Intent to Issue Air Emission Permit to Mid Continent ... Permit - 083000… · ACTV5: All IA's...

Draft Air Individual Permit Part 70 Reissuance

08300023-101 Permittee: Mid Continent Cabinetry

Facility name: Mid Continent Cabinetry 67 E 2nd St N Cottonwood, MN 56229 Lyon County

Expiration date: [Permit expiration date TBD] * All Title I Conditions do not expire Part 70 Reissuance: [Permit issuance date TBD] Permit characteristics: Federal; Part 70/ Limits to avoid NSR; Limits to avoid NSR The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the Permit Applications Table. This permit reissuance supersedes Air Emission Permit No. 08300023- 003 and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in the permit. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR § 52.1220 and as such are enforceable by EPA Administrator or citizens under the Clean Air Act.

Signature: [ ] This document has been electronically signed. for the Minnesota Pollution Control Agency

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

Table of Contents

Page

1. Permit applications table ............................................................................................................................................. 3 2. Where to send submittals ............................................................................................................................................ 4 3. Facility description ....................................................................................................................................................... 5 4. Summary of subject items ........................................................................................................................................... 6 5. Limits and other requirements .................................................................................................................................. 14 6. Submittal/action requirements ................................................................................................................................. 45 7. Appendices ................................................................................................................................................................. 46

Appendix A. Insignificant Activities and General Applicable Requirements ............................................................ 46 Appendix B. Maximum Materials Content and Usage Rates ................................................................................... 47 Appendix C. Work Practice Implementation Plan (WPIP) ........................................................................................ 48

Permit issued: [month day, year] 08300023-101 Permit expires: [month day, year] of 49

1. Permit applications table

Subsequent permit applications: Title description Application receipt date Action number Part 70 Reissuance 12/07/2012, with supplemental

information received on 02/10/17 08300023-101

Minor Amendment 06/05/2013 08300023-101


2. Where to send submittals

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

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by Minn. R. 7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition.

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460

Send any application for a permit or permit amendment to:

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

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

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

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

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

Or Email a signed and scanned PDF copy to: [email protected] (for submittals related to stack testing) [email protected] (for other compliance submittals) (See complete email instructions in “Routine Air Report Instructions Letter” at http://www.pca.state.mn.us/nwqh472.)

mailto:[email protected]

mailto:[email protected]

http://www.pca.state.mn.us/nwqh472


3. Facility description

The Mid Continent Cabinetry (Facility) is located at 67 E 2nd St N in Cottonwood, MN, Lyon County, Minnesota. Mid Continent Cabinetry operates a stationary wood kitchen cabinetry manufacturing facility located in Cottonwood, Minnesota. The facility consists of fourteen spray booths with particulate control consisting of high efficiency filters. The facility also has three drying ovens, a laminator, and many pieces of woodworking equipment. Three fabric filters control particulate emissions from several pieces of woodworking equipment, and many other woodworking units are uncontrolled. There are also several activities that qualify as insignificant under Minnesota Rules. These are listed in Appendix A of the permit. The primary pollutants emitted from the existing facility are volatile organic compounds (VOCs), particulate matter, particulate matter less than 10 microns, and particulate matter less than 2.5 microns (PM/PM10/PM2.5), and hazardous air pollutants (HAPs) with lesser emissions from the combustion of natural gas.


4. Summary of subject items

SI ID: Description

Relationship Type

Related SI ID: Description

ACTV5: All IA's COMG10: Controlled Woodworking Units with Hood Capture

has members

EQUI2, EQUI3, EQUI4, EQUI6, EQUI8, EQUI9, EQUI10, EQUI13, EQUI27, EQUI42, EQUI43, EQUI44, EQUI51, EQUI53, EQUI58, EQUI60, EQUI61, EQUI63, EQUI66, EQUI68

COMG11: Controlled Woodworking Units with Total Enclosure

has members

EQUI1, EQUI12, EQUI14, EQUI30, EQUI35, EQUI54, EQUI59, EQUI64, EQUI65, EQUI67

COMG1: Wood Furniture Manufacturer NESHAP

has members

EQUI15, EQUI16, EQUI17, EQUI18, EQUI19, EQUI20, EQUI21, EQUI22, EQUI23, EQUI24, EQUI36, EQUI37, EQUI38, EQUI39, EQUI40, EQUI41

COMG2: Fabric Filters for Woodworking Units

has members

TREA14, TREA15, TREA16

COMG4: VOC and Coating Limits

has members

EQUI15, EQUI16,

SI ID: Description

Relationship Type

Related SI ID: Description EQUI17, EQUI18, EQUI19, EQUI20, EQUI21, EQUI22, EQUI23, EQUI24, EQUI36, EQUI37, EQUI38, EQUI39, EQUI40, EQUI41

COMG7: Panel Filters Subject to CAM

has members

TREA1, TREA2, TREA3, TREA4, TREA5, TREA6, TREA7, TREA8, TREA9, TREA10, TREA11, TREA12, TREA13, TREA17

COMG9: Uncontrolled Woodworking Units

has members

EQUI26, EQUI28, EQUI31, EQUI47, EQUI62, EQUI69, EQUI70, EQUI73, EQUI74, EQUI75, EQUI76, EQUI77, EQUI78, EQUI79, EQUI80, EQUI81, EQUI82, EQUI83, EQUI84, EQUI85, EQUI86, EQUI87, EQUI88, EQUI89, EQUI90,

Permit Issued: [month day, year] 08300023-101 Permit Expires: [month day, year] of 49

SI ID: Description

Relationship Type

Related SI ID: Description EQUI91, EQUI92, EQUI93, EQUI94, EQUI95, EQUI96, EQUI97, EQUI98, EQUI99, EQUI100, EQUI101, EQUI102, EQUI103, EQUI104, EQUI105, EQUI106, EQUI107, EQUI108, EQUI109, EQUI110, EQUI111, EQUI112, EQUI113, EQUI114, EQUI115, EQUI116, EQUI117, EQUI118, EQUI119, EQUI120, EQUI121, EQUI122, EQUI123, EQUI124, EQUI125, EQUI126, EQUI127, EQUI128, EQUI129, EQUI130, EQUI131, EQUI132, EQUI133

EQUI100: 5-piece Dado Machine

EQUI101: Shaper (M54) EQUI102: Dado Table Saw

EQUI103: Chop Saw (1509)

EQUI104: Ritter Plaster

SI ID: Description

Relationship Type


13 EQUI105: Drill Tub (M20)

EQUI106: Miter Saw EQUI107: Carlson 2 - Drill Box Machine

EQUI108: Carlson 2D / Dovetail - Drill Box Machine

EQUI109: Drill Tub (M36)

EQUI10: Table Saw (1519)

sends to STRU7: Pneumafil baghouse


is controlled by

TREA15: Fabric Filter - Low Temperature, i.e., T<180 Degrees F

EQUI110: Full Overlay Drill

EQUI111: Drawer Pilot Drill (M42)

EQUI112: Router Table (M52)

EQUI113: Overlay Drill (M49)

EQUI114: Drill Press 12" Bench Top

EQUI115: Router Machine

EQUI116: Drill Press (M39)

EQUI117: Router Table EQUI118: Chop Saw EQUI119: Double Miter Saw

EQUI120: Drill Press 12" Bench Top

EQUI121: Chop Saw - Selection Center

EQUI122: Chop Saw - Refrigerator End Panel

EQUI123: Chop Saw (M32)

EQUI124: Chop Saw EQUI125: Drill Press EQUI126: Hang Hole Machine

EQUI127: Drawer Front


SI ID: Description

Relationship Type


Hang Hole Machine EQUI128: Hang Hole Machine

EQUI129: Shaper - Murano Doors (1705)

EQUI12: Edge Bander (1525)


EQUI12: Edge Bander (1525)

is controlled by


EQUI130: Copeland Belt Sanding (1711)

EQUI131: Band Saw 14" (M-3)

EQUI132: Horizontal Belt Sander

EQUI133: Chop Saw EQUI13: Wall Machine Grooving (1510)


EQUI13: Wall Machine Grooving (1510)

is controlled by


EQUI14: Panel Saw (1506)


EQUI14: Panel Saw (1506)

is controlled by


EQUI15: Toner Booth #1 sends to STRU10: Toner Booth #1

EQUI15: Toner Booth #1 is controlled by

TREA17: Split Paper + Polyester Paint Arrestor

EQUI16: Toner Booth #2 sends to STRU9: Toner Booth #2

EQUI16: Toner Booth #2 is controlled by


EQUI17: Stain Booth #2 sends to STRU11: Stain Booth #2

SI ID: Description

Relationship Type


EQUI17: Stain Booth #2 is controlled by





EQUI19: Sealer Booth #2 sends to STRU13: Sealer Booth #2

EQUI19: Sealer Booth #2 is controlled by


EQUI1: Drill Tub (1601) sends to STRU6: Carter/Day baghouse

EQUI1: Drill Tub (1601) is controlled by





EQUI21: Topcoat Booth #2

sends to STRU15: Topcoat Booth #2


is controlled by



sends to STRU16: Topcoat Booth #3


is controlled by


EQUI23: Glaze Booth #1 sends to STRU17: Glaze Booth

EQUI23: Glaze Booth #1 is controlled

TREA8: Split Paper +


SI ID: Description

Relationship Type


by Polyester Paint Arrestor

EQUI24: New Finish Special Booth

sends to STRU18: New Finish Special Booth

EQUI24: New Finish Special Booth

is controlled by


EQUI25: Drying Oven #2 sends to STRU19: Drying Oven #2




is controlled by


EQUI2: Radial Arm Saw (1508)


EQUI2: Radial Arm Saw (1508)

is controlled by


EQUI30: Belt Sander (1902)

sends to STRU6: Carter/Day baghouse

EQUI30: Belt Sander (1902)

is controlled by


EQUI35: Butfering Frame Sander (1901)

sends to STRU22: Torit baghouse

EQUI35: Butfering Frame Sander (1901)

is controlled by





EQUI37: Topcoat Booth sends to STRU3:

SI ID: Description

Relationship Type


#1 Topcoat Booth #1


is controlled by





EQUI39: Old Finish Special Booth

sends to STRU5: Old Finish Special Booth

EQUI39: Old Finish Special Booth

is controlled by


EQUI3: Chop Saw (1502) sends to STRU7: Pneumafil baghouse

EQUI3: Chop Saw (1502) is controlled by


EQUI40: Laminator sends to STRU8: Laminator

EQUI41: Cleaning & Thinning Solvent

EQUI42: Bottom Notcher (1507)


EQUI42: Bottom Notcher (1507)

is controlled by


EQUI43: Notcher (1516) sends to STRU7: Pneumafil baghouse

EQUI43: Notcher (1516) is controlled by


EQUI44: Notcher (1517) sends to STRU7: Pneumafil baghouse


SI ID: Description

Relationship Type


EQUI44: Notcher (1517) is controlled by


EQUI46: Make Up Air Unit

EQUI4: Base Backs Notcher (1505)


EQUI4: Base Backs Notcher (1505)

is controlled by



EQUI51: Base Machine Grooving (1512)


EQUI51: Base Machine Grooving (1512)

is controlled by



EQUI53: Sliding Table Saw (1524)


EQUI53: Sliding Table Saw (1524)

is controlled by


EQUI54: Butfering Sander (1904)


EQUI54: Butfering Sander (1904)

is controlled by


EQUI55: Make Up Air Unit (New Finish)

EQUI56: Make Up Air Unit (New Finish)

EQUI57: Make Up Air Unit (Rupp - White

SI ID: Description

Relationship Type


Wood) EQUI58: Molding Sander (1907)


EQUI58: Molding Sander (1907)

is controlled by


EQUI59: Door Sander (1906)


EQUI59: Door Sander (1906)

is controlled by


EQUI60: Dado Saw - 1/2" Plywood Area (1400)


EQUI60: Dado Saw - 1/2" Plywood Area (1400)

is controlled by


EQUI61: Table Saw - 1/2" Plywood Area (1401)


EQUI61: Table Saw - 1/2" Plywood Area (1401)

is controlled by


EQUI62: MMTJ EQUI63: CNC Machining Center (1535)


EQUI63: CNC Machining Center (1535)

is controlled by






SI ID: Description

Relationship Type





EQUI66: Wall Back Machine Grooving (1511)


EQUI66: Wall Back Machine Grooving (1511)

is controlled by


EQUI67: Brush Sander (1905)

sends to STRU22: Torit baghouse

EQUI67: Brush Sander (1905)

is controlled by


EQUI68: Panel Shaper (1706)


EQUI68: Panel Shaper (1706)

is controlled by


EQUI69: Mini Planer (1707)

EQUI6: L- Machine (1513)


EQUI6: L- Machine (1513)

is controlled by


EQUI70: Coper Machine (1709)

EQUI71: Make Up Air Unit (Cutting/Specials Dept.)

EQUI72: Make Up Air Unit (Assembly North)

EQUI73: Downdraft sanding table - small

SI ID: Description

Relationship Type



EQUI75: Chop Saw EQUI76: Chop Saw EQUI77: Dado Saw - pneumatic

EQUI78: Downdraft sanding table - large

EQUI79: 3-spindle Shaper - Outside Profiler (1710)

EQUI80: Unique - profile cuts (1712)

EQUI81: Unique - profile cuts (1713)





EQUI86: Hinge Machine EQUI87: Broom Side Machine (M23)

EQUI88: Dado Machine (M25)

EQUI89: Side Saw (M24) EQUI8: Altendorf (1520) sends to STRU7:

Pneumafil baghouse

EQUI8: Altendorf (1520) is controlled by


EQUI90: Table Saw EQUI91: Hinge Machine (M28)

EQUI92: Hinge Machine (M29)

EQUI93: Grass Hinger EQUI94: Blum Hinger EQUI95: Miter Saw EQUI96: Hinge Machine EQUI97: Miter Saw EQUI98: Hinge Machine (M42)

EQUI99: Table Saw


SI ID: Description

Relationship Type


EQUI9: Router (1501) sends to STRU7: Pneumafil baghouse

EQUI9: Router (1501) is controlled by


STRU10: Toner Booth #1 STRU11: Stain Booth #2 STRU12: Stain Booth #3 STRU13: Sealer Booth #2 STRU14: Sealer Booth #3 STRU15: Topcoat Booth #2

STRU16: Topcoat Booth #3

STRU17: Glaze Booth STRU18: New Finish Special Booth

STRU19: Drying Oven #2 STRU1: Drying Oven #1 STRU20: Drying Oven #3 STRU22: Torit baghouse STRU23: Lunch Room STRU24: Assembly STRU25: Assembly STRU26: Corridor STRU27: Finish STRU28: Sawing and Cutting

STRU29: Sawing and Cutting

STRU2: Stain Booth #1 STRU30: Sawing and Cutting

STRU31: Storage and Framing

STRU32: Drilling and Framing

STRU33: Sawing and Cutting

STRU34: Parts Storage STRU35: Sawing and Cutting

STRU36: Offices STRU37: Offices STRU38: Maintenance STRU39: Laminator and Storage

SI ID: Description

Relationship Type


STRU3: Topcoat Booth #1

STRU40: Finish Warehouse

STRU41: Compressor Room

STRU42: Paint Pump and Mixing Room

STRU43: New Finish Line STRU4: Sealer Booth #1 STRU5: Old Finish Special Booth

STRU6: Carter/Day baghouse

STRU7: Pneumafil baghouse

STRU8: Laminator STRU9: Toner Booth #2 TFAC2: Mid Continent Cabinetry














TREA6: Split Paper +


SI ID: Description

Relationship Type


Polyester Paint Arrestor TREA7: Split Paper + Polyester Paint Arrestor


SI ID: Description

Relationship Type




5. Limits and other requirements

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation TFAC 2 08300023 Mid Continent

Cabinetry

5.1.1 PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R. 7007.1800, (A)(2)]

5.1.2 Equipment Inventory: The Permittee shall maintain a written list of all emissions units and control equipment on site. The Permittee shall update the list to include any replaced, modified, or new equipment prior to making the change. The list shall correlate the units to the Subject Item numbers used in this permit and shall include the data on GI-04, GI-05B, GI-05C, and GI-05F. The date of construction shall be the date the change was made for replaced, modified, or new equipment. [Minn. R. 7007.0800, subp. 2]

5.1.3 Equipment Labeling: The Permittee shall permanently affix a unique number to each emissions unit for tracking purposes. The numbers shall correlate the unit to the appropriate Subject Item numbers used in this permit. The number can be affixed by placard, stencil, or other means. The number shall be maintained so that it is readable and visible at all times from a safe distance. If equipment is added, it shall be given a new unique number; numbers from replaced or removed equipment shall not be reused. [Minn. R. 7007.0800, subp. 2]

5.1.4 Permit Appendices: This permit contains three appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendix A: Insignificant Activities and General Applicable Requirements, Appendix B: Maximum Materials Content and Usage Rates, and Appendix C: Work Practice Implementation Plan (WPIP). [Minn. R. 7007.0800, subp. 2]

5.1.5 The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. Stat.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

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

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

5.1.8 Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J)]

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

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

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

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

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

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

5.1.15 Performance Test Notifications and Submittals:


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Performance Test Notification and Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test The Notification, Test Plan, and Test Report must be submitted in a format specified by the commissioner. [Minn. R. 7017.2017, Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2035, subps. 1-2]

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

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

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

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

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


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation from those changes. [Minn. R. 7007.0800, subp. 5(B)]

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

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

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

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

5.1.25 Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation;


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. [Minn. R. 7019.1000, subp. 1]

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

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

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

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

5.1.30 This permit establishes limits on the facility to keep it a minor source under New Source Review. The Permittee cannot make any change at the source that would make the source a major source under New Source Review until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

COMG 1 GP003 Wood Furniture

Manufacturer NESHAP

5.2.1 Volatile Hazardous Air Pollutant (VHAP) means any volatile hazardous air pollutant listed in Table 2 of 40 CFR pt. 63, subp. JJ. [40 CFR 63.801, 40 CFR pt. 63, subp. JJ (Table 2), Minn. R. 7011.7340]


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.2.2 The Permittee shall limit VHAP emissions from finishing operations

by complying with one of the following: 1) HAPs - Volatile <= 1.0 kilograms per kilograms (kg VHAP/kg solids) average content (E) of all finishing materials, including but not limited to, stains, basecoats, washcoats, enamels, sealers and topcoats, as applied. E shall be calculated using the equation given in this permit; OR 2) HAPs - Volatile <= 1.0 kilograms per kilograms (kg VHAP/kg solids) for each finishing material, including but not limited to, stains, basecoats, washcoats, enamels, sealers and topcoats, as applied. [40 CFR 63.802(a)(1), 40 CFR pt. 63, subp. JJ (Table 3), Minn. R. 7011.7340]

5.2.3 HAPs - Volatile <= 1.0 kilograms per kilograms (kg VHAP/kg solids) for each contact adhesive, as applied. This limit does not apply to aerosol adhesives and contact adhesives applied to nonporous substrates. [40 CFR 63.802(a)(2), 40 CFR pt. 63, subp. JJ (Table 3), Minn. R. 7011.7340]

5.2.4 Volatile Organic Compounds <= 0.80 kilograms per kilograms (kg VOC/kg solids) for each strippable spray booth coating, as applied. [40 CFR 63.802(a)(3), 40 CFR pt. 63, subp. JJ (Table 3), Minn. R. 7011.7340]

5.2.5 The Permittee shall limit formaldehyde emissions by complying with one of the following: 1) Limit the use in coatings and contact adhesives of Formaldehyde <= 400 pounds per year 12-month rolling sum; OR 2) Use coatings and contact adhesives only if they are low formaldehyde coatings and adhesives, as defined in 40 CFR Section 63.801(a) and Table 3 of 40 CFR pt. 63, subp. JJ, in any wood furniture manufacturing operations. [40 CFR 63.802(a)(4), 40 CFR pt. 63, subp. JJ (Table 3), Minn. R. 7011.7340]

5.2.6 At all times, 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. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. [40 CFR 63.802(c), Minn. R. 7011.7340]

5.2.7 Work Practice Implementation Plan: The Permittee shall maintain and adhere to the Work Practice Implementation Plan (WPIP) which defines environmentally desirable work practices for each wood furniture manufacturing operation and addresses each of the work practice standards in paragraphs (b) through (l) of Section 63.803. These standards are included in Appendix C of this permit. The plan shall be available upon request by the Administrator and shall be revised upon request by the Administrator. [40 CFR 63.803(a),


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Minn. R. 7011.7340]

5.2.8 HAPs - Volatile: The VHAP content for each finishing material, thinner, and strippable spray booth coating shall be determined as specified in 40 CFR Section 63.805(a). This information shall be found on the certified product data sheet (CPDS). [40 CFR 63.805(a)(1), Minn. R. 7011.7340]

5.2.9 HAPs - Volatile: Compliance Procedure for Finishing Materials: If the Permittee is complying with the VHAP averaging limit from 40 CFR Section 63.804(a)(1), the Permittee shall calculate the average VHAP content (E) using the following equation: E = (Mc1 Cc1 +Mc2 Cc2 +...+Mcn Ccn +S1 W1 +S2 W2 +...+Sn Wn ) / (Mc1 +Mc2 +...+Mcn ) (Equation 1 from 40 CFR pt. 63, subp. JJ) Where: n+1,2,3...(the first finishing material(c), the second finishing material(c), etc.); E = the emission limit achieved, in kg VHAP/kg solids (lb VHAP/lb solids); Mc = the mass of solids in a finishing material(c), in kg (lb); Cc = the VHAP content of a finishing material(c), in kg of VHAP per kg of coating solids (lb VHAP/lb solids), as supplied; S = the VHAP content of a solvent, in weight fraction, added to finishing materials; and W = amount of solvent, in kg (lb), added to finishing materials during the monthly averaging period. [40 CFR 63.804(a)(1), Minn. R. 7011.7340]

5.2.10 HAPs - Volatile: Compliance Procedure for Finishing Materials: If the Permittee is complying with the VHAP compliant materials limit from 40 CFR Section 804(a)(2), the Permittee shall demonstrate that: 1) each stain, sealer, and topcoat has a VHAP content of no more than 1.0 kg VHAP/kg solids (1.0 lb VHAP/lb solids), as applied, and each thinner contains no more than 10.0 percent VHAP by weight by maintaining certified product data sheets for each coating and thinner; 2) each washcoat, basecoat, and enamel that is purchased pre-made, that is, it is not formulated onsite by thinning another finishing material, has a VHAP content of no more than 1.0 kg VHAP/kg solids (1.0 lb VHAP/lb solids), as applied, and each thinner contains no more than 10.0 percent VHAP by weight by maintaining certified product data sheets for each coating and thinner; and 3) each washcoat, basecoat, and enamel that is formulated at the affected source is formulated using a finishing material containing no more than 1.0 kg VHAP/kg solids (1.0 lb VHAP/lb solids) and a thinner containing no more than 3.0 percent VHAP by weight. [40


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation CFR 63.804(a)(2)(i), (ii), and (iii), Minn. R. 7011.7340]

5.2.11 HAPs - Volatile: Compliance Procedure for Contact Adhesives: The Permittee shall use compliant contact adhesives with a VHAP content no greater than 1.0 kg VHAP/kg solids (1.0 lb VHAP/lb solids), as applied. [40 CFR 63.804(c)(1), Minn. R. 7011.7340]

5.2.12 Formaldehyde: Compliance Procedure for Formaldehyde Emissions: If the Permittee is complying with the formaldehyde averaging limit from 40 CFR Section 63.802(a)(4)(i), the Permittee shall calculate the total formaldehyde emissions from all finishing materials and contact adhesives (Ftotal ) using the following equation: Ftotal =(Cf1 Vc1 +Cf2 Vc2 +...+Cfn Vcn +Gf1 Vg1 +Gf2 Vg2 +...+Gfn Vgn ) (Equation 5 from 40 CFR pt. 63, subp. JJ) Where: n+1,2,3...(the first material(c), the second material(c), etc.); Ftotal = total formaldehyde emissions in each 12 rolling month period, in lb; Cf = the formaldehyde content of a finishing material(c), in lb formaldehyde per gallon of coating (lb/gal); Gf = the formaldehyde content of a contact adhesive (g), in lb formaldehyde per gallon of contact adhesive (lb/gal); Vc = the volume of formaldehyde-containing finishing material (c), in gal; and Vg = the volume of formaldehyde-containing contact adhesive (g), in gal. [40 CFR 63.804(h)(1), Minn. R. 7011.7340]

5.2.13 Formaldehyde: Compliance Procedure for Formaldehyde Emissions: If the Permittee is complying with the low-formaldehyde option from 40 CFR Section 63.802(a)(4)(ii), the Permittee shall demonstrate compliance by use of coatings and contact adhesives only if they are low-formaldehyde coatings and contact adhesives maintaining a certified product data sheet for each coating and contact adhesive used, as required by 40 CFR Section 63.806(b)(1), and submitting a compliance certification with the semiannual report required in this permit. [40 CFR 63.804(h)(3), Minn. R. 7011.7340]

5.2.14 Recordkeeping: The Permittee shall maintain the following records onsite: 1) A certified product data sheet for each finishing material, thinner, and strippable spray booth coating; 2) Copies of the averaging calculation for each month following the compliance date, as well as the data on the quantity of coatings and thinners used that is necessary to support the above E calculation; 3) The VHAP content, in kg VHAP/kg solids, as applied, of each finishing material and contact adhesive; 4) The formaldehyde content, in lb/gal, as applied, of each finishing material and contact adhesive subject to the emission limit in 40 CFR Section 63.802(b)(4); 5) The VOC content, in kg VOC/kg solids, as applied, of each


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation strippable booth coating; and 6) The WPIP and all records associated with fulfilling the requirements of the WPIP. [40 CFR 63.806(b), 40 CFR 63.806(c), 40 CFR 63.806(e), Minn. R. 7011.7340]

5.2.15 The minimum WPIP onsite record content shall include: 1) Records demonstrating that the operator training program is in place; 2) Records collected in accordance with the inspection and maintenance plan; 3) Records associated with the cleaning solvent accounting system; 4) Records associated with the formulation assessment plan required by 63.803(l); and 5) Copies of documentation such as logs developed to demonstrate that the other provisions of the WPIP are followed. [40 CFR 63.806(e), Minn. R. 7011.7340]

5.2.16 The Permittee shall maintain records of all reports submitted to the agency including the supporting materials. [40 CFR 63.806(h) and (i), Minn. R. 7011.7340]

5.2.17 The Permittee shall maintain all records for a period of 5 years and, at a minimum, the most recent 2 years of data shall be retained on site. The records including all required reports shall be in a form suitable and readily available for expeditious inspection and review. [40 CFR 63.10(b)(1), 40 CFR 63.806(j), Minn. R. 7011.7340]

5.2.18 The Permittee shall maintain records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control equipment and monitoring equipment. The Permittee shall maintain records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR Section 63.802(c), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. [40 CFR 63.806(k), Minn. R. 7011.7340]

5.2.19 Content of Semiannual Compliance Status Report: At a minimum, the report shall include: 1) results of the averaging calculation of VHAP from finishing operations for each month within that semiannual period using the above equation "E" (if using this option); 2) a compliance certification stating the value of "E" was always less than 1.0 (if using this option); 3) a compliance certification stating that compliant stains, washcoats, sealers, topcoats, basecoats, enamels, and thinners, as applicable, have been used each day (if using this option); 4) a compliance certification stating that compliant contact and/or foam adhesives have been used each day; 5) a compliance certification stating that compliant strippable spray


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation booth coatings have been used each day; 6) a compliance certification stating that the WPIP was followed; 7) a compliance certification stating that Ftotal was always less than 400 (if using this option); and 8) if using the low-formaldehyde option during the reporting period, a certification stating that low-formaldehyde coatings and contact adhesives, as applicable, have been used each day in the semiannual reporting period or otherwise identifying the periods of noncompliance and the reasons for noncompliance, as required by 40 CFR Section 63.804(h)(3)(i). The certification must be signed by a responsible official of the facility. If the Permittee is out of compliance with any of the requirements in the NESHAP, the Permittee shall identify which requirements as required by 40 CFR Section 63.804(g) and (h) and shall state the measures taken to bring the facility back into compliance. [40 CFR 63.804(g)(1), (g)(2), (g)(5), (g)(7), and (g)(8), 40 CFR 63.804(h)(1) and (3), 40 CFR 63.807(c), Minn. R. 7011.7340]

5.2.20 Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, but is not limited to: (1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere; or (2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions. [40 CFR 63.4(b), Minn. R. 7011.7000]

5.2.21 Prior to construction or reconstruction of a major-emitting "affected source" under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit. [40 CFR 63.5(b)(3), Minn. R. 7011.7000]

5.2.22 After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, the Permittee who constructs a new affected source that is not major-emitting or reconstructs an affected source that is not major-emitting that is subject to such standard, or reconstructs a source such that the source becomes an affected source subject to the standard, must notify the Administrator of the intended construction or reconstruction. The notification must be submitted in accordance with the procedures in 40 CFR Section 63.9(b). [40 CFR 63.5(b)(4), Minn. R. 7011.7000]

5.2.23 After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source. [40 CFR 63.5(b)(6), Minn. R. 7011.7000]

5.2.24 Recordkeeping: The Permittee shall maintain files of all information required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site. [40 CFR 63.10(b)(1), Minn. R. 7019.0100, subp. 2(B)]

COMG 2 GP004 Fabric Filters for

Woodworking Units

5.3.1 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99 percent control efficiency. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.3.2 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 93 percent control efficiency. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.3.3 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 93 percent control efficiency. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.3.4 Pressure Drop >= 0.3 and <= 0.9 inches of water, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.3.5 The Permittee shall vent emissions from all woodworking units in COMG 10 and COMG 11, including existing, modified, or new woodworking units, to control equipment meeting the permit requirements for COMG 2. The Permittee shall document periods of non-operation of the control equipment. [Title I Condition: Avoid


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.3.6 If the Permittee replaces any existing fabric filter, adds new fabric filters, or modifies the fabric filters listed in COMG 2, such equipment is subject to all of the requirements of COMG 2. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

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

5.3.8 Visible Emissions: The Permittee shall check the fabric filter stacks STRU 6, STRU 7, and STRU 22 for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.3.9 Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.3.10 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

5.3.11 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. [Minn. R. 7007.0800, subp. 4]

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

COMG 4 GP006 VOC and Coating

Limits

5.4.1 The Permittee shall limit emissions of Volatile Organic Compounds <= 19.6 tons per month 12-month rolling average to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. All VOC-emitting equipment at the Facility is subject to this limit except for the following: combustion equipment and insignificant activities. If the Permittee replaces any existing VOC-emitting equipment, adds new VOC-emitting equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the requirements COMG 4. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee is not required to complete VOC calculations described in Minn. R. 7007.1200, subp. 2. A permit amendment will 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 this permit. VOC contents for each VOC-containing material shall be determined as described under the Material Content requirement in COMG 4. The calculation of VOCs used may take into account recovered/recycled VOCs as described under the Waste Credit requirement in COMG 4. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.4.2 The Permittee shall limit emissions of Particulate Matter <= 45.0 tons per year 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. If the Permittee replaces any existing PM-emitting coating equipment, adds new PM-emitting coating equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the requirements of COMG 4. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Solids contents for each material shall be determined as described under the Material Content requirement in COMG 4. The calculation of solids used may take into account recovered/recycled solids as described under the Waste Credit requirement in COMG 4. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.4.3 The Permittee shall limit emissions of PM < 10 micron <= 45.0 tons per year 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. If the Permittee replaces any existing PM10-emitting coating equipment, adds new PM10-emitting coating equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the requirements of COMG 4. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. Solids contents for each material shall be determined as described under the Material Content requirement in COMG 4. The calculation of solids used may take into account recovered/recycled solids as described under the Waste Credit requirement in COMG 4. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.4.4 The Permittee shall limit emissions of PM < 2.5 micron <= 45.0 tons per year 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. If the Permittee replaces any existing PM2.5-emitting coating equipment, adds new PM2.5-emitting coating equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the requirements of COMG 4. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. Solids contents for each material shall be determined as described under the Material Content requirement in COMG 4. The calculation of solids used may take into account recovered/recycled solids as described under the Waste Credit requirement in COMG 4. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.4.5 The Permittee shall vent emissions from all spray booths, including existing, modified, or new spray booths, to panel filters meeting the permit requirements for COMG 7. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Minn. R. 7007.3000]

5.4.6 Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the total quantity of all coatings and other VOC and solids-containing materials used at the facility. This shall be based on written usage logs and/or delivery records. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.4.7 Volatile Organic Compounds: Monthly Recordkeeping -- VOC Emissions. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total usage of VOC-containing materials for the previous calendar month using the daily usage records. This record shall also include the VOC and solids contents of each material as determined by the Material Content requirement of this permit; 2) The VOC emissions for the previous month using the formulas specified in this permit; and 3) The average monthly VOC emissions for the previous 12-month period by summing the monthly VOC emissions data for the previous 12 months and dividing by 12. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

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

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

5.4.10 PM < 2.5 micron: Monthly Recordkeeping. By the 15th of the month, the Permittee shall calculate and record the following:


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 1) The total usage of each solids-containing material for the previous calendar month using the daily usage records. This record shall also include solids contents of each material as determined by the Material Content requirement of this permit; 2) The PM2.5 emissions for the previous month using the formulas specified in this permit; and 3) The 12-month rolling sum PM2.5 emissions for the previous 12-month period by summing the monthly PM2.5 emissions data for the previous 12 months. [Minn. R. 7007.0800, subps. 4-5]

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

5.4.12 Particulate Matter: Monthly Calculation. The Permittee shall calculate Particulate Matter emissions from the spray booths using the following equations: Particulate Matter (tons/month) = S(1-CE)(1-TE) - W S = (A1 x B1) + (A2 x B2) + (A3 x B3) + ..... W = (C1 x D1) + (C2 x D2) + (C3 x D3) + ...... Where: S = total solids used in tons/month; CE = overall control efficiency, as a fraction. This shall be 0.68 for all spray booths; TE = transfer efficiency, as a fraction. This shall be 0.75 for all HVLP spray guns; A# = amount of each solids-containing material sprayed, in tons/month; B# = weight percent solids in A#, as a fraction; W = the amount of solids shipped in waste, in tons/month; C# = amount, in tons/month, of each solids-containing waste material shipped. If the Permittee chooses to not take credit for waste shipments, this parameter would be zero; and D# = weight percent of solids in C#, as a fraction. [Minn. R. 7007.0800, subps. 4-5]

5.4.13 PM < 10 micron: Monthly Calculation. The Permittee shall calculate PM10 emissions from the spray booths using the following equations: PM10 (tons/month) = S(1-CE)(1-TE) - W S = (A1 x B1) + (A2 x B2) + (A3 x B3) + .....


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation W = (C1 x D1) + (C2 x D2) + (C3 x D3) + ...... Where: S = total solids used in tons/month; CE = overall control efficiency, as a fraction. This shall be 0.68 for all spray booths; TE = transfer efficiency, as a fraction. This shall be 0.75 for all HVLP spray guns; A# = amount of each solids-containing material sprayed, in tons/month; B# = weight percent solids in A#, as a fraction; W = the amount of solids shipped in waste, in tons/month; C# = amount, in tons/month, of each solids-containing waste material shipped. If the Permittee chooses to not take credit for waste shipments, this parameter would be zero; and D# = weight percent of solids in C#, as a fraction. [Minn. R. 7007.0800, subps. 4-5]

5.4.14 PM < 2.5 micron: Monthly Calculation. The Permittee shall calculate PM2.5 emissions from the spray booths using the following equations: PM2.5 (tons/month) = S(1-CE)(1-TE) - W S = (A1 x B1) + (A2 x B2) + (A3 x B3) + ..... W = (C1 x D1) + (C2 x D2) + (C3 x D3) + ...... Where: S = total solids used in tons/month; CE = overall control efficiency, as a fraction. This shall be 0.68 for all spray booths; TE = transfer efficiency, as a fraction. This shall be 0.75 for all HVLP spray guns; A# = amount of each solids-containing material sprayed, in tons/month; B# = weight percent solids in A#, as a fraction; W = the amount of solids shipped in waste, in tons/month; C# = amount, in tons/month, of each solids-containing waste material shipped. If the Permittee chooses to not take credit for waste shipments, this parameter would be zero; and D# = weight percent of solids in C#, as a fraction. [Minn. R. 7007.0800, subps. 4-5]

5.4.15 Material Content. VOC and Solids (PM, PM<10 microns, and PM<2.5 microns) contents in all materials shall be determined by the Environmental Data Sheet (EDS), Certified Data Product Sheet (CDPS), Safety Data Sheet (SDS) or the Material Safety Data Sheet (MSDS) provided by the supplier for each material used. If a material content range is given on the SDS or the MSDS, the highest number in the range shall be used in all compliance calculations. If there is information provided in the Regulatory Section of the SDS, the highest number in the range of that section may be used. When using the MSDS as the basis of calculating particulate emissions, the conservative assumption is made that PM consists entirely of PM less than 10 microns or less than 2.5 microns. Other alternative methods approved by the MPCA may be used to determine the VOC and solids contents. The Commissioner reserves the right to


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation require the Permittee to determine the VOC and solids contents of any material, according to EPA or ASTM reference methods. If an EPA or ASTM reference method is used for material content determination, the data obtained shall supersede the SDS or the MSDS. [Minn. R. 7007.0800, subps. 4-5]

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

5.4.17 Maximum Contents of Materials: The Permittee assumed certain worst-case contents of materials when determining the short term potential to emit of units in COMG 4. These assumptions are listed in Appendix B of this permit. Changing to a material that has a higher content of any of the given pollutants is considered a change in method of operation that must be evaluated under Minn. R. 7007.1200, subp. 3 to determine if a permit amendment or notification is required under Minn. R. 7007.1150. [Minn. R. 7005.0100, subp. 35a]

COMG 7 GP008 Panel Filters

Subject to CAM

5.5.1 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 68 percent control efficiency. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.5.2 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 68 percent control efficiency. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.5.3 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 68 percent control efficiency. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.5.4 The Permittee shall vent emissions from all COMG 4 spray booths, including existing, modified, or new spray booths, to panel filters


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation meeting the permit requirements for COMG 7. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.5.5 If the Permittee replaces any existing panel filter, adds new panel filters, or modifies the panel filters listed in COMG 7, such equipment is subject to all of the requirements of COMG 7. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.5.6 Daily Inspections: At least once per 24-hour period, the Permittee shall visually inspect the condition of the panel filter with respect to alignment, saturation, tears, holes and any other matter that may affect the filter's performance. The Permittee shall record the time and date of each inspection and any actions resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.5.7 Periodic Inspections: The Permittee shall inspect the control equipment components as required by the manufacturing specifications. The Permittee shall maintain a written record of these inspections. [40 CFR 64.3, Minn. R. 7017.0200]

5.5.8 Corrective Actions: The Permittee shall take corrective action as soon as possible if the panel 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 panel filter. The Permittee shall keep a record of the type and date of any corrective action taken for the panel filter. [40 CFR 64.7(d), Minn. R. 7017.0200]

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

5.5.10 Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R. 7017.0200]

5.5.11 As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R. 7017.0200]

5.5.12 The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R. 7017.0200]

5.5.13 Hood Certification and Evaluation: The Permittee shall maintain the most current record of the hood evaluation and certification on site. The control device hood must be evaluated by a testing company as specified in Minn. R. 7011.0072, subp. 2(A) and must conform to the design and operating requirements listed in Minn. R. 7011.0072, subps. 2(B) and 3. The hood certification must address how cross-drafts are accommodated in the design (e.g., higher face velocity, oversized hood, etc.) and the Permittee shall certify this as specified in Minn. R. 7011.0072, subps. 2 and 3. [Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.5.14 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 parameter that was measured during the most recent hood certification to verify the hood design and operation parameters meet or exceed the parameters measured during the most recent hood evaluation conducted according to Minn. R. 7011.0072, subps. 2 & 3 as required by Minn. R. 7011.0072, subp. 4. The Permittee shall maintain a copy of the annual evaluations on site for 5 years. [Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

COMG 9 Uncontrolled

Woodworking Units

5.6.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.6.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of

exhaust gas unless required to further reduce emissions to comply


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0715, subp. 1(A)]

COMG 10 Controlled

Woodworking Units with Hood Capture

5.7.1 The Permittee shall operate and maintain each COMG 10 unit such that it achieves a capture efficiency for Particulate Matter >= 80 percent capture efficiency. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.7.2 The Permittee shall vent emissions from all COMG 10 units, including existing, modified, or new units, to fabric filters meeting the permit requirements for COMG 2. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.7.3 If the Permittee replaces any existing units, adds new units, or modifies the units listed in COMG 10, such equipment is subject to all of the requirements of COMG 2 and COMG 10. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.7.4 Hood Certification and Evaluation: The Permittee shall maintain the most current record of the hood evaluation and certification on site. The control device hood must be evaluated by a testing company as specified in Minn. R. 7011.0072, subp. 2(A) and must conform to the design and operating requirements listed in Minn. R. 7011.0072, subps. 2(B) and 3. The hood certification must address how cross-drafts are accommodated in the design (e.g., higher face velocity, oversized hood, etc.) and the Permittee shall certify this as specified in Minn. R. 7011.0072, subps. 2 and 3. [Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.7.5 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 parameter that was measured during the most recent hood certification to verify the hood design and operation parameters meet or exceed the parameters measured during the most recent hood evaluation conducted according to Minn. R. 7011.0072, subps. 2 & 3 as required by Minn. R. 7011.0072, subp. 4. The Permittee shall maintain a copy of the annual evaluations on site for 5 years. [Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

COMG 11 Controlled

Woodworking Units with Total Enclosure

5.8.1 The Permittee shall operate and maintain each COMG 11 unit in a total enclosure. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.8.2 The Permittee shall vent emissions from all COMG 11 units, including existing, modified, or new units, to fabric filters meeting the permit requirements for COMG 2. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.8.3 If the Permittee replaces any existing units, adds new units, or modifies the units listed in COMG 11, such equipment is subject to all of the requirements of COMG 2 and COMG 11. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI 1 EU008 Drill Tub (1601) 5.9.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.9.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of

exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0715, subp. 1(A)]

EQUI 2 EU009 Radial Arm Saw

(1508)



EQUI 3 EU010 Chop Saw (1502) 5.11.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.11.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of

exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 7011.0735. [Minn. R. 7011.0715, subp. 1(A)]

EQUI 4 EU011 Base Backs

Notcher (1505)



EQUI 6 EU013 L- Machine

(1513)



EQUI 8 EU015 Altendorf (1520) 5.14.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.14.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 9 EU016 Router (1501) 5.15.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.15.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 10 EU017 Table Saw (1519) 5.16.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.16.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 12 EU019 Edge Bander

(1525)


exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 7011.0735. [Minn. R. 7011.0715, subp. 1(A)]

EQUI 13 EU020 Wall Machine

Grooving (1510)



EQUI 14 EU023 Panel Saw (1506) 5.19.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.19.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 15 EU028 Toner Booth #1 5.20.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.20.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 16 EU029 Toner Booth #2 5.21.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.21.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 17 EU030 Stain Booth #2 5.22.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.22.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of





Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation EQUI 19 EU032 Sealer Booth #2 5.24.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.24.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 20 EU033 Sealer Booth #3 5.25.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.25.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 21 EU034 Topcoat Booth

#2




#3



EQUI 23 EU036 Glaze Booth #1 5.28.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.28.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 24 EU037 New Finish

Special Booth




Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation EQUI 25 EU038 Drying Oven #2 5.30.1 Opacity <= 20 percent opacity except for one six-minute period per

hour of not more than 60 percent opacity. [Minn. R. 7011.0610, subp. 1(A)(2)]

5.30.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0610, subp. 1(A)(1)]

5.30.3 Fuel Type: natural gas only, by design. [Minn. R. 7005.0100, subp. 35a]

EQUI 27 EU041 Chop Saw (1509) 5.31.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.31.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 30 EU044 Belt Sander

(1902)



EQUI 35 EU027 Butfering Frame

Sander (1901)






#1



Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0715, subp. 1(A)]

EQUI 38 EU003 Sealer Booth #1 5.36.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.36.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 39 EU004 Old Finish Special

Booth



EQUI 40 EU024 Laminator 5.38.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.38.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 42 EU048 Bottom Notcher

(1507)



EQUI 43 EU049 Notcher (1516) 5.40.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.40.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 44 EU050 Notcher (1517) 5.41.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.41.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of

exhaust gas unless required to further reduce emissions to comply


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0715, subp. 1(A)]

EQUI 46 EU052 Make Up Air Unit 5.42.1 Opacity <= 20 percent opacity except for one six-minute period per




EQUI 50 EU006 Drying Oven #1 5.43.1 Opacity <= 20 percent opacity except for one six-minute period per




EQUI 51 EU021 Base Machine

Grooving (1512)



EQUI 52 EU039 Drying Oven #3 5.45.1 Opacity <= 20 percent opacity except for one six-minute period per




EQUI 53 EU053 Sliding Table Saw

(1524)


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.46.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.46.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 54 EU054 Butfering Sander

(1904)



EQUI 55 EU055 Make Up Air Unit

(New Finish)

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




(New Finish)





(Rupp - White Wood)


5.50.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0610, subp. 1(A)(1)]


EQUI 58 EU058 Molding Sander

(1907)



EQUI 59 EU059 Door Sander

(1906)



EQUI 60 EU060 Dado Saw - 1/2"

Plywood Area (1400)



EQUI 61 EU061 Table Saw - 1/2"

Plywood Area (1401)



EQUI 63 EU063 CNC Machining

Center (1535)




Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation EQUI 64 EU064 Drill Tub (1602) 5.56.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.56.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 65 EU065 Drill Tub (1603) 5.57.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.57.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of


EQUI 66 EU066 Wall Back

Machine Grooving (1511)



EQUI 67 EU067 Brush Sander

(1905)



EQUI 68 EU068 Panel Shaper

(1706)




(Cutting/Specials Dept.)



Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.61.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of

exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0610, subp. 1(A)(1)]



(Assembly North)




6. Submittal/action requirements

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

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation TFAC 2 08300023 Mid Continent

Cabinetry

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

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

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


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 6.1.4 The Permittee shall submit an annual report : Due annually, by

the 31st of January. The report shall describe the changes made at the Facility during the previous calendar year using the latest MPCA application forms. The report shall include information for any new or replaced Subject Items. The report shall document the COMG 4 VOC 12-month rolling average calculations and the COMG 4 PM, PM<10 micron, and PM<2.5 micron 12-month rolling sum calculations for the previous calendar year. The report shall be submitted with the annual Compliance Certification required by this permit. As part of the Annual Report, the Permittee shall verify and certify that the Facility has maintained minor source status for New Source Review. [Minn. R. 7007.0800, subp. 2]

COMG 1 GP003 Wood Furniture

Manufacturer NESHAP

6.2.1 Following 06/07/1996, the Permittee shall submit a compliance status report: Due semiannually, by the 30th of January and July. The Semiannual Compliance Status Report shall contain the information specified in COMG 1 of this permit. [40 CFR 63.807(c), Minn. R. 7011.7340]

7. Appendices

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

Minn. R. Rule description of the activity General applicable requirement Minn. R. 7007.1300, subp. 3(B)(1)

Infrared electric ovens Opacity ≤ 20% (Minn. R. 7011.0105 or 7011.0110)

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

Brazing, soldering or welding equipment PM, variable depending on airflow Opacity ≤ 20% (Minn. R. 7011.0710/0715)

Minn. R. 7007.1300, subp. 3(I) Individual units with potential emissions less than 2000 lb/year of certain pollutants The Permittee operates 3 Air Make Up Units (3.65 MMBtu/hr total), 3 furnaces (0.260 MMBtu/hr total), and 19 space heaters (2.04 MMBtu/hr total).

Fuel-burning: PM, variable depending on airflow Opacity ≤ 20% (with exceptions) (Minn. R. 7011.0610/0615)

Minn. R. 7007.1300, subp. 3(J) Fugitive dust emissions from unpaved entrance roads and parking lots

Requirement to take reasonable measures to prevent PM from becoming airborne (Minn. R. 7011.0150)


Appendix B. Maximum Materials Content and Usage Rates

The table below details the maximum materials contents and usage rates used in calculating potential to emit at the time of permit issuance. Changing to a material with a higher VOC or solids content, increasing the material usage rate, or reducing the transfer efficiency are considered changes in method of operation that must be evaluated under Minn. R. 7007.1200, subp. 3 to determine if a permit amendment or notification is required.

Subject Item

Emission Unit Subject Item Description

Maximum Usage Rate

(gal/hr)

Maximum Solids Content,

as applied (lb/gal)

Maximum VOC Content, as

applied (lb/gal)

Minimum Transfer

Efficiency EQUI 36 EU 001 Stain Booth #1 30.0 7.04 6.99 75% EQUI 37 EU 002 Topcoat Booth #1 45.0 7.04 6.99 75% EQUI 38 EU 003 Sealer Booth #1 45.0 7.04 6.99 75% EQUI 39 EU 004 Old Finish Special Booth 18.75 7.04 6.99 75% EQUI 40 EU 024 Laminator 23.4 8.98 0.122 100% EQUI 41 EU 025 Cleaning Solvents 0.40 N/A 7.32 N/A EQUI 15 EU 028 Toner Booth #1 28.2 7.04 6.99 75% EQUI 16 EU 029 Toner Booth #2 28.2 7.04 6.99 75% EQUI 17 EU 030 Stain Booth #2 28.4 7.04 6.99 75% EQUI 18 EU 031 Stain Booth #3 28.4 7.04 6.99 75% EQUI 19 EU 032 Sealer Booth #2 26.0 7.04 6.99 75% EQUI 20 EU 033 Sealer Booth #3 26.0 7.04 6.99 75% EQUI 21 EU 034 Topcoat Booth #2 26.0 7.04 6.99 75% EQUI 22 EU 035 Topcoat Booth #3 26.0 7.04 6.99 75% EQUI 23 EU 036 Glaze Booth #1 28.2 7.04 6.99 75% EQUI 24 EU 037 New Finish Special Booth 28.2 7.04 6.99 75%


Appendix C. Work Practice Implementation Plan (WPIP) At a minimum, a work practice implementation plan (WPIP) shall contain the following:

A. Operator training course - the Permittee shall train all personnel involved in finishing, gluing, cleaning, and washoff operations, use of manufacturing equipment, or implementation of the requirements of the MACT standard. Those personnel hired before the compliance date shall be trained within six months of the compliance date and new personnel shall be trained prior to performing their job duties. At a minimum all personnel shall receive annual refresher training. The Permittee shall maintain a copy of the program with the WPIP, each with minimum of following information:

1) a list of all current personnel by name and job description;

2) outline of all training materials;

3) lesson plans which shall include, but not limited to appropriate application techniques, cleaning and washoff procedures, equipment setup and adjustment to minimize finishing material usage and overspray, and appropriate management of cleanup wastes; and

4) documentation of successful completion of training.

B. Inspection and maintenance plan – The Permittee shall follow a written leak inspection and maintenance plan. At a minimum this plan shall specify the following:

1) a visual inspection frequency of at least once per month for all equipment used to transfer or apply coating, adhesives, or organic HAP solvents;

2) an inspection schedule;

3) methods for documenting the date and results of each inspection and any repairs that were made; and

4) the timeframe between identifying the leak and making the repair. A first attempt at repair and final repairs shall be made within 5 and 15 calendar days after the leak is detected respectively. If new equipment must be purchased, the leak must be repaired within three months of discovery.

C. Cleaning and washoff solvent accounting system – The Permittee shall maintain an accounting system to record the following:

1) the quantities and types of organic HAP solvent used/month for cleaning and washoff operations;

2) the number of pieces washed off and the reason for the washoff; and

3) the quantity of spent HAP solvent from each washoff and cleaning operation and whether it is recycled onsite or disposed offsite.

D. Chemical composition of cleaning and washoff solvents - The facility is prohibited from using cleaning or washoff solvents containing the chemicals listed in Table 4 of 40 CFR pt. 63, subp. JJ, in concentrations subject to MSDS reporting as required by OSHA.

E. Spray booth cleaning – The Permittee shall not use compounds containing more than 8.0 percent by weight of VOC for cleaning spray booth components other than conveyors, continuous coaters and total enclosures, metal filters, or plastic filters unless the spray booth is being refurbished. If the Permittee is replacing the spray booth coating or other protective material used to cover the booth, the Permittee shall use no more than 1.0 gallon of organic HAP solvent per booth to prepare the surface of the booth prior to applying the booth coating.


F. Storage requirements – the Permittee shall use normally closed containers for storing finishing, gluing, cleaning, and washoff materials.

G. Application equipment requirements - the WPIP shall specify when conventional air spray guns are allowed to be used in application of finishing materials as outlined in 40 CFR Section 63.803(h).

H. Line Cleaning – the Permittee shall pump or drain all organic HAP solvent used for line cleaning into a normally closed container.

I. Gun cleaning – the Permittee shall collect all organic HAP solvent used to clean spray guns into a normally closed container.

J. Washoff operations – the Permittee shall use normally closed tanks for washoff and minimizing dripping by tilting or rotating the part to drain as much solvent as possible.

K. Formulation assessment plan (FAP) for finishing operations – the Permittee shall prepare and maintain with the WPIP a formulation assessment plan only if any of the following chemicals are being used in finishing operations: dimethylformamide, formaldehyde, methylene chloride, 2-nitropropane, isophorone, styrene monomer, phenol, diethanolamine, 2-methoxyethanol, 2-ethoxyethyl acetate. A FAP shall be done in accordance with 40 CFR Section 63.803(l).

Intent to Issue Air Emission Permit to Mid Continent ... Permit - 083000… · ACTV5: All IA's...

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