Andersen Corporaton for its facility located at 100 Fourth ...

Permit No. ANDXL‐002

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Table of Contents

Section Description Page

1 Introduction 1

2 Definitions 2

3 Facility Description 3

4 Steam and Heat Project 5

5 Environmental Release Limits and Requirements 5

6 Pollution Prevention Planning and Reporting 7

7 Rules Varied by ANDXL‐002 7

8 Submittals 8

9 Amendment of the Permit 13

10 Permit Reissuance 13

11 Permit Revocation 13

12 Environmental Review 14

13 Inspections 14

14 MPCA and Washington County Fees 14

15 Record Retention 14

16 Extension Requests 15

17 Oil and Hazardous Substance Liability 15

18 Documents Superseded by ANDXL‐002 15

19 Severability 16

20 Confidentiality 16

21 Transfer of Rights and Obligations 16

22 Changes Allowed by Permit to include PM2.5 increase of ≤ 0.00 lb/hr 16

Attachment A Air Emission Part 70 Permit Conditions (Air Requirements)

Attachment B NPDES Permit Conditions (Water Requirements)

Attachment C Waste Requirements

Attachment D List of Process Equipment

Attachment E List of Milling Control Equipment

Attachment F Airflow Verification Plan

Attachment G Tanks Summary

Appendix 1 Future PM10 Modeling Requirements

Appendix 2 PM10 Modeled Parameters

1. Introduction

ANDXL‐001 was issued under the state and federal regulatory reform experiment known as “Project XL.” Minnesota is authorized to issue Minnesota XL permits under Minn. Stat. ch. 114C. ANDXL‐002 is issued under the state regulatory reform experiment known as “Project XL.” Under Project XL, the MPCA has developed a permit that is designed to achieve the following four broad goals:

A. Achieve environmental performance that is superior to what would be achieved through compliance

with current and reasonably anticipated future regulations; B. Promote increased operational and administrative flexibility to reduce costs; C. Encourage greater pollution prevention and other innovation efforts; and D. Facilitate increased stakeholder support with multi‐stakeholder involvement in the design and

implementation of XL permits.


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In addition to ANDXL‐002, there is a Final Project Agreement (FPA), entered into by the Permittee, the MPCA, the U.S. Environmental Protection Agency (EPA), and Washington County, which includes the Permittee’s pollution prevention goals and the measurements being made to determine the success of this Project XL experiment. Under Minn. Stat § 114C.12, a Minnesota XL permit may include variances from applicable state rules or local ordinances if the variance promotes reduction in overall levels of pollution beyond what is required by applicable law or reduces the administrative burden on state or local agencies or the permittee, provided that alternative monitoring, testing, notification, recordkeeping, or reporting requirements will provide the information needed by the state or local agency to ensure compliance. As required by Minn. Stat. § 114C.12, subd. 2, ANDXL‐002 identifies, in general terms, any state rules or local ordinances being varied.

2. Definitions.

For the purposes of ANDXL‐002, the following terms have the meanings specified: A. Accelerated Corrosion – Corrosion that is more than surface deterioration. It is corrosion that has penetrated into the tank liner (i.e. moderate to severe pitting) to the extent that it could possibly compromise the integrity of a tank or tank liner prior to the next scheduled inspection as determined by the testing company/consultant. B. Best Management Practices (BMPs) – Practices to prevent or reduce the pollution of the waters of the state, including schedules of activities, prohibitions of practices, and other management practices and also includes treatment requirements, operating procedures and practices to control plant site runoff, spillage or leaks, sludge, or waste disposal or drainage from material storage, as defined in Minn. R. 7001.0120, subp. 5. Examples of BMPs can be found in Management for Industrial Activities, Developing Pollution Prevention Plans and Best Management Practices, September 1992, EPA 832/R–92–006, NTIS No. PB 92–235969, ERIC No. N477; Storm Water Management for Industrial Activities, Developing Pollution Prevention Plans and Best Management Practices: Summary Guidance, EPA 833/R–92–002, NTIS No. PB 94–133782; ERIC No. W492. C. Community Advisory Committee (CAC) – The body formed to assist the Permittee in development of its XL proposal. The CAC is made up of direct participants: individuals representing a variety of stakeholders including local residents, employees, business, environmental groups and government. D. Delivered for use – When used in Attachment A of ANDXL‐002, receipt of a material (e.g., preservative, coating, adhesive, etc.) to be used at a particular process at the Facility. Deliveries can include internal transfers between processes at the Facility. E. Diptank – A piece of process equipment used to treat wood window and door components with wood preservative. The process equipment consists of an open‐top tank containing wood preservative, piping, overflow tanks, the solvent recovery system and carriages that convey pallets of window and door components into and out of the preservative solution. F. Environmental Management System (EMS) – A comprehensive, documented program implemented by the Permittee to ensure compliance with environmental laws and promote environmental performance. G. F032 – Waste code for hazardous waste defined as wastewaters, process residuals (sludges), preservative drippage, and spent formulations from wood preserving processes generated at plants that currently use or have previously used chlorophenolic formulations.


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H. Fibrex™ – The Permittee’s reclaimed wood/vinyl composite used in the production of window and patio door components. The composite is less than 50 percent wood by weight. Wood fibers used for Fibrex™ are reclaimed directly from the Permittee’s manufacturing operations. I. Final Project Agreement (FPA) – The negotiated agreement among the Permittee, the MPCA, the U.S. Environmental Protection Agency, and Washington County concerning the Permittee’s XL proposal. The agreement was signed on June 30, 1999, by the parties to the FPA and later revised by those parties effective December 30, 2003. J. Floodcoater Reservoir – A two foot deep concrete basin with an epoxy‐coated steel liner which was part of the Permittee’s former floodcoater system. This system was used to treat wood window and door components with preservative until December 1992 when it was then shut‐down and dismantled. In December 1993, the reservoir was cleaned, filled with sand and capped with concrete. K. Paintlines – Any process by which window or door parts receive a surface coating in an automated inline process. L. Pentachlorophenol – A toxic fungicide and insecticide compound that was once widely used in the preservation of wood. M. Preservative Application Process – Any process where wood parts that are not intended to be painted are treated with a wood preservative. N. U.S. Environmental Protection Agency (EPA) – The federal governmental agency charged with implementing United States environmental laws and the sponsoring agency for XL projects. O. VM&P‐ Varnish Makers and Painters naphtha. A term used to describe a mixture of petroleum spirits with specific boiling points. Used as a thinner in paints and varnish. Also used as a carrier in the wood preservative solution. P. Waters of the State – All streams, lakes, ponds, marshes, wetlands, watercourses, waterways, wells, springs, reservoirs, aquifers, irrigation systems, drainage systems and all other bodies or accumulations of water, surface or underground, natural or artificial, public or private, which are contained within, flow through, or border upon the state or any portion thereof. Q. Wood Preservative – An insecticide solution used to prevent or inhibit the deterioration of wood products. R. Written – When used in reference to recordkeeping, “written” means electronic, paper, microfiche, or other permanent storage. This definition does not apply to written submittals. Section 8 of ANDXL‐002 specifies the format for written submittals.

3. Facility Description.

The Permittee manufactures clad wood windows and patio doors at their main manufacturing plant at 100 Fourth Avenue North in Bayport, Minnesota (Fourth Avenue Site), along the St. Croix River, a federally designated “Wild and Scenic River,” which forms the border between Minnesota and Wisconsin in that area. At the time of the ANDXL‐001 issuance there were approximately 3,000 employees at the Fourth Avenue Site. Existing Fourth Avenue Site manufacturing facilities are located on 110 acres, consisting of 78 buildings,


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most of which are interconnected. Manufacturing and related processes include wood cutting and milling, wood preservative application, painting, vinyl processing, adhesive operations, by‐product transfer, wood and natural gas‐fired boilers, assembly operations, technology development, production support and maintenance functions. The various manufacturing processes have the potential to emit the following air pollutants: Volatile Organic Compounds (VOC), Particulate Matter, Particulate Matter less than 10 microns, and Particulate Matter less than 2.5 microns (PM/PM10/PM2.5), and various Hazardous Air Pollutants (HAPs). The fuel burning equipment also emits Greenhouse Gases (GHGs), Carbon Monoxide (CO), Nitrogen Oxides (NOx), Sulfur Dioxide (SO2), and various HAPs from the combustion of fuel. The Facility is considered a major source of air pollutants under all applicable MPCA and EPA air programs. ANDXL‐002 contains various requirements that limit the emissions of all of the above pollutants. The permit contains a VOC limit that is a Plant‐wide Applicability Limit (PAL) under New Source Review (NSR) (40 CFR § 52.21(aa)). The original permit authorized a major modification under NSR for the milling operations (PM/PM10 emissions) and a minor modification under NSR for the Steam and Heat Project, as described in Section 4 of ANDXL‐002. ANDXL‐002 authorizes a change to the milling operations (PM/PM10/PM2.5 emissions) which requires a major amendment under Minn. R. 7007.1500. ANDXL‐002 authorizes facility changes as long as each change does not increase the PM10 emission rate on a pound per hour (lb/hr) basis, as further described in Section 22 of ANDXL‐002. The water discharges at the Facility consist primarily of cooling waters which are used for non‐contact cooling processes and stormwater runoff from the plant site. Water discharges are to the St. Croix River. Water used in non‐contact cooling systems is currently supplied by groundwater pumped from plant wells at the Facility. No chemical additives are used in these non‐contact cooling water systems. Non‐contact cooling water is also used in new heat exchanger systems for purposes of heating the facility buildings (part of the Steam and Heat Project), and is discharged via a new surface discharge. This water is used solely in non‐contact cooling systems (used in facility heat exchangers in make up air systems to supplement heating of the facility). The source water for this system is obtained from the Xcel Allen S. King Generating Plant located next to the Andersen facility. A small portion of the Xcel condenser cooling water normally discharged directly to the river from the Xcel plant is pumped from the Xcel plant after it exits the Xcel plant condenser. Use of this condenser cooling water is a beneficial reuse of the Xcel generating plant cooling water since additional heat is extracted from this cooling water at the Andersen facility before being discharged to the river. With the exception of relatively low flow of reverse osmosis reject water, all process and sanitary wastewaters are discharged to the Metropolitan Council of Environmental Services (MCES) sanitary sewer system. See Attachment B for more discussion of this discharge. Stormwater has been controlled and pollutant concentrations in stormwater minimized through implementation of a stormwater pollution prevention plan. This NPDES permit incorporates the conditions, requirements, and provisions required under the Facility’s prior NPDES/SDS General Stormwater Permit MN006167332. The Permittee also operates a groundwater treatment system for remediation of contaminated groundwater under the plant, which contains trace concentrations of Pentachlorophenol (PCP). PCP was an ingredient used as a wood treatment preservative at the Facility until 1986. The groundwater treatment system consists of a gradient control system designed to prevent migration of PCP from the site and a pump and treat system, which extracts the contaminated groundwater and treats it through a granular activated


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carbon system. The treated groundwater is used as makeup for non‐contact cooling water at buildings 5, 5A, 10, and 14, and is discharged to the St. Croix River via non‐contact cooling water discharge outfalls. However, the activated carbon system effluent is routinely monitored prior to its discharge to the non‐contact cooling water systems to ensure adequate PCP removal. The ground water treatment system was originally implemented in 1982. A Response Order by Consent (Consent Order) between the Permittee and the MPCA was executed on January 27, 1987, and is in effect until its provisions have been satisfied as specified in Section XXXIII of the Consent Order. The ground water treatment system has undergone several modifications and improvements, and will continue to operate until the response action objectives and cleanup levels established by the July 1995 Minnesota Decision Document (MDD) have been achieved. ANDXL‐002 requires periodic monitoring of the water discharges described above. The monitoring requirements are described in Section 5.B and Attachment B, NPDES Permit Conditions (Water Requirements). The Permittee is a large quantity generator of hazardous waste licensed by Washington County. The Permittee generates primarily hazardous paint sludge, solvents, wood preservative sludge, fluorescent lamps, and lead acid batteries from its manufacturing operations. The Permittee also generates used oil, oil filters, and oil sorbent materials which, along with essentially all hazardous wastes, are recycled or burned as fuel off‐site. Most of the solid industrial waste (scrap wood, wood shavings, scrap vinyl, scrap metal, cardboard, tires) the Permittee generates is also reused, reclaimed/recycled, or used as fuel if possible.

4. Steam and Heat Project

The Permittee has completed the Steam and Heat Project as defined in ANDXL‐001 and shall comply with all relevant requirements set forth in ANDXL‐002 and Attachments A and B that apply to the Steam and Heat Project.

5. Environmental Release Limits and Requirements

A. Air Emission Limits and Requirements

The Permittee shall not cause to be discharged into the atmosphere from the Facility any pollutant listed in Table 1 in an amount that exceeds the emission limitation for that pollutant. Table 1 is not a complete list of emission limits applicable to the Permittee, but is intended to highlight the most significant site‐specific limits that apply to the Facility. Further details on these limits are in Attachment A. Other emission limitations and requirements are also set forth in Attachment A. The Permittee shall comply with the requirements set forth in Attachment A.

Table 1: Key Air Limits

Pollutant Emission Limit

VOC Plantwide Applicability Limit Effective Date: May 4, 2006 Expiration Date: May 4, 2016

2397 tons/year, rolling sum

PM/PM10/PM2.5 from Non‐milling Operations 55 tons/year, rolling sum

PM/PM10/PM2.5 from Milling, BACT Emission Limit 0.0030 grains per dry standard cubic feet

Air Toxics Requirements See Attachment A

Other Pollutants See Attachment A


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B. Water Monitoring and Discharge Limitations and Requirements

The Permittee is authorized to discharge from outfall numbers SD001, SD002, SD005, and SD006, and SD007. The discharges shall be monitored and limited as set forth in Table 2. The Permittee shall comply with the requirements set forth in Attachment B.

Table 2: Water Monitoring and Discharge Limits

Effluent Characteristic Maximum Discharge Limitation Frequency of Analysis Sample Type

Flow ‐‐‐ Estimated

pH 6.0 – 9.0 ‐‐‐ ‐‐‐

Temperature 86F Monthly Grab

Phosphorus, Total Total from all stations shall not exceed 104 kilograms/year

Yearly Grab

The discharges to the above outfalls are limited to non‐contact cooling waters at SD001, SD002, SD005, and SD006; non‐contact condenser cooling water originating from the Xcel Allen S. King Generating Plant at SD007; reverse osmosis reject water discharged to non‐contact cooling waters; stormwater runoff; and treated effluent from the activated carbon system treating water from the groundwater pumpout system discharging into non‐contact cooling waters SD002 and SD005. The Permittee shall not discharge water entering floor drains, sanitary wastewater, process wastewater, and other miscellaneous wastewater to the above discharge outfalls, but shall discharge these wastewaters to the municipal sanitary sewer system (Metropolitan Council of Environmental Services). The Permittee shall not discharge any chemical cleaning wastes resulting from periodic cleaning of the reverse osmosis system. If the Permittee discharges stormwater into a municipal storm sewer the Permittee shall notify the operator of the municipal storm sewer of the existence of ANDXL‐002. The Permittee shall not discharge floating solids or visible foam in other than trace amounts. The Permittee shall not discharge oil or other substances in amounts that create a visible color film. ANDXL‐002 does not authorize the discharge of hazardous substances or oil resulting from an on‐site spill. The Permittee has not received approval to use chemical additives in the non‐contact cooling waters. The Permittee has received approval to use salt for ice thawing and/or removal and to use calcium chloride and Coherex® on surfaces for dust control.

C. Waste Limitations and Requirements

In regard to hazardous waste management, including evaluation of wastes, manifesting, generation and storage, personnel training, contingency plan, preparedness and prevention, emergency arrangements and procedures, recordkeeping, and reporting requirements, the Permittee shall comply with all applicable sections of the Minnesota Hazardous Waste Rules in Minn. R. ch. 7045 and all applicable Federal regulations in 40 CFR part 262. The Permittee also shall comply with the requirements set forth in Attachment C. Table 3 highlights some of the key limitations and requirements from Attachment C.

Table 3: Key Waste Requirements

Non‐destructive tank testing The Permittee shall conduct non‐destructive tank testing on the West diptank within 2 years of initial permit issuance and the East diptank within 5 years of initial permit issuance.


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Washington County Ordinance #187 (or current hazardous waste management ordinance) governs management of hazardous wastes in Washington County. Some of the Permittee’s activities included in Attachment C, Waste Requirements, herein, have the potential to fall outside the strict requirements of the ordinance for purposes of ANDXL‐002. Washington County hereby grants the Permittee a variance to operate outside the strict requirements of Washington County Ordinance #187 in the following instance:

When the Permittee engages in the activities in Attachment C and these activities would cause the Permittee to fall outside the strict requirements of the ordinance, the Permittee is allowed to proceed with the activities under the requirements set forth in ANDXL‐002.

This variance is for the Permittee only and no other entity in Washington County and is limited to the duration of ANDXL‐002 or extensions thereof. This allowance does not relieve the Permittee of its obligations to remain in compliance with all other provisions of the ordinance.

6. Pollution Prevention Planning and Reporting

A. The Permittee shall satisfy the requirement of Minn. Stat. § 115D.08 to submit an annual pollution prevention (P2) progress report (Form P2PR) by submitting to the Minnesota Emergency Planning and Community Right‐to‐Know ACT (EPCRA) Program a copy of the toxic chemical release form(s) (Form(s) R) required under 42 U.S.C. § 11023 (Emergency Planning and Community Right‐To‐Know Act or EPCRA, § 313). The Permittee shall submit Form R(s) to EPA and the Minnesota EPCRA Program office by the national deadline established in 40 CFR § 372.30(d). The Permittee shall report progress towards its specific pollution prevention goals and objectives in the Annual XL Report, due April 1 of each year and described in Section 8 of ANDXL‐002. The April 1 submittal must include reports of progress towards specific P2 goals and objectives for Form R (EPCRA 313) chemicals. As allowed by Minn. Stat. § 114C.11, subd. 6, ANDXL‐002 alters the requirements of the Minnesota EPCRA Program that are applicable to the Permittee under Minn. Stat. § 115D.08.

B. The Permittee shall satisfy the requirement of Minn. Stat. § 115D.07 to prepare a separate pollution

prevention (P2) facility plan per the process described by the Permittee’s Environmental Management System (EMS). In accordance with its EMS, the Permittee shall review operations at least annually, generate new P2 project ideas, and create a plan for implementing selected projects. That plan must include specific goals and objectives for projects addressing chemicals listed under 42 U.S.C. § 11023(c) (EPCRA, § 313(c)). The EMS is and must continue to be supported and certified by Permittee’s top management. The EMS currently includes and must continue to include a commitment to seek continuous environmental improvement, both in the Permittee’s own operations and in those of its suppliers. As allowed by Minn. Stat. § 114C.11, subd. 6, ANDXL‐002 alters the requirements of the Minnesota EPCRA Program that are applicable to the Permittee under Minn. Stat. § 115D.07.

7. Rules Varied By ANDXL‐002

ANDXL‐002 includes variances from the following state rules and local ordinances: A. Minn. R. 7007.0800 subp. 6(A)(2); B. Minn. R. 7007.0800 subp. 6(C); C. Minn. R. 7007.1150, subp. C as specifically listed in Attachment A of ANDXL‐002; D. Minn. R. 7007.1200, subp. 3 as specifically listed in Attachment A of ANDXL‐002; E. Minn. R. 7045.0145 as specifically listed in Attachment C; and F. Washington County Ordinance 187 as specifically listed in Section 5.C of ANDXL‐002.


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As allowed by Minn. Stat. § 114C.11, subd. 6, ANDXL‐002 alters the requirements of Minn. Stat. §§ 115D.07 and 115D.08 that are applicable to the Permittee. All variances granted by ANDXL‐002 expire upon the earlier of either the expiration of the permit or expiration of the PAL should the Permittee choose not to renew the PAL. As required by Minn. R. 7007.0450, subp. 2, all limits and requirements listed as Title I Conditions in Attachment A of ANDXL‐002 do not expire.

8. Submittals

A. Submittals Required

The Permittee shall make the submittals listed below and in Attachments A‐C to the MPCA unless otherwise noted. Those submittals required by Minn. R. chs. 7007 or 7001 shall be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. Where the submittal is required by a federal program, the Permittee shall submit a written (paper) document. The Permittee may also submit an additional electronic copy with the paper document. All other submittals may be sent electronically. If an electronic reporting method is approved by the MPCA, EPA, Washington County, and the Minnesota EPCRA Program, then the Facility may choose to send the federally‐required submittals electronically. Unless another person is identified in the applicable Table, the Permittee shall send all submittals to:

Submittals Center Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155‐4194

The Permittee shall send submittals that are required to be submitted to the EPA Regional office to:

Mr. George Czerniak, Chief Air Enforcement and Compliance Assurance Branch Air and Radiation Division EPA Region V 77 West Jackson Boulevard Chicago, Illinois 6060

The Permittee shall send submittals that are required to be submitted to the Andersen Community Advisory Committee to each Committee member, using the most recent mailing list. The Permittee shall send submittals that are required to be submitted to Washington County to:

Program Manager, Solid and Hazardous Waste Washington County Department of Public Health and Environment 14949 62nd Street North, P.O. Box 6 Stillwater, Minnesota 55082‐0006

The Permittee shall send submittals that are required to be submitted to the Minnesota EPRCA Program to: Minnesota Emergency Planning and Community Right‐to‐Know Act Program

444 Cedar Street, Suite 223


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St. Paul, MN 55101‐6223

Table 4: Submittals

Submittal When Basis

Annual Report Due by April 1st of each calendar year starting May 4, 2006. This report shall cover the previous calendar year and include the following elements: Air Emissions Inventory Report, the Annual Discharge Monitoring Report, Annual Stormwater Report and the items listed in Section 8.B. of the permit. The Permittee shall submit this report to the MPCA, CAC, EPA and Washington County.

Minn. Stat. § 116.07 subd. 4a; Minn. R. 7007.0800, subp. 2; FPA, Part III.G; Minn. R. 7001.0150, subp. 2(B).

Air: Annual Compliance Certification

Due by February 15th of each calendar year starting May 4, 2006. To be submitted on a form approved by the Commissioner. This report covers all deviations experienced during the previous calendar year. The Permittee shall submit this report to the MPCA and EPA.

Minn. R. 7007.0800, subp. 6(C) as varied by ANDXL‐002; Minn. Stat. § 114C.12, subd. 2

Air: Semi‐Annual Report The first report shall cover the calendar half‐year in which ANDXL‐002 is issued. The first report of each calendar year thereafter covers January through June and is due by August 15th. The second report of each calendar year thereafter covers July through December and is due by February 15th. This report shall include the Deviations Report as required by Minn. R. 7007.0800, subp. 6(A)(2) as well as the information listed in Section 8.C. of ANDXL‐002. The Permittee shall submit this report to the MPCA, EPA, and CAC.

Minn. Stat. § 116.07 subd. 4a; Minn. Stat. § 114C.12, subd. 2; Minn. R. 7007.0800, subp. 6(A)(2) as varied by ANDXL‐002; Minn. R. 7001.1090, subp. 1(D)

Air: PAL Semi‐Annual Report

Due 30 days after each calendar half year following ANDXL‐002 issuance (i.e., January 30th and July 30th). The first report shall cover the calendar half‐year in which ANDXL‐002 is issued.The report shall include the information listed in Section 8.D. of ANDXL‐002 and shall use Agency approved forms, where available. Specifically, this report shall include updated MPCA air permit application forms showing changes to stacks, emissions units, tanks, and controls. The Permittee shall submit this report to the MPCA, EPA, and CAC.

Title I Condition: 40 CFR § 52.21(aa)(14)(i)


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Table 4: Submittals


Air: PAL Renewal Application

PAL Renewal. If the Permittee wishes to renew the VOC PAL, the Permittee shall submit a complete renewal application meeting the requirements of 40 CFR § 52.21(aa)(10)(iii) at least 6 months prior to, but not earlier than 18 months from, the date of PAL expiration. If the Permittee submits a complete application to renew the PAL within this time period, then the PAL shall continue to be effective until the revised permit with the renewed PAL is issued. During this time period, the Permittee can continue to utilize the PAL Applicability Analysis for proposed changes as explained in Attachment A of ANDXL‐002.

Title I Condition: 40 CFR § 52.21(aa)(10) and Minn. R. 7007.3000

Air: PAL Expiration PAL Expiration. If the Permittee does not wish to renew the PAL, the Permittee shall submit a proposal for re‐allocating the PAL as required by 40 CFR § 52.21(aa)(9)(i)(a) at least 6 months prior to, but not earlier than 18 months from, the date of PAL expiration. Until the Agency issues the revised permit incorporating allowable limits as required under 40 CFR § 52.21(aa)(9)(i)(b), the Permittee shall continue to comply with the PAL emission limitation specified in ANDXL‐002. Once the PAL expires, the Permittee can no longer utilize the PAL applicability analysis for proposed changes (as explained in Attachment A of ANDXL‐002).


Air: Emissions Inventory Report

Due on or before April 1 of each calendar year following permit issuance, to be submitted on a form approved by the Commissioner.

Minn. R. 7019.3000 ‐ 7019.3100

Air: Emission Fees Due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 through Minn. R. 7002.0065

Proposed Non‐destructive Diptank Testing Method and Procedures

Due at least 15 days prior to the planned test date.

Minn. Stat. § 116.07 subds. 4a and 9(b)

Non‐destructive Diptank Test Report

Due 60 days after completion of the testing. Minn. Stat. § 116.07 subds. 4a and 9(b)

Hazardous Waste Generator License Renewal Application

Annually to Washington County by January 31. Minn. R. 7045.0248 Minn. R. 7045.1020

Hazardous Waste Generator License Fees

Annually to Washington County, due 30 days after billing by Washington County.

Washington County Ordinance 187 (or current hazardous waste management ordinance)


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Table 4: Submittals


Biennial Report Due by March 1 of even‐numbered years to EPA

and MPCA. The EPA report shall be mailed to: Mary Villarreal FOIA Coordinator/BRS Regional Contact Waste, Pesticides & Toxics Division USEPA, Region 5 77 West Jackson Boulevard Chicago, Illinois 60604

40 CFR § 262.41

Remediation system report Due by February 15th of each calendar year starting May 4, 2006. This report shall cover the previous calendar year.

Minn. Stat. § 116.07 subds. 4a and 9(b)

Notification of noncompliance or environmental incident to CAC

If a notification of noncompliance or environmental incident (i.e., spill notification, other environmental emergency) is made to MPCA, EPA, or Washington County, the Permittee shall also notify the CAC, either in writing or orally within a reasonable period of time after the notification is made.

FPA, Section III.G.

Project Cost Assessment Due by November 1, 2015 the Permittee shall submit an assessment of the success of the XL Project in reducing the time and money spent at the facility on paperwork and other administrative tasks that do not directly benefit the environment.

Minn. Stat. § 114C.12, subd. 2(6)

B. Annual Report

In addition to the items required in Section 8, Table 4, the Annual Report shall include the following: 1. Monthly Non‐milling PM/PM10/PM2.5 emissions for each month of the reporting period; 2. Monthly Total Facility VOC emissions for each month of the reporting period; 3. The Facility’s total filter system capacity (in dry standard cubic feet) that was measured and/or

calculated during the reporting period. Internally vented (Control Equipment 004 in Attachment A of ANDXL‐002) and externally vented systems (Control Equipment 003 in Attachment A of ANDXL‐002) shall be reported as two separate numbers;

4. An Annual Stormwater Report which summarizes P2 actions, describes inspections, lists reportable spills, describes any changes in nonstructural and structural BMPs, and notes any other applicable information related to stormwater management at the site; and

5. An Annual Discharge Monitoring Report that describes each calendar month’s discharge data for the prior calendar year. The Permittee shall report monitoring results in the units specified by ANDXL‐002 on a Discharge Monitoring Report (DMR) form or other report form provided by the MPCA. The annual discharge monitoring report shall include complete monitoring results from all monitoring completed.

The Annual Report shall include a summary of the Permittee’s activities under the project for the year and shall specifically include information regarding:


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1. Installation of new or reconstructed paintlines and preservative processes and their performance (as described in Attachment A of ANDXL‐002);

2. Installation of new internally vented milling equipment capacity (as authorized by Attachment A) including locational information;

3. A general discussion of how changes made during the past year might affect the calculated health risk values in the Air Toxics Review as approved in February 2003 (e.g., comparison of changes from a specific project with values in the health benchmark analysis); and

4. Progress toward the specific pollution prevention goals and objectives set forth in the FPA or the EMS, including general cost information. This must include a report of progress toward specific P2 goals and objectives for the chemicals reported on Form R pursuant to 42 U.S.C. § 11023 (EPCRA, § 313).

C. Semi‐Annual Report (Air)

In addition to containing the Deviations Report as specified in Section 8, Table 4 of ANDXL‐002, the Semi‐Annual Report shall include the total PM/PM10/PM2.5 non‐milling emissions (in tons/year) on a 12‐month rolling total for each month in the reporting period recorded as required by Attachment A of ANDXL‐002. The report shall also include all data relied upon in calculating the monthly and annual PM/ PM10/PM2.5 non‐milling emissions. This report shall also include reports and information specifically identified in Attachment A of ANDXL‐002.

D. PAL Semi‐Annual Report

In addition to the items required in Section 8, Table 4, the PAL Semi‐Annual Report shall include the following information:

1. The identification of Permittee and the permit number.

2. Total annual emissions (tons/year) of VOC on a 12‐month rolling total for each month in the reporting period recorded as required by ANDXL‐002.

3. All data relied upon, including, but not limited to, any Quality Assurance or Quality Control data, in calculating the monthly and annual VOC emissions.

4. A list of any VOC‐emitting emissions units modified, removed, or added to the facility during the preceding 6‐month period (this includes the “add‐on” units described in Attachment A of ANDXL‐002).

5. The number, duration, and cause of any deviations or monitoring malfunctions (other than the time associated with zero and span calibration checks) associated with any VOC‐emitting emissions unit or associated control or monitoring equipment, and any corrective action taken.

6. A notification of a shutdown of any monitoring system associated with a VOC‐emitting unit, whether the shutdown was permanent or temporary, the reason for the shutdown, the anticipated date that the monitoring system will be fully operational or replaced with another monitoring system, and whether the emissions unit monitored by the monitoring system continued to operate, and the calculation of the emissions of the pollutant or the number determined by the methods required by Attachment A of ANDXL‐002.


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7. A signed statement by the responsible official certifying the truth, accuracy, and completeness of the information provided in the report.

9. Amendment of the Permit

ANDXL‐002 establishes an alternative applicability test for determining if permit amendments or notifications are needed for proposed changes at the Facility that could affect air emissions. This applicability test is described in Attachment A of ANDXL‐002. For any changes not covered by the test described in Attachment A, the Permittee shall determine if amendments or notifications are required using the applicable rules. ANDXL‐002 may be amended in accordance with the procedures set forth in Minn. Stat. § 114C.12, subd. 4 and Minn. R. 7007.0850. The Permittee shall apply for and obtain an amendment to ANDXL‐002 if an air emission facility permit amendment is required by Minn. R. 7007.1150 to 7007.1500 (as varied by Attachment A of ANDXL‐002), or if a NPDES permit modification is justified under Minn. R. 7001.0170. If a modification or change at the Facility or an amendment of the FPA would make the Facility subject to a permit requirement that is not satisfied by ANDXL‐002, the Permittee shall apply for and obtain either the appropriate MPCA permit or an amendment to ANDXL‐002 authorizing the modification or change, in accordance with applicable statutes and rules.

10. Permit Reissuance

The Permittee applied for permit reissuance on November 4, 2009. Permit reissuance shall be processed as required by Minn. Stat. § 114C.12, subd. 4. Any Title I Condition shall remain in effect without regard to permit expiration or reissuance, and shall be restated in the reissued permit.

11. Permit Revocation

A. Findings

The MPCA may revoke ANDXL‐002 if the MPCA finds that any of the conditions set forth in Minn. Stat. § 114C.12, subd. 5(a), items (1) through (4), or those found in Section VII of the FPA, exist. In addition, if the calculated Performance Ratio (as defined in the FPA) exceeds the Project Limit, the MPCA shall revoke ANDXL‐002, unless the Permittee demonstrates to the satisfaction of the CAC, EPA, and MPCA, each acting in its independent capacity, within 60 days of written notice from the MPCA of the intent to revoke the permit, why the project should continue.

B. Request by Permittee

The MPCA may revoke ANDXL‐002 without making the findings set forth in Section 11.A of ANDXL‐002 if the Permittee requests revocation of the permit prior to the expiration of the permit. The Permittee shall provide written notice of its request to the MPCA, EPA, and Washington County at least 60 days prior to the requested date of revocation. If the MPCA, EPA, Washington County or the Permittee requests, the dispute resolution procedures of Part VIII of the FPA shall be initiated to resolve any dispute relating to the Permittee’s request for revocation. If, following any dispute resolution or informal discussion, the Permittee still requests revocation of the permit, a termination date shall be established in accordance with the procedures set forth in Part VII.B. of the FPA. The termination date shall be included in the revocation order required by Section 11.C. of ANDXL‐002.


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C. Revocation Order If the MPCA revokes a Minnesota XL permit, it shall in its revocation order:

1. delay any compliance deadlines that had been varied by the Minnesota XL permit if the MPCA finds it necessary to provide the Permittee a reasonable amount of time to obtain alternative permits under chapters other than Minn. R. chs. 7007 and 7001 and under local ordinances and regulations, and to achieve compliance; and

2. establish practical interim requirements to replace the requirements of the Minnesota XL permit that the MPCA finds the Permittee will not be able to comply with between the time of permit revocation and issuance of the alternative permits, provided that such interim requirements shall not allow pollution from the Facility in excess of that allowed by applicable law at the time the permit was issued.

The Permittee shall comply with the MPCA's order and with all requirements of the Minnesota XL permit for which alternative interim requirements have not been established in the MPCA's order, until the applicable alternative permits have been issued. In no event will the implementation schedule in the MPCA order extend beyond the end of the project term described in the FPA.

12. Environmental Review

The Permittee shall complete environmental review of any activity prior to beginning construction or operation of the activity at the Facility if environmental review is required under Minn. R. ch. 4410. The emission limits established in Table 1 have already undergone environmental review pursuant to Minn. R. 4410.4300, subp. 15, and a negative declaration was issued on December 26, 2003.

13. Inspections

The Permittee shall, upon presentation of credentials and other documents as may be required by law, allow the MPCA, or its representative, to enter the Permittee's premises to have access to and copy any records, papers, and/or memoranda pertaining to ANDXL‐002, to inspect at reasonable times (which include any time the source is operating) any facilities, equipment, practices or operations, and to sample or monitor any substances or parameters at any location.

14. MPCA and Washington County Fees

The Permittee shall pay the same permit fees it would have had to pay if it had obtained the permits that ANDXL‐002 replaces. In addition the Permittee shall continue to pay Hazardous Waste Generator Fees to Washington County.

15. Record Retention

The Permittee shall keep the records required by ANDXL‐002 for a period of ten (10) years from the date of monitoring, sampling, measurement, or report, or 5 years after the XL Project Termination, whichever is shorter. Records which must be retained include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Notwithstanding the previous paragraph, the Permittee shall retain a copy of the following records on site for the duration of the PAL effective period plus 5 additional years:


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1. a copy of the PAL permit application and any applications for revisions to the PAL; and

2. a copy of each annual certification of compliance required in Section 8, Table 4 and the data relied on in certifying compliance.

All records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A).

16. Extension Requests

The Permittee may submit a request to extend a deadline in ANDXL‐002 by no more than a total of 120 days, provided, however, that the MPCA may only extend a deadline established by an applicable requirement described in part 7007.0100, subp. 7(A) to 7(K) if the MPCA has been delegated the authority to make such extensions by the EPA Administrator. The Permittee must request the extension in writing at least 10 days before the scheduled deadline, or as soon as possible before that date if the reason for the extension request arises less than 10 days before the deadline. Each deadline extension request shall separately specify the reason why the extension is needed. No requested extension shall be effective until approved in writing by the MPCA. The MPCA shall grant an extension only for the period of time the MPCA determines is reasonable under the circumstances. The written approval or grant of an extension request shall be considered an enforceable part of the Permit. The Permittee has the burden of demonstrating to the satisfaction of the MPCA that the request for the extension is timely and that good cause exists for granting the extension. Good cause can include, but is not limited to, the following: 1. circumstances entirely beyond the reasonable control of the Permittee; and 2. delays caused by the MPCA in reviewing timely submittals required by ANDXL‐002, that were submitted in

complete and approvable form, which make it not feasible for the Permittee to meet the specified deadlines.

Good cause does not include unanticipated costs, increases in the cost of control equipment, or delays in MPCA review of submittals when the submittals are not in complete and approvable form.

17. Oil and Hazardous Substance Liability.

Nothing in ANDXL‐002 shall be construed to preclude the initiation of any legal action or relieve the Permittee from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under Section 311 of the federal clean Water Act, as amended, 33 U.S.C. § 1251 et. seq. and Minn. Stat. chs. 115 and 116, as amended, and any rules adopted thereunder.

18. Documents Superseded By ANDXL‐002

Upon final issuance, ANDXL‐002 supersedes or replaces the following permits and documents: 1. Minnesota XL Permit No. ANDXL‐001 2. NPDES/SDS General Stormwater Permit MN006167332. 3. The Corrective Action Agreement between the MPCA and the Permittee dated May 4, 1995. 4. All air emissions permits and all of their amendments issued by the MPCA under the facility

identification number 549.


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19. Severability

The provisions of ANDXL‐002 are severable. If a provision of ANDXL‐002, or the application of a provision of ANDXL‐002 to any circumstance, is held invalid, the application of such provision to other circumstances and the remainder of the permit shall not be affected.

20. Confidentiality

Except for data determined to be confidential according to Minn. Stat. §§ 13.37 and 116.075, subd. 2, all reports required by ANDXL‐002 shall be available for public inspection at the MPCA St. Paul office. Effluent and emissions data shall not be considered confidential. A request for confidentiality will be considered when the Permittee submits a request in writing according to Minn. R. 7000.1300.

21. Transfer of Rights and Obligations

A. Notice of Transfer

If the Permittee proposes to transfer its rights and obligations under ANDXL‐002 to another person, the Permittee shall provide written notice of the proposed transfer to the MPCA, EPA and Washington County at least 45 days prior to the effective date of the transfer. The notice shall identify the proposed transferee, a description of the proposed transferee’s financial and technical ability to assume the obligations of the permit, and a statement of the proposed transferee’s intention to sign the FPA as an additional party. Prior to any transfer of ownership of the property where the Facility is located, the Permittee shall also satisfy the conditions of Attachment C Sections 1.B.c and 2.A.c.

B. Amendment of Permit

If the MPCA, EPA and Washington County, after consultation with the CAC, approve the transfer, the MPCA shall proceed in accordance with Section 9 of ANDXL‐002 to amend ANDXL‐002 to change the name of the Permittee to the name of the transferee. The rights and obligations of the permit remain with the Permittee prior to the effective date of the amendment transferring the permit to the transferee.

22. Changes Allowed by Permit to include PM2.5 increase of ≤ 0.00 lb/hr

A. Background

Modeled compliance with the PM10 NAAQS was demonstrated prior to issuance of ANDXL‐001 thus allowing replacement of any and all milling equipment. At the time of the issuance of ANDXL‐002, Andersen has not demonstrated modeled compliance with PM2.5 NAAQS. PM2.5 is presumed to be equal to PM10 because there are no published or site specific emission factors.

B. Requirements

Based on the information in Section 22.A. above and set forth below, no project may increase the PM10 (and thus PM2.5) emission rate on a pound per hour (lb/hr) basis until modeling is completed that indicates compliance with current PM2.5 NAAQS and the permit is amended as necessary to incorporate any restrictions needed to pass the modeling as required in Attachment A of ANDXL‐002.


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The Permittee may continue to make changes to all milling equipment as was permitted in the ANDXL‐001 permit with the additional requirement that each change does not increase PM10 (and thus PM2.5) emission rate on a lb/hr basis. For any project with a projected PM10 increase, the Permittee will undertake other reductions in PM10 emissions sufficient to offset the projected increase. Pound per hour based emission rates gained or lost in one project may not be applied to other projects and the PM10 (as a surrogate for PM2.5) emission rate on a pound per hour basis is at maximum physical capacity. Note that PM10 neutrality calculations are additional to and different from regulatory and permit calculations (e.g. Title I non‐milling calculations). All proposed changes shall include an analysis of the PM10 emission rate change and the resultant approval or denial made by the Permittee. The Permittee, according to ANDXL‐001, shall record and retain all approved or denied PM10 project reviews and shall report approved PM10 projects as they would constitute a facility change. This paragraph is reflected in Attachment A of ANDXL‐002 and discusses state only enforceable requirements. These requirements are more fully documented in correspondence from MPCA dated January 14, 2010 and March 19, 2010, and in a letter to MPCA from Andersen Corporation dated March 11, 2010. As discussed in the January 14, 2010, MPCA letter, the Permittee shall test for PM2.5 during any performance test for PM10 that is required by ANDXL‐002. Performance test plans, approvals, submittals, etc. shall follow MPCA performance testing rules and protocol as required by Attachment A of ANDXL‐002. If the Permittee desires to establish any site specific PM2.5 emission factors, a site specific PM2.5 emission factor development plan shall be submitted to the MPCA for approval as required by Attachment A.

ATTACHMENT A Air Emission Part 70 Permit Conditions

(AIR REQUIREMENTS)

Table of Contents

Process Page

Total Facility Requirements 1

001, Preservative Processes 18

002, Painting Processes 19

003, Milling Equipment 23

004, Vinyl and Other Plastic or Composite Processes 26

005, Combustion Sources 29

006, Miscellaneous VOC Sources 45

007, Other Miscellaneous Sources 48

008, Wood and Ash Silos 50

Control Equipment

001, Panel Filters 51

002, not used in ANDXL‐002 52

003, Externally Vented Milling Fabric Filters 52

004, Internally Vented Milling Fabric Filters 54

005, Non‐milling Fabric Filters 56

006, Preservative Solvent Recovery Units 58

007, Pretreatment Solvent Recovery Units 60

008, Regenerative Thermal Oxidizer 61

009, Electrostatic Precipitator 64

Insignificant Activities

001, Insignificant Activities and Tanks 66

ATTACHMENT A AIR REQUIREMENTS

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Process: Total Facility Requirements

Total Facility Requirements

Citation Requirement

SOURCE‐SPECIFIC EMISSION AND OPERATIONAL LIMITS

Title I Condition: 40 CFR § 52.21(aa) (PAL) and Minn. R. 7007.3000

Volatile Organic Compounds (VOC): The Permittee shall not cause to be discharged into the atmosphere from the Facility VOC emissions in an amount that is greater than or equal to 2,397 tons per year based on a 12‐month rolling sum calculated as required by ANDXL‐002. All VOC‐emitting equipment at the Facility is subject to this limit and shall be included in this calculation as well as all VOC emissions from startup, shutdown, and malfunction.

If the Permittee replaces or changes any existing VOC‐emitting equipment or adds new VOC‐emitting equipment, such equipment is subject to ANDXL‐002 limit as well as the other pertinent requirements of ANDXL‐002.

Title I Condition: 40 CFR § 52.21(aa)(7)(ii) and Minn. R. 7007.3000

VOC PAL Effective Date: May 4, 2006 VOC PAL Expiration Date: May 4, 2016, unless extended under the provisions of 40 CFR § 52.21(aa)(10) (PAL renewal) as detailed in Section 8 of ANDXL‐002.

Minn. Stat. §§ 114C.10, subd. 1 and 114C.12, subd. 3; Minn. R. 7007.0800, subp. 2

Non‐Milling Total Particulate Matter, Particulate Matter less than 10 microns and Particulate Matter less than 2.5 microns (PM/PM10/PM2.5): The Permittee shall not cause to be discharged into the atmosphere from the Facility PM/PM10/PM2.5 emissions in an amount that exceeds 55.0 tons per year based on a 12‐month rolling sum calculated as required by this Attachment A. All Non‐milling equipment at the Facility is subject to this limit and shall be included in this calculation (e.g., combustion, painting, etc.) except as provided below.

Specifically, equipment listed in the portion of this Attachment A entitled “Insignificant Activities 001” (other than fuel combustion) are not included in this limit as well as any equipment added after ANDXL‐002 issuance under Minn. R. 7007.1250, subp. 1(A).

If the Permittee replaces or changes any existing Non‐milling equipment or adds Non‐milling equipment, such equipment is subject to ANDXL‐002 limit as well as the other pertinent requirements of ANDXL‐002.

For the purposes of this limit, PM, PM10, and PM2.5 shall be tracked as one number. Where separate PM, PM10, and PM2.5 emissions factors exist for the same process, the largest of the three factors shall be used for tracking purposes.

Until accepted emission factors for PM2.5 are established, PM2.5 emission factors shall be equal to PM10 emission factors. Accepted emission factors for PM2.5 can be obtained from AP‐42, others sources if approved by the Agency, or Agency approved Plan submitted by the Permittee to establish site specific PM2.5 emission factor.

Minn. R. 7007.1150 and 7007.1200 as varied by ANDXL‐002; Minn. Stat. §§ 114C.10, subd. 1 and 114C.12, subd. 3 This applicability analysis

Applicability Analysis for Proposed Changes. Prior to making any proposed change, the Permittee shall determine if a permit amendment or other type of notification is needed under Minn. R. 7007.1150 with the following exceptions:

1) For changes affecting only PM/PM10/PM2.5 emissions from activities covered by the Non‐milling emissions cap and/or VOC emissions from activities covered by the PAL, the Permittee shall calculate the emissions change using the applicable federal rules as described in 7007.1200, subp. 2


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procedure can only be used while ANDXL‐002 and the VOC PAL are in effect.

and shall not use the method listed in 7007.1200, subp. 3.

2) For changes affecting multiple pollutants, the Permittee shall use the calculation method described in item 1 of this section for VOC and/or PM/PM10/PM2.5 emissions. Additionally, the Permittee shall use the applicable calculation in Minn. R. 7007.1200 for any other affected pollutant.

3) For changes affecting only VOC and PM/PM10/PM2.5 emissions where it is determined that no permit amendment is needed using the calculation method described in item 1, the Permittee is not required to submit the notifications listed under Minn. R. 7007.1150, subp. C and shall instead follow the recordkeeping and reporting requirements listed in the applicable sections of ANDXL‐002.

A permit amendment may still be needed regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to the limits or monitoring and recordkeeping in ANDXL‐002.

Title I Condition: to avoid a major modification under 40 CFR § 52.21 and Minn. R. 7007.3000; Minn. R. 7007.1150

Applicability Analysis for Proposed Changes. Prior to making any proposed change, the Permittee shall determine if a permit amendment or other type of notification is needed under Minn. R. 7007.1150 with the following exceptions:

‐ For changes affecting PM10/PM2.5 emissions from any activity, the Permittee shall ensure that each change does not increase PM10/PM2.5 emissions on a pound per hour (lb/hr) basis. For any project with a projected PM10/PM2.5

increase, the Permittee will undertake other reductions in PM10/PM2.5 emissions sufficient to offset the projected increase. This requirement shall be in effect until modeled compliance with the MAAQS and NAAQS is demonstrated or until Permittee otherwise demonstrates compliance with the NAAQS and MAAQS to the satisfaction of MPCA such that certain non‐milling emission changes are then allowable. All proposed changes shall include an analysis of the PM10/PM2.5 emission rate change and the resultant internal approval or denial.

A permit amendment may still be needed regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to the limits or monitoring and recordkeeping in ANDXL‐002.

Title I Condition: 40 CFR § 52.21(k) and Minn. R. 7007.3000

Parameters Used in Modeling: The stack heights, emission rates, and other parameters used in the PM10 air emission dispersion modeling (submitted November 2010) are listed in Appendix 2 of ANDXL‐002.


The Permittee shall conduct dispersion modeling according to the air dispersion modeling applicability approach outlined in Appendix 1 of ANDXL‐002 for future projects involving changes to PM10 emission rates and relevant stack parameters. The receptor grid for future analyses shall contain the largest area inclusive of modeled impacts equal to or greater than the PM10 significant impact levels.

The analysis shall be completed and submitted to MPCA as required by Appendix 1, prior to making the proposed change. Submitted analysis shall include two tables which contain model input parameters from the November 2010 submittal (Appendix 2) and model input parameters from the current


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analysis. Model input parameters included in the tables shall include emission rates, stack heights, stack diameters, exit velocities, and stack temperatures, as well as any additional relevant input parameters for all modeled sources.


The Permittee shall complete a full “Tier 3” modeling analysis of the Facility and the neighboring Allen S. King electric generating plant at least every 3 years after July 16, 2008 (most recent Tier 3 analysis submittal) unless no changes affecting the modeled parameters in Appendix 2 were made at the Facility during that time period. An MPCA‐approved Tier 3 modeling analysis shall supersede the July 16, 2008 Tier 3 analysis submittal. References to that report shall thereafter refer to the approved Tier 3 analysis.


AERMOD‐PRIME was approved as a guideline model on November 9, 2005, effective December 9, 2005. All future Tier 3 submittals shall be conducted with the current version of AERMOD‐PRIME or the current preferred regulatory model as listed in 40 CFR Part 51, Appendix W’s ‘Guideline on Air Quality Models’.

40 CFR § 63.52(b)(1) and 63.52(e)(1)

For changes that do not require a permit amendment:

‐ The Permittee shall submit a Part 1 MACT application within 30 days of startup of any 112(j) affected source. The application shall meet the requirements of 40 CFR § 63.53(a).

‐ The Permittee shall submit a Part 2 MACT application within 90 days of startup of any 112(j) affected source. The application shall meet the requirements of 40 CFR § 63.53(b).

112(j) affected source is defined in 40 CFR § 63.51. As of permit issuance, 112(j) affected sources include industrial, commercial, and institutional boilers and process heaters; brick and structural clay products manufacturing; clay ceramics manufacturing.

Standards of Performance for Pre‐1969 Industrial Equipment (as defined in Minn. R. 7011.0710, subp. 1)

Minn. R. 7011.0710, subp. 1(A)

Total Particulate Matter: The Permittee shall not cause to be discharged into the atmosphere from industrial process equipment gases which in any one hour contain particulate matter in excess of the amount permitted in Minn. R. 7011.0730 for the allocated process weight; provided that the Permittee shall not be required to reduce the particulate matter emissions below the concentrations permitted by Minn. R. 7011.0735 for the appropriate source gas volume; further provided that regardless of the mass emissions permitted by Minn. R. 7011.0735, the Permittee shall not emit particulate matter in a concentration in excess of 0.30 grains per dry standard cubic foot of exhaust gas. This limit applies individually to each piece of pre‐1969 industrial process equipment other than those described by Process 005.

Minn. R. 7011.0710, subp. 1(B)

Opacity: The Permittee shall not cause to be discharged into the atmosphere from industrial process equipment gases which exhibit greater than 20 percent opacity, except for one six‐minute period per hour of not more than 60 percent opacity. This limit applies individually to each piece of pre‐1969 industrial process equipment other than those described by Process 005.


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Standards of Performance for Post‐1969 Industrial Equipment (as defined in Minn. R. 7011.0715, subp. 1)

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

Total Particulate Matter: The Permittee shall not cause to be discharged into the atmosphere from industrial process equipment gases which in any one hour contain particulate matter in excess of the amount permitted in Minn. R. 7011.0730 for the allocated process weight; provided that the Permittee shall not be required to reduce the particulate matter emissions below the concentrations permitted by Minn. R. 7011.0735 for the appropriate source gas volume; further provided that regardless of the mass emissions permitted by Minn. R. 7011.0735, the Permittee shall not emit particulate matter in a concentration in excess of 0.30 grains per dry standard cubic foot of exhaust gas. This limit applies individually to each piece of post‐1969 industrial process equipment other than those described by Process 005.

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

Opacity: The Permittee shall not cause to be discharged into the atmosphere from industrial process equipment gases which exhibit greater than 20 percent opacity. This limit applies individually to each piece of post‐1969 industrial process equipment other than those described by Process 005.

SOURCE‐SPECIFIC MONITORING AND RECORDKEEPING

Title I Condition: 40 CFR § 52.21(aa)(7)(vi) and (aa)(4)(i)(a) and Minn. R. 7007.3000

Monthly Recordkeeping: VOC Emissions. By the last day of the next calendar month, the Permittee shall calculate and record the following:

1) Total VOC emissions for the previous month, in tons/month, by summing each of the tons/month emissions numbers calculated as specified in the portions of this Attachment for Processes 001, 002, 004, 005, 006, and 007.

2) The 12‐month rolling sum VOC emissions, in tons, for the previous 12 months by summing the total monthly emissions data for the previous 12 months.

This value shall be less than the PAL specified in ANDXL‐002.

Minn. R. 7007.0800, subp. 4 and 5

Monthly Recordkeeping: PM/PM10/PM2.5 Non‐Milling Emissions. By the last day of the next calendar month, the Permittee shall calculate and record the following:

1) The total Non‐milling PM/PM10/PM2.5 emissions for the previous month, in tons/month, by summing each of the tons/month emissions numbers calculated as specified in the portions of this Attachment for Processes 002, 004, 005, 007 and 008.

2) The 12‐month rolling sum Non‐milling PM/PM10 emissions, in tons, for the previous 12 months by summing the total monthly emissions data for the previous 12 months.

Title I Condition: 40 CFR § 52.21(aa)(12)(iii) and (vii) and Minn. R. 7007.3000 (VOC); Minn. R. 7007.0800, subp. 4 and 5 (solids)

Material Content: When a material content is used in calculations required by ANDXL‐002, the Permittee shall determine the VOC and solids content of raw materials using supplier certified data for each material used. If the data provides a material content range, the highest number in the range shall be used for all calculations. Other alternative methods approved by the MPCA may be used to determine the VOC or solids content. The Commissioner reserves the right to require the Permittee to analyze samples of the materials for VOCs or solids as per EPA and/or ASTM reference methods. If the EPA or ASTM


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reference method is used, it shall supersede the supplier certified data for that particular volume (e.g., sampled batch) of materials.

For any given material, if the required data is not available for a calculation required by ANDXL‐002, the Permittee shall assume the maximum potential content of the given pollutant without considering enforceable limitations or operational restrictions in that calculation.

Title I Condition: 40 CFR § 52.21(aa)(12)(iii)(a) and (12)(ix) and Minn. R. 7007.3000

Material VOC Content Validation: The Permittee shall validate the VOC content of materials that are used at the Facility according to the following criteria.

1) Where the content is based on a Certificate of Analysis that lists the content of that particular shipment/batch/container based on testing and analysis (i.e., not formulation data), or where the particular material is 100% VOC, no further validation is needed.

2) Where the content is based on supplier certified data that is formulation‐based (e.g., MSDS, EDS, etc.), the Permittee shall annually validate the contents of each material that was used in amounts that resulted in actual emissions greater than or equal to 1 ton in the previous calendar year. The validation shall be completed by the end of July for the previous calendar year.

3) Where the content is based on supplier certified data that is formulation‐based (e.g., MSDS, EDS, etc.), and the material content was not required to be validated by item 2 above, the Permittee shall validate the content at least once every 5 years after permit issuance.

Contents shall be determined per EPA and/or ASTM reference methods by the manufacturer, vendor/supplier, or an independent laboratory. The results cannot be used directly in the calculations required by ANDXL‐002 for other than the specific shipment that was sampled.

All content data collected under this requirement is considered re‐validation information and is subject to the reporting requirements in 40 CFR § 52.21(aa)(14)(iii).

Title I Condition: 40 CFR § 52.21(aa)(12)(iii) and (vii) and Minn. R. 7007.3000 (VOC); Minn. R. 7007.0800, subp. 4 and 5 (solids)

Material Content of Shipped Wastes: If the Permittee elects to obtain credit for solids and VOC shipped in waste materials, the Permittee shall either use item 1) or 2) to determine the VOC and/or solids content for each credited shipment.

1) The Permittee shall analyze a composite sample of waste to determine the weight content of VOC or total solids excluding water. An alternative testing frequency of waste shipments (e.g., not each shipment) may be approved by the MPCA if the Permittee presents historical data that shows the waste content of any given waste stream is within 10% of the original value (e.g., original value 20%, second value 22%). This would need to be provided on an individual waste stream basis. At a minimum, an annual composite sample will be required for each waste stream.

2) The Permittee may use supplier certified data for raw materials to determine the VOC or solids content of the waste. If the waste contains several materials, the content of mixed waste shall be assumed to be the


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lowest VOC and solids content of any of the raw materials.

If the data required under items 1) or 2) above is not available for a given shipment, then no credit is given for that shipment.

Minn. R. 7007.0800, subp. 4 and 5

The Permittee shall conduct an evaluation of the PM/PM10/PM2.5 “add‐ons” used in the calculations required by this Attachment A (Processes 002 and 004) to determine if the numbers are still valid. The results shall be included as part of the permit reissuance application required by Section 8 of ANDXL‐002.

Title I Condition: 40 CFR § 52.21(aa)(12)(ix) and Minn. R. 7007.3000

The Permittee shall conduct an initial evaluation of the VOC “add‐ons” used in the calculations required by this Attachment A (Processes 002, 004, and 006) to determine if the “add‐on” emission rates are still valid. The Permittee shall use the same methodology as was used to originally derive the “add‐ons”. The results shall be due at the time of and included as part of the permit reissuance application required by Section 8 of ANDXL‐002.

The Permittee shall conduct on‐going evaluations of the VOC “add‐ons” at least once every 5 years after the initial evaluation.

VOC data collected under this requirement is considered re‐validation information and is subject to the reporting requirements in 40 CFR § 52.21(aa)(14)(iii).

Minn. R. 7007.0800, subp. 5

Equipment Labeling Requirements: The Permittee shall affix and maintain a label on each piece of equipment described by Attachment A, other than equipment excluded below, showing a unique equipment identification number. If equipment is added, it shall be given a new unique number; numbers from removed or replaced equipment shall not be reused.

The Permittee shall then maintain a list showing each piece of equipment and its identification number, correlating it to the appropriate Process or Control Equipment number (e.g., 001‐007) and the Delta EU number from Attachment D of ANDXL‐002. The Permittee shall update the list to add new pieces of equipment or identify equipment that has been taken out of service.

Equipment Excluded from this Labeling Requirement: Equipment meeting the requirements listed in the portion of this Attachment A entitled “Process Equipment 003” and “Control Equipment 004” shall only meet the labeling requirements detailed in those portions of this Attachment A.

Minn. R. 7007.1200, subp. 4

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

STANDARD OPERATIONAL REQUIREMENTS

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


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Minn. R. 7007.0800, subps. 2 and 16(J)

Air Pollution Control Equipment: The Permittee shall operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in ANDXL‐002.

Minn. R. 7007.0800, subps. 14 and 16(J)

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

Minn. R. 7019.1000, subp. 4

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

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

40 CFR pt. 50; Minn. Stat. § 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010‐7009.0080

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

Minn. R. 7030.0010‐7030.0080

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

Minn. R. 7007.0800, subp. 16

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

STANDARD PERFORMANCE TESTING REQUIREMENTS

Minn. R. ch. 7017 Performance Testing: The Permittee shall conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in ANDXL‐002.

All VOC performance tests for ANDXL‐002 other than for destruction efficiency shall measure VOC emissions on a mass basis as VOC.

Minn. R. 7017.2030, subp. 1 through 4; Minn. R. 7017.2035, subp. 1 and 2

When conducting performance tests, the Permittee shall submit the following performance test notifications and reports:

1) Performance Test Notification (written): due 30 days before each


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Performance Test;

2) Performance Test Plan: due 30 days before each Performance Test;

3) Performance Test Pre‐test Meeting: due 7 days before each Performance Test;

4) Performance Test Report: due 45 days after each Performance Test (satisfies 40 CFR § 52.21(aa)(14)(iii)); and

5) Performance Test Report ‐ Microfiche Copy: due 105 days after each Performance Test.

The Notification, Test Plan, and Microfiche Copy of the Test Report may be submitted in an alternative format as allowed by Minn. R. 7017.2018.

Minn. R. 7017.2025 Limits set as a result of a performance test apply until superseded as specified in Minn. R. 7017.2025 following formal review of a subsequent test on the same unit.

40 CFR § 52.21(aa)(14)(iii) and Minn. R. 7007.3000

PAL Re‐Validation Results. For all re‐validation submittals not regulated by Minn. R. 7017.2001‐2060 (performance tests), the Permittee shall submit to the Agency the results of any revalidation test or method within 3 months after completion of such test or method. Where such a submittal is regulated by Minn. R. 7017.2001‐2060, those deadlines shall apply.

STANDARD MONITORING REQUIREMENTS

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

Calibration of Monitoring Equipment: The Permittee shall annually calibrate all required monitoring equipment unless otherwise noted in ANDXL‐002.

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

Operation of Monitoring Equipment: Unless otherwise noted in ANDXL‐002, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shut down, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they shall reflect any such periods of process shutdown or checks of the monitoring system.

STANDARD RECORDKEEPING REQUIREMENTS FOR PROJECTS NOT SUBJECT TO NEW SOURCE REVIEW

Title I Condition: 40 CFR § 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2

These requirements apply if a reasonable possibility (RP) as defined in 40 CFR § 52.21(r)(6)(vi) exists that a proposed project, analyzed using the actual‐to‐projected‐actual (ATPA) test (either by itself or as part of the hybrid test at § 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no RP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of § 52.21(r)(6)(vi)(b).

Even though a particular modification is not subject to New Source Review (NSR), or where there isn't a RP that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R. 7007.1150 ‐ 7007.1500.

Title I Condition: 40 CFR § 52.21(r)(6); Minn. R.

These requirements do not apply to VOC emissions increases under the PAL. Preconstruction Documentation ‐‐ Before beginning actual construction on a


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7007.3000; Minn. R. 7007.1200, subp. 4; Minn. R. 7007.0800, subps. 4 & 5

project, the Permittee shall document the following:

1. Project description

2. Identification of any emission unit (EU) whose emissions of an NSR pollutant could be affected

3. Pre‐change potential emissions of any affected existing EU, and the projected post‐change potential emissions of any affected existing or new EU.

4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the EU could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination.

The Permittee shall maintain records of this documentation.

Title I Condition: 40 CFR § 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

These requirements do not apply to VOC emissions increases under the PAL.

The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the ATPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project.

Title I Condition: 40 CFR § 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

These requirements do not apply to VOC emissions increases under the PAL.

The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR § 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain:

a. The name and ID number of the facility, and the name and telephone number of the facility contact person

b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded.

c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection.

STANDARD REPORTING/SUBMITTALS

Minn. R. 7019.1000, subp. 3

Shutdown Notifications: The Permittee shall notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or


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process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the Permittee does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B, and C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the Permittee shall inform the Commissioner of the cause of the shutdown and the estimated duration. The Permittee shall notify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 2

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

At the time of notification or as soon as possible thereafter, the Permittee shall inform the Commissioner of the cause of the breakdown and the estimated duration. The Permittee shall notify the Commissioner when the breakdown is over.

Minn. R. 7019.1000, subp. 1

Notification of Deviations. The Permittee shall report deviations which could endanger human health or the environment as soon as possible after discovery of the deviation in accordance with Minn. R. 7019.1000.

Minn. R. 7019.1000, subp. 1

Written Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, the Permittee shall notify the Commissioner in writing of any deviations from permit conditions which could endanger human health or the environment. The Permittee shall include the following information in this written description:

1) the cause of the deviation;

2) the exact dates of the period of the deviation, if the deviation has been corrected;

3) whether or not the deviation has been corrected;

4) the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and

5) steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation.

Title I Condition: 40 CFR § 52.21(aa)(14)(ii) and Minn. R. 7007.3000

PAL Deviations Reporting. This report shall be submitted with the Notifications of Deviations Endangering Human Health or the Environment listed elsewhere in Attachment A of ANDXL‐002 or in the Air: Semi‐Annual Report listed in Section 8 of ANDXL‐002, whichever is applicable. The PAL Deviations Report shall include the following information and shall use Agency approved forms, where available:

(a) The identification of Permittee and the permit number;

(b) The PAL requirement that experienced the deviation or that was exceeded;


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(c) Emissions resulting from the deviation or the exceedance; and

(d) A signed statement by the responsible official certifying the truth, accuracy, and completeness of the information provided in the report.

Total Facility Requirements National Emission Standards for Hazardous Air Pollutants (NESHAP) for Surface Coating of Wood Building Products (40 CFR pt. 63, subp. QQQQ)


40 CFR § 63.4681; Minn. R. 7011.8000

The provisions listed in this portion of Attachment A apply to all surface coating of wood building products as defined in 40 CFR § 63.4781.

The affected source is the collection of all the following items (or updated as listed in 40 CFR § 63.4682(b)(1) through (4)).

(1) All coating operations as defined in § 63.4781 (includes preservative processes as well as traditional coating);

(2) All storage containers and mixing vessels in which coatings, thinners, and cleaning materials are stored or mixed;

(3) All manual and automated equipment and containers used for conveying coatings, thinners, and cleaning materials; and

(4) All storage containers and all manual and automated equipment and containers used for conveying waste materials generated by a coating operation.

40 CFR § 63.4683(b); 40 CFR § 63.6(c)(1); Minn. R. 7011.8000

The Permittee shall comply with the applicable portions of 40 CFR pt. 63, subp. QQQQ (referred to as “subpart QQQQ” in this portion of Attachment A) by May 28, 2006.

EMISSION AND OPERATIONAL LIMITS

40 CFR § 63.4690(b); Minn. R. 7011.8000

Hazardous Air Pollutants (HAP): The Permittee shall not cause to be discharged into the atmosphere from the Facility organic HAP emissions in an amount that is greater than or equal to 231 grams HAP/liter solids (1.93 lb HAP/gallon solids) determined as a 12‐month rolling average calculated as required by 40 CFR § 63.4751 by the end of each calendar month for the previous 12 month period. While the permit requirements generally only list metric units (i.e., grams and liters), all monitoring and recordkeeping can be completed in either metric or English (i.e., pounds and gallons) units.

40 CFR § 63.4700(a)(1); Minn. R. 7011.8000

The Permittee must be in compliance with the emission limitations in subpart QQQQ as specified in paragraph (a)(1) of 40 CFR § 63.4700. Any coating operation(s) for which the Permittee uses the emission rate without add‐on controls option, as specified in 40 CFR § 63.4691(a) and (b), must be in compliance with the applicable emission limit in 40 CFR § 63.4690 at all times.

40 CFR § 63.4700(b); 40 CFR § 63.6(e)(1)(i); Minn. R. 7011.8000

At all times, including periods of startup, shutdown, and malfunction, the Permittee must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards, as described by 40 CFR § 63.6(e)(1)(i).


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MONITORING AND RECORDKEEPING

40 CFR § 63.4691; Minn. R. 7011.8000

The Permittee shall include all coatings, thinners, and cleaning materials used in the affected source when determining whether the organic HAP emission rate is equal to or less than the applicable emission limit in 40 CFR § 63.4690. To make this determination, the Permittee must use at least one of the three compliance options listed in paragraphs (a) through (c) of 40 CFR§ 63.4691. ANDXL‐002 only includes option (b) based on the current operations of the affected source. If the Permittee later chooses to switch to one or both of the other options, the Permittee shall comply with all applicable portions of subpart QQQQ for those options.

40 CFR § 63.4691(b); Minn. R. 7011.8000

The Permittee shall demonstrate that, based on the coatings, thinners, and cleaning materials used in the coating operation(s), the organic HAP emission rate for the coating operation(s) is less than or equal to the applicable emission limit(s) in 40 CFR § 63.4690, calculated as a rolling 12‐month emission rate and determined on a monthly basis. The Permittee must meet all the requirements of 40 CFR §§ 63.4750, 63.4751, and 63.4752 to demonstrate compliance with the emission limit using this option.

40 CFR § 63.4730(a) and (b); Minn. R. 7011.8000

The Permittee must collect and keep records of the data and information specified below. Failure to collect and keep these records is a deviation from the NESHAP.

(a) A copy of each notification and report submitted to comply with subpart QQQQ, and the documentation supporting each notification and report.

(b) A current copy of information provided by materials suppliers or manufacturers, such as manufacturer’s formulation data, or test data used to determine the mass fraction of organic HAP and density for each coating, thinner, and cleaning material and the volume fraction of coating solids for each coating. If the Permittee conducted testing to determine mass fraction of organic HAP, density, or volume fraction of coating solids, the Permittee must keep a copy of the complete test report. If the Permittee used information provided by the manufacturer or supplier of the material that was based on testing, the Permittee must keep the summary sheet of results provided by the manufacturer or supplier. The Permittee is not required to obtain the test report or other supporting documentation from the manufacturer or supplier.

40 CFR § 63.4730(c) through (k); Minn. R. 7011.8000

continued

(c) For each compliance period, the records specified below:

(1) A record of the coating operations at which the Permittee used each compliance option and the time periods (beginning and ending dates and times) the Permittee used each option.

(2) [not currently applicable]

(3) A record of the calculation of the total mass of organic HAP emissions for the coatings, thinners, and cleaning materials used each month, using Equations 1, 1A through 1C, and 2 of 40 CFR § 63.4751; and, if applicable, the calculation used to determine mass of organic HAP in waste materials


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according to 40 CFR § 63.4751(e)(4); the calculation of the total volume of coating solids used each month, using Equation 2 of 40 CFR § 63.4751; and the calculation of each 12‐month organic HAP emission rate, using Equation 3 of 40 CFR § 63.4751.

(d) A record of the name and volume of each coating, thinner, and cleaning material used during each compliance period.

(e) A record of the mass fraction of organic HAP for each coating, thinner, and cleaning material used during each compliance period.

(f) A record of the volume fraction of coating solids for each coating used during each compliance period.

(g) A record of the density for each coating used during each compliance period; and, the density for each thinner and cleaning material used during each compliance period.

(h) If the Permittee used an allowance in Equation 1 of 40 CFR § 63.4751 for organic HAP contained in waste materials sent to or designated for shipment to a treatment, storage, and disposal facility (TSDF) according to 40 CFR § 63.4751(e)(4), the Permittee must keep records of the information specified in paragraphs (h)(1) through (3) of 40 CFR § 63.4730.

(i) [Reserved]

(j) The date, time, and duration of each deviation.

(k) [not currently applicable]

40 CFR § 63.4750; Minn. R. 7011.8000

The Permittee must complete the initial compliance demonstration for the initial compliance period according to the requirements of 40 CFR § 63.4751. The initial compliance period begins on May 28, 2006 and ends on May 31, 2007. The Permittee must determine the mass of organic HAP emissions and volume of coating solids used each month and then calculate a 12‐month organic HAP emission rate at the end of the initial 12‐month compliance period. The initial compliance demonstration includes the calculations according to 40 CFR § 63.4751 and supporting documentation showing that during the initial compliance period the organic HAP emission rate was equal to or less than the applicable emission limit in 40 CFR § 63.4690.

40 CFR § 63.4751; Minn. R. 7011.8000

The Permittee must meet all the requirements of 40 CFR § 63.4751 to demonstrate initial compliance with the applicable emission limit in 40 CFR § 63.4690 for the coating operation(s).

The Permittee does not need to re‐determine the mass of organic HAP in coatings, thinners, or cleaning materials that have been reclaimed onsite and reused in the coating operation(s).

40 CFR § 63.4751(a) through (e); Minn. R. 7011.8000

The Permittee must:

(a) Determine the mass fraction of organic HAP for each coating, thinner, and cleaning material used during each month according to the requirements in 40 CFR § 63.4741(a).


Page 14 of 67



(b) Determine the volume fraction of coating solids for each coating used during each month according to the requirements in 40 CFR § 63.4741(b).

(c) Determine the density of each coating, thinner, and cleaning material used during each month from test results using ASTM Method D1475–90, information from the supplier or manufacturer of the material, or reference sources providing density or specific gravity data for pure materials. If there is disagreement between ASTM Method D1475–90 test results and such other information sources, the test results will take precedence.

(d) Determine the volume (liters) of each coating, thinner, and cleaning material used during each month by measurement or usage records.

(e) Calculate the mass of organic HAP emissions. The mass of organic HAP emissions is the combined mass of organic HAP contained in all coatings, thinners, and cleaning materials used during each month minus the organic HAP in certain waste materials.

40 CFR § 63.4751(e) continued; Minn. R. 7011.8000

continued

Calculate it using Equation 1.

we RCBAH (Equation 1)

Where: He = Total mass of organic HAP emissions during the month, grams.

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

B = Total mass of organic HAP in the thinners used during the month, grams, as calculated in Equation 1B.

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

Rw = Total mass of organic HAP in waste materials sent or designated for shipment to a hazardous waste TSDF for treatment or disposal during the month, grams, determined according to 40 § CFR 63.4751(e)(4). (The Permittee may assign a value of zero to Rw if the Permittee does not wish to use this allowance.)

(1) Calculate the mass of organic HAP in the coatings used during the month, using Equation 1A.

m

iicicic WDVolA

1,,, ))()(( (Equation 1A)

Where:

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

Volc,i = Total volume of coating, i, used during the month, liters.


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Dc,i = Density of coating, i, grams coating per liter coating.

Wc,i = Mass fraction of organic HAP in coating, i, grams organic HAP per gram coating.

m = Number of different coatings used during the month.

(2) Calculate the mass of organic HAP in the thinners used during the month, using Equation 1B.

n

jjtjtjt WDVolB

1,,, ))()(( (Equation 1B)

Where:

B = Total mass of organic HAP in the thinners used during the month, grams.

Volt,j = Total volume of thinner, j, used during the month, liters.

Dt,j = Density of thinner, j, grams per liter.

Wt,j = Mass fraction of organic HAP in thinner, j, grams organic HAP per gram thinner.

n = Number of different thinners used during the month.

(3) Calculate the mass of organic HAP in the cleaning materials used during the month using Equation 1C.

p

kksksks WDVolC

1,,, ))()(( (Equation 1C)

Where:

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

Vols,k = Total volume of cleaning material, k, used during the month, liters.

Ds,k = Density of cleaning material, k, grams per liter.

Ws,k = Mass fraction of organic HAP in cleaning material, k, grams organic HAP per gram material.

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

(4) If the Permittee chooses to account for the mass of organic HAP contained in waste materials sent or designated for shipment to a hazardous waste TSDF in Equation 1, then the Permittee must determine it according to paragraphs 40 CFR § 63.4751(e)(4)(i) through (iv).

40 CFR § 63.4751(f) and (g); Minn. R. 7011.8000

continued

(f) Determine the total volume of coating solids used which is the combined volume of coating solids for all the coatings used during each month, using Equation 2.


Page 16 of 67



m

iisicst VVolV

1,, ))(( (Equation 2)

Where:

Vst = Total volume of coating solids used during the month, liters.

Volc,i = Total volume of coating, i, used during the month, liters.

Vs,i = Volume fraction of coating solids for coating, i, liter solids per liter coating, determined according to 40 CFR § 63.4741(b).

m = Number of coatings used during the month.

(g) Calculate the organic HAP emission rate for the 12‐month compliance period, grams organic HAP per liter coating solids used, using Equation 3.

12

1

12

1

yst

ye

yr

V

H

H (Equation 3)

Where:

Hyr = Organic HAP emission rate for the 12‐month compliance period, grams organic HAP per liter coating solids.

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

Vst = Total volume of coating solids used during month, y, liters, as calculated by Equation 2.

y = Identifier for months.

40 CFR § 63.4751(h); Minn. R. 7011.8000

Compliance demonstration. The organic HAP emission rate for the initial 12‐month compliance period, calculated using Equation 3, must be less than or equal to the applicable emission limit in 40 CFR § 63.4690. The Permittee must keep all records as required by 40 CFR §§ 63.4730 and 63.4731. As part of the Notification of Compliance Status required by 40 CFR § 63.4710, the Permittee must identify the coating operation(s) for which the Permittee used the emission rate without add‐on controls option and submit a statement that the coating operation(s) was (were) in compliance with the emission limitations during the initial compliance period because the organic HAP emission rate was less than or equal to the applicable emission limit in 40 CFR § 63.4690, determined according 40 CFR § 63.4751.

40 CFR § 63.4752; Minn. R. 7011.8000

(a) To demonstrate continuous compliance, the organic HAP emission rate for each compliance period, calculated using Equation 3, must be less than or equal to the applicable emission limit in 40 CFR § 63.4690. A compliance period consists of 12 months. Each month after the end of the initial compliance period described in 40 CFR § 63.4750 is the end of a compliance period consisting of that month and the preceding 11 months. The Permittee must perform the calculations in 40 CFR § 63.4751(a) through (g) on a monthly basis


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using data from the previous 12 months of operation.

(b) If the organic HAP emission rate for any 12‐month compliance period exceeded the applicable emission limit in 40 CFR § 63.4690, this is a deviation from the emission limitations for that compliance period and must be reported as specified in 40 CFR §§ 63.4710(c)(6) and 63.4720(a)(6).

(c) As part of each semi‐annual compliance report required by 40 CFR by § 63.4720, the Permittee must identify the coating operation(s) for which the Permittee used the emission rate without add‐on controls option. If there were no deviations from the emission limitations, the Permittee must submit a statement that the coating operation(s) was (were) in compliance with the emission limitations during the reporting period because the organic HAP emission rate for each compliance period was less than or equal to the applicable emission limit in 40 CFR § 63.4690, determined according to 40 CFR § 63.4751(a) through (g).

40 CFR § 63.4731and 40 CFR § 63.10(b)(1); Minn. R. 7011.8000; Minn. R. 7019.0100, subp. 2

The Permittee shall maintain files of all information (including all reports and notifications) required by this part recorded in a form suitable and readily available for expeditious inspection and review. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent 2 years of data shall be retained on site. The remaining 3 years of data may be retained off site. Such files may be maintained on microfilm, on a computer, on computer floppy disks, on magnetic tape disks, or on microfiche.

40 CFR § 63.10(b)(2); Minn. R. 7011.8000; Minn. R. 7019.0100, subp. 2

The Permittee shall maintain relevant records of:

1) The occurrence and duration of each startup, shutdown, or malfunction of operation (i.e., process equipment);

2) All required measurements needed to demonstrate compliance with a relevant standard (including, but not limited to raw performance testing measurements that support data that the source is required to report);

3) All results of performance tests;

4) All measurements as may be necessary to determine the conditions of performance tests and performance evaluations; and

5) All documentation supporting initial notifications and notifications of compliance status under 40 CFR § 63.9.

SUBMITTALS AND NOTIFICATIONS

40 CFR § 63.9(j); Minn. R. 7011.8000; Minn. R. 7019.0100, subp. 2

Any change in the information already provided under 40 CFR § 63.9 shall be provided to the Administrator in writing within 15 calendar days after the change.

40 CFR § 63.4720(a)(1) and (3); Minn. R. 7011.8000

Semi‐Annual Compliance Reports. The Permittee must submit semi‐annual compliance reports for each affected source as part of the Air: Semi‐Annual Report listed in Section 8 of ANDXL‐002 (due August 15th and February 15th, dates established under 40 CFR § 63.4720(a)(1)(iv)) starting on February 15, 2008. The Semi‐Annual Compliance Report must contain the information


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specified in 40 CFR § 63.4720(a)(3)(i) through (v) and in 40 CFR § 63.4720(a)(4) through (a)(7) and (c)(1), as applicable to the affected source.

40 CFR § 63.4720(2); Minn. R. 7011.8000

Deviations Report. The Permittee must report all deviations as defined in 40 CFR pt. 63, subp. QQQQ with the Notifications of Deviations Endangering Human Health or the Environment listed elsewhere in Attachment A of ANDXL‐002 or in the Air: Semi‐Annual Report listed in Section 8 of ANDXL‐002, whichever is applicable.

Process: 001 Preservative Processes Preservative processes include any equipment where wood parts that are not intended to be painted are treated with a wood preservative, whereas, pretreatment refers to a coating applied prior to painting. Systems may use solventborne or waterborne solutions, and may be batch or in‐line systems. During drafting of ANDXL‐002, the preservative processes at the Facility consist of two solventborne diptanks, one solventborne dryer, an R&D water‐based treater,and 6 waterborne in‐line treatment systems (ILTS) and miscellaneous repair/rework areas. See Attachment D of ANDXL‐002 for the complete list. All preservative processes at the Facility, including those that are modified, reconstructed, added or replaced after permit issuance, shall meet the requirements of this section of Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.

Process Equipment 001



Title I Condition: Limit to avoid classification as a major modification under 40 CFR § 52.21 and Minn. R. 7007.3000

VOC Emissions Control: The Permittee shall vent the emissions from the two solventborne diptanks and the solventborne dryer (EUs 100, 101, and 102) to control equipment meeting the requirements set forth in the portion of this Attachment A entitled “Control Equipment 006” whenever the process equipment is in operation.

Minn. Stat. § 114C.10, subd. 1; FPA, Part II.D.1.e

VOC Emissions: The Permittee shall not cause VOCs to be discharged into the atmosphere at a rate greater than 2.0 pounds per gallon of preservative used from any new or reconstructed preservative application process with a potential to emit 40 tons per year or more of VOC. “Reconstructed” shall have the meaning given in 40 CFR § 60.15(b).



Daily Recordkeeping: On each day of operation, the Permittee shall record and maintain the total quantity of VOC‐containing preservative materials delivered for use in the preservative processes, in gallons, based on purchasing records.


Monthly Recordkeeping: VOC Emissions. By the last day of each calendar month, the Permittee shall calculate and record the VOC emissions from the preservative processes, in tons/month, for the previous calendar month using the methods specified in ANDXL‐002.

Title I Condition: 40 CFR § 52.21(aa)(7)(vi) and (aa)(12)(vii) and Minn. R.

Monthly Calculation: VOC Emissions. The Permittee shall make the following calculation for the preservative processes


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7007.3000 (as a group), each calendar month:

1) The Permittee shall calculate the total VOC emitted from all deliveries for the month using the total quantity delivered and VOC content determined as required by ANDXL‐002. This may be done by multiplying each delivery amount by its VOC content and summing the results or by summing deliveries of a particular material for the period and multiplying the sum by the applicable VOC content. VOCs from all materials are then summed.

2) The Permittee may elect to calculate the amount of VOC shipped off‐site. If elected, this shall be done by using the material content for shipped wastes determined as set forth in the portion of this Attachment A entitled “Total Facility Requirements”, multiplied by the amount shipped. VOCs from all shipments are then summed.

VOC emissions for the month are equal to item 1) minus item 2). Item 2) may be zero.

If delivery data is not available, the Permittee shall assume the maximum potential usage of the given material (or worst‐case material if no data exists indicating which material was delivered) without considering enforceable limitations or operational restrictions for the period of time when data was not available.

Title I Condition: Recordkeeping for limit under 40 CFR § 52.21(aa) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 and 5

Recordkeeping of Equipment Changes: The Permittee shall keep records of any processes that are modified, reconstructed, added or replaced. The records shall include the date the process was modified, reconstructed, added, or replaced, a description of the change, the equipment manufacturer and model number (if applicable), and the potential to emit.

Minn. R. 7007.0800, subp. 4 and 5

Pre‐Change Notification: The Permittee shall submit a written notice to the MPCA 10 days prior to the installation of any new or reconstructed preservative application process with a potential to emit 40 tons per year or more of VOC. The notice shall include a description of the emissions unit (i.e., manufacturer, model number, and maximum capacity) and a description of how the unit will meet the 2.0 lbs of VOC/gallon of preservative limit.

If the new or reconstructed preservative process has different technology than an existing best performing preservative system, the Permittee must provide justification that the new equipment is environmentally superior and must obtain MPCA written approval prior to construction of the new or reconstructed equipment.

Process: 002 Painting Processes Painting processes at the Facility consist of “paintlines”, which are production related and automated; “other production related painting processes”, which are production related and not automated; and “other painting processes” which are not production related. Coatings used in painting processes may include pretreatments, primers, topcoats and related coatings. Pretreatments are coatings applied prior to painting, but are considered part of the painting processes under ANDXL‐002.


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The term “production painting processes” as used in the permit shall refer to both paintlines and other production related painting processes. “Paint application equipment” refers to the part of a painting process that is used to apply a coating such as a spray gun, disc or bell. This applies to all painting processes. Paintlines: A “paintline” means any process by which window or door parts receive a surface coating in an automated inline process. This includes all equipment that applies and dries coatings for surface protection of door and window parts. During drafting of ANDXL‐002, the Facility has six vertical paintlines (each equipped with two application silos) with pretreatment processes, two horizontal paintlines (one flexiframe line with two booths, and one longlength line with one booth), with pretreatment processes, two interior lineal booths, and two door paintlines (flatlines) with pretreatment on each line. Other production‐related painting processes: The Facility has two, non‐automated production related processes. These are an endspray booth and the Doors Manual Booth. Each process includes all associated equipment that applies and dries coatings for surface protection of door and window parts. Other Painting Processes: There are currently three other painting processes at the Facility. These are a maintenance spray booth, a research and development spray booth, and housekeeping/upkeep painting which does not usually occur in a booth (painting of buildings, structures, etc.). They are not related to production and are not automated. These processes would otherwise qualify as insignificant under Minn. R. 7007.1300, subp. 3(K), and subp. 4(B) and (C). See Attachment D of ANDXL‐002 for the complete list of painting processes. All painting processes at the Facility, including those that are modified, reconstructed, added or replaced after permit issuance, shall meet the requirements of this section of Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.




Minn. Stat. § 114C.10, subd. 1; FPA, Part II.D.1.e

VOC Emissions: The Permittee shall not cause VOCs to be discharged into the atmosphere at a rate greater than 4.5 pounds per gallon of coating applied from any new or reconstructed paintline that has a potential to emit 40 tons per year or more of VOC. “Reconstructed” shall have the meaning given in 40 CFR § 60.15(b).


Particulate Matter Control: All paint application equipment, other than equipment used for housekeeping/upkeep painting, must be controlled by equipment meeting the requirements set forth in the portion of this Attachment A entitled “Control Equipment 001” whenever the process equipment is operated.

Title I Condition: limit under 40 CFR § 52.21(aa) and Minn. R. 7007.3000; FPA, Part II.D.1.d

VOC Control of Doorplant (EU 182): The Permittee shall operate a regenerative thermal oxidizer to control VOC emissions from the door flatline painting processes until receiving written approval from the MPCA to discontinue use of the oxidizer as described in the portion of this Attachment A entitled “Control Equipment 008”.

Minn. R. 7007.0800, subp. 2

VOC Control of Flow Coaters and Associated Flashoff Areas (EUs 118, 119, and 120): Except as detailed below, the Permittee shall vent the emissions from the flow coaters and associated flashoff areas on paintlines 3, 4, and 5&6 to control equipment meeting the requirements set forth in the portion of this Attachment A entitled “Control Equipment 007” whenever the process equipment is in operation


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and using materials that contain VOC.

If any of these units are modified such that they comply with the above VOC Emissions limit (4.5 pounds/gallon) without the use of controls, then this control requirement does not apply. If this exclusion applies, the Permittee shall keep a record of the demonstration that the unit complies with the VOC emissions limit.


Title I Condition: 40 CFR § 52.21(aa)(12) and Minn. R. 7007.3000 (VOC); Minn. R. 7007.0800, subp. 4 and 5 (PM/PM10)

Daily Recordkeeping: On each day of operation, the Permittee shall record and maintain the total quantity of all materials delivered for use to the production painting processes, in gallons, based on purchasing records.


Monthly Recordkeeping: Materials Used. By the last day of each calendar month, the Permittee shall determine which materials were used in the previous calendar month at each of the various production painting processes that uses a different control efficiency or emissions factor. This shall be done using the daily records of delivered materials and daily production records from each of the production painting processes.


Monthly Recordkeeping: VOC Emissions. By the last day of each calendar month, the Permittee shall calculate and record the total VOC emissions, in tons/month, from all painting processes for the previous calendar month using the methods specified in ANDXL‐002.

Minn. R. 7007.0800, subp. 4 and 5

Monthly Recordkeeping: PM/PM10/PM2.5 Emissions. By the last day of each calendar month, the Permittee shall calculate and record the total PM/PM10/PM2.5 emissions, in tons/month, from all painting processes for the previous calendar month using the methods specified in ANDXL‐002.

Title I Condition: 40 CFR § 52.21(aa)(7)(vi) and (12)(vii) and Minn. R. 7007.3000

Monthly Calculation: VOC Emissions. The Permittee shall make the following calculations separately for each type of production painting process which uses a different control efficiency, for each calendar month:

1) The Permittee shall calculate the total VOC delivered for the month using total quantity delivered and VOC content determined as required by ANDXL‐002. This may be done by multiplying each delivery amount by its VOC content and summing the results or by summing deliveries of a particular material for the period and multiplying the sum by the applicable VOC content. VOCs from all materials are then summed.

2) The Permittee may elect to calculate the amount of VOC shipped off‐site for the given painting process. If elected, this shall be done by using the material content for shipped wastes determined as set forth in the portion of this Attachment A entitled “Total Facility Requirements”, multiplied by the amount shipped. VOCs from all shipments are then summed.

3) If the Permittee elects to calculate VOC from waste shipped under item 2), then the Permittee shall subtract item 2) from item 1).


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4) The Permittee shall multiply item 3) by [1 minus the most recent approved overall capture and control efficiency], expressed as a fraction, for that painting process for the given period of operation or use of materials. Currently, only the door flatlines have VOC controls as set forth in the portion of this Attachment A entitled “Control Equipment 008”.

VOC emissions are the sum of item 4) for all production painting processes plus 0.044 tons/month for the other painting processes (the VOC “add‐on”). The capture and control value and item 2) may be zero.


Minn. R. 7007.0800, subp. 4 and 5

Monthly Calculation: PM/PM10/PM2.5 Emissions. The Permittee shall make the following calculations separately for each type of production painting process which uses a different emissions factor, for each calendar month:

1) The Permittee shall calculate the total solids delivered to the painting process for the month using total quantity delivered and solids content determined as required by ANDXL‐002. This may be done by multiplying each delivery amount by its solids content and summing the results or by summing deliveries of a particular material for the period and multiplying the sum by the applicable solids content. Solids from all materials are then summed.

2) The Permittee may elect to calculate the amount of solids shipped off‐site from the given painting process. If elected, this shall be done by using the material content for shipped wastes determined as set forth in the portion of this Attachment A entitled “Total Facility Requirements”, multiplied by the amount shipped. Solids are then summed for all shipments.

3) If the Permittee elects to calculate solids from waste shipped under item 2), then the Permittee shall subtract item 2) from item 1).

4) The Permittee shall multiply item 3) by the most recent approved PM/PM10/PM2.5 emission factor for that painting process.

PM/PM10/PM2.5 emissions are the sum of item 4) for all production painting processes plus 0.022 tons/month for the other painting processes (the PM/PM10/PM2.5 “add‐on”). Item 2) may be zero.

The Emissions Factor for each painting process shall be the emissions factor specified in this paragraph or an MPCA‐approved alternative factor. Currently there are three emission factors; one for the vertical paintlines (2.70E‐03 lb/lb sprayed), one for the horizontal paintlines and other production related painting processes (6.80E‐03 lb/lb sprayed) and one for the door flatlines. The flatline value is zero. The Permittee may elect to use the higher of the emissions factors in any or all calculations. This would allow combination of those types of painting processes for the calculation and recordkeeping requirements given above.

The Permittee may propose alternative emissions factors derived from MPCA‐


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approved performance tests. If approved by MPCA, the Permittee shall use the alternative emissions factor if it is higher than the one currently being used, and may use it if it is lower than the one currently being used. This paragraph does not mean that processes cannot be combined as allowed above.


Recordkeeping of Equipment Changes: The Permittee shall keep records of any processes that are modified, reconstructed, added, or replaced. The record shall include the date the process was modified, reconstructed, added, or replaced, a description of the change, the manufacturer and model number (if applicable), and the potential to emit.

Minn. R. 7007.0800, subp. 4 and 5

Pre‐Change Notification: The Permittee shall submit a written notice to the MPCA 10 days prior to the installation of any new or reconstructed paintline process with a potential to emit 40 tons per year or more of VOC. The notice shall include a description of the emissions unit (i.e., manufacturer, model number, and maximum capacity) and a description of how the unit will meet the 4.5 lbs of VOC/gallon of paint limit.

If the new or reconstructed paintline has different technology than an existing best performing paint system, the Permittee must provide justification that the new equipment is environmentally superior and must obtain MPCA written approval prior to construction of the new or reconstructed equipment.

Process: 003 Milling Equipment Milling equipment refers to activities that involve the cutting and shaping of wood or Fibrex™ except that shaping by extrusion shall not be considered milling. Equipment includes cutters, saws, sanders, grinders, planers, tenoners, moulders, joiners, silo vents, drills, trimmers, and hogs. In addition, for the purposes of ANDXL‐002, milling processes include solid waste compacting and bailing as detailed in the August 12, 2005, BACT analysis. All milling equipment is controlled by fabric filters that are vented either externally or internally, as described by the portions of this Attachment A entitled “Control Equipment 003” for externally vented units, or “Control Equipment 004” for internally vented units. The Permittee’s raw wood materials are plank and cut‐stock. Plank is milled into clear cut‐stock using rip saws and cut‐off saws. Smaller cut‐offs are glued together into glued cut‐stock. “Cut‐stock” refers to wood that is cut to pre‐determined lengths based on industry standards for sizes and shapes of windows. Cut‐stock is then milled into parts specific to the Permittee’s products. Milling cut‐stock primarily uses moulders (which cut the sides) and tenoners (which cut the ends). Cut‐off saws are used to shorten damaged pieces to the next shorter size. Tenoners will reshape an end. Parts then proceed to other portions of the Facility for coating, assembly, etc. Fibrex™ milling operations generally include cut‐off saws and end fabrication of profiles after extrusion. See Attachment D of ANDXL‐002 for the complete list of milling emissions units that exist during drafting of ANDXL‐002. All milling equipment at the Facility, including those activities that are modified, reconstructed, added or replaced after permit issuance, shall meet the requirements of this section of Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.


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Title I Condition: 40 CFR § 52.21(j) (BACT) and Minn. R. 7007.3000

PM and PM10 BACT Limits for Externally Vented Units: The Permittee shall not cause to be discharged into the atmosphere from any externally vented milling equipment either PM10 or PM emissions in an amount that exceeds 0.0030 gr/dscf based on a 3‐hour average.

Title I Condition: to avoid a major modification under 40 CFR § 52.21 and Minn. R. 7007.3000

PM2.5 Limits for Externally Vented Units: The Permittee shall not cause to be discharged into the atmosphere from any externally vented milling equipment PM2.5 emissions in an amount that exceeds 0.0030 gr/dscf based on a 3‐hour average.

Title I Condition: 40 CFR § 52.21(j) (BACT) and Minn. R. 7007.3000

PM/PM10 Control for both Internally and Externally Vented Units: The Permittee must control all milling equipment with equipment meeting the requirements set forth in the portions of this Attachment A entitled “Control Equipment 003” for externally vented units, or “Control Equipment 004” for internally vented units, whenever the process equipment is operated.


PM2.5 Control for both Internally and Externally Vented Units: The Permittee must control all milling equipment with equipment meeting the requirements set forth in the portions of this Attachment A entitled “Control Equipment 003” for externally vented units, or “Control Equipment 004” for internally vented units, whenever the process equipment is operated.

Title I Condition: 40 CFR § 52.21(j)(4) and Minn. R. 7007.3000

BACT Evaluation: In accordance with 40 CFR § 52.21(j)(4), the Permittee shall re‐evaluate the BACT determination at least every 18 months and shall submit those findings to the MPCA for review and approval. If the MPCA determines that the BACT limits in ANDXL‐002 no longer meet the re‐evaluated BACT, the permit will be amended to address future milling modifications.

Title I Condition: 40 CFR § 52.21(j)(4) and Minn. R. 7007.3000

Authorized Milling Changes under BACT: 1) Each milling emissions unit consists of any milling process equipment or

group of milling process equipment up to the capacity listed in the table below controlled by the listed CE device. Individual process equipment may be moved, replaced, or added, so long as the listed capacities are not exceeded and all pertinent permit requirements are met.

2) Control equipment may be replaced with like‐kind equipment so long as all pertinent permit requirements are met.

3) All control equipment shall meet the requirements listed in the portions of this Attachment entitled “Control Equipment 003” and “Control Equipment 004”.

Emission Unit ID (see Attachment D)

Control Equipment ID

(see Attachment E)

Milling Process Equipment

Maximum Capacity

502 003 57600 acfm

504 005 35200 acfm

505 006 75000 acfm

506 007 53000 acfm

507 008 22190 acfm

508 009 2000 acfm

510 011 14000 acfm


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512 013 8000 acfm

514 015 44376 acfm

515 016 60000 acfm

518 017 35200 acfm

521 018 28440 acfm

524 021 1270 acfm

525 022 1750 acfm

526 023 1270 acfm

527 024 110370 acfm

532 029 14000 acfm

533 030 10000 acfm

548 012 35000 acfm

553 004 48000 acfm

555 010 15000 acfm

557 014 35200 acfm

567 001 46000 acfm

570 002 48000 acfm

575 019 52350 acfm

577 020 52350 acfm

579 025 71630 acfm

583 026 71630 acfm

588 028 71630 acfm

593 055 2690 acfm

594 056 36980 acfm

595 057 22190 acfm

599 078 15400 acfm

603 079 87750 acfm

604 080 42108 acfm

605 081 115675 acfm

Emission Unit ID (see Attachment D)

Control Equipment ID

(see Attachment E)

Milling Process Equipment

Maximum Capacity

606 082 27000 acfm

607 083 24000 acfm

608 (new capacity) 084 250000 acfm


Title I Condition: Recordkeeping for BACT limit, 40 CFR § 52.21(j) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 and 5

Equipment Labeling and Recordkeeping for Externally Vented Milling Equipment: The Permittee shall affix and maintain a label on each piece of externally vented milling equipment showing a unique equipment identification number. If equipment is added, it shall be given a new unique number; numbers from removed or replaced equipment shall not be reused.

The Permittee shall maintain a list of all milling equipment vented to each externally vented filter system. Each list shall include the airflow requirements and date of installation of each piece of milling equipment, its identification number, and the Delta EU number from Attachment D of ANDXL‐002. The Permittee shall update the list whenever a change is made (e.g., addition of a


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new milling unit or to identify equipment that has been taken out of service).


Recordkeeping for Internally Vented Milling Equipment: At least once per calendar year, the Permittee shall verify that the airflow capacities of the Internally Vented Milling Emissions Units (EUs 603‐608) remain less than or equal to the values listed under the “Authorized Milling Changes” in the portion of this Attachment A entitled “Process Equipment 003”. Verification shall consist of re‐calculating the airflow capacities of each Internally Vented Milling Emissions Unit based on the forced exhaust flow rate for each unit.

Title I Condition: Monitoring for BACT limit, 40 CFR § 52.21(j) and Minn. R. 7007.3000; Minn. R. 7017.2020, subp. 1

The Permittee shall conduct performance tests on two of the milling emissions units each year after ANDXL‐001 expiration to verify the PM10 and PM2.5

emissions rate:

The Permittee shall propose which 2 milling emissions units to test for each year starting May 4, 2011 as part of the Notification required by Minn. R. 7017.2030, subp. 1. The proposed emissions units must meet the following criteria:

1 EU from the 10 largest milling units in terms of current actual airflow

1 EU from the 15 smallest milling units in terms of current actual airflow where the actual airflow is 70‐95% of the rated capacity

Process: 004 Vinyl and Other Plastic or Composite Processes Raw materials are blended to make vinyl and other plastic or composite material. Blended material is extruded into either a sheet (sheet extruders) or a profile (profile extruders). Sheet material is vacuum formed into a seamless frame cover which is used as an exterior skin for some window products. The profiles may be solid or have an inner core of a different material. Scrap material from the sheet extruders, profile extruders, and vacuum formers is collected and ground for re‐use. The grinders produce chips, which are passed through a pelletizing extruder, formed into pellets, and re‐extruded into a profile. The Facility also processes composite pellets (Fibrex™, a wood and vinyl composite) which are extruded into profiles. During drafting of ANDXL‐002, the equipment consists of three sheet extruders, 12 vacuum formers, and 33 profile extruders that can extrude either vinyl or composite materials, one pelletizing extruder, a shuttle former, and one compounder (units that emit both VOC and PM/PM10). There are also five grinders, three bin vents, one blender, and one wood/vinyl separator (units that emit only PM/PM10). The blender is controlled by fabric filters. The Facility also has two Research and Development (R & D) extruders and a Brabender extruder which are used for research and testing purposes. These processes would otherwise qualify as insignificant under Minn. R. 7007.1300, subp. 4(B) and (C), with actual emissions of VOC and PM10/PM2.5 of less than 1 ton per year. See Attachment D of ANDXL‐002 for the complete list of vinyl and other plastic composite process equipment. All vinyl and other plastic or composite processes at the Facility, including those that are modified,


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reconstructed, added or replaced after permit issuance, shall meet the requirements of this section of Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.





Particulate Control of Blender, Pulverizers, and Wood/Vinyl Separator, (EUs 270, 629, and future pulverizers): These units must be controlled by equipment meeting the requirements set forth in the portion of this Attachment A entitled “Control Equipment 005” whenever the process equipment is operated.

Minn. R. 7007.0800, subp. 2 Future Additional Particulate Control: The Permittee may choose to control emissions from vinyl and other plastic or composite processes with new control equipment described by the portion of this Attachment A entitled “Control Equipment 005”. For time periods when the control equipment is operated and when the control equipment meets the requirements of “Control Equipment 005”, the Permittee may take credit for its operation in the emissions calculations detailed in this section. Credit can be taken by using an MPCA‐approved controlled emissions factor.


Vacuum Formers Throughput Limit: The Permittee shall process no more than 13,000 tons per year of materials in the vacuum formers, as a group, based on a 12‐month rolling sum to be calculated as required by ANDXL‐002.


Vinyl Grinding Throughput Limit: The Permittee shall process no more than 20,000 tons per year of materials in the vinyl grinders, as a group, based on a 12‐month rolling sum to be calculated as required by ANDXL‐002.


Vinyl Pulverizing Throughput Limit: The Permittee shall process no more than 200 tons per year of materials in the vinyl pulverizers, as a group, based on a 12‐month rolling sum to be calculated as required by ANDXL‐002.


Sheetlines Throughput Limit: The Permittee shall process no more than 13,000 tons per year of materials in the sheetlines, as a group, based on a 12‐month rolling sum to be calculated as required by ANDXL‐002.


Title I Condition: 40 CFR § 52.21(aa)(12) and Minn. R. 7007.3000 (VOC); Minn. R. 7007.0800, subps. 4 and 5 (PM/PM10)

Daily Recordkeeping. 1) For units that emit both VOC and PM/PM10/PM2.5: On each day of

operation, the Permittee shall calculate and record the pounds of material processed for each type of process that has a separate emissions factor. At a minimum, the Permittee shall always separately record pounds of material processed at the vacuum formers and sheetlines.

2) For blenders, bins, conveyors, grinders, wood/vinyl separators, and pulverizers: On each day of operation, the Permittee shall calculate and record the total pounds of material processed for each group of equipment.

3) For all units, the record shall indicate if a particulate control device was used as allowed in this portion of Attachment A (see “Particulate Control”). The record shall be sufficient to determine what material was controlled versus uncontrolled.

Title I Condition: Recordkeeping for limit

Monthly Throughput Calculations: By the last day of each calendar month, the Permittee shall calculate and record the following for the vacuum formers,


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under 40 CFR § 52.21(k) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 and 5

pulverizers, sheetlines, and grinders, each as a separate group (e.g., calculate items #1 and #2 for all of the vacuum formers, calculate items #1 and #2 for all of the pulverizers, etc.):

1) The total throughput, in tons/month for the previous calendar month using the daily records.

2) The 12‐month rolling sum throughput, in tons/year, for the previous 12 month period by summing the monthly throughput values for the previous 12 months.


Monthly Recordkeeping: VOC and PM/PM10/PM2.5 Emissions. By the last day of each calendar month, the Permittee shall calculate and record the total VOC and PM/PM10/PM2.5 emitted, in tons/month, for the previous calendar month using the methods specified in ANDXL‐002.


Monthly VOC Emissions Calculations. The Permittee shall calculate the VOC emissions from the vinyl and other plastic or composite processes by multiplying the pounds of material processed in the month by the appropriate emissions factor. VOC emissions are the sum of all the calculations using different emissions factors plus 0.087 tons/month for the testing extruders (the VOC “add‐on”).

The VOC Emissions Factor shall be the emissions factor specified in this paragraph or an MPCA‐approved alternative factor. There are currently six different process types with separate VOC emissions factors (all in units of pounds of VOC per pound of vinyl): one for the sheetlines (4.85E‐03), one for the vacuum formers (7.30E‐03), one for the profile extruders (8.55E‐03), one for the composite extruders (1.18E‐03), one for the pelletizing extruder (2.13E‐04), and one for the compounder (1.89E‐03).

The Permittee may propose alternative emissions factors derived from MPCA‐approved performance tests. If approved by MPCA, the Permittee shall use the alternative emissions factor. If the required material processing data is not available, the Permittee shall assume the maximum potential processing rate of the given material without considering enforceable limitations or operational restrictions for the period of time when data was unavailable.

Minn. R. 7007.0800, subp. 4 and 5

Monthly PM/PM10/PM2.5 Emissions Calculations. The Permittee shall calculate the PM/PM10/PM2.5 emissions from the vinyl and other plastic or composite processes by multiplying the pounds of material processed in the month by the appropriate emissions factor. The PM/PM10/PM2.5 emissions are the sum of all the calculations using different emissions factors plus 0.0056 tons/month for the testing extruders (the PM/PM10/PM2.5 “add‐on”).

The PM/PM10/PM2.5 Emissions Factor shall be the emissions factor specified in this paragraph or an MPCA‐approved alternative factor, in either pounds of PM/PM10/PM2.5 per pound of material processed or in pounds of PM/PM10/PM2.5 per hour of operation. There are currently ten different process types with separate PM/PM10/PM2.5 emissions factors (all in units of pounds of PM/PM10/PM2.5 per pound of vinyl unless otherwise stated): one for


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the sheetlines (1.30E‐04), one for the vacuum formers (4.72E‐04), one for the profile and composite extruders (8.55E‐05), one for the pelletizing extruders (1.80E‐04), one for the compounder (1.04E‐04), one for the bins (2.43E‐06), one for the grinders (6.50E‐05), one for the pulverizer (9.19E‐04), one for the blender (1.09E‐05), and one for the wood/vinyl separator (1.50E‐04).

The Permittee may propose alternative emissions factors derived from MPCA‐approved performance tests. If approved by MPCA, the Permittee shall use the alternative emissions factor.


Recordkeeping of Equipment Changes: The Permittee shall keep records of any vinyl or other plastic processes that are modified, reconstructed, added or replaced. The record shall include the date the process was modified, reconstructed, added or replaced, a description of the change, and the manufacturer and model number (if applicable).

Title I Condition: 40 CFR § 52.21(aa)(12)(ix) and Minn. R. 7007.3000; Minn. R. 7017.2020, subp. 1

Performance Tests. The Permittee shall conduct performance tests on the following Process 004 equipment according to the following schedule to verify the VOC emissions factor for the given process group:

One of each of the following before the end of each 60 month period following the initial performance test, in parentheses: Composite Extruder (October 3, 2007), Pelletizing Extruder (October 22, 2008), Profile Extruder (October 3, 2007), and Vacuum Former (October 22, 2008)

One of each of the following ‐‐ Sheetlines and Compounder: before the end of each 60 month period starting May 4, 2006 (See Attachment D for EU numbers of the given types of equipment.)

Process: 005 Combustion Sources

Specific emission and operational limits that apply to specific subgroups are listed under each subgroup of combustion sources. Limits that apply across subgroups are listed in the table below. See Attachment D of ANDXL‐002 for the complete list of combustion sources that exist or are authorized as of permit issuance.

All combustion sources at the Facility, including those that are modified, reconstructed, added or replaced after permit issuance, shall meet the requirements of this section of Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.





Combined Gas Limit: The Permittee shall combust no more than 100 million cubic feet of natural gas per year based on a 12‐month rolling sum calculated by the last day of the next calendar month (as detailed later in this section) in the following units: EU 622 and EUs 625‐628.


Title I Condition: Monitoring to avoid a major modification under 40 CFR § 52.21 and Minn. R.

Daily Recordkeeping: On each day of operation, the Permittee shall record and maintain the total quantity of natural gas combusted (in million cubic feet) in EUs 622 and 625‐628 combined.


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7007.3000


Monthly Recordkeeping. By the last day of each calendar month, the Permittee shall calculate and record the following using the methods specified in ANDXL‐002:

1) The total sawdust burned at each type of unit that uses a different emissions factor, in tons, during the previous month using fuel meters.

2) The total oil burned at each type of unit that uses a different emissions factor, in gallons, during the previous month using purchase records and/or fuel meters.

3) The total natural gas burned at each type of unit that uses a different emissions factor, in million cubic feet, during the previous month using purchase records and/or fuel meters.

4) The total VOC and PM/PM10/PM2.5 emitted, in tons/month, for the previous month.

All fuel used at the Facility shall be included in this recordkeeping, including fuel burned in units described by the portion of this Attachment A entitled “Insignificant Activities 001”.

Title I Condition: 40 CFR § 52.21(aa)(7)(vi) and (12)(vii) and Minn. R. 7007.3000 (VOC); Minn. R. 7007.0800, subp. 4 and 5 (PM/PM10)

Monthly Calculations: VOC and PM/PM10/PM2.5 Emissions. The Permittee shall calculate both the VOC and PM/PM10/PM2.5 emissions from the combustion processes by multiplying the amount of fuel burned in the period by the appropriate emissions factor. The results are then summed for all fuels for each pollutant.

The Emissions Factor for each fuel and pollutant shall be the current EPA published emissions factor, the one specified in this paragraph, or an MPCA‐approved alternative factor. There is currently one MPCA‐approved PM/PM10 emissions factor for wood combustion in the boilers (in pounds of PM/PM10

per ton of wood combusted): wood/gas boilers (0.00871). There are also several MPCA‐approved PM/PM10 and VOC factors for the Eastside and Westside generators. When separate factors are available for PM, PM10, and PM2.5, the Permittee shall use the highest of the three in these calculations.

The Permittee may propose alternative emissions factors derived from MPCA‐approved performance tests or any of the other sources listed in Minn. R. 7005.0100, subp. 10a(C). If approved by MPCA, the Permittee shall use the alternative emissions factor.

VOC Calculations: If fuel usage/purchase data is not available, the Permittee shall assume the maximum potential usage of the given fuel (or worst‐case fuel if no data exists indicating which fuel was used/purchased) without considering enforceable limitations or operational restrictions for the period of time when data was not available.

Title I Condition: Recordkeeping for limit to avoid a major modification under 40 CFR § 52.21 and Minn. R. 7007.3000

Monthly Calculations: Combined Natural Gas. By the last day of the calendar month, the Permittee shall calculate and record the following for EUs 622 and 625‐628 combined:

1) total quantity of natural gas combusted in the previous calendar month, by


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summing the daily records; and

2) the 12‐month rolling total of natural gas combusted, for the previous 12 months by summing the total monthly fuel numbers for the previous 12 months.


Recordkeeping of Equipment Changes: The Permittee shall keep records of any combustion sources that are modified, reconstructed, added or replaced. The record shall include the date the unit was modified, reconstructed, added or replaced, a description of the change, and the manufacturer and model number (if applicable).

A. Indirect Heating Equipment (Not Subject to NSPS)

The section is removed because it applied to Boilers 1‐6 which are removed from the facility. B. Boilers subject to 40 CFR pt. 60, subp. Dc, Natural Gas only During drafting of ANDXL‐002, the Facility has two natural gas boilers subject to 40 CFR pt. 60, subp. Dc that are used to supply steam for process or heating use (Boilers 9 and 10; EUs 008 and 009, respectively). The total capacity is 19.2 MMBtu/hr. The emission and operational limits apply upon issuance of ANDXL‐002.

Process Equipment 005(B)



Minn. R. 7005.0100, subp. 35a The boilers are limited, by equipment design, to burning only natural gas.

40 CFR § 69.48c(g) By the last day of each calendar month, the Permittee shall record the amount of natural gas combusted in the boilers during the previous calendar month. These records shall consist of purchase records, receipts, or fuel meter readings.

C. Boilers subject to 40 CFR pt. 60, subp. Dc, Distillate Fuel Oil/Natural Gas During drafting of ANDXL‐002, the Facility has one boiler (EU 622) meeting the description of this portion of Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.

Process Equipment 005(C)




The boiler (EU 622) shall meet the following criteria:

1) it shall combust only distillate fuel oil and natural gas;

2) the natural gas burner shall be a low NOx burner;

3) the boiler shall have flue gas recirculation (FGR);

4) the quantity of fuel combusted shall be limited as required in this


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portion of this Attachment A entitled “Process 005” (see combined gas limit); and

5) have a maximum capacity of 50 MMBtu/hr.


The Permittee shall combust no more than 250,000 gallons per year of distillate oil in EU 622, based on a 12‐month rolling sum calculated by the last day of the next calendar month as detailed later in this section.


Fuel Sulfur Content: The Permittee shall only combust distillate oil that has a sulfur content of less than or equal to 0.15% by weight.


Nitrogen Oxides (NOx): The Permittee shall not cause to be discharged into the atmosphere from EU 622 NOx in an amount greater than 0.04 lb/million Btu heat input. This applies to the unit when combusting natural gas.


Carbon Monoxide (CO): The Permittee shall not cause to be discharged into the atmosphere from EU 622 CO in an amount greater than 200 parts per million on a dry basis corrected to 3 percent oxygen. This applies to the unit when combusting either fuel.


Title I Condition: Monitoring to avoid a major modification under 40 CFR § 52.21 and Minn. R. 7007.3000

Daily Recordkeeping: On each day of operation, the Permittee shall record and maintain the total quantity of distillate fuel oil combusted in EU 622, in gallons.


Monthly Calculations: Distillate Fuel Oil. By the last day of the calendar month, the Permittee shall calculate and record the following for EU 622:

1) total quantity of distillate fuel oil combusted in the previous calendar month, in gallons, by summing the daily records; and

2) the 12‐month rolling total of distillate fuel oil combusted, in gallons, for the previous 12 months by summing the total monthly fuel numbers for the previous 12 months.


Distillate Fuel Oil Sulfur Content: For each delivery of distillate fuel oil, the Permittee shall either

1) obtain and maintain a certification from the fuel oil supplier certifying that the sulfur content does not exceed 0.15% by weight; OR

2) sample the contents to determine the distillate fuel oil sulfur content. Sampling shall be conducted using appropriate ASTM methods.

Title I Condition: Monitoring to avoid a major modification under 40 CFR § 52.21 and Minn. R. 7007.3000; Minn. R. 7017.2020, subp. 1

Performance Test: The Permittee shall conduct a performance test before the end of each 60 months starting April 18, 2007 on EU 622 to measure CO emissions while combusting natural gas.

Title I Condition: Monitoring to avoid a major modification

Performance Test: The Permittee shall conduct a performance test before the end of each 36 months starting April 18, 2007 on EU 622 to measure


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under 40 CFR § 52.21 and Minn. R. 7007.3000; Minn. R. 7017.2020, subp. 1

NOx emissions while combusting natural gas.

NSPS Requirements, 40 CFR pt. 60, subp. Dc

NSPS EMISSION AND OPERATIONAL LIMITS

40 CFR § 60.42c(d); Minn. R. 7011.0570

Sulfur Dioxide (SO2): When combusting oil, the Permittee shall not cause to be discharged into the atmosphere from EU 622 SO2 in an amount greater than 0.5 lbs/million Btu heat input OR

The Permittee shall only combust distillate oil that has a sulfur content of less than or equal to 0.5% by weight.

This standard applies on and after the date of the initial performance test is completed or required to be completed under 40 CFR § 60.8, whichever date is first, including periods of startup, shutdown, and malfunction.

40 CFR § 60.43c(e)(1) and 60.43c(e)(4); Minn. R. 7011.0570

Particulate Matter: The Permittee shall not cause to be discharged into the atmosphere from EU 622 particulate matter in an amount greater than 0.030 lbs/million Btu heat input.

The permittee shall only combust distillate oil that has a sulfur content of less than or equal to 0.5% by weight.

This standard applies on and after the date of the initial performance test is completed or required to be completed under 40 CFR § 60.8, except during periods of startup, shutdown, and malfunction.

40 CFR § 60.43c(c); Minn. R. 7011.0570

Opacity: When combusting oil, the Permittee shall not cause to be discharged into the atmosphere from EU 622 gases which exhibit greater than 20 percent opacity (6‐minute average), except for one six‐minute period per hour of not more than 27 percent opacity.


NSPS MONITORING AND RECORDKEEPING

40 CFR §§ 60.44c(h), 60.45c(c), 60.47c(c), and 60.48c(f); Minn. R. 7011.0570

Distillate Fuel Oil Supplier Certification: The Permittee shall obtain a certification from the fuel oil supplier for each fuel oil delivery. The certification shall include the supplier’s name, a statement from the supplier that the oil complies with the specification under the definition of distillate oil in 40 CFR § 60.41c, and the sulfur content or maximum sulfur content of the oil. This certification is considered to be the performance test referenced in the emissions limits above.

40 CFR §§ 60.45c(c), 60.47c(c), and 60.48c(g); Minn. R. 7011.0570

Gaseous Fuel Supplier Certification: The Permittee shall maintain fuel supplier certifications of the sulfur content of the fuels burned in EU 622 to show the potential sulfur dioxide emission rate is less than or equal to 0.32 lb/MMBtu heat input. This certification is considered to be the performance test referenced in the emissions limits above.

40 CFR § 60.48c(g); Minn. R. 7011.0570

Fuel Usage Recordkeeping: The Permittee shall record and maintain records of the amounts of each fuel combusted during each calendar month.

40 CFR § 60.11(d); Minn. R. 7011.0570

At all times, including startup, shutdown, and malfunction, the Permittee shall, to the extent practicable, maintain and operate the boiler in a manner


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consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the MPCA which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the Facility.

Performance Testing

40 CFR § 60.45c(a) and § 60.47c(a); Minn. R. 7011.0570

The Permittee shall conduct a performance test as required under 40 CFR § 60.8, and shall conduct subsequent performance tests as requested by the Administrator, to determine compliance with the standards using Method 9 of USEPA 40 CFR Part 60, Appendix A–4 to determine the opacity of stack emissions. If during the initial 60 minutes of observation all 6‐minute averages are less than 10 percent and all individual 15‐second observations are less than or equal to 20 percent, the observation period may be reduced from 3 hours to 60 minutes.

40 CFR § 60.47c(a)(1)(i) through (iv); Minn. R. 7011.0570

Initial Performance Test: The Permittee shall conduct an initial performance test to measure opacity within one year of ANDXL‐002 issuance.

40 CFR § 60.47c(a)(1)(i) through (iv); Minn. R. 7011.0570

Performance Tests: The Permittee shall conduct performance tests to measure opacity on a frequency based on previous test results according to 40 CFR § 60.47c(a)(1)(i) through (iv).

40 CFR § 60.47c(c); Minn. R. 7011.0570

Owners and operators of an affected facilities that burn only distillate oil that contains no more than 0.5 weight percent sulfur and/or liquid or gaseous fuels with potential sulfur dioxide emission rates of 26 ng/J (0.060 lb/MMBtu) heat input or less and that do not use a post‐combustion technology to reduce SO2 or PM emissions and that are subject to an opacity standard in §60.43c(c) are not required to operate a COMS if they follow the applicable procedures in §60.48c(f).

NSPS SUBMITTALS

40 CFR § 60.48c(d), (e), (f), and (j); Minn. R. 7011.0570

Reporting: The Permittee shall submit a report within 30 days after the end of each six month period starting March 22, 2007. The report shall include:

1) calendar dates in the reporting period;

2) the name of the oil supplier

3) statements from the oil suppliers that the oil complies with the specifications under the definition of distillate oil in §60.41c

4) the sulfur content or maximum sulfur content of the oil

5) a certified statement signed by the Permittee that the certifications represent all fuel oil combusted during the reporting period.

D. Boilers subject to 40 CFR pt. 60, subp. Dc, Wood/Natural Gas During drafting of ANDXL‐002, the Facility has two industrial boilers (EU 620 and 621) meeting the description of this portion of Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.


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Process Equipment 005(D)




The boilers (EU 620 and 621) shall meet the following criteria:

1) the boilers shall combust only unadulterated wood and natural gas;

2) the boilers shall have flue gas recirculation (FGR);

3) the quantity of fuel combusted shall be limited as required in this portion of this Attachment A;

4) emissions from the boilers shall be vented to an electrostatic precipitator (ESP) meeting the requirements set forth in the portions of this Attachment A entitled “Control Equipment 009” whenever the boilers are operated using any amount of unadulterated wood; and

5) have a combined maximum capacity of 104 MMBtu/hr.


The Permittee shall combust no more than 521,050 million Btu heat input from wood and natural gas per 12 months in EU620 and EU621 combined based on a 12‐month rolling sum calculated by the last day of the next calendar month as detailed later in this section.


Steam Output: EU620 and EU621 may be operated at maximum design capacity, operating independently or simultaneously.


Nitrogen Oxides (NOx): The Permittee shall not cause to be discharged into the atmosphere, from either EU 620 or 621, NOx in an amount greater than 0.24 lb/million Btu heat input. This applies to each unit when combusting either fuel.

Title I Condition: to avoid a major modification under 40 CFR § 52.21 and Minn. R. 7007.3000;

Particulate Matter (PM): The Permittee shall not cause to be discharged into the atmosphere from each boiler and both boilers combined PM in an amount greater than 0.025 lbs/million Btu heat input. This limit applies at all times. Any emissions above this limit shall be considered a violation of the limit for each of the two boilers unless available information/documentation indicates only one of the boilers was operating at the time the emissions limit was exceeded.


Particulate Matter less than 10 microns (PM10): The Permittee shall not cause to be discharged into the atmosphere, from either EU 620 or 621, PM10 in an amount greater than 0.050 lb/million Btu heat input. This applies to each unit when combusting wood.


Particulate Matter less than 2.5 microns (PM2.5): The Permittee shall not cause to be discharged into the atmosphere, from either EU 620 or 621, PM2.5 in an amount greater than 0.050 lb/million Btu heat input. This applies to each unit when combusting wood.


Carbon Monoxide (CO): The Permittee shall not cause to be discharged into the atmosphere, from either EU 620 or 621, CO in an amount greater than 350.0 parts per million on a dry basis corrected to 7 percent oxygen. This applies to the each unit when combusting either fuel.

Minn. R. 7007.0800, subp. 2 Mercury: The Permittee shall not cause to be discharged into the atmosphere from each boiler mercury in an amount greater than 0.0000030 lbs/million Btu heat input. This limit applies at all times except during periods of startup, shutdown, and malfunction.


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Minn. R. 7007.0800, subp. 2 Hydrogen Chloride (HCl): The Permittee shall not cause to be discharged into the atmosphere from each boiler HCl in an amount greater than 0.020 lbs/million Btu heat input. This limit applies at all times except during periods of startup, shutdown, and malfunction.

Minn. R. 7007.0800, subp. 2 Mercury Operating Limit for the fuel analysis compliance option: The Permittee shall maintain the fuel type or fuel mixture such that the mercury emission rate calculated according to the equation below is less than the emission limit for mercury.

Where:

Mercury = Mercury emission rate from the boiler or process heater in units of pounds per million Btu.

HGi90= 90th percentile confidence level concentration of mercury in fuel, i, in units of pounds per million Btu as calculated according to Equation 8 of this section.

Qi= Fraction of total heat input from fuel type, i, based on the fuel mixture that has the highest mercury content. If you do not burn multiple fuel types, it is not necessary to determine the value of this term. Insert a value of “1” for Qi.

n = Number of different fuel types burned in your boiler or process heater for the mixture that has the highest mercury content.

Minn. R. 7007.0800, subp. 2 HCl Operating Limit for the fuel analysis compliance option: The Permittee shall maintain the fuel type or fuel mixture such that the HCl emission rate calculated according to the equation below is less than the emission limit for HCl.

Where:

HCl = HCl emission rate from the boiler or process heater in units of pounds per million Btu.

Ci90= 90th percentile confidence level concentration of chlorine in fuel type, i, in units of pounds per million Btu as calculated according to Equation 8 of this section.

Qi= Fraction of total heat input from fuel type, i, based on the fuel mixture that has the highest content of chlorine. If you do not burn multiple fuel types, it is not necessary to determine the value of this term. Insert a value of “1” for Qi.

n = Number of different fuel types burned in your boiler or process heater for the mixture that has the highest content of chlorine.

1.028 = Molecular weight ratio of HCl to chlorine.


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Minn. R. 7017.1006 Emissions Monitoring: The owner or operator shall use a COMS to measure opacity emissions from boilers 11 and 12 (EU 620 and EU 621).


Hourly Recordkeeping: For each hour of operation, the Permittee shall record the total pounds per hour of steam output (EU 620 and EU 621 operating independently or simultaneously) during an eight hour block average. Calculate the eight hour block average by calculating the total steam output from the eight hour period and divide by the total operating time during the eight hour period. Down time of 15 or more minutes shall not be included as operating time.


Daily Recordkeeping: On each day of operation, the Permittee shall record and maintain the total quantity of wood combusted (in tons) and the total quantity of natural gas combusted (in million cubic feet) in EUs 620 and 621.


Monthly Calculations: Wood and Natural Gas. By the last day of the calendar month, the Permittee shall calculate and record the following for EU 620 and 621 combined:

1) total quantity of heat input from wood and natural gas combusted in the previous calendar month, by summing the daily records and converting them to million Btu; and

2) the 12‐month rolling total of heat input (in million Btu) from wood and natural gas combusted, for the previous 12 months by summing the total monthly heat input for the previous 12 months.

Minn. R. 7007.0800, subp. 5(A) Fuel Records: The Permittee must keep records of the type and amount of all fuels burned in each boiler or process heater during the reporting period to demonstrate that all fuel types and mixtures of fuels burned would result in lower emissions of HCl and mercury than the emission limit for each pollutant (if you demonstrate compliance through fuel analysis), or result in lower fuel input of chlorine and mercury than the maximum values calculated during the last performance tests (if you demonstrate compliance through performance testing).

Minn. R. 7007.0800, subp. 2 If the Permittee plans to burn a new type of fuel, the Permittee must submit an application for a permit amendment to authorize any new fuel type not authorized by this permit and obtain any permit the MPCA determines is applicable prior to commencing combustion of this fuel.

Minn. R. 7007.0800, subp. 5(A) The Permittee must also keep the following records for each boiler:

‐ Monthly fuel use by each boiler, including the type(s) of fuel and amount(s) used;

‐ For the fuel analysis compliance option, a copy of all calculations and supporting documentation of HCl emission rates, using the HCl equation under EMISSION AND OPERATIONAL LIMITS of this table that were done to demonstrate compliance with the HCl emission limit. Supporting documentation should include results of any fuel analyses and basis for the estimates of maximum chlorine fuel input or HCl emission rates. The Permittee can use the results from one fuel analysis for multiple boilers


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provided they are all burning the same fuel type. However, the Permittee must calculate chlorine fuel input, or HCl emission rate, for each boiler.

‐ For the fuel analysis compliance option, a copy of all calculations and supporting documentation of mercury emission rates, using the mercury equation under EMISSION AND OPERATIONAL LIMITS of this table that were done to demonstrate compliance with the mercury emission limit. Supporting documentation should include results of any fuel analyses and basis for the estimates of maximum mercury fuel input or mercury emission rates. The Permittee can use the results from one fuel analysis for multiple boilers provided they are all burning the same fuel type. However, the Permittee must calculate mercury fuel input, or mercury emission rates, for each boiler.

PERFORMANCE TESTING AND FUEL ANALYSIS

Minn. R. 7007.0800, subp. 2 Compliance Demonstration for HCl and Hg: The Permittee may demonstrate compliance with the emission limits for HCl and/or for mercury through fuel analysis. Otherwise, the Permittee must demonstrate compliance using Performance Testing for HCl and/or mercury.


Annual Performance Tests (CO). The Permittee shall conduct annual performance tests for each EU620 and EU621 (test each unit separately) to measure CO emissions. Each annual performance test must be conducted between 10 and 12 months after the previous performance test.


Performance Test (NOx). The Permittee shall conduct a performance test every 36 months for each EU620 and EU621 (test each unit separately) to measure NOx emissions starting June 16, 2007.


Performance Test (PM10). The Permittee shall conduct a performance test every 60 months for each EU620 and EU621 (test each unit separately) to measure PM10 emissions starting of June 16, 2007.


Initial Performance Test (PM2.5). The Permittee shall conduct an initial performance test within 365 days after permit issuance for each EU620 and EU621 (test each unit separately) to measure PM2.5 emissions.


Performance Test (PM2.5). The Permittee shall conduct a performance test every 60 months for each EU620 and EU621 (test each unit separately) to measure PM2.5 emissions starting after initial performance test for PM2.5.

Title I Condition: Monitoring to avoid a major modification under 40 CFR § 52.21 and Minn. R. 7007.3000 (PM); Minn. R. 7017.2020, subp. 1;

Annual Performance Tests (PM and Opacity). The Permittee shall conduct annual performance tests for each EU620 and EU621 to concurrently measure PM emissions and opacity. Each annual performance test must be conducted between 10 and 12 months after the previous performance test.


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Alternative Monitoring Procedure approved under 40 CFR § 63.8(f)(1)

The Permittee can conduct performance tests less often for a given pollutant if performance tests for the pollutant (particulate matter or TSM) for at least 3 consecutive years show compliance with the emission limit. In this case, the Permittee does not have to conduct a performance test for that pollutant for the next 2 years. The Permittee must conduct a performance test during the third year and no more than 36 months after the previous performance test.

If the boiler continues to meet the emission limit for particulate matter or TSM, the Permittee may choose to conduct performance tests for these pollutants every third year, but each such performance test must be conducted no more than 36 months after the previous performance test.

If a performance test shows noncompliance with an emission limit for particulate matter or TSM, the Permittee must conduct annual performance tests for that pollutant until all performance tests over a consecutive 3‐year period show compliance.

All PM and opacity performance tests shall be conducted under two operating scenarios per the EPA‐approved Alternative Monitoring Procedure:

‐ Testing shall be done on each boiler individually while operating at worst case conditions; and

‐ Testing shall be done on both boilers combined while each boiler is operating at worst case conditions.

Minn. R. 7017.2030 and 7017.2035; Minn. R. 7007.0800, subp. 4(B) and 5

Annual Performance Tests (HCl and/or Hg) (if the Performance Test compliance option is chosen). The Permittee shall conduct annual performance tests, beginning within 1 year of permit issuance for each EU620 and EU621 (test each unit separately) to measure HCl and/or Hg emissions. Each annual performance test must be conducted between 10 and 12 months after the previous performance test.

The Permittee can conduct performance tests less often for a given pollutant if performance tests for the pollutant (HCl or mercury) for at least 3 consecutive years show compliance with the emission limit. In this case, the Permittee does not have to conduct a performance test for that pollutant for the next 2 years. The Permittee must conduct a performance test during the third year and no more than 36 months after the previous performance test.

If the boiler continues to meet the emission limit for HCl or mercury, the Permittee may choose to conduct performance tests for these pollutants every third year, but each such performance test must be conducted no more than 36 months after the previous performance test.

If a performance test shows noncompliance with an emission limit for HCl or mercury, the Permittee must conduct annual performance tests for that pollutant until all performance tests over a consecutive 3‐year period show compliance.


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Minn. R. 7017.2030 and 7017.2035; Minn. R. 7007.0800, subp. 4(B) and 5

Fuel Analyses (if the fuel analysis compliance option is chosen): The Permittee shall conduct fuel analyses for mercury and HCl for each type of fuel burned in each boiler within 5 years of June 27,2007. The Permittee shall conduct all fuel analyses according to Minn. R. 7017.2030 and 7017.2035 and establish maximum fuel pollutant input levels according to the equation below.

Where:

Clinput= Maximum amount of chlorine entering the boiler or process heater through fuels burned in units of pounds per million Btu.

Ci= Arithmetic average concentration of chlorine in fuel type, i, analyzed according to 40 CFR §63.7521, in units of pounds per million Btu.

Qi= Fraction of total heat input from fuel type, i, based on the fuel mixture that has the highest content of chlorine. If you do not burn multiple fuel types during the performance testing, it is not necessary to determine the value of this term. Insert a value of “1” for Qi.

n = Number of different fuel types burned in your boiler or process heater for the mixture that has the highest content of chlorine.

The Permittee must conduct fuel analyses according to 40 CFR § 63.7521 for each type of fuel burned no later than 5 years after the previous fuel analysis for each fuel type. If the Permittee burns a new type of fuel, the Permittee must conduct a fuel analysis before burning the new type of fuel in either boiler and obtain the appropriate permit amendment if the fuel type is not authorized by this permit. The Permittee must still meet all applicable continuous compliance requirements in Minn. R. 7007.0800, subp. 5.

NSPS Requirements, 40 CFR pt. 60, subp. Dc; all requirements apply separately to each boiler

NSPS EMISSION AND OPERATIONAL LIMITS

40 CFR § 60.43c(c); Minn. R. 7011.0570

Opacity: When combusting wood, the Permittee shall not cause to be discharged into the atmosphere from each boiler gases which exhibit greater than 20 percent opacity except for one six‐minute period per hour of not more than 27 percent opacity.


NSPS MONITORING AND RECORDKEEPING

40 CFR § 60.48c(g); Minn. R. 7011.0570

Fuel Usage Recordkeeping: The Permittee shall record and maintain records of the amounts of each fuel combusted during each day, in each boiler.

40 CFR § 60.11(d); Minn. R. 7011.0570

At all times, including startup, shutdown, and malfunction, the Permittee shall, to the extent practicable, maintain and operate the boilers and their pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether


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acceptable operating and maintenance procedures are being used will be based on information available to the MPCA which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the Facility.

40 CFR § 60.13(b); Minn. R. 7011.0570

All continuous monitoring systems and monitoring devices shall be installed and operational prior to conducting performance tests under 40 CFR § 60.8. Verification of operational status shall, as a minimum, include completion of the manufacturer’s written requirements or recommendations for installation, operation, and calibration of the device.

NSPS COMS REQUIREMENTS

40 CFR § 60.47c(a); Minn. R. 7011.0570

Continuous Opacity Monitor System (COMS): The Permittee shall install, calibrate, certify, maintain, and operate a Continuous Opacity Monitoring System (COMS) by January 31, 2007.

40 CFR § 60.47c(b); Minn. R. 7011.0570

All COMS for measuring opacity shall be operated in accordance with the applicable procedures under Performance Specification (PS) 1 (Appendix B of 40 CFR pt. 60). The span value of the COMS shall be between 60 and 80 percent.

40 CFR § 60.13(f); Minn. R. 7011.0570

All continuous monitoring systems and monitoring devices shall be installed such that representative measurements of emissions or process parameters from the boilers are obtained. Procedures for the location of continuous monitoring systems are contained in PS 1 (Appendix B of 40 CFR pt. 60).

40 CFR § 60.13(e); Minn. R. 7017.1090, subp. 1

Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start‐up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment.

Acceptable monitor downtime includes reasonable periods as listed in Items A, B, C and D of Minn. R. 7017.1090, subp. 2.

Minn. R. 7017.1210, subp. 1; Quality Assurance Plan: The Permittee shall Develop and implement a written quality assurance plan that covers each COMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by Minn. R. 7017.1210, subp. 1. The plan shall include the manufacturer’s spare parts list for each COMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list.

40 CFR § 60.13(a); Minn. R. 7017.1210

QA/QC: The Permittee is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each COMS according to the QA/QC procedures in Minn. R. 7017.1210.

40 CFR § 60.13(d)(l) and (d)(2); Minn. R. 7017.1210, subp. 2

Daily Calibration Drift: The Permittee must automatically, intrinsic to the opacity monitor, check the zero and upscale (span) calibration drifts at least once daily. The span value shall be between 60% and 80%. For COMS without automatic zero adjustments, the optical surfaces exposed to the effluent gases shall be cleaned prior to performing the zero and span drift


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adjustments. For COMS with automatic zero adjustments, the optical surfaces shall be cleaned when the cumulative automatic zero compensation exceeds 4 percent opacity.

Minimum procedures must include an automated method for producing a simulated zero opacity condition and an upscale opacity condition as specified in 40 CFR § 60.13(d)(2).

Minn. R. 7017.1180, subp. 2 Calibration Error Audit Notification: The Permittee shall submit the Calibration Error Audit Notification 30 days before the COMS Calibration Error Audit.

Minn. R. 7017.1210, subp. 3 Calibration Error Audit: The Permittee shall submit the Calibration Error Audit before the end of each calendar half‐year following Permit Issuance. Audits are to be at least three months apart but no more than eight months apart except that a calibration error audit need not be conducted during any semiannual period in which the emission unit operated less than 24 hours. The calibration error audit shall be conducted according to the procedures in 40 CFR pt. 60, Appendix B, Performance Specification No. 1.

Minn. R. 7017.1210, subp. 4 Attenuator Calibration: The Permittee shall have an independent testing company conduct calibrations of each of the neutral density filters used in the calibration error audit according to the procedure in Code of Federal Regulations, Title 40, Part 60, Appendix B, Section 7.1.3.1 within the time frame of opacity stability guaranteed by the attenuator manufacturer. The manufacturer's guarantee of stability shall be on site available for inspection.

Minn. R. 7017.1130 Recordkeeping: The Permittee must retain records of all COMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the Facility.

40 CFR § 60.13(h) Reduction of Monitoring Data: The Permittee must reduce the monitoring data from the CMS as specified in 40 CFR § 60.13(h).

Minn. R. 7017.1220 Calibration Error Audit Results Summary: The Permittee shall submit the Calibration Error Audit Results Summary 30 days after the end of each calendar quarter in which the COMS calibration error audit was completed.

40 CFR §§ 60.7(c) and 60.48c(c) and (j); Minn. R. 7011.0570; Minn. R. 7017.1110, subp. 1 and 7019.0100, subp. 1

Excess Emissions/Downtime Reports (EERs): The Permittee shall submit excess emission reports for any excess emissions from the boilers which occurred during the reporting period within 30 days after the end of each calendar quarter starting January 22, 2007. The report shall include all information required by 40 CFR § 60.7(c) or (d), as applicable, as well as Minn. R. 7017.1110, subp. 2 and shall be submitted even if there were no excess emissions, monitor downtime, or monitor bypasses during the quarter.


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NESHAP Requirements, 40 CFR pt. 63, subp. DDDDD (referred to as “subpart DDDDD” in this portion of Attachment A)

40 CFR Part 63, Subpart DDDDD

Comply with 40 CFR Part 63, Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters, as applicable for existing boilers as specified under 40 CFR Section 63.7490, by the appropriate deadlines as specified under 40 CFR Section 63.7495.

Note that During drafting of ANDXL‐002, the effective date of this standard has been delayed until such time as judicial review is no longer pending or until the EPA completes its reconsideration of the rules, whichever is earlier (Federal Register / Vol. 76, No. 96 / May 18, 2011).

E. Stationary Internal Combustion Engines During drafting of ANDXL‐002, the Facility has the following internal combustion engines used primarily for backup power generation during an emergency: three diesel‐fired generators, two natural gas‐fired generators, and one diesel fuel‐fired fire pump. The emission and operational limits apply upon issuance of ANDXL‐002.

Process Equipment 005(E)



Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: The Permittee shall not cause to be discharged into the atmosphere from any stationary internal combustion engine any gases which contain sulfur dioxide in excess of 0.5 lbs/million Btu actual heat input. This limit applies individually to each stationary internal combustion engine. The potential to emit based on allowable fuels and equipment design is 0.29 lbs/million Btu heat input for diesel and less than 0.001 lb/million Btu heat input for natural gas.

Minn. R. 7011.2300, subp. 1 Opacity: The Permittee shall not cause or permit the emission of visible air contaminants from any stationary internal combustion engine in excess of 20% opacity once operating temperatures have been attained. This limit applies individually to each stationary internal combustion engine.

Minn. R. 7007.0800, subp. 4 & 5

Hours of Operation: The Permittee shall maintain documentation on site that the emergency equipment listed under this portion of Attachment A qualifies by design under the U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) for Emergency Generators" dated September 6, 1995, limiting operation to 500 hours per year per unit.

Minn. R. 7007.0800, subp. 4 & 5

Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel supplier certification for each shipment of diesel fuel, certifying that the sulfur content does not exceed 0.5% by weight.

Minn. R. 7005.0100, subp. 35a

The stationary internal combustion engines are limited, by equipment design, to the following fuel types:

‐ Eastside, Westside, and Building 45 Emergency Generators and Emergency Fire Pump (EUs 001, 002, 015, and 006): Diesel Fuel.

‐ Building 14S and Building 46 Emergency Generators (EU 010 and 016): Natural Gas.


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Process Equipment 005(E)



Operation of the Eastside and Westside Generators (EUs 001 and 002): The Permittee shall operate each of these emergency generators no more than 12 hours in any 24 hour period.

Minn. R. 7007.0800, subp. 2 Weekly and Annual Testing of the Eastside and Westside Generators (EUs 001 and 002):

Testing of each of these units shall occur independently of other generator testing (i.e., only one at a time).

Testing of the Westside Generator (EU 002) shall occur only between the hours of noon and 5 PM.

Weekly tests shall last for no more than 1 hour for each generator.

Minn. R. 7007.0800, subp. 4 and 5

Testing Records: The Permittee shall maintain written documentation for each generator test stating which unit was tested, on what date, when it was turned on, and when it was turned off.

Title I Condition: Recordkeeping for limit under 40 CFR § 52.21(k) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 and 5

Operating Records for Eastside and Westside Generators (EUs 001 and 002): The Permittee shall maintain written documentation of hours of operation for each generator stating the date of operation, the time it was turned on, the time it was turned off, and the calculated total hours of operation for each 24‐hour period.

F. Direct Heating Equipment During drafting of ANDXL‐002, the Facility has a regenerative thermal oxidizer with a total natural gas burner capacity of 9.0 MMBtu/hr (EU 612). This oxidizer is an emissions control device and is considered direct heating equipment due to its natural gas burners. The Facililty also has four (4) direct heating units that are used for backup space heating (EUs 625, 626, 627, and 628). The total authorized capacity is 40 MMBtu/hr. The emission and operational limits apply upon issuance of ANDXL‐002.

Process Equipment 005(F)




The four direct heating units (EUs 625‐628) shall meet the following criteria: 1) they shall combust only natural gas;

2) they shall have low NOx burners;

3) the quantity of fuel combusted shall be limited as required elsewhere in ANDXL‐002; and

4) they shall have a combined maximum capacity of 40 MMBtu/hr.


Nitrogen Oxides (NOx): The Permittee shall not cause to be discharged into the atmosphere, from EUs 625, 626, 627 or 628, NOx in an amount greater than 0.04 lb/million Btu heat input. This applies separately to each unit.

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

Total Particulate Matter: The Permittee shall not cause to be discharged into the atmosphere from direct heating equipment gases which in any one hour


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Process Equipment 005(F)


contain particulate matter in excess of the amount permitted in Minn. R. 7011.0730 for the allocated process weight; provided that the Permittee shall not be required to reduce the particulate matter emissions below the concentrations permitted by Minn. R. 7011.0735 for the appropriate source gas volume; further provided that regardless of the mass emissions permitted by Minn. R. 7011.0735, the Permittee shall not emit particulate matter in a concentration in excess of 0.30 grains per dry standard cubic foot of exhaust gas. This limit applies individually to each direct heating unit.

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

Opacity: The Permittee shall not cause to be discharged into the atmosphere from direct heating equipment gases which exhibit greater than 20 percent opacity except for one six‐minute period per hour of not more than 60 percent opacity. This limit applies individually to each direct heating unit.

Minn. R. 7005.0100, subp. 35a The direct heating equipment is limited, by equipment design, to natural gas only.



Performance Test Data for Nitrogen Oxides: For EUs 625, 626, 627, and 628, the Permittee shall obtain and maintain certified test data from the manufacturer of each unit demonstrating that each unit will emit less than the NOx limit in ANDXL‐002. This data shall be at the Facility prior to startup of any of the units.


Annual Burner Maintenance: The Permittee shall ensure that the burners on EUs 625, 626, 627, and 628 are properly maintained and shall have them tuned for maximum combustion efficiency at least annually by the burner manufacturer or its representative. The Permittee shall keep a written record of all maintenance/tuning including the date it is performed.

Process: 006 Miscellaneous VOC Sources The sources included in this Process are those where the material use does not fall into any other Process and does not result in emissions other than VOCs (and specific compounds that make up those VOCs). During drafting of ANDXL‐002, this Process consists of several adhesive application operations, silicone application, multiple cleaners, non‐bulk solvent use that is not related to other processes, and a laboratory. These operations typically use many different materials in small containers throughout the Facility. They are purchased in various container sizes, ranging from 4 oz. tubes to 350 gallon totes. See Attachment D of ANDXL‐002 for the complete list of Miscellaneous VOC Sources. Materials in the Miscellaneous VOC Sources are divided into three categories: Tracked Materials: These materials are tracked as delivered and VOC emissions are calculated each calendar month. During drafting of ANDXL‐002, these include cleaner and adhesive application operations, silicone application, and non‐bulk solvent use; Annual Materials: These materials are not tracked as delivered and VOC emissions are calculated annually. During drafting of ANDXL‐002, no materials are tracked under this category; and Insignificant Materials: These materials are not tracked as delivered or annually. A set number is added to account for them in the monthly calculations (the VOC “add‐on”). These include the Model Shop, Printing Press, and laboratory. These processes would otherwise qualify as insignificant under Minn. R. 7007.1300, subp. 3(G), and subp. 4(B) and (C).


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All Miscellaneous VOC sources at the Facility, including those that are modified, reconstructed, added or replaced after permit issuance, shall meet the requirements of this section of Attachment A.





Daily Recordkeeping: On each day of operation, the Permittee shall separately record and maintain the total quantity of all Tracked Materials delivered for use to the Facility, based on purchasing records. The units of each delivery will vary (e.g., ounces, gallons, pounds, etc.).


Monthly Recordkeeping: By the last day of each calendar month the Permittee shall calculate and record the total VOC emissions, in tons/month, from the Miscellaneous VOC Sources for the previous calendar month. Monthly VOC emissions are equal to item 3 from the monthly calculation for the Tracked Materials plus item 4 from the most recent annual calculation for the Annual Materials (both on the following page of this Attachment A) plus 0.142 tons/month for the Insignificant Materials (the VOC “add‐on”).

This number shall be used in the monthly calculations set forth in the portion of this Attachment A entitled “Total Facility Requirements”.


Annual Recordkeeping: By January 30th of each calendar year, the Permittee shall calculate and record actual VOC emissions, in tons, from Annual Materials for the previous year, using the methods specified in ANDXL‐002. This value will be used in the VOC calculations included in the XL Annual Report, Emissions Inventory, the January 30th PAL Semi‐Annual Report, and the February 15th Semi‐Annual Report for the subject year.

If the total VOC emissions from the Annual Materials are determined to be greater than 50 tons, the Permittee shall reclassify items in the Annual Materials as Tracked Materials such that the actual emissions of the remaining Annual Materials are less than 50 tons. These reclassified lists of Annual and Tracked Materials shall be used for tracking for the next calendar year.


Monthly Calculation: VOC Emissions from Tracked Materials. The Permittee shall make the following calculation for Tracked Materials delivered to the Facility.

1) The Permittee shall calculate the total VOC delivered for each calendar month using total quantity delivered and VOC content determined as required by ANDXL‐002. This may be done by multiplying each delivery amount by its VOC content and summing the results or by summing deliveries of a particular material for the month and multiplying the sum by the applicable VOC content. VOCs from all materials are then summed.

2) The Permittee may elect to calculate the amount of VOC shipped off‐site for Miscellaneous VOC Sources. If elected, this shall be done by using the material content for shipped wastes determined as set forth in the portion of this Attachment A entitled “Total Facility Requirements”, multiplied by the amount shipped. VOCs from all shipments are then summed.


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3) The Permittee shall calculate the VOC emissions for the month by subtracting item 2) from item 1). Item 2) may be zero.


Title I Condition: 40 CFR § 52.21(aa)(7)(vi) and Minn. R. 7007.3000

Annual Calculation: VOC Emissions from Annual Materials. The Permittee shall make the following calculation for Annual Materials delivered to the Facility.

1) The Permittee shall calculate the total VOC delivered for the annual period using total quantity delivered and VOC content determined as required by ANDXL‐002. This may be done by multiplying each delivery amount by its VOC content and summing the results or by summing deliveries of a particular material for the period and multiplying the sum by the applicable VOC content. VOCs from all materials are then summed.

2) The Permittee may calculate the amount of VOC shipped off‐site for the Annual Material sources. If elected, this shall be done by using the material content for shipped wastes determined as set forth in the portion of this Attachment A entitled “Total Facility Requirements”, multiplied by the amount shipped. VOCs from all shipments are then summed.

3) The Permittee shall calculate the VOC emissions for the year by subtracting item 2) from item 1). Item 2) may be zero.

4) The Permittee shall determine the annual average monthly emissions, in tons/month, by dividing item 3) by 12.


Recordkeeping of Equipment Changes: The Permittee shall keep records of any Miscellaneous VOC Sources that are modified, reconstructed, added or replaced. The record shall include the date the process was modified, reconstructed, added or replaced, a description of the change, and the manufacturer and model number (if applicable).

Process: 007 Other Miscellaneous Sources Due to the nature of ANDXL‐002, units that would otherwise qualify as insignificant under Minn. R. 7007.1300, subpart 3(I) must be included in the various calculations and are therefore no longer considered insignificant under Minnesota rules. During drafting of ANDXL‐002, no units at the Facility would be tracked under this process group, but the Permittee may add them in the future. All other miscellaneous sources at the Facility, including those that are modified, reconstructed, added or replaced after permit issuance, shall meet the requirements of this section of Attachment A.


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Minn. R. 7007.0800, subp. 2 Each Process 007 unit shall meet both of the following criteria. 1) Have a potential to emit less than:

4,000 lbs/year of carbon monoxide; and

2,000 lbs/year each of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, particulate matter less than two and one half microns, volatile organic compounds, and ozone.

1,000 lbs/year of CO2e

2) Be subject to only one of the following applicable requirements:

Minn. R. 7011.0715 as described in the portion of this Attachment A entitled “Total Facility Requirements”;

Minn. R. 7011.0610, Minn. R. 7011.0515, or Minn. R. 7011.2300 as described in the portion of this Attachment A entitled “Process 005”; or

Minn. R. 7011.0110 (general opacity rule).



Monthly Recordkeeping: Process Parameters. 1) If the Permittee calculated VOC or PM/PM10/PM2.5 actual emissions, in

whole or in part, from VOC‐containing materials purchased, the Permittee shall record by the last day of each calendar month, the amount of each VOC‐containing material purchased, and the VOC content (determined as required by the Material Content requirement in the portion of this Attachment A entitled “Total Facility Requirements”) for the previous calendar month.

2) If the Permittee calculated VOC or PM/PM10/PM2.5 actual emissions, in whole or in part, by using fuel burned, the Permittee shall record by the last day of each calendar month the amount of each fuel purchased or used for the previous calendar month.

3) If the Permittee calculated VOC or PM/PM10/PM2.5 actual emissions, in whole or in part, by using hours of operation, the Permittee shall record by the last day of each calendar month the hours operated for each emissions unit, rounded to the nearest hour for the previous calendar month.

4) If the Permittee calculated VOC or PM/PM10/PM2.5 actual emissions, in whole or in part, by using the quantity of material handled or product produced, the Permittee shall record by the last day of each calendar month for each material handled and for each product produced, the amount of the material handled and the amount of product produced for the previous calendar month.


Monthly Recordkeeping: VOC and PM/PM10/PM2.5 Emissions. By the last day of each calendar month, the Permittee shall calculate and record the total VOC and PM/PM10/PM2.5 emitted, in tons/month, from the Process 007 units, for the previous calendar month using the methods specified below.


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Title I Condition: 40 CFR § 52.21(aa)(7)(vi) and (12)(vii) and Minn. R. 7007.3000 (VOC); Minn. R. 7007.0800, subp. 4 and 5 (PM/PM10)

Monthly Calculations: VOC and PM/PM10/PM2.5 Emissions. The Permittee shall calculate both the VOC and PM/PM10/PM2.5 actual emissions for each Process 007 emissions unit, except that similar emissions units may be aggregated for emission calculation purposes. The Permittee shall use the calculation methods described by Options 1 or 2. The results are then summed for all units for each pollutant.

Option 1: Emissions Factor and Operating Parameters. E = OP x EF, where

E = Actual Emissions in tons per month

OP = Operating Parameter as required by the Emission Factor (hours of operation or units produced)

EF = Emission Factor (pounds of pollutant per hour of operation or units produced) as defined in part 7005.0100, subpart 10a. When separate emissions factors are available for PM, PM10, and PM2.5, the Permittee shall use the higher of the three in these calculations. The Permittee shall submit any proposed emissions factors under Minn. R. 7005.0100, subp. 10a(C) to the MPCA for review and approval prior to using the factors.

Option 2: Material Balance. E = (a ‐ b ‐ c), where

E = Actual Emissions in tons per month

a = the amount of the pollutant (VOC or PM/PM10/PM2.5) entering the process.

b = the amount of the pollutant incorporated permanently into the product. This includes VOCs chemically transformed in production or the solids transferred onto a painted part from a spraying operation. It does not include latent VOC remaining in the product that will at some time be released to the atmosphere or solids overspray from a spraying operation.

c = the amount of pollutant, if any, leaving the process as waste and not emitted to the atmosphere. If elected, this shall be done by using the material content for shipped wastes determined as set forth in the portion of this Attachment A entitled “Total Facility Requirements”, multiplied by the amount shipped.

VOC Calculations: If the data required by the above formulas is not available (e.g., quantity purchased, hours of operation, etc.), the Permittee shall assume the maximum potential operating conditions (worst‐case material, maximum hours, maximum processing rate) without considering enforceable limitations or operational restrictions for the period of time when data was not available.


Recordkeeping of Equipment Changes: The Permittee shall keep records of any Process 007 units that are modified, reconstructed, added or replaced. The record shall include the date the unit was modified, reconstructed, added or replaced, a description of the change, the manufacturer and model number (if applicable), the calculated potential to emit, and the rule


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requirements that apply to the unit from the list earlier in this portion of Attachment A.

Process: 008 Wood and Ash Silos During drafting of ANDXL‐002, the Facility has one wood silo (EU 623) meeting the description of this portion of Attachment A. All Wood and Ash Silos at the Facility, including those that are modified, reconstructed, added or replaced after permit issuance, shall meet the requirements of this section of the Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.




Title I Condition: to avoid major modification under 40 CFR § 52.21 and Minn. R. 7007.3000

PM/PM10/PM2.5: The Permittee shall not cause to be discharged into the atmosphere from any wood or ash silo either PM, PM10, or PM2.5 emissions in an amount that exceeds 0.0050 gr/dscf based on a 3‐hour average.

Title I Condition: to avoid major modification under 40 CFR § 52.21 and Minn. R. 7007.3000

PM/PM10/PM2.5 Control: The Permittee must control all wood and ash silos with equipment meeting the requirements set forth in the portions of this Attachment A entitled “Control Equipment 005” whenever the process equipment is operated.


Minn. R. 7007.0800, subps. 4 and 5

Daily Recordkeeping: On each day of operation, the Permittee shall calculate and record the actual hours of operation of each wood and ash silo.

Minn. R. 7007.0800, subp. 4 and 5

Monthly Recordkeeping: PM/PM10/PM2.5 Emissions. By the last day of each calendar month, the Permittee shall calculate and record the total PM/PM10/PM2.5 emissions, in tons/month, from all wood and ash silos for the previous calendar month using the methods specified in ANDXL‐002.

Minn. R. 7007.0800, subp. 4 and 5

Monthly PM/PM10/PM2.5 Emissions Calculations. The Permittee shall calculate the PM/PM10/PM2.5 emissions from the wood and ash silos in tons/month by multiplying the actual monthly hours of operation of all wood and ash silos by the total maximum airflow, by the emissions limit, and by the appropriate conversion factors.

Minn. R. 7007.0800, subp. 4 and 5

Recordkeeping of Equipment Changes: The Permittee shall keep records of any wood or ash silos that are modified, reconstructed, added or replaced. The record shall include the date the silo was modified, reconstructed, added or replaced, a description of the change, and the manufacturer and model number (if applicable).

Control Equipment: 001 Panel Filters Panel filters are used on all paintlines, other production‐related painting processes, the maintenance spray booth and the research and development spray booth. The filters collect paint overspray from the paint application equipment. Specifically, a panel filter is present at the bottom of each of silos 1‐6 through which the


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exhaust air must pass before exiting the silo. Panel filters consisting of multi‐layer paper paint arrestors are used in the flexiframe, longlength, endspray, maintenance, and research and development booths. All panel filters at the Facility, including those that are modified, reconstructed, added or replaced after ANDXL‐002 issuance, shall meet the requirements of this section of Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.

Control Equipment 001



Title I Condition: limit under 40 CFR § 52.21(k) and Minn. R. 7007.3000

The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency, for Total Particulate Matter, greater than or equal to 74 percent.


The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency, for Particulate Matter less than 10 microns, greater than or equal to 74 percent.


The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency, for Particulate Matter less than 2.5 microns, greater than or equal to 74 percent.


The Permittee shall operate and maintain each panel filter any time the associated process equipment is in operation. The Permittee shall document periods of non‐operation of the control equipment.


Operation and Maintenance of Filters: The Permittee shall operate and maintain each filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and review by MPCA staff.


Title I Condition: Monitoring for limit under 40 CFR § 52.21(k) and Minn. R. 7007.3000

Daily Inspections: Once each operating day, the Permittee shall visually inspect the condition of each panel filter with respect to alignment, saturation, tears, holes and any other condition that may affect the filter’s performance. The Permittee shall maintain a daily written record of filter inspections.

Minn. R. 7007.0800, subp. 2, 5 and 14

Periodic Inspections: The Permittee shall inspect the control equipment components as required by the O & M Plan. The Permittee shall maintain a written record of these inspections.


Corrective Actions: If the filters or any of their components are found during the inspections to need repair, the Permittee shall follow the O & M Plan for the panel filter and take corrective action within the timing prescribed in the O & M Plan. The Permittee shall keep a record of the type and date of any corrective action taken for each filter.


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Minn. R. 7007.0800, subp. 2 and 14

Hood Design and Evaluation: On an annual basis, the Permittee shall visually inspect each fan that is part of a paint spray booth or silo system. The inspection shall include checking the fan belt for condition and tightness, and checking the motor for excessive noise and/or vibration. The Permittee shall maintain a written log of the inspection. If there is an indication of a condition needing attention or repair, the Permittee shall take immediate responsive action. The Permittee shall include the date of inspection and the dates of any follow‐up and repairs in the inspection log.

For new painting processes, the Permittee shall document that the hood design conforms to the design and operating practices recommended in "Industrial Ventilation ‐ A Manual of Recommended Practice, American Conference of Governmental Industrial Hygienists" (see Minn. R. 7011.0070, subp. 1).

Control Equipment: 002 not used in ANDXL‐002 Control Equipment: 003 Externally Vented Milling Fabric Filters During drafting of ANDXL‐002, the Permittee has 41 externally vented filter systems that control particulate emissions from milling equipment. The existing control systems were installed since 1976 and range from 1,000 to approximately 110,000 cubic feet per minute of design airflow capacity. See Attachment E of ANDXL‐002 for the complete list of the externally vented milling fabric filters. All externally vented milling fabric filters at the Facility, including those that are modified, reconstructed, added or replaced after ANDXL‐002 issuance, shall meet the requirements of this section of Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.




Title I Condition: 40 CFR § 52.21(j) (BACT Limit) and Minn. R. 7007.3000

The Permittee shall operate the externally vented fabric filters (both existing and new) so that the air flow rates are less than or equal to those listed in the portion of this Attachment A entitled “Process Equipment 003” as the authorized capacity for the milling emissions units. The Permittee shall maintain a record of each fabric filter design specification showing the calculated maximum airflow requirements.


The Permittee shall operate and maintain each fabric filter any time the associated process equipment is in operation. The Permittee shall document periods of non‐operation of the control equipment.


Operation and Maintenance of Filters: The Permittee shall operate and maintain each fabric filter in accordance with the O & M Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and review by MPCA staff.


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Title I Condition: Monitoring for BACT Limit under 40 CFR § 52.21(j) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5

Daily Inspections: Once each day of operation, the Permittee shall visually inspect each control device described by Control Equipment 003. The Permittee shall visually inspect the "clean" side for sawdust leaking and/or malfunctioning filter bags, and inspect the "dirty" side discharge (airlock, rotary valve, or discharge shoot) to ensure proper sawdust transfer. The Permittee shall also observe the external discharge of each system to verify that no visible emissions are occurring and that there is no sawdust accumulation on the roof around the stack/vent. Upon completion of the inspection, the Permittee shall complete an inspection form. If there is indication of a filter bag leak or malfunction, the Permittee shall take immediate responsive action including an initial attempt to repair the system or, if necessary, shutting the system down to address any malfunction. The Permittee shall include the time of discovery and response actions in the comment section of the inspection form.

Minn. R. 7007.0800, subp. 2, 5, and 14

Monthly Inspections: At least once per calendar month, the Permittee shall inspect each fabric filter’s components that are subject to wear or plugging, for example, bearings, belts, hoses, fans, nozzles, orifices, and ducts. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

Minn. R. 7007.0800, subp. 2, 5, and 14

Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect each fabric filter’s components that are not subject to wear including structural components, housings, ducts, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

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

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


Airflow Verification Plan: The Permittee shall retain at the Facility and shall implement and maintain the approved airflow verification plan, Attachment F, for all control equipment meeting the requirements set forth in the portion of this Attachment A entitled “Control Equipment 003”. All airflow measurements shall be maintained at the facility. The plan must be available for inspection and copying by the Administrator upon request. An amendment to the permit will be needed to revise the airflow verification plan.

Control Equipment: 004 Internally Vented Milling Fabric Filters Internally vented fabric filters that are in areas of the Facility that are ventilated by the larger externally vented filter systems are not subject to the requirements in this section. The external system is considered the BACT control device and must meet the requirements in the portion of this Attachment A entitled “Control Equipment


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003”. The requirements of this section apply to the filters that vent internally and are not served by the external filter systems. The internally vented filters are divided into two types: Category 1 and Category 2. Category 1 filters are those that:

consist of cyclone collectors followed by two or more filter bags or cartridge filters (common types include but are not limited to Torit® systems);

have rigid ductwork connected directly to the filter system; AND

are tracked with internal fixed asset or tracking numbers. During drafting of ANDXL‐002, the Permittee has nine (9) Category 1 internally vented milling fabric filters. They consist of filters for equipment as described under Process 003, including wood and Fibrex™ operations. They occur in buildings that are either remote from the majority of the milling operations at the main facility or are remote from the main facility such as building 13S. Category 2 filters are those that:

consist of single or double bag collectors and industrial vacuum cleaners (common manufacturers include but are not limited to Shop‐Vac®, Dust Kop®, Jet®, and Delta®);

do not have rigid ductwork connected to the filter housing (have flexible ducting instead); AND are not tracked with internal fixed asset or tracking numbers.

During drafting of ANDXL‐002, the Permittee has 15 Category 2 filters. These filters are located in the same five buildings as the Category 1 filters. The requirements that apply to both categories are listed at the beginning of the following table while additional requirements that apply only to Category 1 filters are listed at the end of the table (and labeled as “Additional Category 1 Requirements”). All internally vented milling fabric filters at the Facility, including those that are modified, reconstructed, added or replaced after ANDXL‐002issuance, shall meet the requirements of this section of Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.





The Permittee shall operate and maintain control equipment such that it achieves a collection efficiency, for Total Particulate Matter, greater than or equal to 99 percent.


The Permittee shall operate and maintain control equipment such that it achieves a collection efficiency, for Particulate Matter less than 10 microns, greater than or equal to 99 percent.


The Permittee shall operate and maintain control equipment such that it achieves a collection efficiency, for Particulate Matter less than 2.5 microns, greater than or equal to 99 percent.


The Permittee shall operate and maintain each fabric filter any time the associated process equipment is in operation.


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Control Equipment Department Procedure: The Permittee shall retain at the Facility and shall implement a Department Procedure (DP) for all air pollution control equipment described by the portions of this Attachment A entitled “Control Equipment 004”. At a minimum, the DP shall require the use of such controls at all times that internally vented milling equipment is in operation, shall include a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for the DP, and the records kept to demonstrate DP implementation.

Corrective actions may include the repair or replacement of the control device with a similar device.



Weekly Inspections: The Permittee shall inspect the internally vented milling equipment (EUs 603‐608) once per calendar week. The inspection shall:

verify all milling equipment that was in use was connected to control equipment meeting the requirements of “Control Equipment 004”;

verify that for milling equipment not in use during the inspection, that it was either connected to control equipment or that control equipment was available for connection; and

verify that the control equipment was operating properly by checking for visual signs of dust buildup or other indications of system performance.

The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. For the last bullet above, if corrective action is taken within 1 week, the item requiring corrective action shall not be considered a deviation.

Additional Category 1 Requirements







Equipment Labeling and Recordkeeping for Category 1 Filters: The Permittee shall affix and maintain a label on each Category 1 fabric filter showing a unique equipment identification number. If equipment is added, it shall be given a new unique number; numbers from removed or replaced equipment shall not be reused.

The Permittee shall maintain a list of Category 1 fabric filters. The list shall include the following information for each fabric filter: its identification number, date of installation, the Delta EU number served by the fabric filter (from Attachment D of ANDXL‐002), and the airflow design capacity. The Permittee shall update the list whenever a change is made.


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Monthly Inspections: The Permittee shall inspect each Category 1 filter, once per calendar month. The inspection shall consist of a visual inspection of the filter media, the fan, other mechanical components and a visual inspection of the surrounding area for dust buildup. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

Minn. R. 7007.0800, subp. 2, 5, and 14


Control Equipment: 005 Non‐milling Fabric Filters During drafting of ANDXL‐002, the Permittee operates two cartridge fabric filters that control particulate emissions from operations other than milling equipment. These are used to control the Blender described in the portion of this Attachment A entitled “Process 004, Vinyl and Other Plastic or Composite Processes”. ANDXL‐002 also authorizes the installation of new fabric filters to control equipment described in the portion of this Attachment A entitled “Process 008, Wood and Ash Silos”. All non‐milling fabric filters at the Facility, including those that are modified, reconstructed, added or replaced after ANDXL‐002 issuance, shall meet the requirements of this section of Attachment A as specified under in the portions of this Attachment A entitled “Process 004, Vinyl and Other Plastic or Composite Processes” and “Process 008, Wood and Ash Silos”. The emission and operational limits apply upon issuance of ANDXL‐002.





Existing Controls on Blender and Pulverizer. The Permittee shall operate and maintain each fabric filter any time the associated process equipment is in operation. The Permittee shall document periods of non‐operation of the control equipment.

Title I Condition: to avoid a major modification under 40 CFR § 52.21; limit under 40 CFR § 52.21(k) and Minn. R. 7007.3000

Controls on Wood and Ash Silos (Process 008): The Permittee shall operate and maintain each fabric filter any time the associated process equipment is in operation. The Permittee shall document periods of non‐operation of the control equipment.

Minn. R. 7007.0800, subp. 2 New Equipment for Process 004 Installed After ANDXL‐002 Issuance. The Permittee may take credit for the operation of the new control equipment described in this section in the emissions calculations in the portion of this Attachment A entitled “Process 004” under the following conditions:

1) The emissions from the emission unit are vented to the control equipment during the entire time period for which credit is taken; and

2) The control equipment meets the requirements of this section.

During time periods when credit is not taken, the requirements of this section do not apply.


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New Equipment for Process 004 Installed After ANDXL‐002 Issuance. The Permittee shall operate and maintain each fabric filter any time the associated process equipment is in operation and credit is taken in the emissions calculations detailed in this Attachment A.




Minn. R. 7007.0800, subp. 4 and 5

The Permittee shall maintain a record of all non‐milling fabric filters documenting which process units they control. The Permittee shall update the list whenever a change is made that affects the units that are controlled (e.g., addition of a control device on a process unit).

Minn. R. 7007.0800, subp. 4 and 5

Alternative Monitoring Scenarios: The Permittee shall monitor the existing non‐milling fabric filters under either Monitoring Scenario 1 or Monitoring Scenario 2 as described in this portion of Attachment A. The Permittee shall maintain a written log that records which filter systems are begin monitored under which monitoring scenario. All systems added or modified after ANDXL‐002issuance shall use Monitoring Scenario 2.

Monitoring Scenario 1: Pressure Drop

Minn. R. 7007.0800, subp. 4 The Permittee shall operate the control equipment monitoring equipment at all times that the control equipment is required to be operated.


Pressure Drop: The Permittee shall maintain each fabric filter such that the pressure drop ranges listed below are maintained until a new range is set pursuant to Minn. R. 7017.2025, subp. 3. If a new range is required to be set, it will be based on the values recorded during the most recent MPCA‐approved performance test where compliance was demonstrated.

Blender (CE 040): 0.25‐7.0 inches water

Pulverizer (CE 045): 0.25‐7.0 inches water


Pressure Drop Recordkeeping: The Permittee shall record the pressure drop for each fabric filter as least once every 24 hours when in operation.


Corrective Action: If the pressure drop is not in the range specified in this Attachment A for a given fabric filter, the Permittee shall take corrective action as described in the O & M Plan within the timing prescribed in the O & M Plan to return the pressure drop to within the required range. The Permittee shall keep a written record of the type and date of any corrective action taken for each fabric filter.

Minn. R. 7007.0800, subp. 2 & 14

Annual Calibration: The Permittee shall calibrate each pressure drop gauge at least annually and shall maintain a written record of the calibration and any action resulting from the calibration.


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Monitoring Scenario 2: Daily Inspections

Title I Condition: Monitoring to avoid a major modification under 40 CFR § 52.21 (Process 008 only) and for limit under 40 CFR § 52.21(k) and Minn. R. 7007.3000

Daily Inspections: Once each day of operation, the Permittee shall visually inspect each non‐milling filter system. The Permittee shall visually inspect the "clean" side for dust leaking and/or malfunctioning filter bags, and inspect the "dirty" side discharge (airlock, rotary valve, or discharge shoot) to ensure proper dust transfer. The Permittee shall also observe the external discharge of each system to verify that no visible emissions are occurring and that there is no dust accumulation on the roof around the stack/vent. Upon completion of the inspection, the Permittee shall complete an inspection form. If there is indication of a filter bag leak or malfunction, the Permittee shall take immediate responsive action including an initial attempt to repair the system or, if necessary, shutting the system down to address any malfunction. The Permittee shall include the time of discovery and response actions in the comment section of the inspection form.

All Monitoring Scenarios

Minn. R. 7007.0800, subp. 2, 5, and 14

Monthly Inspections: At least once per calendar month, the Permittee shall inspect each fabric filter’s components that are subject to wear or plugging, for example, bearings, belts, hoses, fans, nozzles, orifices, and ducts. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

Minn. R. 7007.0800, subp. 2, 5, and 14


Control Equipment: 006 Preservative Solvent Recovery Units (SRU) During drafting of ANDXL‐002, the Permittee has two solvent recovery units that control VOC emissions from certain preservative processes. These are used to control the solventborne diptanks and dryer that are described in the portion of this Attachment A entitled “Process 001, Preservative Processes”. All Preservative SRUs at the Facility, including those that are modified, reconstructed, added or replaced after permit issuance, shall meet the requirements of this section of Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.





Inlet Temperature: The Permittee shall operate the control equipment so as to maintain the process air inlet temperature less than or equal to 110 degrees Fahrenheit.


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The Permittee shall operate and maintain each SRU any time the associated process equipment is in operation. The Permittee shall document periods of non‐operation of the control equipment.


Operation and Maintenance of the Solvent Recovery Units: The Permittee shall operate and maintain each SRU in accordance with the O & M Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and review by MPCA staff.


Minn. R. 7007.0800, subp. 4 Monitoring Equipment: The Permittee shall maintain the monitoring equipment necessary for measuring the various temperatures required to be measured by ANDXL‐002. The monitoring equipment must be installed, in use, and properly maintained whenever the associated control equipment is required to be operated.

Minn. R. 7007.0800, subp. 4 and 5

The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the air inlet temperature of each SRU. The monitoring device shall have a margin of error less than the greater of +/‐ 0.75 percent of the temperature being measured or +/‐ 2.5 degrees Celsius.


The Permittee shall maintain a continuous hard copy readout or computer disk file of the air inlet temperature for each SRU.

Minn. R. 7007.0800, subp. 4 and 5

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

Minn. R. 7007.0800, subp. 2, 5 and 14



Corrective Actions: If the SRUs or any of their components are found during the inspections to need repair, the Permittee shall follow the O & M Plan for the SRU and take corrective action within the timing prescribed in the O & M Plan. The Permittee shall keep a record of the type and date of any corrective action taken for each SRU.

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

Initial Hood Certification and Evaluation: The control device hood must conform to the requirements listed in Minn. R. 7011.0070, subp. 1, and the Permittee shall certify this as specified in Minn. R. 7011.0070, subp. 3 within 60 days after permit issuance. The Permittee shall maintain a copy of the evaluation and certification on site.

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

Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method. The Permittee shall maintain a copy of the annual evaluation on site.


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Control Equipment: 007 Pretreatment Solvent Recovery Units (SRU) During drafting of ANDXL‐002, the Permittee has three solvent recovery units that control VOC emissions from certain pretreatment processes. These are used to control the three flow coaters and associated flashoff areas that are described in the portion of this Attachment A entitled “Process 002, Painting Processes”. All Pretreatment SRUs at the Facility, including those that are modified, reconstructed, added or replaced after permit issuance, shall meet the requirements of this section of Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.




Minn. R. 7007.0800, subp. 2

Inlet Temperature: The Permittee shall operate the control equipment so as to maintain the process air inlet temperature less than or equal to 110.0 degrees Fahrenheit.

Minn. R. 7007.0800, subp. 2

The Permittee shall operate and maintain each SRU any time the associated process equipment is in operation and using materials that contain VOC. The Permittee shall document periods of non‐operation of the control equipment.

Minn. R. 7007.0800, subp. 2

Operation and Maintenance of the Solvent Recovery Units: The Permittee shall operate and maintain each SRU in accordance with the O & M Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and review by MPCA staff.


Minn. R. 7007.0800, subp. 4

Monitoring Equipment: The Permittee shall maintain the monitoring equipment necessary for measuring the various temperatures required to be measured by ANDXL‐002. The monitoring equipment must be installed, in use, and properly maintained whenever the associated control equipment is required to be operated.

Minn. R. 7007.0800, subp. 4 and 5

The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the air inlet temperature of each SRU.

The monitoring device shall have a margin of error less than the greater of 0.75 percent of the temperature being measured or 2.5 degrees Celsius.

Minn. R. 7007.0800, subp. 4 and 5

The Permittee shall maintain a continuous hard copy readout or computer disk file of the air inlet temperature for each SRU.

Minn. R. 7007.0800, subp. 4 and 5


Minn. R. 7007.0800, subp. 2, 5 and 14


Minn. R. 7007.0800, subp. 2, 5 and 14

Corrective Actions: If the SRUs or any of their components are found during the inspections to need repair, the Permittee shall follow the O & M Plan for the SRU and take corrective action within the timing prescribed in the O & M Plan. The Permittee shall keep a record of the type and date of any corrective action taken for each SRU.


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

Initial Hood Certification and Evaluation: The control device hood must conform to the requirements listed in Minn. R. 7011.0070, subp. 1, and the Permittee shall certify this as specified in Minn. R. 7011.0070, subp. 3 within 60 days after permit issuance. The Permittee shall maintain a copy of the evaluation and certification on site.

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

Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method. The Permittee shall maintain a copy of the annual evaluation on site.

Control Equipment: 008 Regenerative Thermal Oxidizer (RTO) In August 2005, the Permittee was issued a permit by the MPCA that authorized the replacement of an existing catalytic oxidizer with a new regenerative thermal oxidizer (RTO). This replacement was completed in January 2006. The RTO is used to control VOC emissions from the door flatline painting processes that are described in the portion of this Attachment A entitled “Process 002, Painting Processes”. The natural gas burners for the RTO shall not exceed 9.0 MMBtu/hr. All RTOs at the Facility, including those that are modified, reconstructed, added or replaced after permit issuance, shall meet the requirements of this section of Attachment A. The emission and operational limits apply upon issuance of ANDXL‐002.



CONDITIONS FOR SHUTDOWN

Title I Condition: limit under 40 CFR § 52.21(aa) and Minn. R. 7007.3000; FPA, Part II.D.1.d

The Permittee shall operate an RTO to control VOC emissions from the door flatline painting processes except as specifically allowed by ANDXL‐002 until receiving written approval from the MPCA to discontinue use of the RTO. During the period that the Permittee discontinues use of the RTO pursuant to that approval, the conditions for Control Equipment 008 do not apply.

Minn. R. 7007.0800, subp. 2; FPA, Part II.D.1.d

If the Permittee wishes to shut down or dismantle the RTO, the Permittee shall submit a written request to the MPCA. The request shall:

1) Demonstrate, based on information generated in the Air Toxics Review performed by the Permittee pursuant to Part II.D.1.f. of the FPA, that the shutdown of the RTO will not represent an unacceptable risk to public health;

2) Demonstrate that the VOC PAL and performance ratio limits in the FPA will continue to be met if use of the RTO is discontinued; and

3) Demonstrate that the CAC has agreed to the proposed shutdown or dismantlement of the RTO.

In addition, the Permittee shall reinvest any cost savings from shutting down the RTO in VOC emission reduction projects. The Permittee shall demonstrate that such reinvestment has been made in the Annual Report required by Section 8, Table 4 of ANDXL‐002.


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Title I Condition: limit under 40 CFR § 52.21(aa) and Minn. R. 7007.3000

The Permittee shall operate and maintain the control equipment such that it achieves a destruction efficiency, for Volatile Organic Compounds, greater than or equal to 95 percent.

Title I Condition: limit under 40 CFR § 52.21(aa) and Minn. R. 7007.3000; 40 CFR § 52.21(aa)(12)(viii); Minn. R. 7017.2025, subp. 3

Combustion Chamber Temperature: The Permittee shall operate the control equipment so as to maintain a combustion chamber temperature greater than or equal to 1420 degrees Fahrenheit as a three hour rolling average, until a new minimum is set pursuant to Minn. R. 7017.2025, subp. 3. If a new minimum is required to be set, it will be based on the average temperature recorded during the most recent MPCA‐approved performance test where compliance was demonstrated. If the three hour rolling average temperature drops below the minimum temperature, the VOC used during that time shall be considered uncontrolled until the average minimum temperature limit is once again achieved. This shall be reported as a deviation. Down time of 15 or more minutes is not to be included as operating time.

Reference Notice of Compliance dated November 5, 2007.


The Permittee shall operate and maintain the RTO any time the associated process equipment is in operation, except as specifically allowed in the “Routine Damper Maintenance” portion of this table. The Permittee shall document periods of non‐operation of the control equipment.


Operation and Maintenance of Oxidizer: The Permittee shall operate and maintain the RTO in accordance with the O & M Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and review by MPCA staff.


Minn. R. 7007.0800, subp. 4

Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring as required by ANDXL‐002. The monitoring equipment must be installed, in use, and properly maintained whenever the associated control equipment is required to be operated.

Minn. R. 7007.0800, subp. 4 and 5

The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the RTO. The monitoring device shall have a margin of error less than the greater of +/‐ 0.75 percent of the temperature being measured or +/‐ 2.5 degrees Celsius. The recording device shall also calculate the three‐hour rolling average combustion chamber temperature.


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

Minn. R. 7007.0800, subp. 4 and 5



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Minn. R. 7007.0800, subp. 2, 5, and 14

Quarterly Inspections: At least once per quarter or as specified by the manufacturer, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the ductwork, refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

Minn. R. 7007.0800, subp. 2, 5, and 14

Annual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration. Annual replacement is acceptable in lieu of calibration.


For periods when the RTO is operated above the minimum combustion chamber temperature limit, the Permittee shall use the applicable efficiency determined during the most recent MPCA‐approved performance test when completing calculations required elsewhere in ANDXL‐002.

For periods when the RTO is NOT operated above the minimum combustion chamber temperature, or when temperature data is not available, the Permittee shall assume 0% overall control for that time period.

Starting April 27, 2006, if the tested efficiency is less than the efficiency limit in ANDXL‐002, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test.

Title I Condition: 40 CFR § 52.21(aa)(12)(ix) and Minn. R. 7007.3000; Minn. R. 7017.2020, subp. 1 and 7007.1400, subp. 1(H)

Performance Test. The Permittee shall conduct performance tests on the RTO before the end of each 60 month period starting April 27, 2006 to determine VOC capture and destruction efficiency.

A test extension is granted for the testing of CE085 due before April 27, 2011. The test is now due before August 25, 2011. Subsequent tests will continue to be based on April 27 date.

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

Corrective Actions: If the temperature is below the minimum specified by ANDXL‐002 or if the RTO or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the RTO. The Permittee shall keep a record of the type and date of any corrective action taken.

ROUTINE DAMPER MAINTENANCE


The Permittee is authorized to bypass the RTO while the painting processes controlled by the RTO are operating when performing routine damper maintenance (RDM). This is referred to as the “RDM Bypass” in ANDXL‐002. Performing RDM while the painting processes are not operating is not considered a bypass since there are no emissions to control. The Permittee shall minimize emissions to the greatest extent possible during the RDM Bypass.

Minn. R. 7007.0800, subp. 2

RDM Bypass Time Restriction: The Permittee shall limit the amount of time of RDM Bypass to an amount less than or equal to 0.50 percent of annual operating uptime for each unit controlled by the RTO. This limit applies on a calendar year basis.


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Daily Recordkeeping: On each day of operation, the Permittee shall record and maintain the total operating uptime for each unit controlled by the RTO as well as the total time spent in RDM Bypass. The Permittee shall also keep records sufficient to determine the level of uncontrolled emissions of VOC that occurred during each RDM Bypass.

Minn. R. 7007.0800, subp. 4 and 5

Annual Recordkeeping and Reporting: The Permittee shall complete calculations specified below after ANDXL‐002 issuance.

By the last day of January for each calendar year, the Permittee shall calculate and record the following for each unit controlled by the RTO:

1) the total RDM Bypass time for the previous calendar year;

2) the total operating uptime for the unit for the previous calendar year; and

3) the RDM Bypass time for the unit, expressed as a percent of operating uptime for the previous calendar year.

The Permittee shall submit these calculations in the Air: Semi‐Annual Report listed in Section 8 of ANDXL‐002 that is due by February 15th of each calendar year.

Control Equipment: 009 Electrostatic Precipitator (ESP) During drafting of ANDXL‐002, the Permittee has one piece of control equipment meeting the description of this portion of Attachment A. All ESPs at the Facility, including those that are modified, reconstructed, added or replaced after permit issuance, shall meet the requirements of this section of Attachment A as well as the applicable requirements listed in the portion of this Attachment entitled “Process 005(D)”. The emission and operational limits apply upon issuance of ANDXL‐002.





The Permittee shall operate and maintain the ESP any time the associated process equipment is in operation. The Permittee shall document periods of non‐operation of the control equipment.


Operation and Maintenance of ESP: The Permittee shall operate and maintain the ESP in accordance with the O & M Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and review by MPCA staff.

Title I Condition: to avoid a major modification under 40 CFR § 52.21 and Minn. R. 7007.3000; Minn. R. 7017.2025, subp. 3

Minimum ESP Fields on: At any time the associated process equipment is in operation, at least two of the three fields of the ESP must be on. If at any time the ESP is operated with less than two fields of the ESP on line, the duration shall be reported as a deviation.

Title I Condition: to avoid a major modification under

Minimum Total Secondary Voltage Input: The Permittee shall maintain the 3‐hour rolling average total secondary voltage input greater than or equal to 24.0


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40 CFR § 52.21 and Minn. R. 7007.3000; Minn. R. 7017.2025, subp. 3

kilovolts (kV) when operating. If the three hour rolling average drops below the minimum total secondary voltage input of 24.0 kV, it shall be reported as a deviation. Down time of 15 or more minutes is not to be included as operating time.


Minimum Total Secondary Amperage Input: The Permittee shall maintain the 3‐hour rolling average total current input greater than zero milliamps when operating. If the three hour rolling average drops below the minimum total current input of zero milliamps, it shall be reported as a deviation. Down time of 15 or more minutes is not to be included as operating time.


Minimum ESP Fields on: At any time the associated process equipment is in operation, all three fields of the ESP must be on when operating above 60,000 pounds per hour of steam output. If at any time when operating above 60,000 pounds per hour of steam output the ESP is operated with less than three fields of the ESP on line, the duration shall be reported as a deviation.



The Permittee must install, operate, and maintain each continuous parameter monitoring system (CPMS) for monitoring the ESP total power input by the startup date of the first boiler.

Minn. R. 7007.0800, subp. 2, 5 and 14

Hourly Recordkeeping: For each hour of operation, the Permittee shall record the number of fields online.

Minn. R. 7007.0800, subp. 2, 5 and 14

Daily Monitoring and Recordkeeping: The Permittee shall physically verify that CPMS is working and recording the value as required by this Attachment A at least once each operating day.

Minn. R. 7007.0800, subp. 2, 5 and 14

Monthly Inspections: At least once per calendar month, or as required by the manufacturer, the Permittee shall inspect the control equipment components that are subject to wear or plugging, for example: bearings, belts, hoses, fans, nozzles, orifices, and ducts. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

Minn. R. 7007.0800, subp. 2, 5 and 14

Quarterly Inspections: At least once per calendar quarter, or as required by the manufacturer, the Permittee shall inspect the control equipment components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

Minn. R. 7007.0800, subp. 2, 5 and 14

Annual Inspections: At least once per calendar year, the Permittee shall inspect the control equipment internal components not covered by the monthly or quarterly inspections. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

Minn. R. 7007.0800, subp. 2, 5, and 14

Annual Calibration: The Permittee shall calibrate the total power input monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration. Annual replacement is acceptable in lieu of calibration.

Minn. R. 7007.0800, subp. 2, 5 and 14

Corrective Actions: If the ESP or any of its components are found during the inspections to need repair, the Permittee shall follow the O & M Plan for the ESP and take corrective action within the timing prescribed in the O & M Plan. The Permittee shall keep a record of the type and date of any corrective action taken for each ESP.


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Insignificant Activities: 001 Insignificant Activities, Storage Tanks, and Applicable Requirements Many of the units that would otherwise qualify as insignificant are accounted for in the process groups listed in this Attachment A. For example, a maintenance parts washer is included in Process 006, Miscellaneous VOC Sources. In general, where the activity is accounted for in the process groups, it is no longer considered an insignificant activity and is not listed in this Attachment A. There is one exception, the VOC storage tanks. The VOC emissions from the tanks are accounted for in the VOC tracking required elsewhere in this Attachment A due to the way the mass balance calculations are performed (e.g., based on delivered materials). However, the storage tanks are subject to applicable requirements, and the Part 70 regulations require them to be listed in ANDXL‐002 (See Attachment G, Tanks Summary). Rather than including tank applicable requirements with each process group, they are listed at the end of the following table. The table below lists the remaining insignificant activities that are at the Facility as of ANDXL‐002 issuance and their associated applicable requirements. The Permittee shall comply with the requirements set forth in the table below.

Minn. R. 7007.1300, subpart

Rule Description of the Activity

Applicable Requirement (pollutant regulated)

3(B)(1) Infrared electric ovens Minn. R. 7011.0105 or 7011.0110 (opacity)

3(H)(3) Equipment used for hydraulic or hydrostatic testing. Minn. R. 7011.0105 or 7011.0110 (opacity)

3(H)(4) Brazing, soldering or welding equipment. Minn. R. 7011.0710 or 7011.0715 (opacity and PM)

3(H)(5) Blueprint copiers and photographic processes. Minn. R. 7011.0105 or 7011.0110 (opacity)

3(I) Individual units with potential emissions less than 2000 lb/year of certain pollutants

Minn. R. 7011.0715 and 7011.0610 (PM and opacity)

3(J) Fugitive Emissions from unpaved roads and parking lots. Minn. R. 7011.0150 (opacity)

4 Individual units with potential emissions less than: A. 5.7 lb/hr of CO B. 2.28 lb/hr of PM, PM10, NOX, SO2, VOCs C. 25% of subp. 5 values D. 10,000 ton/yr of CO2e

Minn. R. 7011.0715 and 7011.0610 (PM and opacity)

Tanks not subject to NSPS

20 VOC storage tanks greater than 2,000 gallons, each. Total capacity 163,000 gallons.

17 VOC storage tanks less than 2,000 gallons each. Total capacity 6,590 gallons.

Minn. R. 7011.1505, subp. 3 (B) (tank filling requirements)

Minn. R. 7011.0710 or 7011.0715 (opacity and PM)

Tanks subject to NSPS

2‐15,000 gallon VOC storage tanks. 40 CFR pt. 60, subp. Kb, specifically 40 CFR § 60.116b(b) (record of tank capacity)


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Minn. R. 7007.1300, subpart

Rule Description of the Activity

Applicable Requirement (pollutant regulated)

Minn. R. 7008.4110

Equipment venting particulate matter (PM) or particulate matter less than 10 microns (PM10) inside a building, provided that emissions from the equipment are:

a) filtered through an air cleaning system; and

b) vented inside of the building 100% of the time.

Note: This does not include milling equipment, as defined in ANDXL‐002. During drafting of ANDXL‐002, these systems consist primarily of cut‐off saws or other milling‐type equipment (tenoners, planers, cutters, moulders, etc.) for non‐milling operations ‐‐ vinyl parts, vinyl clad wood parts, resin conveying, fiberglass cutting, and other miscellaneous operations.

Minn. R. 7011.0710 or 7011.0715 (opacity and PM)

Under Minn. R. 7007.1250, subp. 1(A), the Permittee may add insignificant activities listed in 7007.1300, subps. 2 and 3 to the stationary source throughout the term of the permit without getting permit amendments. Certain exclusions apply and are listed in Minn. R. 7007.1250, subp. 2. In addition, ANDXL‐002 specifically limits non‐milling PM/PM10/PM2.5 and plant‐wide VOC emissions, so any listed insignificant activities emitting these pollutants must be tracked under the permit limits as required by ANDXL‐002.

ATTACHMENT B NPDES PERMIT CONDITIONS

(WATER REQUIREMENTS)

Page 1 of 12

Table of Contents


1 Description 1

2 Definitions 3

3 Discharges Authorized 4

4 Monitoring 6

5 Inspections and Maintenance 8

6 Recordkeeping 8

7 Extension of Deadlines 8

8 Spill Prevention and Response Procedure 9

9 Bypasses/Upsets 9

10 Failure of Treatment Works 10

11 Noncompliance Notification 10

12 Incorporation By Reference 11

13 Outfall Location Map 12

1. Description.

The water discharges at the Facility consist primarily of cooling waters which are used for non‐contact cooling processes, and stormwater associated with an industrial activity from the plant site. Water discharges are to the St. Croix River, which is designated within Minn. R. 7050.0180 (Non‐degradation For Outstanding Resource Value Waters) as an Outstanding Resource Value Water, in the “river cove” area adjacent to the plant. An average of 843,000 gallons per day (gpd), maximum of 1,850,000 gpd, of non‐contact cooling water is currently discharged via surface discharge outfalls SD001, SD002, SD005, and SD006. Water used in non‐contact cooling systems, eventually discharging into these discharge outfalls, is currently supplied by groundwater pumped from plant wells at the Facility. No chemical additives are used in these non‐contact cooling water systems. An average of 4,000,000 gpd, maximum of 6,500,000 gpd, of non‐contact cooling water will also be used in new heat exchanger systems for purposes of heating the facility buildings, and will be discharged via a new surface discharge point, discharge outfall SD007. This water will be used solely in non‐contact cooling systems (used in facility heat exchangers in make‐up air systems to supplement heating of the facility). The source water for this system will be obtained from the Xcel Allen S. King Generating Plant located next to the Andersen facility. A small portion of the Xcel condenser cooling water at the rates stated above, normally discharged directly to the river from the Xcel plant, will be pumped from the Xcel plant after it exits the Xcel plant condenser. Use of this condenser cooling water is a beneficial reuse of the Xcel generating plant cooling water since additional heat will be extracted from this cooling water at the Andersen facility before being discharged to the river. The SD007 discharge outfall will be located at the head of the river cove discharge area adjacent to the Andersen facility. No chemical additives will be routinely used in this non‐contact cooling water system. However, in the event of certain fish and/or zebra mussel infestation of the Xcel cooling water system specific chemical additives may be used by Xcel in their condenser cooling water system. These chemical additives are reviewed and approved by the MPCA and regulated via the NPDES permit for the Xcel plant. These chemical additives would be used very infrequently, typically less than annually, and of short term use, often only for one day. The dosage and use of any chemical additives are regulated by the MPCA to assure that the discharges do not pose a threat to aquatic life in the river.

ATTACHMENT B WATER REQUIREMENTS

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With the exception of relatively low flow of reverse osmosis reject water, all process and sanitary wastewaters are discharged to the Metropolitan Council of Environmental Services (MCES) sanitary sewer system. A reverse osmosis system is used to treat groundwater to supply boiler feedwaters. The reverse osmosis system concentrates dissolved salts in the groundwater and will be discharged to the river via the non‐contact cooling water discharges at an average rate of about 14,000 gpd. In the past this water was discharged to the sanitary sewer system and hence the municipal wastewater treatment plant. However, wastewater treatment of the reverse osmosis reject water, by MCES is not required for this waste stream and the constituents in the RO waste stream when co‐mingled with the non‐contact cooling water waste stream do not pose an environmental impact to the river.

Process and sanitary wastewaters generated from domestic and janitorial wastes, process wastewater oil/water separators, cooling tower blowdown, solvent recovery condensates, closed loop extruder contact cooling water, floor drains, and related process wastewater are discharged to the sanitary sewer for treatment at the municipal wastewater treatment plant at an average rate of about 85,000 gallons per day.

Stormwater associated with an industrial activity generated at the Facility is discharged to the St. Croix River through various discharge locations. This NPDES permit includes the conditions, requirements, and provisions required under the Facility’s prior NPDES/SDS General Stormwater Permit MN006167332, incorporated herein.

The Permittee also operates a groundwater treatment system for remediation of contaminated groundwater under the plant, which contains trace concentrations of pentachlorophenol (PCP). PCP was an ingredient used as a wood treatment preservative at the Facility until 1986. The groundwater treatment system consists of a gradient control system designed to prevent migration of PCP from the site and a pump and treat system, which extracts the contaminated groundwater and treats it through a granular activated carbon system. The activated carbon system effectively removes the PCP to non‐detectable levels. Although the PCP levels after the activated carbon treatment system have been non‐detect for a period of years the permit requires that PCP be monitored in the activated carbon effluent at least once per year. The permit also requires that low level mercury be monitored in the activated carbon effluent at least once per year. The treated groundwater after the activated carbon treatment system is directed to storage tanks and used as makeup for non‐contact cooling water at buildings 5, 5A, 10, and 14, and is discharged to the St. Croix River via the non‐contact cooling water discharge outfalls SD002 and SD005. The activated carbon system effluent is monitored prior to its discharge to the non‐contact cooling water systems to ensure adequate PCP removal.

The activated carbon ground water treatment system was originally implemented in 1982. A Response Order by Consent (Consent Order) between the Permittee and the MPCA was executed on January 27, 1987, and is in effect until its provisions have been satisfied as specified in Section XXXIII of the Consent Order. The ground water treatment system has undergone several modifications and improvements, and will continue to operate until the response action objectives and cleanup levels established by the July 1995 Minnesota Decision Document (MDD) have been achieved.

The Facility uses certain MPCA approved chemical additives for “dust” control to minimize total suspended solids in stormwater associated with an industrial activity. The facility is required to obtain MPCA approval for any new, or modifications to, chemical additives used at the plant that may be discharged. These include chemicals used for dust control, cooling water, or used in the groundwater treatment system. Currently no chemical additives are used in the non‐contact cooling waters. Any chemical additives proposed to be used in the cooling waters that may discharge to the river, such as biocides, requires MPCA review and approval. MPCA approval of any chemical additives may include conditions for their use, including limitation of dosages.


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2. Definitions. The following terms are defined for Attachment B only.

A. Bypass means an intentional diversion of a waste stream from a portion of the treatment works. B. Composite sample means: a. a series of grab samples collected at least once per hour at equally spaced time intervals, and

proportioned together relative to the flow volume of each grab sample; or b. a combination of equal volume grab samples, each collected after a predetermined volume of flow has

passed (such as 25 milliliter samples after each 1000 gallons of flow). C. Discharge means the conveyance, channeling, runoff, or drainage of surface stormwater runoff (including

snow melt) from the site, and/or the conveyance and release of cooling waters or treated wastewaters. D. Grab sample type means an individual sample collected at one point in time. E. Impervious Surface means a constructed hard surface that either prevents or retards the entry of water

into the soil and causes water to run off the surface in greater quantities and at an increased rate of flow than prior to development. Examples include rooftops; sidewalks; patios; driveways; parking lots; storage areas; and concrete, asphalt, or gravel roads.

F. Instantaneous sample type means a measurement, such as flow or temperature, taken at the time of

sampling for chemical characteristics. G. Maximum means the greatest sample value recorded during the designated monitoring period. H. Monthly Average means the arithmetic mean of all samples collected during one calendar month. The

mean concentration shall be flow‐weighted, calculated by: a) multiplying each individual sample concentration times its respective individual flow; b) adding all such calculations for samples taken during the month; and c) dividing by the sum of the respective flows.

I. Non Stormwater Discharge means any discharge not comprised entirely of stormwater. J. Nonstructural BMPs refers to practices that will reduce or eliminate pollutants to stormwater and do not

require installation of permanent structural devices to treat runoff. Examples of nonstructural BMPs include but are not limited to parking lot and street sweeping; employee training; changing material handling practices; installation of silt fence, minimizing materials exposed to stormwater through inventory reduction, tarping, or moving of material indoors.

K. Significant Materials includes, but is not limited to: raw materials; fuels; materials such as solvents,

detergents, and plastic pellets; finished materials such as metallic products; raw materials used in food processing or production; hazardous substances designated under section 101(14) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); any chemical the Facility is required to report pursuant to Section 313 of the Emergency Planning and Community Right‐to‐Know Act (EPCRA); fertilizers; pesticides; and waste products such as ashes, slag, and sludge that have the potential to be released with the stormwater discharges. When determining whether a material is significant, the physical and chemical characteristics of the material should be considered (e.g. the material’s solubility, transportability, and toxicity characteristics) to determine the material’s pollution potential.


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L. Stormwater means stormwater runoff, snow melt runoff, and surface runoff and drainage. M. Structural BMPs refers to the installation of devices that will reduce or eliminate pollutants to

stormwater through installation of permanent structural devices to treat or control runoff. Examples of structural BMPs include but are not limited to installation of stormwater diversion berms or channels; sedimentation basins (retention or detention basins); oil/water separators; grit chambers; roofs, awnings or buildings to cover significant material.

N. Upset means an exceptional incident in which the permit discharge limits are unintentionally and

temporarily exceeded due to factors beyond the reasonable control of the Permittee.

3. Discharges Authorized. The Permittee is authorized by ANDXL‐002 to discharge to the St. Croix River through discharge points as follows: non‐contact cooling waters originating from plant wells via SD001, SD002, SD005, and SD006, non‐contact cooling water originating from condenser cooling water from the Xcel Allen S. King Generating Plant discharged via SD007, groundwater used as makeup for cooling waters and discharged via SD002 and SD005, and low flow reverse osmosis reject water via non‐contact cooling water discharges.

Outfall point

Typical average Daily Discharge Rate (gpd)

Typical Maximum Daily Discharge Rate (gpd)

Frequency of Discharge

SD001 276,900 720,000 Continuous

SD002 127,900 432,000 Continuous

SD005 340,700 576,000 Continuous

SD006 97,900 122,400 Continuous

SD007 4,000,000 6,500,000 Continuous during months of Jan, Feb, Mar, April, Oct, Nov, Dec,

intermittent during other months

Discharges through these outfalls are not limited by the discharge rates noted. The Permittee is also authorized by ANDXL‐002 to discharge stormwater runoff to the St. Croix River via undesignated discharge outfalls. Discharges to these undesignated outfalls are limited solely to stormwater runoff.

A. Chemical Additives. No chemicals are added to the non‐contact cooling waters. An infrequent exception

may be the use of chemical additives at the Xcel A.S. King Generating plant for control of zebra mussel in the Xcel condenser cooling water system. The Xcel condenser cooling water is used as the source water for Andersen non‐contact cooling water discharging to SD007. Salt may be used on occasion during the winter to thaw ice/snow from parking and sidewalk areas. In addition calcium chloride and/or a compound called Coherex®, approved for use by the MPCA, may be used for purposes of dust control on gravel parking and storage areas. Miscellaneous wastewater including water entering floor drains, boiler blowdown, demineralizer regenerate discharges, etc. is discharged to the sanitary sewer.

The Permittee shall not use water treatment additive(s) that may be discharged through the outfalls without the prior approval of the MPCA. The Permittee shall submit a written request for approval to use a chemical that may be discharged to an outfall. The written request must be submitted in advance


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of a proposed (non‐emergency) chemical use. The written request shall include, at a minimum, the following information for each proposed additive:

a. The commercial and chemical name(s) of the product to be used.

b. Aquatic toxicity and human health or mammalian toxicity data.

c. Environmental fate information including but not limited to persistence, half‐life, intermediate breakdown products, and bioaccumulation data.

d. Whether the chemical is a suspected carcinogen, mutagen, or teratogen.

e. The proposed dosage rates and frequencies of chemical addition.

f. Material safety data sheets and product labels, including instructions for use. The MPCA may require monitoring and/or restrictions in use or discharge of a water treatment or chemical additive.

B. Stormwater Pollution Prevention Plan. The Permittee has developed and implemented a Stormwater

Pollution Prevent Plan which meets the requirements below. The Permittee shall continue to follow its existing SWPPP to eliminate, or minimize to the extent possible, the contact of stormwater with significant materials that may result in pollution of the runoff.

The SWPPP was completed pursuant to requirements in prior general stormwater permits issued for the plant site. The SWPPP controls stormwater runoff at the plant site through minimizing contact of stormwater with significant materials that may result in pollution of runoff. The SWPPP may be updated on occasion when changes occur. The SWPPP implemented includes both structural and nonstructural BMPs for stormwater control. The Permittee shall retain the SWPPP at the Facility and shall update or revise the SWPPP when necessary to accommodate any changes at the plant site to assure continued minimization of stormwater contamination. The Permittee shall update the SWPPP as needed based on any site changes pertinent to the following items:

a. A drainage map of the site for drainage areas and directions of stormwater runoff, applicable discharge

outfalls from the site, areas where significant materials are exposed to stormwater, locations of storm sewer inlets, and locations and types of BMPs installed or used at the Facility used to minimize or eliminate pollutants discharged in the stormwater.

b. An inventory of exposed significant materials which may contact and contaminate stormwater including, but not limited to, raw materials, such as fuels; solvents; petroleum products; by‐products or intermediate products such as wood dust, chips or bark; recycled products; finished materials or products; waste products such as sludges, ash, solid and liquid wastes; hazardous substances designated under section 101 (14) of the CERCLA; and any chemical the Permittee is required to report under section 313 of the EPCRA.

c. Evaluation of the Facility for exposure of significant materials to stormwater to include at a minimum the following: vehicle and equipment maintenance, parking and storage areas including fueling and washing/cleaning areas; liquid storage tanks and other bulk material stockpile areas; loading and unloading areas; outdoor manufacturing, processing or storage areas and industrial plant yards to determine if leaks or spills of solvents, fuels, or lubricants have occurred in soils; dust or particulate generating areas including dust collection devices that may release dust; rooftops or other surfaces contaminated by industrial activity or operation of a pollution control device; on‐site waste disposal


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areas such as waste ponds, dumpsters, solid waste storage or management areas; and exposed (non‐vegetated) soil areas where there is a potential for erosion to occur.

d. The appropriate BMPs, both structural and nonstructural, that will be used at the site to minimize or eliminate pollution of stormwater. The BMPS shall be described to include an objective for each BMP, the proper functioning of the BMPs, and the maintenance requirements of the BMPs. The following general categories shall be considered and one or more shall be incorporated into the SWPPP if significant materials are exposed to stormwater: reduction and/or elimination of significant materials exposed to stormwater at the site; diversion of stormwater drainage away from exposed significant materials through use of curbing, berms, sewers or other forms of drainage control or elevation of exposed significant material above surrounding drainage; and treatment to reduce the amount and concentration of pollutants in the discharged stormwater where contact with significant materials is unavoidable.

e. Evaluation of all discharge conveyances from the site to determine if any liquids other than stormwater are being discharged from these devices. The evaluation should include sewer inlets and floor drains to determine which inlets/drains are connected to sanitary sewer lines, storm sewer lines, or septic tanks/drainage fields, etc. The Permittee shall certify in the SWPPP that discharges from the site have been evaluated for the presence of non stormwater discharges.

f. Continuation of a preventive maintenance program of regular inspection and maintenance of stormwater management devices, as well as inspection and testing of applicable plant equipment and systems to uncover conditions that could cause breakdowns or failures resulting in discharges of pollutants to surface waters.

g. Employee training programs shall be updated as needed to inform appropriate personnel of components and goals of the SWPPP, and identify periodic dates for such training.

h. Identify and update all personnel responsible for managing and implementing the SWPPP as well as those responsible for any applicable reporting requirements.

C. Additional BMPs. The Permittee shall install and/or use any additional BMPs, both structural and

nonstructural, as needed for any changes at the site requiring such BMPs. 4. Monitoring.

Samples and monitoring for the site discharges shall be representative of the combined discharge and shall be taken at a point or points representative of the discharge(s) to the St. Croix River. Monitoring is not required for pH. However, the Permittee shall conduct pH monitoring at the applicable and affected outfall(s) in the event of a spill of materials that may cause any pH changes.


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The following table lists the monitoring requirements and discharge limitations for SD001, SD002, SD005, SD006, and SD007:

Water Monitoring and Discharge Limits

Effluent Characteristic Discharge Limitation Frequency of Analysis Sample Type

Flow ‐‐‐ Monthly Estimated

pH 6.0 minimum – 9.0 maximum pH Units

‐‐‐ ‐‐‐

Temperature 86F maximum Monthly Grab

Phosphorus, Total Total from all stations shall not exceed 104

kilograms/year

Yearly Grab

All monitoring results shall be summarized onto a Discharge Montioring Report form provided by the Agency. Monitoring is not required during months when a discharge is not occurring. The Permittee shall sample and analyze ground water from recovery wells 10 and 11, via grab samples after the water has passed through the activated carbon treatment system (effluent of the activated carbon treatment system prior to discharge to the non‐contact cooling water systems) as follows:

Parameter Monitoring Frequency Sampling Date

Pentachlorophenol (PCP) Annually by October 1 each calendar year

Dioxins and Furans Biennial by October 1 odd calendar years

All monitoring results shall be summarized onto a Discharge Montioring Report form provided by the Agency and the Permittee shall submit the results of analyses of groundwater activated carbon treatment system effluent with the Annual Report submitted by April 1 of the following calendar year. The Permittee shall also monitor the activated carbon treatment system operation as needed for process control to assure efficient continued PCP removal and treatment, and for determination of carbon replacement when needed. The Permittee may add oxygen and nutrients to the groundwater remediation system as approved by the Minnesota Department of Health (MDH) and the MPCA. Currently oxygen, tripolyphosphates, and ammonium chloride are approved additives. In the event other additive(s) are proposed for use in the groundwater remediation system, the Permittee shall obtain approval from the MPCA and MDH prior to use. The low level mercury monitoring requirement has been removed from the permit. All monitoring and analytical instruments used to monitor as required by ANDXL‐002 shall be calibrated and maintained at a frequency necessary to ensure accuracy. The Permittee shall measure flows, where applicable and required, to ensure accuracy within plus or minus ten percent of the true flow values. The Permittee shall maintain written records of all calibrations and maintenance where applicable. The Permittee shall maintain the following records for each sample and measurement:

a. The exact place, date and time of the sample or measurement.

b. The date of analysis.


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c. The individuals who performed the sample collection, measurement, analysis, or calculation.

d. The analytical techniques, procedures, and methods used.

e. The analytical results. 5. Inspections and Maintenance.

The Permittee shall conduct site inspections at least once every 2 months during non‐frozen conditions. Inspections shall be conducted by appropriately trained personnel. The purpose of the inspections is to determine whether structural and nonstructural BMPs require maintenance or changes, and to evaluate the completeness and accuracy of the SWPPP. At least one inspection shall be conducted during a reporting period while stormwater is discharging from the site. The following items shall be inspected and documented:

a. Evaluate the site to determine that the SWPPP accurately reflects site conditions and document any

inaccuracies.

b. Evaluate the site to determine whether new exposed materials have been added to the site since completion of the SWPPP and document any new significant materials.

c. During the inspection occurring during a runoff event, observe the runoff to determine any discoloration or visible contamination and document observations.

d. Determine if the structural and nonstructural BMPs as indicated in the SWPPP are installed and/or used and functioning properly.

e. Indicate the date and time of the inspection and the name of the inspector on the inspection form.

f. If conditions are observed at the site that require changes in the SWPPP, the Permittee shall make such changes in the SWPPP prior to submittal of the annual report.

g. If findings of an inspection indicate that BMPs are not meeting the objectives identified in the SWPPP, the Permittee shall initiate corrective actions within 30 days and the BMP restored to full operation as soon as field conditions allow.

The Permittee’s current inspection and maintenance procedures meet the requirements stated above.

6. Recordkeeping.

The Permittee shall retain the SWPPP for the duration of the permit. A copy of the SWPPP and the Permittee’s Contingency Plan/Emergency Response Plan shall remain on site whenever the Permittee staff is available on the site, and be available upon request. The Permittee shall maintain records of dates of inspections, findings of inspections, corrective actions taken, documentation of all changes to the SWPPP, and a copy of annual reports for the period of permit coverage.

7. Extension of Deadlines.

The Permittee may request an extension of deadlines for implementation of new or additional BMPs as described in 5.g. above. Requests should be made in writing to the MPCA, Industrial Division, Land and Water Quality Permits Section, 520 Lafayette Rd, St. Paul, MN 55155‐4194. After review of the extension request the MPCA will provide a written response either approving or denying the extension request.


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8. Spill Prevention and Response Procedure.

The Permittee has in place a Spill Contingency Plan/Emergency Response Plan that describes spill prevention and response procedures. The Permittee shall update the plan as needed for completeness and accuracy of information. The Spill Contingency Plan/Emergency Response Plan may be used as a Spill Prevention Control and Countermeasure Plan (SPCC plan), pursuant to any requirements under 40 CFR § 112.

9. Bypasses/Upsets.

The Permittee may allow a bypass to occur if the bypass will not cause the exceedance of an effluent limitation but only if the bypass is necessary for essential maintenance to assure efficient operation. The Permittee shall submit to the MPCA notice of the need for the bypass at least ten days before the date of the bypass. The notice of the need for a bypass shall include the following information: a. The proposed date and estimated duration of the bypass.

b. The alternatives to bypassing.

c. The proposed measures to mitigate environmental harm caused by the bypass.

d. A proposal for bypass monitoring. The Permittee shall not allow an anticipated bypass to occur that will cause an exceedance of an applicable effluent limitation unless the following conditions are met:

The bypass is unavoidable to prevent loss of life, personal injury, or severe property damage. For the purposes of this paragraph, "severe property damage" means substantial damage to property of the Permittee or of others; damage to the wastewater treatment facilities that may cause them to become inoperable; or substantial and permanent loss of natural resources that can be reasonably expected to occur in the absence of a bypass. "Severe property damage" does not mean economic loss as a result of a delay in production.

There is no feasible alternative to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes, or performance of maintenance during normal periods of equipment downtime. This condition is not satisfied if adequate backup equipment should have been installed in the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal periods of equipment downtime or preventative maintenance.

The Permittee has notified the Commissioner of the anticipated bypass and the Commissioner has approved the bypass. The Commissioner shall approve the bypass if the Commissioner finds that the conditions set forth in Minnesota R. 7001.0190, subp 1, item K are met.

The Permittee shall include within the next monitoring report a written description of bypasses or upsets that occurred during the reporting period. This description shall include at least the following:

a. A description of the upset or bypass including volumes, duration, wastewater characteristics, and

receiving waters.

b. The cause of the bypass or upset and the steps taken to reduce, eliminate, and prevent its recurrence.


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c. The exact dates and times of the bypass or upset and, if it is still occurring, how long it will be before it ends.

d. Those steps the Permittee has taken to minimize adverse impacts to human health, public drinking water supplies, and the environment due to the bypass or upset.

In the event an exceedance of a permitted discharge limitation occurs, the Permittee shall submit a discharge monitoring report for the calendar month during which the exceedance occurs no later than 21 days following that month. The Permittee shall also submit a discharge monitoring report no later than 21 days following a calendar month in which a bypass, spill, upset, or violation of a permit limitation or condition occurred. The discharge monitoring report shall include a written description of the bypass, spill, upset, or permit violation that occurred during the reporting period.

10. Failure of Treatment Works.

If the treatment works fails or is impaired, the Permittee shall halt or limit production or wastewater releases or both, as needed to maintain permit compliance, until the treatment works is restored or alternative treatment is provided. It shall not be a defense for the Permittee in an enforcement action that it would have been necessary to halt or reduce production or other permitted activities in order to comply with ANDXL‐002.

11. Noncompliance Notification.

The Permittee shall notify the Minnesota Department of Public Safety Duty Officer at (800)422‐0798 or (651)649‐5451 immediately of a permit violation that may endanger human health, public drinking water supplies or the environment, or of a discharge or release, accidental or otherwise, of any substance or material under its control which, if not recovered, may cause pollution of waters of the state or endanger human health, public drinking water supplies, or the environment. The Permittee shall take all reasonable steps to minimize the adverse impacts to human health, public drinking water supplies or to the environment resulting from the discharge or release. This may include restricting or preventing untreated or partially treated wastewater, plant chemicals or materials from entering waterways, containing spilled materials, recycling by‐passed wastewater through the plant, or using auxiliary treatment methods. The Permittee shall report to the Duty Officer all pertinent information regarding the discharge, including the following:

a. The name and telephone number of the person reporting the violation or discharge.

b. The Permittee name and telephone number.

c. The city or township, and county.

d. The receiving water of any discharge.

e. The time and duration of the violation or discharge.

f. The volume of any wastewater or release involved.

g. Any treatment or remedial action provided, or steps taken to minimize adverse impacts.

h. Pollutants that are likely to be present.

i. The cause of the violation, discharge, or release.


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j. If there are drinking water supplies or recreational areas (such as swimming beaches) that may be impacted.

k. If a fish kill has occurred.

l. If immediate assistance is needed.

m. If news media have been notified.

The Permittee shall provide a written description of the permit violation, discharge or release, to the MPCA within five days of discovery of the violation. The written description must contain all of the information listed in subparagraphs a. through m. above.

12. Incorporation By Reference.

The Permittee shall comply with the provisions of 40 CFR §§ 122.41 and 122.42(a), Minn. R. 7001.0150, subp. 3 and 7001.1090, subps. 1 and 2, which are incorporated into ANDXL‐002 by reference, and are enforceable parts of ANDXL‐002.


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13. Outfall Location Map

ATTACHMENT C WASTE REQUIREMENTS

Page 1 of 4

Table of Contents


1 West Process Diptank and Floodcoater Reservoir 1

2 East Process Diptank 3

3 Groundwater Water Remediation Enhancement 4

4 Noncompliance Notification 4

1. West Process Diptank and Floodcoater Reservoir

A. Metal Parts Removal

a. The Permittee shall remove from the West Process Diptank all metal parts that have come in contact with wood preservative containing pentachlorophenol. The Permittee may arrange to have the parts transported to and recycled at a metal smelting operation provided the metal has met cleaning criteria set by the metal smelter, but without the use of a manifest, EPA identification number and similar hazardous waste generator requirements. This varies the chlorophenolic process equipment cleaning requirement of Minn. R. 7045.0145.

b. The Permittee shall submit to the MPCA and Washington County, within 30 days of completion of the

transport and recycling of the metal parts, information on the location, method of treatment, volume, and shipment dates of the metal parts to the metal smelting operation.

c. If the Permittee can certify the metal parts have been cleaned consistent with the requirements of

Minn. R. 7045.0145, then Sections A.a and A.b. above do not apply to the metal parts and the metal parts may be managed by the Permittee as a non‐hazardous waste.

B. Closure

Compliance with the following conditions constitutes proper closure of the West Process Diptank and Floodcoater Reservoir: a. The Permittee shall remove all hazardous waste from the West Process Diptank in accordance with

Minn. R. 7045.0205 through 7045.0320 within 90 days of permanently ceasing operation of the West Process Diptank.

b. The steel tank liner from the West Process Diptank may be left in its current location in the ground,

after it has been hand wiped or spray washed, filled with sand and capped with concrete. In addition, the Floodcoater Reservoir may remain in place in its current condition of being filled with sand and capped with concrete. This constitutes proper closure of the West Process Diptank and the Floodcoater Reservoir.

c. If the Permittee leaves the West Process Diptank and Floodcoater Reservoir in the ground, then the

Permittee shall record in the office of the County Recorder or Registrar of Titles, whichever is appropriate, in and for Washington County, an affidavit, the form of which has been reviewed and approved by the MPCA and Washington County, noting the location of the West Process Diptank and Floodcoater Reservoir.

d. If the Permittee elects to remove the West Process Diptank or Floodcoater Reservoir, then the

Permittee shall submit a plan for review and approval to the MPCA and Washington County to test


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the adjacent soils for chemical contamination and address the sand fill material, the soil under the removed tank and the tanks themselves. If the Permittee elects to remove the West Process Diptank or Floodcoater Reservoir from the ground, the Permittee shall evaluate options for removal of the epoxy coating from the West Process Diptank and/or the Floodcoater Reservoir.

e. The Permittee’s closure of the West Process Diptank and Floodcoater Reservoir in accordance with

the conditions of ANDXL‐002 shall not result in any additional investigation and remediation requirements, unless soils are exposed due to site reconstruction, development, or tank removal activities, thereby facilitating access to the West Process Diptank and Floodcoater Reservoir areas.

C. West Process Diptank Residues

a. During the active life of the West Process Diptank, the Permittee shall manage residues generated from within the tank through the use of the existing formulation as, at a minimum, an F032 waste until the Permittee meets the waste classification removal specifications discussed in Section C.c. below.

b. During the active life of the West Process Diptank, the Permittee shall manage any residues generated

from new preservative formulations as, at a minimum, an F032 waste until the Permittee meets the waste classification removal specifications discussed in Section C.c. below.

c. If the Permittee can demonstrate through analytical results that the West Process Diptank residues

are below the pentachlorophenol threshold for land disposal of 1.2 parts per billion, then the F032 waste designation shall be removed and shall no longer apply to residues generated from within the West Process Diptank for both existing and new formulations. The Permittee shall request from the MPCA that the F032 waste designation be removed and wait for MPCA written approval. The Permittee shall, however, continue to evaluate residues generated from the West Process Diptank in accordance with Minn. R. 7045.0205 through 7045.0320 and shall manage, as applicable, the waste stream consistent with those regulations.

D. Related Provisions

a. As of the effective date of ANDXL‐002, the Corrective Action Agreement between the MPCA and the Permittee dated May 4, 1995 is terminated in its entirety and shall no longer have any force or effect.

b. The Permittee shall use good faith efforts to, but is not obligated to, cease operation of the West

Process Diptank and decommission the diptank within five years from the effective date of ANDXL‐002.

c. During the active life of the West Process Diptank, the Permittee shall perform non‐destructive testing

of the West Process Diptank’s steel liner to evaluate its integrity within two years from the date of permit issuance. The Permittee shall also conduct a second follow‐up non‐destructive test of the West Process Diptank’s liner within eight years of the permit issuance. A qualified tank inspection company familiar with non‐destructive testing technology must conduct the testing. In addition, during the years when non‐destructive testing is not conducted, the Permittee shall have a qualified tank inspection company conduct a visual inspection of the West Process Diptank once per year.

In the event that visual inspections show areas of failure or deterioration of the diptank’s epoxy coating, or non‐destructive testing or visual inspections show areas of accelerated


Page 3 of 4

corrosion/deterioration of the diptank’s steel liner, the Permittee shall implement the appropriate corrective measures, which may be limited to increased maintenance activities (e.g. more frequent sealant application), as approved by the MPCA, to insure the structural integrity of the diptank liner and its epoxy coating. In addition, if accelerated corrosion/deterioration of the steel liner is observed during the first non‐destructive testing event (as noted above) that indicates possible structural concerns, the Permittee shall conduct more frequent follow‐up non‐destructive testing as needed or recommended by the inspection company to insure the continued structural integrity of the West Process Diptank liner. At least 15 days prior to the testing taking place, the Permittee shall submit to the MPCA for review and approval its proposed non‐destructive testing method and procedures for the West Process Diptank. The Permittee shall also submit to the MPCA the results of all non‐destructive testing of the diptank liner along with recommendations made by the inspection company during the life of the permit.

2. East Process Diptank

A. Closure

Compliance with the following conditions constitutes proper closure of the East Process Diptank:

a. The Permittee shall remove all hazardous waste from the East Process Diptank in accordance with Minn. R. 7045.0205 through 7045.0320 within 90 days of permanently ceasing operation of the East Process Diptank.

b. The stainless steel tank liner from the East Process Diptank may be left in its current location in the

ground, after it has been hand wiped or spray washed, filled with sand and capped with concrete. This constitutes proper closure of the East Process Diptank.

c. If the Permittee leaves the closed East Process Diptank in the ground and within 10 days prior to the

time of a transfer in property ownership, the Permittee shall record in the office of the County Recorder or Registrar of Titles, whichever is appropriate, in and for Washington County, an affidavit, the form of which has been reviewed and approved by the MPCA and Washington County, noting the location of the East Process Diptank.

d. If the Permittee elects to remove the East Process Diptank from the ground, then the Permittee shall

submit a plan for review and approval to the MPCA and Washington County to test the adjacent soils for chemical contamination and address the sand fill material (if applicable), the soil under the removed tank and the tank itself.

e. The Permittee’s closure of the East Process Diptank in accordance with the conditions of ANDXL‐002

shall not result in any additional investigation and remediation requirements, unless soils are exposed due to site reconstruction, development, or tank removal activities, thereby facilitating access to the East Process Diptank area.

B. Related Provisions

a. During the active life of the East Process Diptank, the Permittee shall evaluate and manage any waste

generated from new preservative formulations in accordance with Minn. R. 7045.0205 through 7045.0320.


Page 4 of 4

b. During the active life of the East Process Diptank, the Permittee shall perform non‐destructive testing of

the East Process Diptank’s stainless steel liner to evaluate its integrity within five years from the date of the permit issuance. If the initial non‐destructive test results are satisfactory (i.e., shows no areas of accelerated corrosion/deterioration or structural concern), a second follow‐up non‐destructive test of the diptank liner will not be required A qualified tank inspection/testing company familiar with non‐destructive testing technology must conduct the testing. In addition, during the years when non‐destructive testing is not conducted, the Permittee shall have a qualified tank inspection company conduct a visual inspection of the East Process Diptank once per year.

In the event that non‐destructive testing or visual inspections show areas of accelerated corrosion/deterioration of the diptank’s stainless steel liner, the Permittee shall implement the appropriate corrective measures, which may be limited to increased maintenance activities (e.g. more frequent sealant application), as approved by the MPCA, to insure the structural integrity of the diptank liner. In addition, if accelerated corrosion/deterioration of the liner is observed during the initial non‐destructive testing event (as noted above) that indicates possible structural concerns, the Permittee shall conduct additional follow‐up non‐destructive testing as needed or recommended by the inspection company to insure the continued structural integrity of the East Process Diptank liner. At least 15 days prior to the testing taking place, the Permittee shall submit to the MPCA for review and approval its proposed non‐destructive testing method and procedures for the East Process Diptank. The Permittee shall also submit to the MPCA the results of all non‐destructive testing of the diptank liner along with recommendations made by the inspection company during the life of the permit.

3. Groundwater Water Remediation Enhancement

A. The Permittee shall, in consultation with the MPCA, continue to seek methods to enhance the effectiveness of its ground water remediation system. Currently, contaminated ground water is collected by extraction wells, and is subsequently filtered by two carbon modules, before being utilized as make‐up non‐contact cooling water. Floating free product is collected by an extraction well and is properly disposed off‐site. The remediation system also includes injection of oxygenated, nutrient‐enriched water into the ground water upgradient from the area of highest contaminant concentrations.

B. The Permittee shall cooperate with other regulatory agencies, such as the Minnesota Department of

Health, to obtain required approval (i.e., permits or variances) for testing and/or implementing such methods.

C. The Permittee shall consider additional enhancement methods to address the pentachlorophenol and

total hydrocarbon (as VM&P naphtha) contamination in the area(s) of highest concentrations. Specific methods may include the installation of additional injection wells to introduce oxygen and/or nutrients to ground water and/or soil.

4. Noncompliance Notification

In the event of a Hazardous Waste spill or other Hazardous Waste related permit violation at the Facility, the Permittee shall comply with Minn. R. 7045.0275.

ATTACHMENT D List of Process Equipment

Page 1 of 6

Permit Process Group Number

Process Description Emissions Unit Description Air Delta EU

Number

001 Preservative Processes Preservative Diptank 1 100

Preservative Diptank 2 101

Diptank Dryer 102

ILTS 101 (PSCA WC 20) 610



ILTS 201 (Door WC 11) 112

ILTS 121 (Narroline WC 54) 535

ILTS106 (Narroline WC 17) 536

R&D Waterbased Treater 642

002 Painting Processes Paintline 1, Silos 1 and 2 150 & 151

Paintline 2, Silos 1 and 2 152 & 153

Paintline 1 & 2 Dryer 157


Paintline 3 Flow Coater 118


Paintline 4 Flow Coater 119

Paintline 3 & 4 Dryer 164



Paintline 5 & 6, Dryer 171

Paintlines 5 & 6 Flow Coater 120

Flexiframe Booth 1 173

Flexiframe Booth 2 174

Flexiframe Infrared Oven 175

Longlength Booth 176

Longlength Dryer 177

Endspray Booth 178

Flatlines 1, 2, & 3 182

R&D Booth (“add‐on”) 181

Maintenance Mobile Spray Painter (“add‐on”) 412

Maintenance Mobile Spray Painter (“add‐on”) 413

Maintenance Paint Booth (“add‐on”) 416

Flexiframe Infrared Oven 2 609

Gas Air Makeup Unit 3 627

Interior Lineal Booth 1 638

Interior Lineal Booth 2 640

Doors Manual Booth 644

R&D Lineal Booth Oven 636

Interior Lineal Booth Oven 1 639

Interior Lineal Booth Oven 2 641


Page 2 of 6



Number

003 Milling Equipment

Vented externally to Control Equipment 003

moulder ‐ 2, tenoner ‐ 1, saw ‐ 7, jointer ‐ 2 (FS17, 57600 cfm)

502

tenoner ‐ 3, material transfer (FS26, 358200 cfm) 504

moulder ‐ 6, tenoner ‐ 9, saw ‐ 5, drill & strike ‐ 2 (FS18, 75000 cfm)

505

moulder ‐ 6, tenoner ‐ 3, saw ‐ 1 (FS35, 53000 cfm)

506

tenoner ‐ 1, saw ‐ 7 (FS05, 22190 cfm) 507

no equipment (FS23, 2000 cfm) 508

material transfer (FS02, 14000 cfm) 510



514

moulder ‐ 3, tenoner ‐ 2 (FS22, 60000 cfm) 515

saw ‐ 4 (FS15, 35200 cfm) 518

tenoner ‐ 1, saw ‐ 6, jointer ‐ 1 (FS08, 28440 cfm) 521

material transfer (FS10) 524



moulder ‐ 3 (FS29, 110370 cfm) 527



moulder ‐ 1, tenoner ‐ 1, drill ‐ 1, material transfer (FS06, 35000 cfm)

548

moulder ‐ 3, tenoner ‐ 2, material transfer (FS09, 48000 cfm)

553


saw ‐ 6, jointer ‐ 1, planer ‐ 1, sander ‐ 1 (FS16, 35200 cfm)

557



570

moulder ‐ 4, tenoners ‐ 4, saw ‐ 4, drill ‐ 1 (FS24, 52350 cfm)

575

moulder ‐ 2, tenoner ‐ 2, (FS27, 52350 cfm) 577

moulder ‐ 3, tenoner ‐ 2, saw ‐ 4, router ‐ 2, sander ‐ 3, denibber ‐ 2, material transfer (FS30, 71630 cfm)

579

moulder ‐ 1, tenoner ‐ 2, saw ‐ 8, router ‐ 9, drill ‐ 4, sander ‐ 2 (FS31, 71630 cfm)

583

tenoner ‐ 4, saw ‐ 8, router ‐ 2 (FS32, 71630 cfm) 588



Page 3 of 6



Number


tenoners ‐ 2, router ‐ 3, drill ‐ 2, sander ‐ 1, material transfer (FS40, 22190 cfm)

595

saw ‐ 3 (FS37, 15400 cfm) 599

Vented internally to Control Equipment 004

Area 5A‐2 (87750 cfm) 603

Area 13S‐1 (42108 cfm) 604

Area 17‐2 (115675 cfm) 605

Area 41‐1 (27000 cfm) 606

Area 43‐2 (24000 cfm) 607

New Indoor Area (250000) 608

004 Vinyl and Other Plastic or Composite Processes

Sheet line 51 C1981 225



Vacuum Former 3 C1978 224











Shuttle Vacuum Former 13 645

Transfer Line 25 C1883 (Profile Extruder) 200








Solid Line 18 C3314 (Profile Extruder) 210









Page 4 of 6



Number


Transfer Line 22 (Doors) C0290 (Profile Extruder) 241












Profile Extruder 01 C6002 539


Composite Extruder SL04 C3985 541

Composite Extruder SL05 C4683 542

SL39 Pelletizer C2054 255

Composite Compounder 543

Silo Bin Vent 268

Silo Bin Vent 269

Silo Bin Vent 271

Vinyl Grinder 20ZZ57 267





Blender 270

Brabender Q/A Extruder/Bowl (“add‐on”) 274

Developmental Composite Extruder RD04 C5720 (“add‐on”)

613

Developmental Composite Extruder RD05 C7313 (“add‐on”)

614

Wood/Vinyl Separator (C1059) 629

005 Combustion Sources

Boiler 9 008

Boiler 10 009

Wood/Gas Boiler 11 620

Wood/Gas Boiler 12 621

Gas/Oil Backup Boiler 13 622





Page 5 of 6



Number


Regenerative Thermal Oxidizer Burners 612

Eastside Generator 001

Westside Generator 002

Emergency Fire Pump 006

Bldg. 45 Emergency Generator 015

Bldg. 14S Emergency Generator 010

Bldg. 46 Emergency Generator 016

006 Miscellaneous VOC Sources

Tracked Materials CC120/121/122/123/520 (Adhesive/Glaze Application)

300

CC201 (Adhesive/Glaze Application ) 301

CC221/222/225 (Adhesive/Glaze Application ) 304








CC521/527 (Adhesive/Glaze Application ) 321



DHWP Mechanics Parts Washer 402

PSC/A Mechanics Parts Washer 403

Doors Mechanics Parts Washer 404

DHWP Milling Mechanics Parts Washer 405

Machine Builders Parts Washer 406

Machine Shop Parts Washer 407

Plumbers Parts Washer 409

Maintenance Mechanics Parts Washer 410

Garage Parts Washer 411

Vinyl Mechanics Parts Washer 420

East Rip Kerosene 516

Doors WC81 Parts Washer 615

Garage Parts Washer South 616

Garage Parts Washer North 617

Development Lab Parts Washer 618

CC527/529/533/534 (Adhesive/Glaze Application)

619

Annual Materials none at this time

Insignificant Materials Model Shop NA

Printing Press NA


Page 6 of 6



Number

Laboratory NA

007 Other Miscellaneous Sources none at this time

008 Wood and Ash Silos Wood Silo (FS42) 623

ATTACHMENT E List of Milling Control Equipment

Page 1 of 1

Andersen Filter System Number

Description Manufacturer and Model Number Air Delta CE Number

FS19 Low Temperature Fabric Filter Donaldson, 376RF10 001


FS17 Low Temperature Fabric Filter Carter Day, 376RF10 003




FS35 Low Temperature Fabric Filter MAC Environmental, 144RPT364‐364 007

FS05 Low Temperature Fabric Filter MAC Filter, 144MCF153‐153 008








FS22 Low Temperature Fabric Filter MAC Filter, 144MC416‐416 016





FS10 Low Temperature Fabric Filter Carter Day, LRJ48 021


FS12 Low Temperature Fabric Filter Carter Day, LRJ48 023







FS38 Low Temperature Fabric Filter MAC Environmental, 54AV536 055

FS39 Low Temperature Fabric Filter MAC Environmental, 144MCF255 056

FS40 Low Temperature Fabric Filter MAC Environmental, 144MCF153 057

FS37 Low Temperature Fabric Filter Donaldson, 4DFT32 078

NA Low Temperature Fabric Filters Various 079





NA Low Temperature Fabric Filters to be determined 084

ATTACHMENT F Airflow Verification Plan

Page 1 of 5

Table of Contents

1.0 Introduction 2

2.0 Externally Vented Filter Systems Record Keeping 2

3.0 Airflow Testing of Filter Systems 4

3.1 Internal Airflow Testing 3.1.a Triggers 3.1.b Methods 3.1.c Protocol

3.2 External Airflow Testing 3.2.a Triggers 3.2.b Methods 3.2.c Protocol

4.0 Testing Schedule 5

5.0 Corrective Actions for Non‐Compliant Findings 5


Page 2 of 5

1.0 Introduction: Andersen Corporations Bayport facility operates baghouse filter systems to control particulate emissions from milling operations. Wood dust is collected from the milling operations and conveyed to various areas in the facility utilizing fans, blowers, and pumps. Andersen’s XL Permit requires that an Airflow Verification Plan be developed and submitted to the Minnesota Pollution Control Agency (MPCA) for review and approval within 12 months from permit issuance. The purpose of the plan is to show that the actual airflow for each filter system does not exceed the permitted airflows and to validate the existing primary compliance methods. The plan shall establish a schedule for verifying the actual airflow through the filter systems and shall specify the verification method. At a minimum the plan shall include the following five elements as defined by the XL Permit, Control Equipment Group 003, Externally Vented Milling Fabric Filter Systems: 1. Specify a method for testing airflows. 2. Require initial airflow verification for each filter system to be completed within 365 days of approval of the

Plan; 3. Require that records of equipment connected to systems and determination of related airflow be

maintained; 4. Require that if initial testing indicates higher airflows than would be derived from equipment records, the

permittee must document the reasons for the identified differences and appropriate action must be taken; and

5. Specify criteria that trigger re‐testing of airflows for any given system. A filter system airflow test plan dated August 3, 2007 was approved by the MPCA on September 13, 2007. Airflow testing began on September 4, 2007, and was completed on October 3, 2007. Corrective actions for systems that did not meet airflow limits were implemented and completed. An amendment was submitted for additional airflow on filter systems that could not be modified to meet airflow limits. 2.0 Externally Vented Filter System Record Keeping: Andersen maintains a list of each filter system identified by an emission unit number, a stack vent number, and an Andersen asset number. Milling equipment is recorded under each filter system listing a description of the milling equipment, associated asset number, and the calculated airflow of the milling equipment. This is consistent with the XL Permit Process 003, Milling Equipment, Monitoring and Recordkeeping requirements. Milling equipment airflow is determined by adding together the area of each hood drop and multiplying that area in square feet by the recommended conveying velocity of 4,500 feet per minute. (The industry recommended conveying velocity in the duct from the milling equipment to the baghouse for heavy wood dust loading is 4,000 to 5,000 fpm.)


Page 3 of 5

Table 1 illustrates the airflow for varying sizes of ductwork. Values in the table are determined by using the equation πr2 (sq ft) * velocity (ft/min) = cfm. Using a 12 inch duct the cfm is calculated as follows:

3.14* 0.52 ft *4,500 ft/min=3532 cfm

Table 1

Duct Diameter (inches)

Airflow (CFM)

2 99

3 221

4 393

5 614

6 884

7 1,203

8 1,571

9 1,988

10 2,456

12 3,532

14 4,810

15 5,500

16 6,280

24 14,137

Reference: Technical Hand Book: Manufacturers of Dust Collectors and Air Pollution Control Equipment The calculated airflow is applied to each piece of milling equipment and summed to determine the total airflow to the filter system. Table 2 below illustrates how the total calculated airflow is determined for a hypothetical Filter System. Table 2

Description Asset Number Number & Size of Ports

Airflow (cfm) Total Calculated

CFM

Permitted Airflow (cfm)

Rip Saw C0667 2‐6”, 2‐8”, 1‐9” 6,898

Cut Off Saw C6950 1‐4”, 1‐6” 1,277

Cut Off Saw C6951 1‐4”, 1‐6” 1,277

Salvage Saw C0333 1‐4” 393 9845 52,000

Updates to the filter system equipment list are made through Air Permit Modification Forms and periodic filter system audits. Andersen engineers are required to submit an Air Permit Modification Form when milling equipment, fans, pumps or blowers are removed, added, or relocated between filter systems. Air Permit Modifications Forms are used to maintain the externally vented filter system equipment list. In addition to the Air Permit Modification forms, milling equipment audits for the filter systems are performed periodically. During the audits an inventory of milling equipment and conveying operations associated with each filter system is performed. The inventory results are used to update a filter system master list where airflow calculations are performed to ensure calculated airflow is less than permitted filter system airflow limits. Filter system audits are performed by Andersen facility maintenance group approximately every 12‐18 months.


Page 4 of 5

3.0 Airflow Testing of Filter Systems:

3.1 Internal Airflow Testing

3.1.a Triggers

Internal airflow tests (i.e. testing conducted by Andersen personnel) will be performed on a filter system when:

1) Calculated airflow checks for an equipment change determine that there is an increase such that the

airflow after the change will be 90% or greater of the permitted airflow for a given filter system.

2) The airflow needed for an added piece of milling equipment is more than 30% of the permitted airflow for the associated filter system.

A modification involving 30% or more of filter systems calculated airflow would represent a large project which could impact filter system airflow. Projects with a calculated airflow of less than 30% of total airflow do not have the potential to impact the filter systems enough to exceed permitted limits unless that filter system is at 90% or greater of its permitted capacity.

This is because filter system airflow is determined by the cumulative effects of the individual components; hoods, hose, duct, fans and baghouse joined together to form the system. The fans/blowers/pumps that move the air and product through the system are selected based on the static pressure of the system. Once the fan/blower/pump size is determined the airflow through the filter system remains relatively constant unless there is a significant change to the system static pressure or a fan/blower/pump is modified.

3.1.b Methods

Internal airflow checks will be taken using a pitot tube. All measurements will be documented.

3.1.c Protocol

Test results and supporting documentation will be kept on site and available for inspections if required.

3.2 External Airflow Testing

3.2.a Triggers

External testing (i.e. testing performed by a third party) will be conducted under the following conditions:

1) When the internal airflow testing indicates that filter system airflows are 90% or greater of the permitted airflow or;

2) When the calculated airflow is equal to or greater than the permitted airflow.

3.2.b Methods


Page 5 of 5

EPA 40 CFR Part 60 Appendix A; Method 1 for test port location and Method 2 for air flow rates will be utilized for external filter system airflow testing performed by a third party

3.2.c Protocol

Tests required under this section will follow the requirements of Minn.R.7017.2001 to 7007.2060 (the performance test rules) which contain the notification, reporting, and quality assurance requirements for performance testing. In summary Minn R.7017.200 to 7007.260 requires the following:

Submit a complete test plan to the MPCA, postmarked at least 30 days in advance of the scheduled test date. Test plan examples are available on the MPCA Web site at http://www.pca.state.mn.us/air/ptest‐planning.html.

• Arrange a pretest meeting with MPCA staff. The meeting should be held at least seven days before the scheduled test date. The facility is responsible for coordinating the meeting and attaining the necessary approval prior to the test.

• Submit a complete test report to the MPCA no later than 45 days after completing the test. • Submit a compact disc or microfiche copy of the test report to the MPCA, no later than 105 days after completing the test.

4.0 Testing Schedule As specified in ANDXL‐001 some filter systems are tested annually for PM/PM10 compliance. Testing protocol requires that airflow is measured during PM/PM10 compliance testing. EPA Method 2 is utilized for measuring airflow during these compliance tests. Testing protocol meets the requirements listed above. Under the XL permit, Andersen is required to test two filter systems every year. The filter system compliance testing specified in the XL permit will be followed for airflow verification as well as PM/PM10 compliance testing. In addition to the annual compliance tests, airflow checks on externally vented filter systems will be performed every five years by a third party. Systems previously tested within the five year time frame are not required to be tested again. 5.0 Corrective Action for Non‐Compliant Findings If initial internal testing indicates a higher airflow than the permitted airflow, Andersen will investigate the reasons for such an occurrence. Appropriate corrective action will be taken, which may include re‐verification of the filter system airflow, verification of specific equipment airflows, removal or modification of fans or pumps and/or rerouting of airflows to a filter system with existing capacity. Actions taken will be documented and retained. If airflow has been re‐verified and it continues to exceed the permitted limit, Andersen will report this deviation to the MPCA according to ANDXL‐001.

ATTACHMENT G Tanks Summary

Page 1 of 1

Tanks greater than 2000 gallons

Tank ID Air Delta TK Number Product Capacity (gallons)

T7 Overflow 505 vault 8,000

T9 Overflow diptank 10,000

T10 Overflow diptank 10,000

T11 Milltreat F 10,000


T19 006 PILT 8,000

T20 007 VM&P Naphtha 8,000

T23 Overflow Building 46 12,000


T25 008 Waterborne Milltreat 8,000

T26 005 Minerial Spirits 8,000

T27 009 Woodlife F 8,000

T28 010 IBA/MAK 8,000

T29 011 Waterborne Milltreat Conc 8,000


A1 Stabilizer oil 5,000

A2 Propane 10,000

A30 Waterborne Milltreat Conc 4,500

A33 Fuel Oil 10,000

A34 Diesel 3,000

Total 163,000

Tanks less than 2000 gallons

Tank ID Air Delta TK Number Product Capacity (gallons)

T31 Overflow Building 14S 1,000

A3 Diesel 260

A4 Diesel 300

A7 Waterborne Milltreat 540

A8 Diesel W. Emerg Gen 500

A9 Diesel E.Emerg Gen 580

A12 Waste Oil 240

A13 Waste Oil 360

A14 Engine Coolant 150

A15 Kerosene 110

A16 003 Kerosene 240

A17 004 Kerosene 240

A18 Kerosene 110

A19 Kerosene 110

A20 Kerosene 240

A21 Kerosene 110

A31 Waterborne Milltreat RTU 1,500

Total 6,590

Tanks ‐ 15,000 gallons

Tank ID Product Capacity (gallons)

T16 VM&P Naphtha 15,000


APPENDIX 1 Future PM10 Air Dispersion Modeling

Page 1 of 2

The Permittee shall use the following criteria to determine the need for air dispersion modeling of proposed projects affecting PM10 emission rates or stack parameters. Stack Parameter Changes: The Permittee does not need to conduct dispersion modeling to evaluate proposed stack parameter changes that would likely improve dispersion (e.g., raising stack heights, increasing airflow, etc.). The Permittee shall conduct modeling using Tier 1 as detailed below for proposed stack parameter changes that could negatively affect dispersion characteristics (e.g., lowering stack heights, decreasing stack velocities, etc.). Emissions Changes: The Permittee shall conduct modeling using Tier 1, 2, or 3 as detailed below for net emission rate changes greater than or equal to 0.1 lbs/hr. Net emission changes less than 0.1 lbs/hr do not require modeling analyses. When determining the level of modeling that is required, the Permittee shall determine the net emissions change using the following criteria:

Net emissions changes from new units or modifications shall be considered at permitted rates. All rate or parameter changes related to a single project shall be treated together. Changes to sources limited under the vinyl throughput caps are not subject to the PM10 modeling applicability tests. Any such changes shall be included whenever the impact of the entire facility is modeled.

Determining the Level of Modeling Required. For projects causing net emission rate changes greater than 0.1 lb/hr or where the proposed stack parameter changes could negatively affect dispersion, the Permittee shall first model only emissions or stack changes from the proposed modification (Tier 1), unless the Permittee chooses to do Tier 2 or 3 modeling as described below. Projects with highest 6th‐high 24‐hour impacts less than 1 ug/m3 and maximum annual impacts less than 0.2 ug/m3 will not require further action and need not be submitted to the MPCA. The Permittee shall retain records of the analysis: the Permittee is not required to submit the analysis to the MPCA. The Permittee may use Tiers 2 or 3 in lieu of Tier 1 at its discretion. If modeled impacts from the project in question are greater than the levels specified in Tier 1 or if Tier 1 was not used, the Permittee shall model the impacts of all facility PM10 sources, including all cumulative changes from any previous modeling work (Tier 2), unless the Permittee chooses to do Tier 3 modeling as described below. The Permittee shall compare the predicted impacts to the predicted concentrations in the updated MPCA‐approved modeling submittal received December 22, 2005. The relevant concentrations are those attributable to the Permittee only and not any nearby sources of PM10. The results of that analysis were highest 6

th‐high 24‐hour concentration of 86.9 ug/m3 and maximum annual concentration of 20.2 ug/m3. Predicted impacts that do not exceed the specified levels by more than 1 ug/m3 on a 24‐hour basis and 0.2 ug/m3 on an annual basis will not require additional modeling analyses. The completed modeling results shall be submitted to MPCA prior to making any proposed change; however, MPCA approval of the modeling analysis is not required prior to making the change. The Permittee may use Tier 3 in lieu of Tier 2 at its discretion. Tier 3 modeling is required for any increases in ambient impact greater than 1 ug/m3 on a 24‐hour basis and 0.2 ug/m3 on an annual basis (as compared to the Permittee’s ambient impact in the January 10, 2005 submittal) or if the Permittee chose not to perform the required Tier 1 or 2 modeling where allowed. In that case, the Permittee shall model the impacts of the Facility along with those of the neighboring Allen S. King electric generating plant. The Permittee must demonstrate compliance with the PM10 NAAQS/MAAQS and PSD increment prior to proceeding with any project requiring Tier 3 modeling. The results of the analysis shall be

APPENDIX 1 Future PM10 Air Dispersion Modeling

Page 2 of 2

submitted to MPCA prior to making any proposed change; however, MPCA approval of the modeling analysis is not required prior to making the change. In addition to individual projects triggering the modeling requirements, the Permittee shall track cumulative changes and perform modeling analyses as described above when the total net increase reaches 1 lb/hr. The total net increase shall be measured from the last full modeling analysis of the Facility. The Permittee shall complete a full modeling analysis of the Facility and the neighboring Allen S. King electric generating plant at least every 3 years unless no facility changes were completed during the time period. That analysis shall be submitted to the MPCA.

of 64

APPENDIX 2 PM10 Modeled Parameters

ISCST3

Point Sources

Source Type

Stack InsideDiameter

[m] Release Height

[m] Emission

Rate [g/s]

BaseElevation (Optional)

Y Coordinate[m]

X Coordinate[m]

Source ID

Gas ExitTemp.

[K] Gas ExitVelocity

[m/s]

AC_SV001 517633.44 4985640.06 209.80 7.30 550.00 17.49 0.15POINT Eastside Gen

0.02140

AC_SV002 517443.55 4985557.39 212.30 6.40 497.00 30.97 0.15POINT Westside Gen

0.03280

AC_SV006 517529.53 4985524.34 210.30 7.50 464.00 118.79 0.10POINT Emer. Fire Pump

0.00400

AC_SV008 517638.21 4984752.73 210.90 11.20 464.00 7.48 0.63POINT Boiler 9

0.01400

AC_SV009 517633.21 4984751.38 210.90 11.20 464.00 7.48 0.63POINT Boiler 10

0.01400

AC_SV010 517643.02 4984757.15 210.90 10.30 464.00 51.74 0.15POINT Emer. Generator

0.00100


0.00400


0.00100

AC_SV136 517495.57 4985727.69 210.30 14.60 297.00 10.35 0.61POINT Paintline 1, Silo 1

0.04130


0.04130


0.04130


0.04130

03/09/2011

of 64

ISCST3

Source Type


[m] Release Height

[m] Emission

Rate [g/s]


Y Coordinate[m]

X Coordinate[m]

Source ID

Gas ExitTemp.


[m/s]


0.03150


0.03150


0.03150


0.03150


0.03150


0.03150


0.03150


0.03150

AC_SV125 517492.26 4985714.87 210.30 13.40 297.00 7.45 0.76POINT Flexiframe Booth 1

0.05200

AC_SV127 517491.38 4985714.62 210.30 13.40 297.00 5.17 0.91POINT Flexiframe Booth 2

0.05200

AC_SV122 517498.75 4985693.28 210.30 12.10 297.00 6.73 0.76POINT Longlength Booth

0.02650

AC_SV126 517507.10 4985675.14 210.30 12.60 297.00 11.64 0.61POINT Endspray Booth

0.02650

AC_SV560 517464.43 4985845.55 210.30 19.00 297.00 9.70 0.61POINT Paint Booth

0.00E+0

03/09/2011

of 64

ISCST3

Source Type


[m] Release Height

[m] Emission

Rate [g/s]


Y Coordinate[m]

X Coordinate[m]

Source ID

Gas ExitTemp.


[m/s]

AC_SV556 517596.45 4984713.19 210.90 12.50 297.00 4.65 0.84POINT R&D Paint Booth

0.00300

AC_SV148 517317.71 4985739.25 212.70 34.90 382.00 9.05 1.52POINT SV148

0.00E+0

AC_SV200 517615.68 4985494.74 210.30 11.40 305.00 4.31 0.46POINT TL21, TL25, TL26

0.01880

AC_SV201 517615.77 4985534.87 210.30 12.50 305.00 9.70 0.61POINT TL01, TL02

0.00625


0.01880


0.02076

AC_SV205 517615.10 4985449.20 210.30 13.40 305.00 8.62 0.81POINT PE01, TL12, TL15, TL16, TL19, TL20

0.03330

AC_SV206 517577.40 4985458.90 210.30 15.60 305.00 8.19 0.81POINT PE17, PE02, SL03

0.01400

AC_SV207 517588.40 4985421.70 210.30 15.60 305.00 8.19 0.81POINT SL04, SL05, SL06

0.02800

AC_SV208 517477.79 4985816.96 210.30 17.00 319.00 9.31 0.76POINT VF3

0.06667

AC_SV209 517467.52 4985781.52 210.30 15.80 305.00 16.56 0.76POINT SL51, SL53, SL54

0.07380

AC_SV210 517464.31 4985813.11 210.30 16.30 319.00 8.59 0.76POINT VF1

0.05710

AC_SV211 517480.82 4985817.88 210.30 15.90 319.00 12.42 0.76POINT VF2

0.06667

03/09/2011

of 64

ISCST3

Source Type


[m] Release Height

[m] Emission

Rate [g/s]


Y Coordinate[m]

X Coordinate[m]

Source ID

Gas ExitTemp.


[m/s]

AC_SV212 517501.92 4985789.78 210.30 13.70 319.00 9.89 0.71POINT VF5

0.05710

AC_SV213 517511.98 4985793.29 210.30 14.90 305.00 7.28 0.61POINT SL32, SL34, SL35, SL36

0.00485

AC_SV215 517498.87 4985800.47 210.30 14.90 319.00 12.42 0.76POINT VF4

0.05710

AC_SV217 517518.87 4985771.49 210.30 14.90 319.00 4.85 0.61POINT VF12

0.05710


0.01880

AC_SV219 517300.66 4985697.89 212.60 18.80 305.00 2.48 0.91POINT PE33, TL34, TL35

0.01250

AC_SV220 517307.62 4985680.54 212.60 18.80 305.00 2.32 0.91POINT SL42, SL43, TL36, TL37

0.02220

AC_SV224 517542.27 4985811.00 210.30 13.50 300.00 9.70 0.61POINT SL39

0.02940

AC_SV225 517555.87 4985763.38 210.30 15.00 319.00 12.42 0.76POINT VF10

0.05710

AC_SV226 517538.33 4985819.24 210.30 11.90 300.00 15.20 0.30POINT Pulverizer

0.00E+0

AC_SV227 517545.60 4985799.32 210.30 15.00 319.00 12.40 0.66POINT VF6

0.05710

AC_SV228 517548.47 4985789.40 210.30 15.00 319.00 12.40 0.66POINT VF7

0.05710

AC_SV229 517550.09 4985783.61 210.30 15.00 319.00 12.42 0.76POINT VF8

0.05710

03/09/2011

of 64

ISCST3

Source Type


[m] Release Height

[m] Emission

Rate [g/s]


Y Coordinate[m]

X Coordinate[m]

Source ID

Gas ExitTemp.


[m/s]

AC_SV230 517553.01 4985773.38 210.30 15.00 319.00 12.42 0.76POINT VF9

0.05710

AC_SV231 517656.55 4985528.36 210.30 13.00 305.00 3.11 0.76POINT TL07, TL08, TL09, TL22

0.01874

AC_SV232 517628.62 4985487.46 210.30 13.00 300.00 8.62 0.46POINT Vinyl Grinder 20ZZ72

0.01470


0.02870

AC_SV234 517532.18 4985837.18 209.80 20.50 300.00 0.00 0.25POINT Silo Bin Vent

0.00730


0.00730

AC_SV236 517519.46 4985827.61 210.30 13.80 300.00 2.32 0.36POINT Brabender Q/A Extruder/Bowl

0.00E+0


0.00730

AC_SV240 517516.99 4985843.78 210.30 16.50 300.00 10.78 0.30POINT Blender

0.02110


0.02870


0.02870


0.02870

AC_SV245 517324.58 4985965.08 210.20 10.10 322.00 0.00 0.69POINT Fibrex Compounder

0.05246

03/09/2011

of 64

ISCST3

Source Type


[m] Release Height

[m] Emission

Rate [g/s]


Y Coordinate[m]

X Coordinate[m]

Source ID

Gas ExitTemp.


[m/s]

AC_SV544 517483.00 4985818.50 210.31 16.60 319.00 14.55 0.61POINT VF11

0.00E+0

AC_SV401 517537.30 4985574.40 210.30 15.90 297.00 7.28 0.61POINT Maintenance Paint Booth

0.00150

AC_SV402 517536.90 4985576.20 210.30 15.90 297.00 7.28 0.61POINT Maintenance Paint Booth

0.00150

AC_SV500 517559.45 4985505.52 210.30 19.00 294.00 11.90 1.52POINT FS19

0.14920

AC_SV501 517563.02 4985511.89 210.30 17.20 294.00 13.83 1.02POINT FS20 - 1

0.07780

AC_SV502 517560.67 4985511.22 210.30 17.20 294.00 13.83 1.02POINT FS20 - 2

0.07780

AC_SV503 517571.27 4985520.63 210.30 21.10 294.00 14.90 1.52POINT FS17

0.18660

AC_SV504 517589.55 4985548.65 210.30 17.60 294.00 14.05 1.43POINT FS09

0.15550

AC_SV505 517513.75 4985538.69 210.30 15.40 294.00 23.52 0.67POINT FS26 - 1

0.05700

AC_SV506 517516.36 4985537.09 210.30 15.40 294.00 23.52 0.67POINT FS26 - 2

0.05700

AC_SV507 517508.56 4985553.34 210.30 19.40 294.00 16.54 1.17POINT FS18 - 1

0.12150

AC_SV508 517506.74 4985552.88 210.30 19.40 294.00 16.54 1.17POINT FS18 - 2

0.12150

AC_SV509 517537.60 4985496.59 210.30 18.40 294.00 13.72 1.52POINT FS35

0.17190

03/09/2011

of 64

ISCST3

Source Type


[m] Release Height

[m] Emission

Rate [g/s]


Y Coordinate[m]

X Coordinate[m]

Source ID

Gas ExitTemp.


[m/s]

AC_SV510 517557.90 4985454.80 210.30 22.90 294.00 22.96 0.76POINT FS05

0.07190

AC_SV511 517528.27 4985564.24 210.30 14.90 294.00 13.19 0.76POINT FS23

0.04099

AC_SV512 517539.09 4985520.17 210.30 17.60 294.00 8.75 1.01POINT FS13

0.04860

AC_SV513 517520.38 4985533.87 210.30 16.90 294.00 12.51 1.07POINT FS02

0.07686

AC_SV514 517525.00 4985572.37 210.30 20.10 294.00 13.04 1.27POINT FS06 - 1

0.11350

AC_SV516 517561.74 4985549.79 210.30 13.90 294.00 20.86 0.76POINT FS21 - 1

0.06480

AC_SV518 517571.34 4985573.62 210.30 17.90 294.00 18.59 1.07POINT FS16

0.11400

AC_SV519 517552.82 4985568.80 210.30 25.00 294.00 19.62 1.17POINT FS04

0.14380

AC_SV520 517603.74 4985491.33 210.30 19.10 294.00 31.05 0.76POINT FS22 - 1

0.09720

AC_SV521 517597.97 4985489.35 210.30 19.10 294.00 31.05 0.76POINT FS22 - 1

0.09720

AC_SV522 517568.41 4985591.75 210.30 15.20 294.00 14.23 1.22POINT FS15

0.11400

AC_SV523 517607.73 4985625.79 210.30 16.60 294.00 18.19 0.97POINT FS08

0.09210

AC_SV524 517552.75 4985681.23 210.30 17.40 294.00 24.73 0.91POINT FS24 - 1

0.12400

03/09/2011

of 64

ISCST3

Source Type


[m] Release Height

[m] Emission

Rate [g/s]


Y Coordinate[m]

X Coordinate[m]

Source ID

Gas ExitTemp.


[m/s]

AC_SV525 517553.47 4985678.63 210.30 17.70 294.00 24.65 0.66POINT FS24 - 2

0.06500

AC_SV526 517519.91 4985666.80 210.30 17.40 294.00 24.30 0.91POINT FS27 - 1

0.11160

AC_SV527 517525.16 4985676.30 210.30 15.90 294.00 24.30 0.66POINT FS27 - 2

0.05820

AC_SV528 517396.69 4985914.86 210.20 14.50 294.00 0.00 0.34POINT FS10

0.00410

AC_SV529 517397.54 4985920.79 210.20 21.90 294.00 0.00 0.46POINT FS11

0.00570

AC_SV530 517392.67 4985920.24 210.20 20.60 294.00 0.00 0.84POINT FS12

0.01000

AC_SV531 517312.51 4985668.66 212.60 24.80 294.00 24.30 1.17POINT FS29 - 1

0.17880

AC_SV532 517322.56 4985643.89 212.60 24.80 294.00 24.30 1.17POINT FS29 - 2

0.17880

AC_SV533 517325.93 4985676.98 212.60 25.50 294.00 21.28 1.42POINT FS30

0.23210

AC_SV534 517331.01 4985682.04 212.60 24.90 294.00 22.89 1.37POINT FS31

0.23210

AC_SV535 517317.59 4985678.99 212.60 23.20 294.00 18.94 0.81POINT FS32 - 1

0.06750

AC_SV536 517322.45 4985639.63 212.60 23.20 294.00 18.94 1.27POINT FS32 - 2

0.16480

AC_SV537 517359.65 4985932.63 210.20 23.00 294.00 0.00 1.03POINT FS25

0.04540

03/09/2011

of 64

ISCST3

Source Type


[m] Release Height

[m] Emission

Rate [g/s]


Y Coordinate[m]

X Coordinate[m]

Source ID

Gas ExitTemp.


[m/s]

AC_SV538 517366.62 4985931.09 210.20 13.70 294.00 0.00 0.83POINT FS28

0.03240

AC_SV539 517375.50 4985931.80 210.20 7.60 294.00 0.00 0.34POINT FS14

0.01300

AC_SV540 517352.60 4985936.65 210.20 17.30 294.00 0.00 0.40POINT FS38

0.00870

AC_SV541 517355.91 4985932.31 210.20 11.00 294.00 16.28 1.17POINT FS39

0.11980

AC_SV542 517327.94 4985644.20 212.60 19.70 294.00 28.18 0.69POINT FS40

0.07190

AC_SV547 517585.90 4984826.40 210.92 11.20 294.00 8.46 1.02POINT FS37

0.04994

AC_SV548 517483.74 4985723.26 210.30 14.90 305.00 2.44 0.46POINT SL33, SL37

0.00647

AC_SV557 517314.80 4985719.40 212.60 35.10 339.00 14.43 1.12POINT RTO

0.00800

AC_SV558 517594.18 4984774.97 210.92 10.60 294.00 5.48 0.41POINT RD04

0.00269

AC_SV559 517590.71 4984774.97 210.92 10.60 294.00 5.48 0.41POINT RD05

0.00269

AC_SV561 517301.85 4985922.12 210.20 30.48 450.00 7.76 1.52POINT Proposed Wood Boiler

0.65577

AC_SV562 517311.95 4985931.78 210.20 30.48 478.00 3.88 1.52POINT Proposed Nat. Gas Boiler

0.14350

AC_SV563 517327.45 4985891.02 210.20 15.24 294.00 12.94 0.30POINT Wood Silo

0.01081

03/09/2011

of 64

ISCST3

Source Type


[m] Release Height

[m] Emission

Rate [g/s]


Y Coordinate[m]

X Coordinate[m]

Source ID

Gas ExitTemp.


[m/s]

AC_SV564 517318.53 4985887.84 210.20 12.19 294.00 6.47 0.30POINT Ash Silo

0.00E+0

AC_SV566 517366.57 4985929.78 210.20 13.70 294.00 11.37 0.83POINT FS41

0.04216

AC_SV567 517630.72 4984627.59 210.90 3.50 394.00 23.83 0.13POINT Vinyl Oven

0.00020

AC_SV570 517622.76 4984655.07 210.90 12.40 297.00 10.19 0.41POINT R&D Booth

0.00E+0

AC_SV573 517684.71 4984469.33 210.90 13.72 297.00 9.64 0.41POINT Interior Lineal Booth 1

0.04700

AC_SV575 517684.80 4984477.50 210.90 13.72 297.00 9.64 0.41POINT Interior Lineal Booth 2

0.04700

AC_SV577 517289.40 4985979.00 211.00 7.62 294.00 26.41 1.17POINT FS43

0.19400

AC_SV578 517317.30 4985759.10 212.70 20.90 297.00 14.23 0.61POINT Manual Door Booth

0.03400

AC_SV579 517337.30 4985998.20 210.30 10.67 300.00 12.81 0.51POINT Pelletizer_Compounder

0.02270

03/09/2011

of 64

ISCST3

Volume Sources Initial

Vertical Dim. [m]

InitialLateral

Dim. [m] BuildingHeight

[m] Lengthof Side

[m] Source Type

Source ID

X Coordinate[m]

Y Coordinate[m]


EmissionRate [g/s]

ReleaseHeight

[m]

VOLUME 517118.92 4985796.03 212.75 1.50 30.01 6.98 1.39AC_VL001 Surface-Based0.00064













03/09/2011