, Ka* After: 06/11/73 Volatile Organic Liquid Storage Vessels (Including Kb* After: 07/23/84 Petroleum Liquids) Secondary Lead Smelters L After: 06/11/73 Secondary Brass and Bronze Production Plants M After: 06/11/73 Oxygen Process Furnaces N After: 06/11/73 Oxygen Process Steelmaking Facilities Na After: 01/20/83 Sewage Treatment Plants O After: 06/11/73 Primary Copper Smelters P After: 10/16/74 Primary Zinc Smelters Q After: 10/16/74 Primary Lead Smelters R After: 10/16/74 Primary Aluminum Reduction Plants S After: 10/23/74 Phosphate Fertilizer Industry T,U,V,W,X After: 10/22/74 Coal Preparation Plants Y After: 10/24/74 Ferroalloy Production Facilities Z After: 10/24/74 Steel Plants AA,AAa After: 10/21/74 Kraft Pulp Mills BB After: 09/24/76 Glass Manufacturing Plants CC After: 06/15/79 Grain Elevators DD* After: 08/03/78 Surface Coating of Metal Furniture EE* After: 11/28/80 Stationary Gas Turbines GG After: 10/03/77 Lime Manufacturing Plants HH After: 05/03/77 Cold Cleaning Machines JJ Promulgation expected in near future Lead-Acid Battery Manufacturing Plants KK After: 01/14/80 Metallic Mineral Processing Plants LL After: 08/24/82 Automobile and Light-Duty Truck Surface Coating MM After: 10/05/79 Operations Phosphate Rock Plants NN After: 09/21/79 Ammonium Sulfate Manufacture PP After: 02/04/80 TABLE D, continued

Source categories subject to federal performance 40 CFR 60 Effective date constructed, modified or standards Subpart reconstructed Graphic Arts Industry: Publication Rotogravure Printing QQ After: 08/28/80 Pressure Sensitive Tape and Label Surface Coating RR After: 12/30/80 Operations Industrial Surface Coating: Large Appliances SS After: 12/24/80 Metal Coil Surface Coating TT After: 01/05/81 Asphalt Processing and Asphalt Roofing Manufacture UU After: 11/18/80 Equipment Leaks of VOC in the Synthetic Organic VV* After: 01/05/81 Chemicals Manufacturing Industry Beverage Can Surface Coating Industry WW* After: 11/26/80 Bulk Gasoline Terminals XX* After: 12/17/80 New Residential Wood Heaters ** AAA After: 07/01/88 Rubber Tire Manufacturing Industry BBB After: 01/20/83 VOC Emissions from the Polymer Manufacturing DDD After: 09/30/87 Industry Flexible Vinyl and Urethane Coating and Printing FFF After: 01/18/83 Equipment Leaks of VOC in Petroleum Refineries GGG After: 01/04/83 Synthetic Fiber Production Facilities HHH After: 11/23/82 VOC Emissions from the Synthetic Organic Chemical III After: 10/21/83 Manufacturing Industry Air Oxidation Unit Processes Petroleum Dry Cleaners JJJ After: 12/14/82 Onshore Natural Gas Processing: VOC Equipment Leaks KKK, LLL After: 01/20/84 and SO2 Emissions VOC Emissions from Synthetic Organic Chemical NNN* After: 12/30/83 Manufacturing Industry Distillation Operations Nonmetallic Mineral Processing Plants (Including Sand OOO* After: 08/31/83 and Gravel Processing) Wool Fiberglass Insulation Manufacturing Plants PPP After: 02/07/84 VOC Emissions from Petroleum Refinery Wastewater QQQ After: 05/04/87 Systems VOC Emissions from the Synthetic Organic Chemical RRR* After: 06/29/90 Manufacturing Industry (SOCMI) Reactor Processes Magnetic Tape Coating Facilities SSS After: 01/22/86 Industrial Surface Coating: Surface Coating of Plastic TTT After: 01/08/86 Parts for Business Machines Calciners and Dryers in Mineral Industries UUU After: 04/23/86 Polymeric Coating of Supporting Substrates Facilities VVV After: 04/30/87 WWW, Cc Initial Construction * Reprinted versions of regulation available from the MPCA. Contact the Permit Document Coordinator at (651)282-5843 for copies. ** According to Minn. Rules Pt. 7007.0300, subp. 1(B), "any stationary source that would be required to obtain a permit solely because it is subject to Code of Federal Regulations, title 40, part 60, subp. AAA" is exempt from permitting. MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-09F 520 LAFAYETTE ROAD REQUIREMENTS: STRATOSPHERIC ST. PAUL, MN 55155-4194 OZONE PROTECTION (40 CFR pt. 82) 05/11/98 Stratospheric Ozone Protection (1990 Clean Air Act, as amended, Sections 601-618; 40 CFR pt. 82)

The 1990 Clean Air Act Amendments, Sections 601-618 and federal regulations located in 40 CFR pt. 82 regulate ozone depleting substances and requires a phase out of their use. Review the attached list of ozone depleting chemicals, Tables E and F. If you manufacture, sell, distribute or use any the chemicals in Tables E and F, then Sections 601-618 and 40 CFR pt. 82 apply to your facility. Please read Sections 601-618 and 40 CFR pt. 82 to determine all the requirements that apply to your facility.

1) After reviewing Table F check one of the following: NO, my facility does not manufacture, sell, distribute or use any chemicals from the list, and the 1990 Clean Air Act, as amended, Sections 601-618 do not apply to my facility. Return to Form GI-09 Requirements, question 7b. YES, my facility does manufacture, sell, distribute or use one or more of the chemicals from the list. Go to question 2.

2) Indicate below which chemicals you manufacture, sell, distribute or use; whether the chemical is Class I or Class II; and what chemical your facility will be using to replace the phased out chemical. Include additional pages if necessary:

2a) 2b) 2c) 2d) Chemical Class CAS Replacement Chemical Name: Type: Number: (after phase out):

3) Return to form GI-09 Requirements, question 7b. TABLE E CLASS I OZONE DEPLETING CHEMICALS Group I: Chemical CAS Number CFCl3-Trichlorofluoromethane (CFC-11) 75-69-4 CF2Cl2-Dichlorodifluoromethane (CFC-12) 75-71-8 C2F3Cl2-Trichlorotrifluoroethane (CFC-113) 76-13-1 C2F4Cl3-Dichlorotetrafluoroethane (CFC-114) 76-14-2 C2F5Cl-Monochloropentafluoroethane (CFC-115) 76-15-3 All isomers of the above chemicals

Group II: Chemical CAS Number CF2ClBr-Bromochlorodifluoromethane (Halon-1211) 421-01-2 CF3Br-Bromotrifluoroethane (Halon-1301) 75-63-8 C2F4Br2-Dibromotetrafluoroethane (Halon-2402) 124-73-2 All isomers of the above chemicals

Group III: Chemical CAS Number CF3Cl-Chlorotrifluoromethane (CFC-13) 75-72-9 C2FCl5 (CFC-111) 954-56-3 C2F2Cl4 (CFC-112) 76-12-0 C3FCl7 (CFC-211) 422-78-6 C3F2Cl6 (CFC-212) 3182-26-1 C3F3Cl5 (CFC-213) 2354-06-5 C3F4Cl4 (CFC-214) 29255-31-0 C3F5Cl3 (CFC-215) 4259-43-2 C3F6Cl2 (CFC-216) 661-97-2 C3F7Cl (CFC-217) 422-86-6 All isomers of the above chemicals

Group IV: Chemical CAS Number CCl-Carbon Tetrachloride 56-23-5

Group V: Chemical CAS Number C2H3Cl3-1,1,1 Trichloroethane (Methyl chloroform) 71-55-6 All isomers of the above chemical except 1,1,2-trichloroethane 79-00-5

Group VI: Chemical CAS Number CH3BR - Bromomethane (Methyl Bromide)

Group VII: Chemical CAS Number CHFBR2 CHF2Br (HBFC-22B1) CH2FBr C2HFBr4 C2HF2Br3 C2HF3Br2 C2HF4Br C2H2FBr3 C2H2F2Br2 C2H2F3Br C2H2FBr2 C2H3F2Br C2H4FBr C3HFBr6 C3HF2Br5 TABLE E (continued)

Group VII: Chemical CAS Number C3HF3Br4 C3HF4Br3 C3HF5Br2 C3HF6Br C3H2FBR5 C3H2F2BR4 C3H2F3Br3 C3H2F4Br2 C3H2F5BR C3H3FBR4 C3H3F2Br3 C3H3F3Br2 C3H3F4Br C3H4FBr3 C3H4F2Br2 C3H4F3Br C3H5FBr2 C3H5F2Br C3H6FB TABLE F CLASS II OZONE DEPLETING CHEMICALS Chemical CAS Number HCFC-21 CHFCl2 -dichlorofluoromethane 75-43-4 HCFC-22 CHF2Cl -chlorodifluoromethane 75-45-6 HCFC-31 CH2FCl -chlorofluoromethane 593-70-4 HCFC-121 C2HFCl4 -tetrachlorofluoroethane 130879-71-9 HCFC-121 C2HFCl4 -tetrachlorofluoroethane 134237-32-4 HCFC-121 C2HFCl4 -1,1,1,2-tetrachloro-2-fluoroethane 354-11-0 HCFC-121 C2HFCl4 -1,1,2,2-tetrachloro-1-fluoroethane 354-14-3 HCFC-122 C2HF2Cl3 -trichlorodifluoroethane 41834-16-6 HCFC-122 C2HF2Cl3 -trichloro-1,1-difluoroethane 55949-46-7 HCFC-122 C2HF2Cl3 -1,2,2-trichloro-1,1-difluoroethane 354-21-2 HCFC-122 C2HF2Cl3 -1,2,2-trichloro-1,2-difluoroethane 354-15-4 HCFC-122 C2HF2Cl3 -1,1,1-trichloro-2,2-difluoroethane 354-12-1 HCFC-122 C2HF2Cl3 -1,1,2-trichloro-2,2-difluoroethane NA HCFC-123 C2HF3Cl2 -dichlorotrifluoroethane 34077-87-7 HCFC-123 C2HF3Cl2 -dichlorotrifluoroethane 134237-33-5 HCFC-123 C2HF3Cl2 -dichloro-1,1,2-trifluoroethane 90454-18-5 HCFC-123 C2HF3Cl2 -2,2-dichloro-1,1,1-trifluoroethane 306-83-2 HCFC-123a C2HF3Cl2 -1,2-dichloro-1,1,2-trifluoroethane 354-23-4 HCFC-123b C2HF3Cl2 -1,1-dichloro-1,2,2-trifluoroethane 812-04-4 HCFC-123 C2HF3Cl2 -2,2-dichloro-1,1,2-trifluoroethane NA HCFC-124 C2HF4Cl -chlorotetrafluoroethane 63938-10-3 HCFC-124 C2HF4Cl -2-chloro-1,1,1,2-tetrafluoroethane 2837-89-0 HCFC-124 C2HF4Cl -1-chloro-1,1,2,2-tetrafluoroethane 354-25-6 HCFC-131 C2H2FCl3 -trichlorofluoroethane 27154-33-2 HCFC-131 C2H2FCl3 -trichlorofluoroethane 134237-34-6 HCFC-131 C2H2FCl3 -1,1,2-trichloro-1 (or 2)-fluoroethane 90134-98-8 HCFC-131b C2H2FCl3 -1,1,1-trichloro-2-fluoroethane 2366-36-1 HCFC-131a C2H2FCl3 -1,1,2-trichloro-1-fluoroethane 811-95-0 HCFC-131 C2H2FCl3 -1,1,2-trichloro-2-fluoroethane 359-28-4 HCFC-132 C2H2F2Cl2 -dichlorodifluoroethane 25915-78-0 HCFC-132 C2H2F2Cl2 -dichloro-1,1-difluoroethane 55494-45-6 HCFC-132 C2H2F2Cl2 -1,1-dichlorodifluoroethane 31153-51-2 HCFC-132 C2H2F2Cl2 -1,2-dichloro-1,2-difluoroethane 33579-37-2 HCFC-132 C2H2F2Cl2 -1,2-dichloro-1,2-difluoroethane 33489-30-4 HCFC-132c C2H2F2Cl2 -1,1-dichloro-1,2-difluoroethane 1842-05-3 HCFC-132b C2H2F2Cl2 -1,2-dichloro-1,1-difluoroethane 1649-08-7 HCFC-132a C2H2F2Cl2 -1,1-dichloro-2,2-difluoroethane 471-43-2 HCFC-132 C2H2F2Cl2 -1,2-dichloro-1,2-difluoroethane 431-06-1 HCFC-133 C2H2F3Cl -chlorotrifluoroethane 13330-45-6 HCFC-133 C2H2F3Cl -1-chloro-1,2,2-trifluoroethane 431-07-2 HCFC-133b C2H2F3Cl -1-chloro-1,1,2-trifluoroethane 421-04-5 HCFC-133a C2H2F3Cl -2-chloro-1,1,1-trifluoroethane 75-88-7 HCFC-141 C2H3FCl2 -dichlorofluoroethane 25167-88-8 HCFC-141b C2H3FCl2 -1,1-dichloro-1-fluoroethane 1717-00-6 HCFC-141 C2H3FCl2 -1,2-dichloro-1-fluoroethane 430-57-9 HCFC-141a C2H3FCl2 -1,1-dichloro-2-fluoroethane 430-53-5 HCFC-142 C2H3F2Cl -chlorodifluoroethane 25497-29-4 HCFC-142 C2H3F2Cl -chloro-1,1-difluoroethane 55949-44-5 HCFC-142a C2H3F2Cl -2-chloro-1,1-difluoroethane 338-65-8 HCFC-142b C2H3F2Cl -1-chloro-1,2-difluoroethane 338-64-7 HCFC-142 C2H3F2Cl -1-chloro-1,1-difluoroethane 75-68-3 HCFC-221 C3HFCl6 -hexachlorofluoropropane 29470-94-8 TABLE F (continued) Chemical CAS Number HCFC-221 C3HFCl6 -hexachlorofluoropropane 134237-35-7 HCFC-221 C3HFCl6 -1,1,1,2,3,3-hexachloro-3-fluoropropane 431-79-8 HCFC-221 C3HFCl6 -1,1,1,2,3,3-hexachloro-2-fluoropropane 422-40-2 HCFC-221 C3HFCl6 -1,1,1,2,2,3-hexachloro-1-fluoropropane 422-26-4 HCFC-221 C3HFCl6 -1,1,2,2,3,3-hexachloro-1-fluoropropane 422-28-6 HCFC-221 C3HFCl6 -1,1,1,3,3,3-hexachloro-2-fluoropropane NA HCFC-222 C3HF2Cl5 -pentachlorodifluoropropane 116867-32-4 HCFC-222 C3HF2Cl5 -pentachlorodifluoropropane 134237-36-8 HCFC-222 C3HF2Cl5 -1,1,2,3,3-pentachloro-1,3-difluoropropane 421-82-3 HCFC-222 C3HF2Cl5 -1,1,1,2,3-pentachloro-3,3-difluoropropane 431-80-1 HCFC-222c C3HF2Cl5 -1,1,1,3,3-pentachloro-2,2-difluoropropane 422-49-1 HCFC-222 C3HF2Cl5 -1,2,2,3,3-pentachloro-1,1-difluoropropane 422-30-0 HCFC-222 C3HF2Cl5 -1,1,1,2,2-pentachloro-3,3-difluoropropane 422-27-5 HCFC-222 C3HF2Cl5 -1,1,1,2,3-pentachloro-2,3-difluoropropane NA HCFC-222 C3HF2Cl5 -1,1,1,3,3-pentachloro-2,3-difluoropropane NA HCFC-222 C3HF2Cl5 -1,1,2,2,3-pentachloro-1,3-difluoropropane NA HCFC-222 C3HF2Cl5 -1,1,2,3,3-pentachloro-1,2-difluoropropane NA HCFC-223 C3HF3Cl4 -tetrachlorotrifluoropropane 29470-95-9 HCFC-223 C3HF3Cl4 -tetrachlorotrifluoropropane 134237-37-9 HCFC-223 C3HF3Cl4 -1,1,1,3-tetrachloro-2,3,3-trifluoropropane 54002-59-4 HCFC-223 C3HF3Cl4 -1,1,2,3-tetrachloro-1,3,3-trifluoropropane 431-83-4 HCFC-223 C3HF3Cl4 -1,1,1,2-tetrachloro-3,3,3-trifluoropropane 431-81-2 HCFC-223ca C3HF3Cl4 -1,1,3,3-tetrachloro-1,2,2-trifluoropropane 422-52-6 HCFC-223cb C3HF3Cl4 -1,1,1,3-tetrachloro-2,2,3-trifluoropropane 422-50-4 HCFC-223 C3HF3Cl4 -1,2,3,3-tetrachloro-1,1,2-trifluoropropane 422-41-3 HCFC-223 C3HF3Cl4 -2,2,3,3-tetrachloro-1,1,1-trifluoropropane 422-35-5 HCFC-223 C3HF3Cl4 -1,1,2,2-tetrachloro-1,3,3-trifluoropropane 422-29-7 HCFC-223 C3HF3Cl4 -1,1,1,2-tetrachloro-2,3,3-trifluoropropane NA HCFC-223 C3HF3Cl4 -1,1,3,3-tetrachloro-1,2,3-trifluoropropane NA HCFC-223 C3HF3Cl4 -1,2,2,3-tetrachloro-1,1,3-trifluoropropane NA HCFC-223 C3HF3Cl4 -1,1,2,3-tetrachloro-1,2,3-trifluoropropane NA HCFC-224 C3HF4Cl3 -trichlorotetrafluoropropane 127564-91-4 HCFC-224 C3HF4Cl3 -trichlorotetrafluoropropane 134237-38-0 HCFC-224 C3HF4Cl3 -1,1,3-trichloro-1,2,3,3-tetrafluoropropane 53063-53-9 HCFC-224 C3HF4Cl3 -1,1,1-trichloro-2,3,3,3-tetrafluoropropane 53063-52-8 HCFC-224 C3HF4Cl3 -1,2,3-trichloro-1,1,3,3-tetrafluoropropane 431-85-6 HCFC-224 C3HF4Cl3 -1,1,2-trichloro-1,3,3,3-tetrafluoropropane 431-84-5 HCFC-224ca C3HF4Cl3 -1,3,3-trichloro-1,1,2,2-tetrafluoropropane 422-54-8 HCFC-224cb C3HF4Cl3 -1,1,3-trichloro-1,2,2,3-tetrafluoropropane 422-53-7 HCFC-224cc C3HF4Cl3 -1,1,1-trichloro-2,2,3,3-tetrafluoropropane 422-51-5 HCFC-224 C3HF4Cl3 -2,3,3-trichloro-1,1,1,2-tetrafluoropropane 422-47-9 HCFC-224 C3HF4Cl3 -1,2,3-trichloro-1,1,2,3-tetrafluoropropane 422-42-4 HCFC-224 C3HF4Cl3 -1,2,2-trichloro-1,1,3,3-tetrafluoropropane 422-32-2 HCFC-224 C3HF4Cl3 -2,2,3-trichloro-1,1,1,3-tetrafluoropropane NA HCFC-224 C3HF4Cl3 -1,1,2-trichloro-1,2,3,3-tetrafluoropropane NA HCFC-225 C3HF5Cl2 -dichloropentafluoropropane 127564-92-5 HCFC-225 C3HF5Cl2 -1,3-dichloro-1,1,2,3,3-pentafluoropropane 136013-79-1 HCFC-225aa C3HF5Cl2 -2,2-dichloro-1,1,1,3,3-pentafluoropropane 128903-21-9 HCFC-225 C3HF5Cl2 -1,1-dichloro-1,2,3,3,3-pentafluoropropane 111512-56-2 HCFC-225 C3HF5Cl2 -2,3-dichloro-1,1,1,2,3-pentafluoropropane 111512-55-1 HCFC-225 C3HF5Cl2 -2,3-dichloro-1,1,1,2,3-pentafluoropropane 111512-51-7 HCFC-225cc C3HF5Cl2 -1,1-dichloro-1,2,2,3,3-pentafluoropropane 13474-88-9 HCFC-225cb C3HF5Cl2 -1,3-dichloro-1,1,2,2,3-pentafluoropropane 507-55-1 TABLE F (continued) Chemical CAS Number HCFC-225da C3HF5Cl2 -1,2-dichloro-1,1,3,3,3-pentafluoropropane 431-86-7 HCFC-225ca C3HF5Cl2 -3,3-dichloro-1,1,1,2,2-pentafluoropropane 422-56-0 HCFC-225ba C3HF5Cl2 -2,3-dichloro-1,1,1,2,3-pentafluoropropane 422-48-0 HCFC-225 C3HF5Cl2 -1,2-dichloro-1,1,2,3,3-pentafluoropropane 422-44-6 HCFC-226 C3HF6Cl -chlorohexafluoropropane 28987-04-4 HCFC-226 C3HF6Cl -chlorohexafluoropropane 134308-72-8 HCFC-226ba C3HF6Cl -2-chloro-1,1,1,2,3,3-hexafluoropropane 51346-64-6 HCFC-226da C3HF6Cl -2-chloro-1,1,1,3,3,3-hexafluoropropane 431-87-8 HCFC-226ca C3HF6Cl -3-chloro-1,1,1,2,2,3-hexafluoropropane 422-57-1 HCFC-226cb C3HF6Cl -1-chloro-1,1,2,2,3,3-hexafluoropropane 422-55-9 HCFC-226ea C3HF6Cl -1-chloro-1,1,2,3,3,3-hexafluoropropane 359-58-0 HCFC-231 C3H2FCl5 -pentachlorofluoropropane NA HCFC-231 C3H2FCl5 -pentachlorofluoropropane 134190-48-0 HCFC-231 C3H2FCl5 -1,1,1,2,3-pentachloro-2-fluoropropane 421-94-3 HCFC-231 C3H2FCl5 -1,1,2,3,3-pentachloro-2-fluoropropane NA HCFC-231 C3H2FCl5 -1,1,1,3,3-pentachloro-3-fluoropropane NA HCFC-231 C3H2FCl5 -1,1,2,2,3-pentachloro-1-fluoropropane NA HCFC-231 C3H2FCl5 -1,1,1,2,2-pentachloro-3-fluoropropane NA HCFC-231 C3H2FCl5 -1,1,1,2,3-pentachloro-3-fluoropropane NA HCFC-231 C3H2FCl5 -1,1,1,3,3-pentachloro-2-fluoropropane NA HCFC-231 C3H2FCl5 -1,1,2,2,3-pentachloro-3-fluoropropane NA HCFC-231 C3H2FCl5 -1,1,2,3,3-pentachloro-1-fluoropropane NA HCFC-232 C3H2F2Cl4 -tetrachlorodifluoropropane 127564-82-3 HCFC-232 C3H2F2Cl4 -tetrachlorodifluoropropane 134237-39-1 HCFC-232 C3H2F2Cl4 -1,2,3,3-tetrachloro-1,1-difluoropropane 67879-59-8 HCFC-232ca C3H2F2Cl4 -1,1,3,3-tetrachloro-2,2-difluoropropane 1112-14-7 HCFC-232cb C3H2F2Cl4 -1,1,1,3-tetrachloro-2,2-difluoropropane 677-54-3 HCFC-232 C3H2F2Cl4 -1,1,1,3-tetrachloro-3,3-difluoropropane 460-89-9 HCFC-232 C3H2F2Cl4 -1,1,1,3-tetrachloro-2,3-difluoropropane NA HCFC-232 C3H2F2Cl4 -1,1,1,2-tetrachloro-2,3-difluoropropane NA HCFC-232 C3H2F2Cl4 -1,1,1,2-tetrachloro-3,3-difluoropropane NA HCFC-232 C3H2F2Cl4 -1,1,3,3-tetrachloro-1,2-difluoropropane NA HCFC-232 C3H2F2Cl4 -1,1,2,3-tetrachloro-1,2-difluoropropane NA HCFC-232 C3H2F2Cl4 -1,1,2,3-tetrachloro-1,3-difluoropropane NA HCFC-232 C3H2F2Cl4 -1,2,3,3-tetrachloro-1,2-difluoropropane NA HCFC-232 C3H2F2Cl4 -1,2,2,3-tetrachloro-1,1-difluoropropane NA HCFC-232 C3H2F2Cl4 -1,2,2,3-tetrachloro-1,3-difluoropropane NA HCFC-232 C3H2F2Cl4 -1,1,3,3-tetrachloro-1,3-difluoropropane NA HCFC-232 C3H2F2Cl4 -1,1,2,2-tetrachloro-3,3-difluoropropane NA HCFC-232 C3H2F2Cl4 -1,1,2,2-tetrachloro-1,3-difluoropropane NA HCFC-233 C3H2F3Cl3 -trichlorotrifluoropropane 61623-04-9 HCFC-233 C3H2F3Cl3 -trichlorotrifluoropropane 134237-40-4 HCFC-233ca C3H2F3Cl3 -1,1,3-trichloro-2,2,3-trifluoropropane 131221-36-8 HCFC-233cc C3H2F3Cl3 -1,1,1-trichloro-2,2,3-trifluoropropane 131211-71-7 HCFC-233 C3H2F3Cl3 -1,1,3-trichloro-1,2,3-trifluoropropane 54377-32-1 HCFC-233 C3H2F3Cl3 -1,1,1-trichloro-2,3,3-trifluoropropane 54306-56-8 HCFC-233 C3H2F3Cl3 -1,1,2-trichloro-2,3,3-trifluoropropane 13058-99-6 HCFC-233 C3H2F3Cl3 -1,1,1-trichloro-3,3,3-trifluoropropane 7125-84-0 HCFC-233 C3H2F3Cl3 -2,2,3-trichloro-1,1,1-trifluoropropane 7125-83-9 HCFC-233 C3H2F3Cl3 -2,3,3-trichloro-1,1,1-trifluoropropane 431-51-6 HCFC-233cb C3H2F3Cl3 -1,1,3-trichloro-1,2,2-trifluoropropane 421-99-8 HCFC-233 C3H2F3Cl3 -1,2,3-trichloro-1,1,2-trifluoropropane 421-95-4 HCFC-233 C3H2F3Cl3 -1,1,3-trichloro-1,3,3-trifluoropropane 333-26-6 TABLE F (continued) Chemical CAS Number HCFC-233 C3H2F3Cl3 -1,1,2-trichloro-1,2,3-trifluoropropane NA HCFC-233 C3H2F3Cl3 -1,2,3-trichloro-1,2,3-trifluoropropane NA HCFC-233 C3H2F3Cl3 -1,1,2-trichloro-1,3,3-trifluoropropane NA HCFC-233 C3H2F3Cl3 -1,3,3-trichloro-1,1,2-trifluoropropane NA HCFC-233 C3H2F3Cl3 -2,2,3-trichloro-1,1,3-trifluoropropane NA HCFC-233 C3H2F3Cl3 -1,2,3-trichloro-1,1,3-trifluoropropane NA HCFC-233 C3H2F3Cl3 -1,2,2-trichloro-1,1,3-trifluoropropane NA HCFC-234 C3H2F4Cl2 -dichlorotetrafluoropropane 127564-83-4 HCFC-234fa C3H2F4Cl2 -1,3-dichloro-1,1,3,3-tetrafluoropropane 76140-39-1 HCFC-234ca C3H2F4Cl2 -1,3-dichloro-1,2,2,3-tetrafluoropropane 70341-81-0 HCFC-234cd C3H2F4Cl2 -1,1-dichloro-1,2,2,3-tetrafluoropropane 70192-63-1 HCFC-234 C3H2F4Cl2 -1,1-dichloro-1,3,3,3-tetrafluoropropane 64712-27-2 HCFC-234 C3H2F4Cl2 -1,3-dichloro-1,1,2,3-tetrafluoropropane 53149-65-8 HCFC-234 C3H2F4Cl2 -1,3-dichloro-1,1,2,3-tetrafluoropropane 5306355-1 HCFC-234 C3H2F4Cl2 -3,3-dichloro-1,1,1,2-tetrafluoropropane 53063-54-0 HCFC-234 C3H2F4Cl2 -2,2-dichloro-1,1,3,3-tetrafluoropropane 17705-30-5 HCFC-234cb C3H2F4Cl2 -1,1-dichloro-2,2,3,3-tetrafluoropropane 4071-01-6 HCFC-234 C3H2F4Cl2 -1,2-dichloro-1,2,3,3-tetrafluoropropane 425-94-5 HCFC-234cc C3H2F4Cl2 -1,3-dichloro-1,1,2,2-tetrafluoropropane 422-00-5 HCFC-234da C3H2F4Cl2 -2,3-dichloro-1,1,1,3-tetrafluoropropane NA HCFC-234 C3H2F4Cl2 -1,1-dichloro-1,2,3,3-tetrafluoropropane NA HCFC-234 C3H2F4Cl2 -1,2-dichloro-1,1,3,3-tetrafluoropropane NA HCFC-234 C3H2F4Cl2 -2,3-dichloro-1,1,1,2-tetrafluoropropane NA HCFC-234 C3H2F4Cl2 -2,2-dichloro-1,1,1,3-tetrafluoropropane NA HCFC-234 C3H2F4Cl2 -1,2-dichloro-1,1,2,3-tetrafluoropropane NA HCFC-234 C3H2F4Cl2 -1,3-dichloro-1,1,2,3-tetrafluoropropane NA HCFC-235 C3H2F5Cl -chloropentafluoropropane 108662-83-5 HCFC-235 C3H2F5Cl -chloropentafluoropropane 134237-83-5 HCFC-235 C3H2F5Cl -3-chloro-1,1,1,2,3-pentafluoropropane 134251-06-2 HCFC-235da C3H2F5Cl -2-chloro-1,1,1,3,3-pentafluoropropane 28103-66-4 HCFC-235ca C3H2F5Cl -1-chloro-1,2,2,3,3-pentafluoropropane 679-99-2 HCFC-235cc C3H2F5Cl -1-chloro-1,1,2,2,3-pentafluoropropane 677-55-4 HCFC-235fa C3H2F5Cl -1-chloro-1,1,3,3,3-pentafluoropropane 460-92-4 HCFC-235cb C3H2F5Cl -3-chloro-1,1,1,2,2-pentafluoropropane 422-02-6 HCFC-235 C3H2F5Cl -2-chloro-1,1,1,2,3-pentafluoropropane NA HCFC-235 C3H2F5Cl -1-chloro-1,1,2,3,3-pentafluoropropane NA HCFC-235 C3H2F5Cl -2-chloro-1,1,2,3,3-pentafluoropropane NA HCFC-241 C3H3FCl4 -tetrachlorofluoropropane NA HCFC-241 C3H3FCl4 -tetrachlorofluoropropane 134190-49-1 HCFC-241 C3H3FCl4 -1,1,1,2-tetrachloro-3-fluoropropane 84816-05-7 HCFC-241 C3H3FCl4 -1,1,1,3-tetrachloro-3-fluoropropane 23153-22-2 HCFC-241 C3H3FCl4 -1,1,2,3-tetrachloro-3-fluoropropane 21981-25-9 HCFC-241 C3H3FCl4 -1,1,2,2-tetrachloro-1-fluoropropane 7126-06-9 HCFC-241 C3H3FCl4 -1,1,2,3-tetrachloro-2-fluoropropane 3175-26-6 HCFC-241 C3H3FCl4 -1,1,1,2-tetrachloro-2-fluoropropane 3175-25-5 HCFC-241 C3H3FCl4 -1,1,2,3-tetrachloro-1-fluoropropane 666-27-3 HCFC-241 C3H3FCl4 -1,1,1,3-tetrachloro-2-fluoropropane NA HCFC-241 C3H3FCl4 -1,1,2,2-tetrachloro-3-fluoropropane NA HCFC-241 C3H3FCl4 -1,2,2,3-tetrachloro-1-fluoropropane NA HCFC-241 C3H3FCl4 -1,1,3,3-tetrachloro-1-fluoropropane NA HCFC-241 C3H3FCl4 -1,1,3,3-tetrachloro-2-fluoropropane NA HCFC-242 C3H3F2Cl3 -trichlorodifluoropropane 127564-90-3 HCFC-242 C3H3F2Cl3 -trichlorodifluoropropane 134237-42-6 TABLE F (continued) Chemical CAS Number HCFC-242 C3H3F2Cl3 -1,3,3-trichloro-1,1-difluoropropane 460-63-9 HCFC-242 C3H3F2Cl3 -1,2,3-trichloro-1,2-difluoropropane 7164-14-9 HCFC-242 C3H3F2Cl3 -1,1,3-trichloro-2,2-difluoropropane 1112-13-6 HCFC-242 C3H3F2Cl3 -1,2,3-trichloro-1,1-difluoropropane 431-24-3 HCFC-242 C3H3F2Cl3 -1,1,1-trichloro-2,2-difluoropropane 1112-05-6 HCFC-242 C3H3F2Cl3 -1,2,2-trichloro-1,1-difluoropropane 7126-05-8 HCFC-242 C3H3F2Cl3 -1,1,2-trichloro-1,2-difluoropropane 7126-04-7 HCFC-242 C3H3F2Cl3 -1,1,1-trichloro-2,3-difluoropropane NA HCFC-242 C3H3F2Cl3 -1,1,2-trichloro-1,3-difluoropropane NA HCFC-242 C3H3F2Cl3 -1,1,3-trichloro-1,2-difluoropropane NA HCFC-242 C3H3F2Cl3 -1,1,2-trichloro-2,3-difluoropropane NA HCFC-242 C3H3F2Cl3 -1,2,2-trichloro-1,3-difluoropropane NA HCFC-242 C3H3F2Cl3 -2,2,3-trichloro-1,1-difluoropropane NA HCFC-242 C3H3F2Cl3 -1,1,1-trichloro-3,3-difluoropropane NA HCFC-242 C3H3F2Cl3 -1,1,3-trichloro-1,3-difluoropropane NA HCFC-242 C3H3F2Cl3 -1,1,2-trichloro-3,3-difluoropropane NA HCFC-242 C3H3F2Cl3 -1,1,3-trichloro-2,3-difluoropropane NA HCFC-242 C3H3F2Cl3 -1,2,3-trichloro-1,3-difluoropropane NA HCFC-243 C3H3F3Cl2 -dichlorotrifluoropropane 116890-51-8 HCFC-243 C3H3F3Cl2 -dichlorotrifluoropropane 134237-43-7 HCFC-243 C3H3F3Cl2 -2,2-dichloro-1,1,1-trifluoropropane 7126-01-4 HCFC-243cc C3H3F3Cl2 -1,1-dichloro-1,2,2-trifluoropropane 7125-99-7 HCFC-243 C3H3F3Cl2 -1,2-dichloro-1,1,2-trifluoropropane 7126-00-3 HCFC-243da C3H3F3Cl2 -2,3-dichloro-1,1,1-trifluoropropane 338-75-0 HCFC-243ca C3H3F3Cl2 -1,3-dichloro-1,2,2-trifluoropropane 67406-68-2 HCFC-243cb C3H3F3Cl2 -1,1-dichloro-2,2,3-trifluoropropane 70192-70-0 HCFC-243 C3H3F3Cl2 -3,3-dichloro-1,1,1-trifluoropropane 460-69-5 HCFC-243 C3H3F3Cl2 -1,3-dichloro-1,1,2-trifluoropropane NA HCFC-243 C3H3F3Cl2 -1,2-dichloro-1,1,3-trifluoropropane NA HCFC-243 C3H3F3Cl2 -1,1-dichloro-1,2,3-trifluoropropane NA HCFC-243 C3H3F3Cl2 -2,3-dichloro-1,1,2-trifluoropropane NA HCFC-243 C3H3F3Cl2 -2,2-dichloro-1,1,3-trifluoropropane NA HCFC-243 C3H3F3Cl2 -1,2-dichloro-1,2,3-trifluoropropane NA HCFC-243 C3H3F3Cl2 -1,3-dichloro-1,1,3-trifluoropropane NA HCFC-243 C3H3F3Cl2 -1,1-dichloro-1,3,3-trifluoropropane NA HCFC-243 C3H3F3Cl2 -3,3-dichloro-1,1,2-trifluoropropane NA HCFC-243 C3H3F3Cl2 -2,3-dichloro-1,1,3-trifluoropropane NA HCFC-243 C3H3F3Cl2 -1,3-dichloro-1,2,3trifluoropropane NA HCFC-244 C3H3F4Cl -chlorotetrafluoropropane NA HCFC-244 C3H3F4Cl -chlorotetrafluoropropane 134190-50-4 HCFC-244db C3H3F4Cl -2-chloro-1,1,1,3-tetrafluoropropane 117970-90-8 HCFC-244ca C3H3F4Cl -3-chloro-1,1,2,2-tetrafluoropropane 679-85-6 HCFC-244cb C3H3F4Cl -1-chloro-1,2,2,3-tetrafluoropropane 67406-66-0 HCFC-244fb C3H3F4Cl -1-chloro-1,1,3,3-tetrafluoropropane 2730-64-5 HCFC-244da C3H3F4Cl -2-chloro-1,1,3,3-tetrafluoropropane 19041-02-2 HCFC-244bb C3H3F4Cl -2-chloro-1,1,1,2-tetrafluoropropane 421-73-8 HCFC-244cc C3H3F4Cl -1-chloro-1,1,2,2-tetrafluoropropane 421-75-0 HCFC-244 C3H3F4Cl -1-chloro-1,1,2,3-tetrafluoropropane NA HCFC-244 C3H3F4Cl -3-chloro-1,1,1,2-tetrafluoropropane NA HCFC-244 C3H3F4Cl -2-chloro-1,1,2,3-tetrafluoropropane NA HCFC-244 C3H3F4Cl -3-chloro-1,1,1,3-tetrafluoropropane NA HCFC-244 C3H3F4Cl -3-chloro-1,1,2,3-tetrafluoropropane NA HCFC-251 C3H4FCl3 -trichlorofluoropropane NA TABLE F (continued) Chemical CAS Number HCFC-251 C3H4FCl3 -trichlorofluoropropane 134190-51-5 HCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane 84847-80-3 HCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane 84847-79-0 HCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane 76985-34-7 HCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane 76985-33-6 HCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane 67832-50-2 HCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane 67832-44-4 HCFC-251 C3H4FCl3 -1,2,3-trichloro-2-fluoropropane 7126-16-1 HCFC-251 C3H4FCl3 -1,2,2-trichloro-3-fluoropropane 70192-89-1 HCFC-251 C3H4FCl3 -1,1,3-trichloro-1-fluoropropane 818-99-5 HCFC-251 C3H4FCl3 -1,1,3-trichloro-2-fluoropropane 76937-36-5 HCFC-251 C3H4FCl3 -1,1,2-trichloro-1-fluoropropane 421-41-0 HCFC-251 C3H4FCl3 -1,1,2-trichloro-2-fluoropropane 3175-24-4 HCFC-251 C3H4FCl3 -1,1,1-trichloro-2-fluoropropane NA HCFC-251 C3H4FCl3 -1,1,1-trichloro-3-fluoropropane NA HCFC-251 C3H4FCl3 -1,1,2-trichloro-3-fluoropropane NA HCFC-251 C3H4FCl3 -1,1,3-trichloro-3-fluoropropane NA HCFC-251 C3H4FCl3 -1,2,2-trichloro-1-fluoropropane NA HCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane NA HCFC-252 C3H4F2Cl2 -dichlorodifluoropropane NA HCFC-252 C3H4F2Cl2 -dichlorodifluoropropane 134190-52-6 HCFC-252cb C3H4F2Cl2 -1,1-dichloro-2,2-difluoropropane 1112-01-2 HCFC-252 C3H4F2Cl2 -1,1-dichloro-3,3-difluoropropane 131404-17-6 HCFC-252 C3H4F2Cl2 -1,1-dichloro-1,3-difluoropropane 121612-64-4 HCFC-252 C3H4F2Cl2 -1,2-dichloro-1,1-difluoropropane 7126-15-0 HCFC-252 C3H4F2Cl2 -1,2-dichloro-2,3-difluoropropane 70192-74-4 HCFC-252 C3H4F2Cl2 -2,3-dichloro-1,1-difluoropropane 82578-00-5 HCFC-252 C3H4F2Cl2 -1,3-dichloro-1,1-difluoropropane 819-00-1 HCFC-252 C3H4F2Cl2 -1,3-dichloro-1,2-difluoropropane 111483-26-2 HCFC-252ca C3H4F2Cl2 -1,3-dichloro-2,2-difluoropropane 1112-36-3 HCFC-252 C3H4F2Cl2 -1,1-dichloro-1,2-difluoropropane NA HCFC-252 C3H4F2Cl2 -1,1-dichloro-2,3-difluoropropane NA HCFC-252 C3H4F2Cl2 -1,2-dichloro-1,2-difluoropropane NA HCFC-252 C3H4F2Cl2 -1,2-dichloro-1,3-difluoropropane NA HCFC-252 C3H4F2Cl2 -1,3-dichloro-1,3-difluoropropane NA HCFC-252 C3H4F2Cl2 -2,2-dichloro-1,1-difluoropropane NA HCFC-252 C3H4F2Cl2 -2,2-dichloro-1,3-difluoropropane NA HCFC-253 C3H4F3 Cl-chlorotrifluoropropane 26588-23-8 HCFC-253 C3H4F3 Cl -chlorotrifluoropropane 134237-44-8 HCFC-253 C3H4F3 Cl -2-chloro-1,1,1-trifluoropropane 421-47-6 HCFC-253 C3H4F3 Cl -3-chloro-1,1,1-trifluoropropane 460-35-5 HCFC-253 C3H4F3 Cl -1-chloro-1,1,2-trifluoropropane 134251-05-1 HCFC-253 C3H4F3 Cl -2-chloro-1,1,2-trifluoropropane 69202-10-4 HCFC-253 C3H4F3 Cl -3-chloro-1,1,2-trifluoropropane 121612-65-5 HCFC-253 C3H4F3 Cl -1-chloro-1,1,3-trifluoropropane 83124-56-5 HCFC-253cb C3H4F3 Cl -1-chloro-1,2,2-trifluoropropane 70192-76-6 HCFC-253ca C3H4F3 Cl -1-chloro-2,2,3-trifluoropropane 56758-54-4 HCFC-253 C3H4F3 Cl -2-chloro-1,1,3-trifluoropropane NA HCFC-253 C3H4F3 Cl -3-chloro-1,1,3-trifluoropropane NA HCFC-253 C3H4F3 Cl -1-chloro-1,2,3-trifluoropropane NA HCFC-253 C3H4F3 Cl -2-chloro-1,2,3-trifluoropropane NA HCFC-261 C3H5FCl2 -dichlorofluoropropane 127404-11-9 HCFC-261 C3H5FCl2 -dichlorofluoropropane 134237-45-9

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-09G 520 LAFAYETTE ROAD REQUIREMENTS: RISK MANAGEMENT ST. PAUL, MN 55155-4194 PROGRAMS FOR CHEMICAL ACCIDENTAL RELEASE PREVENTION (40 CFR pt. 68) 05/11/98

If you produce, process, store or use any of the substances, in excess of the threshold listed in the following table, you may be subject to the requirements under Section 112(r) of the Clean Air Act. After reviewing Table G, return to form GI-09 Requirements and answer question 8b.

TABLE G LIST OF REGULATED TOXIC SUBSTANCES AND THRESHOLD QUANTITIES FOR ACCIDENTAL RELEASE PREVENTION

Threshold Chemical Name CAS No. Quantity (lbs) Acetaldehyde 75-07-0 10,000 Acetylene [Ethyne] 74-86-2 10,000 Acrolein [2-Propenal] 107-02-8 5,000 Acrylonitrile [2-Propenenitrile] 107-13-1 20,000 Acrylyl chloride [2-Propenoyl chloride] 814-68-6 5,000 Allyl alcohol [2-Propen-1-ol] 107-18-6 15,000 Allylamine [2-Propen-1-amine] 107-11-9 10,000 Ammonia (anhydrous) 7664-41-7 10,000 Ammonia (conc 20% or greater) 7664-41-7 20,000 Arsenous trichloride 7784-34-1 15,000 Arsine 7784-42-1 1,000 Boron trichloride [Borane, trichloro-] 10294-34-5 5,000 Boron trifluoride [Borane, trifluoro-] 7637-07-2 5,000 Boron trifluoride compound with methyl ether (1:1) [Boron, 353-42-4 15,000 trifluoro[oxybis[metane]]-, T-4- Bromine 7726-95-6 10,000 Bromotrifluorethylene [Ethene, bromotrifluoro-] 598-73-2 10,000 1,3-Butadiene 106-99-0 10,000 Butane 106-97-8 10,000 1-Butene 106-98-9 10,000 2-Butene 107-01-7 10,000 Butene 25167-67-3 10,000 2-Butene-cis 590-18-1 10,000 2-Butene-trans [2-Butene, (E)] 624-64-6 10,000 Carbon disulfide 75-15-0 20,000 Carbon oxysulfide [Carbon oxide sulfide (COS)] 463-58-1 10,000 Chlorine 7782-50-5 2,500 Chlorine dioxide [Chlorine oxide (ClO2)] 10049-04-4 1,000 Chlorine monoxide [Chlorine oxide] 7791-21-1 10,000 Chloroform [Methane, trichloro-] 67-66-3 20,000 Chloromethyl ether [Methane, oxybis[chloro-] 542-88-1 1,000 Chloromethyl methyl ether [Methane, chloromethoxy-] 107-30-2 5,000 2-Chloropropylene [1-Propene, 2-chloro-] 557-98-2 10,000 1-Chloropropylene [1-Propene, 1-chloro-] 590-21-6 10,000 TABLE G (Continued)

Threshold Chemical Name CAS No. Quantity (lbs) Crotonaldehyde [2-Butenal] 4170-30-3 20,000 Crotonaldehyde, (E)- [2-Butenal, (E)-] 123-73-9 20,000 Cyanogen [Ethanedinitrile] 460-19-5 10,000 Cyanogen chloride 506-77-4 10,000 Cyclohexylamine [Cyclohexanamine] 108-91-8 15,000 Cyclopropane 75-19-4 10,000 Diborane 19287-45-7 2,500 Dichlorosilane [Silane, dichloro-] 4109-96-0 10,000 Difluoroethane [Ethane, 1,1-difluoro-] 75-37-6 10,000 Dimethyldichlorosilane [Silane, dichlorodimethyl-] 75-78-5 5,000 1,1-Dimethylhydrazine [Hydrazine, 1,1-dimethyl-] 57-14-7 15,000 Dimethylamine [Methanamine, N-methyl-] 124-40-3 10,000 2,2-Dimethylpropane [Propane, 2,2-dimethyl-] 463-82-1 10,000 Epichlorohydrin [Oxirane, (chloromethyl)-] 106-89-8 20,000 Ethane 74-84-0 10,000 Ethyl acetylene [1-Butyne] 107-00-6 10,000 Ethylamine [Ethanamine] 75-04-7 10,000 Ethyl chloride [Ethane, chloro-] 75-00-3 10,000 Ethylene [Ethene] 74-85-1 10,000 Ethylenediamine [1,2-Ethanediamine] 107-15-3 20,000 Ethyleneimine [Aziridine] 151-56-4 10,000 Ethylene oxide [Oxirane] 75-21-8 10,000 Ethyl ether [Ethane, 1,1'-oxybis-] 60-29-7 10,000 Ethyl mercaptan [Ethanethiol] 75-08-1 10,000 Ethyl nitrite [Nitrous acid, ethyl ester] 109-95-5 10,000 Fluorine 7782-41-4 1,000 Formaldehyde (solution) 50-00-0 15,000 Furan 110-00-9 5,000 Hydrazine 302-01-2 15,000 Hydrochloric acid (conc 30% or greater) 7647-01-0 15,000 Hydrocyanic acid 74-90-8 2,500 Hydrogen 1333-74-0 10,000 Hydrogen chloride (anhydrous) [Hydrochloric acid] 7647-01-0 5,000 Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] 7664-39-3 1,000 Hydrogen selenide 7783-07-5 500 Hydrogen sulfide 7783-06-4 10,000 Iron, pentacarbonyl- [Iron carbonyl (Fe(CO)5), (TB-5-11)-] 13463-40-6 2,500 Isobutane [Propane, 2-methyl] 75-28-5 10,000 Isobutyronitrile [Propanenitrile, 2-methyl-] 78-82-0 20,000 Isopentane [Butane, 2-methyl-] 78-78-4 10,000 Isoprene [1,3-Butadiene, 2-methyl-] 78-79-5 10,000 Isopropylamine [2-Propanamine] 75-31-0 10,000 Isopropyl chloride [Propane, 2-chloro-] 75-29-6 10,000 Isopropyl chloroformate [Carbonochloridic acid, 1-methylethyl ester] 108-23-6 15,000 Methacrylonitrile [2-Propenenitrile, 2-methyl-] 126-98-7 10,000 TABLE G (Continued)

Threshold Chemical Name CAS No. Quantity (lbs) Methane 74-82-8 10,000 Methylamine [Methanamine] 74-89-5 10,000 3-Methyl-1-butene 563-45-1 10,000 2-Methyl-1-butene 563-46-2 10,000 Methyl chloride [Methane, chloro-] 74-87-3 10,000 Methyl chloroformate [Carbonochloridic acid, methylester] 79-22-1 5,000 Methyl ether [Methane, oxybis-] 115-10-6 10,000 Methyl formate [Formic acid, methyl ester] 107-31-3 10,000 Methyl hydrazine [Hydrazine, methyl-] 60-34-4 15,000 Methyl isocyanate [Methane, isocyanato-] 624-83-9 10,000 Methyl mercaptan [Methanethiol] 74-93-1 10,000 2-Methylpropene [1-Propene, 2-methyl-] 115-11-7 10,000 Methyl thiocyanate [Thiocyanic acid, methyl ester] 556-64-9 20,000 Methyltrichlorosilane [Silane, trichloromethyl-] 75-79-6 5,000 Nickel carbonyl 13463-39-3 1,000 Nitric acid (conc 80% or greater) 7697-37-2 15,000 Nitric oxide [Nitrogen oxide (NO)] 10102-43-9 10,000 Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide] 8014-95-7 10,000 1,3-Pentadiene 504-60-9 10,000 Pentane 109-66-0 10,000 1-Pentene 109-67-1 10,000 2-Pentene, (E)- 646-04-8 10,000 2-Pentene, (Z)- 627-20-3 10,000 Peracetic acid [Ethaneperoxoic acid] 79-21-0 10,000 Perchloromethylmercaptan [Methanesulfenyl chloride, trichloro-] 594-42-3 10,000 Phosgene [Carbonic dichloride] 75-44-5 500 Phosphine 7803-51-2 5,000 Phosphorus oxychloride [Phosphoryl chloride] 10025-87-3 5,000 Phosphorus trichloride [Phosphorous trichloride] 7719-12-2 15,000 Piperidine 110-89-4 15,000 Propadiene [1,2-Propadiene] 463-49-0 10,000 Propane 74-98-6 10,000 Propionitrile [Propanenitrile] 107-12-0 10,000 Propyl chloroformate [Carbonochloridic acid, propylester] 109-61-5 15,000 Propylene [1-Propene] 115-07-1 10,000 Propyleneimine [Aziridine, 2-methyl-] 75-55-8 10,000 Propylene oxide [Oxirane, methyl-] 75-56-9 10,000 Propyne [1-Propyne] 74-99-7 10,000 Silane 7803-62-5 10,000 Sulfur dioxide (anhydrous) 7446-09-5 5,000 Sulfur tetrafluoride [Sulfur fluoride (SF4), (T-4)-] 7783-60-0 2,500 Sulfur trioxide 7446-11-9 10,000 Tetrafluoroethylene [Ethene, tetrafluoro-] 116-14-3 10,000 Tetramethyl lead [Plumbene, tetramethyl-] 75-74-1 10,000 Tetramethylsilane [Silane, tetramethyl-] 75-76-3 10,000 Tetranitromethane [methane, tetranitro-] 509-14-8 10,000 TABLE G (Continued)

Threshold Chemical Name CAS No. Quantity (lbs) Titanium tetrachloride [Titanium chloride (TiCl4) (T-4)-] 7550-45-0 2,500 Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-methyl-] 584-84-9 10,000 Toluene 2,6-diisocyanate [Benzene, 1,3-diisocyanato-2-methyl-] 91-08-7 10,000 Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-] 26471-62-5 10,000 Trichlorosilane [Silane, trichloro-] 10025-78-2 10,000 Trifluorochloroethylene [Ethene, chlorotrifluoro-] 79-38-9 10,000 Trimethylamine [Methanamine, N,N-dimethyl-] 75-50-3 10,000 Trimethylchlorosilane [Silane, chlorotrimethyl-] 75-77-4 10,000 Vinyl acetate monomer [Acetic acid ethenyl ester] 108-05-4 15,000 Vinyl acetylene [1-Buten-3-yne] 689-97-4 10,000 Vinyl chloride [Ethene, chloro-] 75-01-4 10,000 Vinyl ethyl ether [Ethene, ethoxy-] 109-92-2 10,000 Vinyl flouride [Ethene, fluoro-] 75-02-5 10,000 Vinylidene chloride [Ethene, 1,1-dichloro-] 75-35-4 10,000 Vinylidene flouride [Ethene, 1,1-difluoro-] 75-38-7 10,000 Vinyl methyl ether [Ethene, methoxy-] 107-25-5 10,000 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-09H 520 LAFAYETTE ROAD REQUIREMENTS: CAM (40 CFR pt. 64) ST. PAUL, MN 55155-4194 05/11/98

Compliance Assurance Monitoring (40 CFR pt. 64)

The CAM rule applies to facilities that operate emission control devices subject to federally enforceable regulations promulgated prior to 1990. These regulations are not limited to EPA regulations, but include any regulation that pertains to the Part 70 operating permit. This includes New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAP), and Minnesota Rules contained in the State Implementation Plan. To determine applicability, source owners need to answer the following questions pertaining to individual emissions units: • Is the unit located at a major source required to obtain a Part 70 permit? • Is the unit subject to an emission limitation or standard which is specified in a rule or regulation? • Is a control device used to achieve compliance with that limitation or standard? • Are the potential uncontrolled emissions of the controlled pollutant from the unit at least 100 percent of the major source threshold amount? (As of the date of this fact sheet, “major source threshold amount” as it applies to Minnesota, means 100 tons per year of particulate matter (PM10), sulfur dioxide (SO2), nitrogen oxides (NOX), volatile organic compounds (VOC), carbon monoxide (CO), or lead; 10 tons per year of any hazardous air pollutant (HAP); or 25 tons per year of any combination of HAPs. The levels may be different in current or future nonattainment areas. Refer to 40 CFR § 70.2 under the definition of “major source” for further detail.) CAM applies if the answers to all of these questions is “yes.”

DEADLINES FOR SUBMITTALS Those emissions units with the potential to emit a regulated air pollutant equal to or greater than the major source threshold amount (after effects of control equipment are considered) shall make the required CAM submittals as follows: 1. If the initial Part 70 permit application has not been submitted by April 20, 1998, the owner or operator shall submit CAM information as part of the initial application. 2. On or after April 20, 1998, the owner or operator shall submit CAM information as part of any application for a major amendment to a Part 70 permit, but only with respect to those emissions units for which the proposed amendment is applicable. The owner or operator shall submit any information not submitted under the above deadlines as part of the application for the reissuance of the Part 70 permit. For those emissions units where the potential to emit a regulated air pollutant is below the major source threshold amount after control equipment is taken into account, the information required by the CAM rule shall be submitted with the next application for reissuance of a Part 70 permit. It is not anticipated that Minnesota facilities subject to the CAM rule will be required to take any steps to implement CAM until reissuance of their Part 70 permit, unless they apply for a major amendment to their existing Part 70 permit.

HOW CAM WORKS The Permittee must submit the required information to the MPCA. The CAM submittal should include: • information on indicators (gauges, meters, or other devices used to monitor operating parameters of control equipment) • indicator ranges, or the process by which indicators are to be established • performance criteria • justification for the proposed monitoring • control device operating data recorded during a performance test, supplemented by engineering assessments or manufacturer’s recommendations to justify the proposed indicator range • a test plan and schedule for obtaining data if performance test data are not available • an implementation plan, if monitoring requires installation, testing or other activities prior to implementation The next step is review and approval by the MPCA. If additional information or corrections are required, the MPCA will notify the Permittee that the CAM submittal must be revised or supplemented. If the CAM submittal is determined to be complete and acceptable, the MPCA will establish permit terms for the affected emissions unit. After approval and incorporation of the CAM requirements into the permit, owners and operators of affected units must implement the monitoring upon issuance of the permit, unless the permit specifies a later date.

EXEMPTIONS The CAM rule does not apply to: 1. Units subject to federal regulations issued after 1990. In situations where some portions of a facility operate control devices in order to comply with emission standards issued prior to 1990, only those portions of the facility must comply with the requirements of the CAM rule. 2. Situations where continuous compliance monitoring is already specified in an operating permit. The CAM rule exempts the Permittee from additional monitoring requirements and directs the Permittee to use the continuous compliance monitoring data to fulfill the CAM rule monitoring and certification requirements. 3. Stratospheric ozone protection requirements 4. Acid Rain Program requirements 5. Emission limitations or standards that apply solely under an emissions trading program 6. Municipally-owned utility peak-shaving units where Þ the unit is exempt from all Acid Rain Program monitoring requirements, and Þ the unit operates for the sole purpose of providing electricity during periods of peak electrical demand or emergency situations, and Þ the unit will be operated consistent with that purpose throughout the permit term, and Þ emissions from the unit are less than 50 tons per year.

For additional information, please refer to the CAM rule at 40 CFR pt. 64. MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY PERMIT APPLICATION FORM GI-09I 520 LAFAYETTE ROAD REQUIREMENTS: STATE RULES ST. PAUL, MN 55155-4194 05/11/98

Minnesota State Air Quality Rules

Some businesses and activities in Minnesota are subject to the following rules. Read each question to determine if the rule applies to you.

1) Minnesota Air Pollution Episodes (Minn. R. 7009.1000-7009.1110)

1a) After your facility is permitted, will your facility be allowed to emit more than 250 tons per year of any one of the following pollutants: particulate matter, sulfur dioxide, nitrogen oxides, ozone [volatile organic compounds], carbon monoxide, or non-methane hydrocarbons? No, my facility is not subject to the Minn. R. 7009.1000-7009.1110. Yes, my facility is subject to the Minn. R. 7009.1000-7009.1110

2) Minnesota Standards of Performance for Stationary Sources (Minn. R. ch. 7011)

2a) Does your facility have any equipment that meets the following definition?

"A furnace, boiler or other combustion equipment in Minnesota which burns fossil fuel for the purpose of producing steam, hot water, hot air, or other hot liquid, gas, or solid, where the smoke doesn't have direct contact with the heated medium for which another standard of performance has not been promulgated."

No, my facility is not subject to Minn. R. 7011.0500-7011.0550. Go to question 2b. Yes, my facility is subject to Minn. R. 7011.0500-7011.0550. Standards of Performance for Indirect Heating Fossil-Fuel Burning Equipment. (Read the rule to determine the specific requirements that apply to your facility.)

2b) Is your facility type or process equipment found in Table H on pages 6 and 7? No, none of the Minnesota Rules listed in Table H apply to my facility. Go to question 3. Yes, my facility or process equipment may be subject to the rule associated with it in Table H. Read the associated rule to see if it applies. NOTE: the starred performance standards indicate Minnesota Rules that incorporate by reference federal New Source Performance Standards (NSPS) and/or National Emission Standards for Hazardous Air Pollutants (NESHAP). To comply with these state rules, you must comply with the federal NSPS and/or NESHAP.

2c) After reading through Table H and any rule that may apply to your facility or equipment, list the ones that do apply to your air emission source(s) below. You do not need to list the Standards of Performance for Indirect Heating Fossil-Fuel Burning Equipment again, if it applies (see 2a, above). Minnesota Rule Part that What the Rule Part Applies to (Whole facility or Specific Emission Unit Applies Piece of Equipment) ID Number 7011.0570 boiler 002 7011.2300 generator 022

(DUPLICATE THIS TABLE AS NEEDED)

3) Minnesota Acid Deposition Control (Minn. R. 7021.0050)

3a) Does your facility generate electricity? No. My facility is not subject to Acid Deposition Control Requirements. Go to question 4. Yes. Go to question 3b.

3b) Does your facility contain indirect heating equipment with a rated heat input of more than 5,000 million BTUs per hour? No. Go to question 3c. Yes. My facility is subject to Acid Deposition Control Requirements.

3c) If your facility is an electric utility, is the total generating capacity of all the electric generating facilities in Minnesota which are owned by your facility’s parent company more than 1,000 megawatts? No. My facility is not subject to Acid Deposition Control Requirements. Yes. My facility is subject to Acid Deposition Control Requirements. 4) Standards of Performance for Industrial Process Equipment (Minn. R. 7011.0700 - 7011.0735)

4a) Do you have any industrial process equipment on-site that generates particulate matter (i.e. dust, smoke, or gaseous material) in any amount and is not regulated by another Standard of Performance (NSPS, NESHAP, or MN Rules Standard of Performance)? No, my equipment is not subject to this rule. Go to question 6. Yes. Go to 4b.

4b) Opacity Standard (Note: Opacity is a measure of visible emissions or how much of the view is obscured by stack emissions. The emissions causing opacity are often smoke or dust.)

For industrial process equipment which was in operation before July 9, 1969, the equipment shall not exhibit greater than 20 percent opacity, except that a maximum of 60 percent opacity shall be permissible for four minutes in any 60 minute period and a maximum of 40 percent opacity shall be permissible for four additional minutes in any 60 minute period.

For industrial process equipment which was not in operation before July 9, 1969, the equipment shall not exhibit greater than 20 percent opacity.

4c) Does the industrial process equipment have particulate control equipment with a collection efficiency of at least 99 percent if it was in operation before July 9, 1969, or 99.7 percent if it was not in operation before July 9, 1969? No. Go to question 4d. Yes. My equipment is not subject to the remaining requirements of this rule. Go to question 6.

4d) Is the industrial process equipment located outside of the seven county Minneapolis-St. Paul metropolitan region AND outside of the city of Duluth AND at least 1/4 mile from any residence or public roadway, AND does the industrial process equipment have particulate control equipment with a collection efficiency of at least 85 percent AND is the operation of the entire facility in compliance with all ambient air quality standards? No, my equipment is subject to the remaining requirements. Go to the attached Table I. Yes, my equipment is not subject to the remaining requirements of this rule. Go to question 6. 5) Waste Combustors (Minn. Rules 7011.1201-7011.1290)

Note: Depending on the type of waste combustor you operate, you may be instructed to fill out one or more of the following forms:

WC-01 -- Required if you determine that your waste combustor requires a permit. WC-02 -- Required if you install/operate a Class IV waste combustor at a hospital. WC-03 -- Required if you do not met the stack height requirements of Minn. R. 7011.1235.

If after reading through the following section, you determine that you are required to fill out one or more of the WC forms, contact the Air Quality Permit Document Coordinator.

5a) Do you operate a waste combustor?

“Waste Combustor” means any emissions unit or emission facility where mixed municipal solid waste, solid waste, or refuse-derived fuel is combusted, and includes incinerators, energy recovery facilities, or other combustion devices. A metals recovery incinerator is a waste combustor. A combustion device combusting primarily wood, or at least 70 percent fossil fuel and wood in combination with up to 30 percent papermill wastewater treatment plant sludge is not a waste combustor. A soil treatment facility, paint burn-off oven, wood heater, or residential fireplace is not a waste combustor.

“Wood” is defined as: wood, wood residue, bark, or any derivative fuel or residue thereof, in any form, including sawdust, sander dust, wood chips, wood scraps, slabs, millings, shavings, and processed pellets made from wood and other forest residues.

A facility that is co-firing RDF or MSW at rates less than 30 percent by weight is not regulated as a waste combustor, but is regulated as a boiler.

Yes, I operate a waste combustor. Answer questions 5b through 5e to determine whether you are allowed to continue to operate, and what type of permit the waste combustor requires. Allowed waste combustors must obtain an air emissions permit. No, the facility equipment is not subject to this rule. Go to question 6.

5b) Is the waste combustor solely a crematory, pathological or an animal carcass incinerator?

Yes. It is subject to standards of performance in 7011.1215, subp. 3. The waste combustor is an insignificant activity that does not need to be reported. Go to question 6. No, the facility equipment is not subject to this rule. Go to question 6. 5c) Is the design capacity of the waste combustor equal to or greater than 3 million Btu/hr?

“Design capacity” means: the hourly throughput of the waste combustor unit based on heat input from solid waste to the combustion system as stated by the manufacturer or designer, based on accepted design and engineering practices. For a non-continuous feed system, design capacity means the total heat input from solid waste per cycle.

If you don’t have a manufacturer’s design capacity in terms of heat input, you may estimate heat input by the following formula:

Hin = (HHV) x (R)

Where: Hin = Heat input rate HHV = heat value of waste R = waste input rate, in lb/hr, as defined by the manufacturer Commercial/Retail/Institutional Wastes = 7000 Btu/lb General Industrial Wastes = 9000 Btu/lb Medical/Infectious Wastes = 10,000 Btu/lb

Yes, the waste combustor has a design capacity of 3 million Btu/hr or greater. The waste combustor is subject to the standards of performance applicable to waste combustors. There are also additional permit application requirements for this unit, as described in Minn. R. 7007.0501, or 7011.1210. Complete form WC-01. No, the heat input rate is below 3 million Btu/hr. Go to question 5d.

5d) Is the waste combustor used as a metal recover incinerator?

“Metals recovery incinerator” means a furnace or incinerator used primarily to recover precious and non-precious metals by burning the combustible fraction from waste. An aluminum sweat furnace is not a metals recovery incinerator.

Yes. The waste combustor is subject to the standards of performance applicable to waste combustors. There are also additional permit application requirements for this unit, as described in Minn. R. 7007.0501, or 7011.1210. Complete form WC-01. No. Go to question 5e.

5e) Is the waste combustor located at a hospital?

Yes. The waste combustor is subject to the standards of performance applicable to Class IV waste combustors. There are also additional permit application requirements for this unit, as described in Minn. R. 7007.0501, or 7011.1210. Complete form WC-02 if the waste combustor will comply with all of the design, operating, and standards of performance in parts 7011.1201 to 7011.1290. Otherwise, an air emissions permit must be issued, and you must complete for WC-01. [Please Note: There are federal Standards of Performance that must also be met for new sources (see Form GI-09D), and the state will be adopting more stringent standards for existing incinerators by December of 1998.] No, the waste combustor is not located at a hospital. The operation of this waste combustor was banned after January 30, 1996. Your compliance plan must contain specific steps to cease operation of this waste combustor.

6) Return to Form GI-09 REQUIREMENTS, question 11b. Table H: Minnesota Standards of Performance for Stationary Sources

Facility or Equipment Type Associated Minnesota Rule *Steam Generating Units 7011.0555 through 7011.0570 Direct Heating Equipment 7011.0600 through 7011.0610 *Portland Cement Plants 7011.0800 through 7011.0830 *Asphalt Concrete Plants 7011.0900 through 7011.0925 *Asphalt Processing and Roofing Manufacture 7011.0950 *Grain Elevators 7011.1000 through 7011.1015 Coal Handling Facilities 7011.1100 through 7011.1140 *Coal Preparation Plants 7011.1150 Incinerators (waste combustors) 7011.1201 through 7011.1207 *Sewage Sludge Incinerators 7011.1300 through 7011.1350 *Petroleum Refineries 7011.1400 through 7011.1435, and 7011.7280 *Liquid Petroleum and VOC Storage Vessels 7011.1500 through 7011.1520 *Bulk Gasoline Terminals 7011.1550, 7011.7180 *Sulfuric Acid Plants 7011.1600 through 7011.1635 *Nitric Acid Plants 7011.1700 through 7011.1730 *Lead Smelters 7011.1800 through 7011.1820 and 7011.7240 *Copper Smelters 7011.1840 and 7011.9910 *Zinc Smelters 7011.1880 *Brass and Bronze Plants 7011.1900 through 7011.1920 *Iron and Steel Plants 7011.2000 through 7011.2020 *Primary Aluminum Reduction Plants 7011.2050 *Ferroalloy Production Facilities 7011.2080 Inorganic Fibrous Materials 7011.2100 through 7011.2105 Stationary Internal Combustion Engine (Generators) 7011.2300 *Stationary Gas Turbines 7011.2350 *Phosphate Fertilizer Industry 7011.2400 *Kraft Pulp Mills 7011.2450 *Glass Manufacturing Plants 7011.2500 and 7011.9910 *Surface Coating 7011.2550 through 7011.2580 *Lime Manufacturing Plants 7011.2600 *Lead-acid Battery Manufacturing Plants 7011.2650 *Metallic Mineral Processing Plants 7011.2700 *Phosphate Rock Plants 7011.2750 *Ammonium Sulfate Manufacture 7011.2800 *Graphic Arts Industry 7011.2850 *Synthetic Organic Chemicals Manufacturing Industry 7011.2900 and 7011.7040 through 7011.7060 *Residential Wood Heaters 7011.2950 *Rubber Tire Manufacturing Industry 7011.3000 *Polymer Manufacturing Industry 7011.3050 *Polymeric Coating of Substrates Facilities 7011.3100 *Flexible Vinyl and Urethane Coating and Printing 7011.3150 *Synthetic Fiber Production Facilities 7011.3200 *Petroleum Dry Cleaners 7011.3250 *Onshore Natural Gas Processing Plants 7011.3300 *Non-Metallic Mineral Processing Plants 7011.3350 *Wool Fiberglass Insulation Manufacturing Plants 7011.3400 *Magnetic Tape Manufacturing and Coating Facilities 7011.3450 and 7011.7300 * Denotes Minnesota Rule(s) which incorporate federal NSPS and/or NESHAP requirements by reference. Table H (continued)

*Municipal Solid Waste Landfills 7011.3500 through 7011.3510 * Emissions from Coke Oven Batteries 7011.7080 * Emissions from Perchloroethylene Dry Cleaners 7011.7100 * Chromium Emissions from and Decorative Chromium Electroplating and 7011.7120 Chromium Anodizing Tanks *Ethylene Oxide Emissions from Sterilization Facilities 7011.7140 * Industrial Process Cooling Towers 7011.7160 *Halogenated Solvent Cleaning 7011.7200 *Epoxy Resins Production and Non-Nylon Polyamides Production 7011.7220 *Marine Tank Vessel Loading Operations 7011.7260 *Aerospace Manufacturing and Rework Facilities 7011.7320 *Arsenic Trioxide and Metallic Arsenic Production Facilities 7011.9910 *Asbestos 7011.9920 *Benzene Emissions 7011.9930 *Beryllium 7011.9940 *Mercury 7011.9950 *Radon 7011.9960 *Radionuclides 7011.9970 *Vinyl Chloride 7011.9980 *Volatile Hazardous Air Pollutants 7011.9990 * Denotes Minnesota Rule(s) which incorporate federal NSPS and/or NESHAP requirements by reference. TABLE I: INSTRUCTIONS FOR DETERMINING YOUR PARTICULATE LIMIT

Minnesota has a State rule for the concentration of particulate matter that may be in your exhaust stream. The unit of the standard is grains per dry standard cubic foot. You need to convert your actual exhaust flow to dry standard cubic feet per minute to find the emission limit from the rule.

Sources subject to this rule are required to meet the emission limits established at all times. These limits will vary depending on operating conditions. To determine compliance at any point in time (i.e. for a stack test), follow the steps below:

1. Determine the amount of dry material (subtract any water or moisture content) in pounds per hour that is processed by your equipment.

2. Use Table I.1 to determine your allowed emission rate based on process weight rate. If your process weight rate falls between two values on the table, interpolate or extrapolate using the equation:

æ P ö 0.62 E3.59=×ç ÷ for P ≤ 60,000 lbs/hour; and: è 2000ø

æ P ö 0.16 E1=×731. ç ÷ for P > 60,000 lbs/hour è 2000ø

where: E = emission rate in lbs/hour; and P = process weight rate in lbs/hour

3. If your process equipment is vented to the atmosphere, determine the airflow through your stack. Correct to 68 F and 14.7 psi, and correct to remove any moisture in the gas stream to obtain the air flow in dry standard cubic feet per minute (dscfm).

4. Use Table I.2 to determine your allowed concentration in grains per dry standard cubic foot (gr/dscf). Interpolate using the equation:

− c=× 1.7627 V 0.3241

where: c = concentration in gr/dscf, V = gas volume in dscfm

5. Determine which of the two emission rates calculated above is less stringent. To convert a concentration (calculated in step 4) to an emission rate (calculated in step 2), use the following equation:

æ 60 ö E=c×× V ç ÷ è 7000ø where: E = emission rate in lbs/hour; c = concentration in gr/dscf, V = gas volume in dscfm Table I.1 Table I.2 Process Rate (lbs/hour) Emission Rate Source Gas Volume Concentration (lbs/hour) (dscfm) (gr/dscf)

50 0.08 7,000 or less 0.100 100 0.55 8,000 0.096 500 1.53 9,000 0.092 1,000 2.25 10,000 0.089 5,000 6.34 10,000 9.73 20,000 0.071 20,000 14.99 30,000 0.062 60,000 29.60 40,000 0.057 80,000 31.19 50,000 0.053 120,000 33.28 60,000 0.050 160,000 34.85 200,000 36.11 80,000 0.045 400,000 40.35 100,000 0.042 1,000,000 46.72 120,000 0.040 140,000 0.038 160,000 0.036 180,000 0.035 200,000 0.034

300,000 0.030 400,000 0.027 500,000 0.025 600,000 0.024

800,000 0.021 1,000,000 or more 0.020

Regardless of the allowable emission rates calculated from Tables I.1 and I.2, no process equipment is allowed to emit more than 0.30 grains per standard cubic foot of .

Appendix 6-A Fact Sheet: Control Equipment Standards

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Page 6A - 1

Minnesota Pollution Control Agency

AQ Doc. # 4.07 March 1998

Facts about Control Equipment Performance Standards

not choose to use this rule are not subject to The Minnesota Pollution Control Agency the requirements of the rule. rules (Minn. R. pts. 7011.0060 to 7011.0080) allow facilities with certain types of pollution Facilities can only use this rule to determine control equipment to take emission reductions the type of permit needed. This rule cannot be into consideration and reduce the permitting used to avoid permitting altogether. For requirements of the facility. example, once a facility has determined that an air emissions permit is needed, then the What are the advantages of rule may be used to apply for an option D using this rule? registration permit instead of a state or part 70 permit. You may use this rule to calculate your facility’s potential-to-emit (PTE) in order to What types of control equipment avoid New Source Review (NSR); get a state permit instead of a part 70 permit; and/or are in the rule? allow your facility to get an option D The table on page two defines the types of registration permit instead of a more complex pollution control equipment that are assigned state or part 70 permit. a control efficiency under this rule. You may also use this rule to calculate your Table A on page 2 lists the pollutants for facility’s emission rate change resulting from which a control efficiency has been assigned a proposed modification. This may allow you and the control efficiency (percent emission to apply for a minor or moderate amendment reduction) that the facility is allowed to claim instead of a major amendment. Or you may when applying for a permit or permit determine that the change is an insignificant amendment. modification and may require no permit The assigned control efficiency does not apply amendment. to hazardous air pollutants (HAPs). The This rule is used primarily for facility facility is allowed to assign a control modifications/permit amendments and for efficiency for hazardous air pollutants only option D registration permits. The result of after an efficiency has been demonstrated by these reduced permitting requirements will conducting a performance test approved by save eligible facilities time and money. the commissioner under Minn. R. pts. 7017.2001 to 7017.2060. Who is subject to the rule? If you choose to use this rule to limit your facility’s potential-to-emit, you are subject to the requirements of the rule. Facilities that do TABLE A CONTROL EQUIPMENT EFFICIENCY

Control Equipment Description Pollutant Control Efficiency Total Hood Enclosure PM CONTROL CATEGORY - CYCLONES means a device where airflow is forced to spin in a vortex through a tube.

Centrifugal Collector (cyclone) - high efficiency - a cyclonic PM, PM10 80% 64% device with parameters stated in drawing 1 and table B

Centrifugal Collector (cyclone) - medium efficiency - a cy- PM, PM10 50% 40% clonic device with parameters stated in drawing 1 and table B

Centrifugal Collector (cyclone) - low efficiency - a cyclonic PM, PM10 10% 8% device with parameters stated in drawing 1 and table B

Multiple Cyclone without Fly Ash Re-injection - a cyclonic PM, PM10 80% NA device with more than one tube where fly ash isn’t reinjected

Multiple Cyclone with Fly Ash Re-injection - a cyclonic PM, PM10 50% NA device with more than one tube where fly ash is re-injected

Wet Cyclone Separator or Cyclonic Scrubbers - a cyclonic PM, PM10 50% 40% device that sprays water into a cyclone. PM CONTROL CATEGORY - ELECTROSTATIC PRECIPITATORS Control devices in which incoming particulate matter receives an electrical charge and is then collected on a surface with the opposite electrical charge.

- assumed efficiency for boiler fly ash control PM, PM10 40% NA - assumed efficiency for other applications PM, PM10 70% 56% PM CONTROL CATEGORY - OTHER CONTROLS

Fabric Filter - the incoming gas stream to the filter passes PM, PM10 99% 79% through a porous fabric filter forming a dust cake

Spray Tower - the incoming gas stream to the tower passes PM, PM10 20% 16% through a chamber in which it contacts a liquid spray

Venturi Scrubber - the incoming gas stream to the scrubber PM, PM10 90% 72% passes though a venturi into which low pressure liquid is introduced

Impingement Plate Scrubber - the incoming gas stream to the PM, PM10 25% 20% scrubber passes a liquid spray and is then directed at high velocity into a plate

HEPA and other Wall Filters - removable panels for cleaning PM, PM10 92% 74% and replacement, or liquid curtains for particulate removal that provide little resistance to air flow VOC CONTROL CATEGORY Afterburners (thermal or catalytic oxidation) - devices used VOC 95% 57% to reduce VOCs to the products of combustion through thermal (high temperature) oxidation or catalytic (use of a catalyst) oxidation in a combustion chamber Flaring or Direct Combustor - a device in which air, VOC 98% 59% combustible organic waste gases, and supplementary fuel (if needed) react in the flame zone (e.g., at the flare tip) to destroy the VOCs Table A also lists two different control efficiencies: one for a Cyclone Design pollution control system that uses a total enclosure to capture the emissions from the source and another that uses a hood as the De capture device. w The control efficiency for a system that uses a hood is 80 s percent of a system that uses a H total enclosure because hood systems are assigned a capture efficiency of 80 percent instead of 100 percent for total enclosures. D The facility must evaluate and certify the design and operating characteristics of hood systems in order to claim the assigned control efficiency. The system If I have control equipment that is not must comply with the design and operating practices recommended listed in Table A, may I consider its in “Industrial Ventilation - A control efficiency when calculating PTE? Manual of Recommended In general no. However, if you have an Option D permit Practice, American Conference of and have conducted a performance test, the control Governmental Industrial equipment may be eligible. Hygienists.” TABLE B

Ratio Dimensions High Efficiency Medium Efficiency Low Efficiency

Height of inlet, H/D 0.44 > 0.44 and < 0.8 0.8

Width of inlet, W/D 0.2 > 0.2 and < 0.375 0.375

Diameter of gas exit, De/D 0.4 > 0.4 and < 0.75 0.75

Length of vortex finder, S/D 0.5 >0.5 and < 0.875 0.875

If one or more of the “ratio dimensions,” as listed in Table B, are in a different efficiency category (high, medium, low), then the lowest efficiency category shall be applied. Will I have any monitoring and/or recordkeeping responsibilities if I choose to use this rule? Yes. A condition of being able to claim the assigned control efficiency for the pollution control equipment is that the equipment must be operated and maintained in accordance with the rule and the manufacturer’s specifications for the control equipment. You must have the pollution control equipment manufacturer’s specifications to take advantage of this rule. You must also monitor control equipment operating parameters and keep records as specified in Table C.

Who do I contact if I have any question about this rule? Questions regarding this rule may be directed to the Permit Technical Advisor at (651) 282- 5844 or, toll-free at (800) 646-6247. TABLE C Control Equipment Monitoring Requirements

Pollution Control Monitoring Parameters Recordkeeping Requirement Equipment Type Centrifugal Collector Pressure drop Record pressure drop every 24 (Cyclone) hours if in operation Electrostatic Precipitator Primary and secondary voltage; Record each parameter every 24 primary and secondary current; hours if in operation sparking rate; and no. fields on line Fabric Filter (Bag Pressure drop Record pressure drop every 24 House) hours if in operation Spray Tower Liquid flow rate and pressure drop Record each parameter every 24 hours if in operation Venturi or Impingement Pressure drop and liquid flow rate Record each parameter every 24 Plate Scrubber hours if in operation HEPA & Other Wall Condition of the filters including, Record of filter(s) condition every Filters but not limited to, alignment; 24 hours if in operation saturation; and tears and holes Wet Cyclone Separator Pressure drop; and water pressure Record each parameter every 24 hours if in operation Thermal Incinerator Combustion temperature or inlet and Continuous hard-copy readout of outlet temperatures temperatures or manual readings every 15 minutes Catalytic Incinerator Inlet and outlet temperatures; and Continuous hard-copy readout of catalyst bed reactivity as per temperatures or manual readings manufacturer’s specifications every 15 minutes; and results of catalyst bed reactivity Flaring Temperature indicating presence of a Continuous hard-copy readout of flame temperatures or manual readings every 15 minutes

Acronyms APO Administrative Penalty Order AQ Air Quality BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CAS Chemical Abstracts Services CEM Continuous Emission Monitor CFR Code of Federal Regulations EAW Environmental Assessment Worksheet EIS Environmental Impact Statement EPRO Environmental Review and Planning Office EPA Environmental Protection Agency EQB Environmental Quality Board HAPs Hazardous Air Pollutants LAER Lowest Achievable Emission Rate LOW Letter of Warning MAAQS Minnesota Ambient Air Quality Standards MACT Maximum Achievable Control Technology MnTAP Minnesota Technical Assistance Program MPCA Minnesota Pollution Control Agency MSDS Material Safety Data Sheet NAAQS National Ambient Air Quality Standards NESHAPs National Emission Standards for Hazardous Air Pollutants NOV Notice of Violation NSPS New Source Performance Standard NSR New Source Review POTW Publicly Owned Treatment Works PSD Prevention of Significant Deterioration PTE Potential to Emit RACT Reasonable Available Control Technology SIC Standard Industrial Classification SIP State Implementation Plan

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Acronyms - 1

Glossary acfm - actual cubic feet per minute. A measurement of the rate of exhaust (volume per unit of time) from an emission unit or emission facility. actual emissions - amount of pollutants that are emitted from a stationary source, emission unit, or emission facility over a given period of time. affected facility - facility or emission unit subject to a New Source Performance Standard (NSPS). The affected facilities for each NSPS are outlined in that NSPS. affected source - emission source that is subject to Title IV (Acid Rain). (Minn. R. 7007.0100, subp. 4) affected state - any state located adjacent to Minnesota and whose air can be affected by Minnesota's activities, or any state that is within 50 miles of a permitted source (Minn. R. 7007.0100, subp. 5) affected unit - an emission unit that is subject to Title IV (Acid Rain) (Minn. R. 7007.0100, subp. 6) air toxics - any pollutant, other than the six criteria pollutants, that scientists believe have the potential to cause adverse environmental or health effects. administrative penalty order - an enforcement action used by the MPCA that requires violations to be corrected within 30 days; penalties can be assessed up to $10,000. administrative permit amendment - amendment to correct typographical errors; change company name or ownership or mailing address and other simple changes to a permit that do not change emissions. An administrative permit amendment does not require formal application, and can be initiated by either the permittee or the MPCA. air emission permit - legal document that describes a facility and also how the facility is meeting federal and state air quality regulations. A permit also authorizes construction and operation of a facility. alternative operating scenarios - terms and conditions in an air emission permit that allow planned changes to a facility's operating conditions. These must be identified by the permittee when applying for a permit (Minn. R. 7007.0800, subp. 11) ambient air quality standards - Minnesota (MAAQS) - air quality standards established by the state of Minnesota that apply to outside air in Minnesota. National (NAAQS) - air quality standards established by EPA that apply to outside air throughout the country. applicable requirements - all air quality rules and regulations that apply to emission units in a facility (Minn. R. 7007.0100 subp. 7). application shield - with some exceptions, allows an existing facility that is operating on the effective date of the permit rule and has submitted a complete and timely application to continue operating before the facility's air emission permit is issued (Minn. R. 7007.0350, subp. 3).

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Glossary - 1 attainment area - geographic area considered to have air quality as good as or better than the national ambient air quality standards as defined in the Clean Air Act. An area can be an attainment area for one pollutant and a nonattainment area for others (see nonattainment area). begin actual construction - start of on-site physical construction or other activities in preparation for a planned modification to a facility. Examples include, but are not limited to, installation of building supports and foundations, laying of underground pipework, and construction of permanent storage structures (Minn. R. 7005.0100, subp. 3a). Best Available Control Technology (BACT) - emission limitation based on the maximum degree of emission reduction that can be achieved through application of production processes and available methods, systems and techniques while also considering energy, environmental and economic impacts, and other costs. bottleneck - physical or operational limitation that is part of the design of an emission facility or emission unit. Bottlenecks prevent operation of equipment at 100% of capacity, and can be considered in potential to emit (PTE) calculations when determining if a permit is needed. Clean Air Act - federal law that regulates air pollution in the United States. Clean Air Act Amendments - revisions made in 1990 to the Federal Clean Air Act. carbon monoxide - colorless, odorless gas that is toxic because of its tendency to reduce the oxygen-carrying capacity of the blood. Code of Federal Regulations - regulations published by the Executive departments and agencies of the federal government. The Code of Federal Regulations (CFR) is revised annually as a set of paperback books, and is available in libraries. Title 40 of the CFR contains all federal rules and regulations relating to Protection of the Environment. completeness review administrative - MPCA review confirming that a permit application is submitted on standard forms and is properly organized. technical - MPCA review confirming that the technical details of a permit application are complete and accurate. compliance agreement - a negotiated settlement between a facility and the MPCA that includes a schedule of corrective action (see stipulation agreement). compliance assurance monitoring (CAM) - the methods used to determine continuous compliance with standards and limitations that apply to a facility. compliance certification - portion of a permit application that outlines a facility’s compliance status for all air quality rules and regulations that apply. A responsible official must certify that the compliance certification is accurate and complete (see responsible official). Compliance certifications are also required on an annual basis after the permit is issued. compliance plan - plan in an air emission permit that shows how a facility will be in compliance with the air quality rules and regulations that apply to the facility. A compliance plan includes specific monitoring, record keeping, reporting, and operation and maintenance procedures that must be followed during the life of a permit.

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Glossary - 2 compliance schedule - negotiated agreement between a facility and a government agency that specifies dates and procedures by which a facility will reduce emissions, and thereby, comply with a regulation. construction - any fabrication, erection, or installation of an emission facility, emission unit or stationary source (Minn. R. 7005.0100, subp. 5; also see begin actual construction). construction permit - permit to construct (not operate) a source (see installation and operation permit). continuous compliance - compliance status of a facility when monitoring data show the facility to be operating within emission limits and standards throughout a specified reporting period. corrective action - activities undertaken to correct air quality violation(s). criteria pollutants - six pollutants (ozone, carbon monoxide, total suspended particulates, sulfur dioxide, lead, and nitrogen oxide) determined by the US EPA to be hazardous to human health. The term "criteria pollutants" comes from the requirement that EPA must describe the characteristics and potential health and welfare effects of these pollutants. It is on the basis of these criteria that air quality standards are established. dscfm - dry standard cubic feet per minute. A measurement of the volume of air per unit of time exhausted from an emission unit or emission facility (see acfm), corrected to account for the temperature and moisture content being different from "standard conditions." deviation - departure from permit limits or conditions that may or may not endanger human health or the environment. Facilities are required to report deviations in their air permits within schedules contained in Minn. R. 7007.0800, subp. 6. dispersion modeling - analysis of a facility's air emission data using computer programs to estimate the affects of emissions on the surrounding air. emission - pollution discharged into the atmosphere from smokestacks, other vents, and surface areas of commercial or industrial facilities. emission facility - any group of activities and/or equipment that can cause pollutants to be released into the air. Emission facilities are made up of emission units and are contained within stationary sources (Minn. R. 7005.0100, subp. 10). emission factor - number that describes the relationship between the amount of raw material processed in an emission unit and the amount of pollution produced from the emission unit. For example, an emission factor for a gas-fired boiler would be pounds of NOx produced per million cubic feet of gas burned. emission limit - restriction on the amount of a particular pollutant that can be released from an emission unit or emission facility over a given period of time. Emission limits are commonly expressed as a concentration (grains per dry standard cubic foot) or rate (pounds per hour). emission point - where air pollutants are emitted to the outside air from a facility (e.g., a stack or vent). One or more emission units may exhaust at an emission point. emission source - (see emission unit).

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Glossary - 3 emission thresholds - levels of emission rates (pounds/hour or tons/year) above which certain rules or permit requirements apply. emission trading - EPA policy that allows a facility to increase and decrease emissions of the same pollutant among several emission units provided that total facility emissions do not increase. Emission trades cannot result in a Title I modification or violate any applicable requirement (see operational flexibility). emission unit - an identifiable piece of equipment or process that emits air pollution. Examples include a boiler, a coal storage pile, a parts washer or any activity or equipment that can cause pollutants to be released. enforcement waiver - in some cases, protection from potential enforcement actions for not holding a permit in the past for facilities that should have had one. Environment Assessment Worksheet (EAW) - tool of environmental review. It may be mandatory, meaning the project falls into a category specified in Minnesota rules, or it may be ordered when facts indicate the project "may have the potential for significant environmental effects." An EAW is required by Minnesota rules when the construction or modification of a stationary source results in an increase of 100 tons per year or more of a single air pollutant, after pollution control equipment is considered, or under any of the other conditions listed under Minn. R. 4410.4300. The EAW process typically takes six months to complete. Environment Impact Statement (EIS) - the more intensive part of environmental review. An EIS is not always required, but is mandatory under the conditions listed in Minn. R. 4410.4400. The EIS is required when the project is such that it is inevitable that it will have some impact on the environment. The EIS process typically takes 9-12 months to complete. environmental review - process that provides information to units of government on the environmental impacts of a project before approvals or permits are issued. It creates the opportunity to anticipate and correct potential adverse affects on the environment due to a project (see Environmental Assessment Worksheet and Environmental Impact Statement). fugitive emissions - emissions that are not and cannot be contained or collected and emitted through a stack or vent. Examples are unpaved roads and outdoor storage piles. The determination of whether an emission is fugitive is often made on a case-by-case basis. (Minn. R. 7005.0100, subp. 11c) general permit - permit for a class or category of facilities. gr/dscf - grains per dry standard cubic foot. A unit of measurement of the concentration of a pollutant in flue or exhaust gas. There are 7000 grains in a pound. Hazardous Air Pollutants (HAPs) - group of pollutants regulated by the US EPA, other than the six criteria pollutants, that scientists believe have the potential to cause adverse environmental or health effects. insignificant activities - activities that do not require permitting. Some insignificant activities are required to be listed in a permit application for facilities otherwise required to obtain a permit (Minn. R. 7007.1300).

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Glossary - 4 insignificant modification - constructing or beginning an activity or emission unit that is on the insignificant activities list, or a modification that is not on the insignificant list but results in an increase less than the thresholds listed in the rules (Minn. R. 7007.1250). installation and operation permit - permit issued by the state that authorizes the installation of new equipment or the modification of existing equipment. This type of permit is issued to a facility that lacks a valid total facility permit, but submitted a timely application under the current permit program. intermittent compliance - compliance status of a facility when monitoring data shows the facility to be operating within emission limits and standards for part of a reporting period. In contrast, if a facility is in compliance for an entire reporting period, the facility is in continuous compliance ( continuous compliance). lead - heavy metal that is hazardous to human health when breathed or swallowed. Its use in gasoline, paints, and plumbing compounds has been sharply restricted or eliminated by federal laws and regulations (see criteria pollutants). Letter of Warning (LOW) - enforcement tool used by the MPCA for alleged minor violations; generally requires corrective action but no penalties. listed control equipment - control equipment that is listed in the Minnesota performance standard for control equipment (Minn. R. 7011.0070). Lowest Achievable Emission Rate (LAER) - under the Clean Air Act this is the rate of emissions that reflects: (a) the most stringent emission limitation contained in a State Implementation Plan for a facility, unless the owner or operator of a facility can demonstrate that the limitation is not achievable; or (b) the most stringent emissions limitation achieved in practice, whichever is more stringent. major permit amendment - amendment to an air emission permit that cannot be made under the minor or moderate amendment provisions of the rules. (Minn. R. 7007.1500) Material Safety Data Sheet (MSDS) - document that outlines information about a chemical substance, including ingredients, health and environmental hazards, flammability, safety precautions, etc. MSDSs for all chemical substances are available from the supplier of the material. Maximum Achievable Control Technology (MACT) - emissions limitations based on the best demonstrated control technology or practices to be applied to major sources emitting one or more of the federally listed hazardous pollutants. minor permit amendment - amendment to an air emission permit that allows a modification that results in an emissions increase below the levels described in Minn. R. 7007.1450, subp. 2, with the exceptions that are found in Minn. R. 7007.1450. moderate permit amendment - amendment to an air emission permit that allows a modification that results in an emissions increase greater than the levels described in Minn. R. 7007.1450, subp. 2, but that does not require a major permit amendment (Minn. R. 7007.1450).

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Glossary - 5 modification - any physical or operational change at an emission unit or emission facility or stationary source (not allowed by any existing permit) that can cause the amount of pollutants released to increase, either at the specific unit being changed, or elsewhere in the facility. Also any Title I modification. Routine maintenance, repair, and replacement are not considered modifications (Minn. R. 7007.0100, subp. 15). National Emission Standards for Hazardous Air Pollutants (NESHAPs) - emissions standards set by EPA for air pollutants not covered by NAAQS that may cause an increase in deaths or in serious irreversible or incapacitating illness. New Source Performance Standards (NSPS) - uniform national EPA air emission and water effluent standards that limit the amount of pollution allowed from new sources or from existing sources that have been modified. New Source Review (NSR) - federal program that contains the Nonattainment Area and Prevention of Significant Deterioration programs and that applies to certain facilities with the potential to emit air pollution of 100 or 250 tons per year. nitrogen oxides (NOX) - Oxides of nitrogen (except nitrous oxide) that are regulated because they can cause lung and eye irritation, can contribute to the formation of acid rain, and react in the atmosphere to form ozone and smog (see criteria pollutants). nonattainment area - geographic area that does not meet one or more of the NAAQS for the criteria pollutants designated in the Clean Air Act. Notice of Violation (NOV) - enforcement tool used by the MPCA as a formal notice issued for alleged violations; requires corrective action but no penalties. opacity - amount of light obscured by particulate pollution in the air (e.g., clear window glass has zero opacity, a brick wall has 100 percent opacity). Opacity is used as an indicator of changes in performance of particulate matter pollution control systems. operating permit - permit to operate a source. operational flexibility - provisions in the Minnesota permit rule that allow a facility to make certain changes without obtaining a permit amendment. In order to qualify, the facility would have had to request these changes in their total facility permit application. (See alternative operating scenarios and emission trading.) ozone - at ground level, ozone is a noxious pollutant and is the major component of smog. The source of ozone is the chemical reaction of VOCs and NOX. Health effects of ozone are breathing problems, reduced lung function, asthma, eye irritation, stuffy nose, and reduced resistance to colds and other infections. Environmental effects of ozone can damage plants and trees. Smog also causes reduced visibility (see criteria pollutants). Part 70 - U.S. EPA's interpretation of Title V of the 1990 Clean air Act Amendments, outlined in the Code of Federal Regulations, 40 CFR 70. Part 70 permit - air emission permit issued under Minn R. 7007.0200, and 40 CFR 70. particulate matter - fine liquid or solid particles such as dust, smoke, mist, fumes or smog found in air or emissions. (see PM10).

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Glossary - 6 performance test - the quantification of emissions or the determination of the physical, chemical, or aesthetic properties of those emissions from an emission unit (Minn. R. 7017.2005, subp. 4). permit amendment - document issued by the MPCA to change conditions in a total facility permit. A permit amendment may reflect a physical change or a change in the permit requirements. permit rule method - calculation technique used to quantify changes in emissions due to a physical change. This method is used only when the change is not a Title I modification. Minn. R. 7007.1200 describes the permit rule method. permit shield - condition in a permit stating that if the terms of the permit are complied with, the facility will be considered to be in compliance with the applicable rule or regulation. The permit shield only applies if and where the permit specifically states that it applies (Minn. R. 7007.1800).

PM10 - standard for measuring the amount of solid or liquid matter suspended in the atmosphere. Refers to the amount of particulate matter smaller than 10 micrometers in diameter. The smaller PM10 particles penetrate to the deeper portions of the lung, affecting sensitive population groups such as children and people with respiratory diseases. (see criteria pollutants) portable facility - emission facility capable of being easily moved, e.g., an asphalt plant. portable source - emission source that is capable of being easily moved; e.g., a diesel generator or auxiliary power unit. potential emissions - (see potential to emit) potential to emit (PTE) - maximum amount of a pollutant that a source is capable of emitting, assuming the source runs at full capacity 24 hours per day and 365 days per year. (Minn. R. 7005.0100, subp. 35a). Prevention of Significant Deterioration (PSD) - US EPA program that requires air emission permits to restrict emissions for new or modified sources in places where air quality meets primary and secondary ambient air quality standards. PSD is the part of NSR that applies in attainment areas. responsible official - individual at a facility who is responsible for the accuracy and completeness of a permit application. A responsible official is also required to certify the facility’s compliance status in the permit application and on an annual basis after the permit is issued (Minn. R. 7007.0100, subp. 21; see compliance certification). rolling average - sometimes used as a calculation method for showing compliance with a permit limit. For example, to calculate the "12 month rolling average" for operating hours, each month you would total the operating hours for the 12 months immediately prior to the current month, and divide by 12. rolling sum - sometimes used as a calculation method for showing compliance with a permit limit. For example, to calculate the "12 month rolling sum" for operating hours, each month you would add together the operating hours for the 12 months immediately prior to the current month. (This is very similar to the rolling average, but usually a little easier to use.)

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Glossary - 7 SIC code - Standard Industrial Classification code. The SIC code is a numerical indicator of the primary type of activity at a business. For example, 5153 is a grain elevator; 2951 is an asphalt plant; etc. The first two digits indicate the broad category, the second two digits are more industry-specific. significant level - thresholds for specific regulated pollutants used to determine if a modification is major as defined in New Source Review rules. Modifications that are major must undergo further review. state permit - permit issued under Minn. R. 7007.0250. This is a permit for a source that is not a major source, but still needs a permit under Minnesota Rules (Minn. R. 7007.0100, subp. 24). stationary source - place or object from which pollutants are released and which does not move around. Stationary sources include power plants, gas stations, incinerators, etc. stipulation agreement - a negotiated settlement between a facility and the MPCA that includes a schedule of corrective action and a penalty for past noncompliance (see compliance agreement). sulfur dioxide (SO2) - heavy, pungent, colorless, gaseous air pollutant formed primarily by industrial fossil fuel combustion processes (see criteria pollutants). synthetic minor limit - federally enforceable operating or emissions limitations accepted by a permit applicant that limits a facility’s PTE and makes the facility a minor source under Part 70 or New Source Review regulations. synthetic minor permit - air emission permit that contains one or more synthetic minor limits. Title I - refers to Title I of the federal Clean Air Act, which protects ambient air quality. Title I programs include Prevention of Significant Deterioration and Nonattainment Area New Source Review; New Source Performance Standards; and National Emission Standards for Hazardous Air Pollutants. Title I condition - permit condition that is based on a requirement of Title I of the Clean Air Act (NSR, NSPS, NESHAPs). This includes conditions required under PSD and Nonattainment Area programs, those that enable a source to avoid becoming subject to PSD or Nonattainment Area programs, and those required for achieving or maintaining NAAQS. Permit requirements set under Title I are permanent requirements (Minn. R. 7007.0100, subp. 26). Title I modification- any change that is considered a modification under Title I of the Clean Air Act (PSD and Nonattainment Area, NSPS, HAPs). (Minn. R. 7007.0100, subp. 27) Title III - Refers to Title III of the Clean Air Act Amendments of 1990 targeting hazardous air pollutants; Title III defines the Hazardous Air Pollutants and describes how the standards will be developed. Title V - section of the Clean Air Act that covers the operating permit program. total facility permit - air emission permit issued for the entire source. volatile organic compounds (VOC) - any organic compound that participates in smog-forming reactions except for those designated by the EPA Administrator as having negligible photochemical reactivity (see criteria pollutants).

MPCA Air Quality Permits Guide Part 1: Defining Your Facility -- Revision 1, September 1998 Glossary - 8