Intent to Issue Air Individual Permit Major Amendment ... · Air Individual Permit . Major...

Air Individual Permit

Major Amendment

14700012-101 Permittee: Crown Cork & Seal Co Inc - Owatonna

Facility name: Crown Cork & Seal Co Inc - Owatonna 2929 West Bridge Street Owatonna, MN 55060 Steele County

Operating permit issuance date: September 10, 2014 Expiration date: September 10, 2019 * All Title I Conditions do not expire Major Amendment: August 23, 2016 Stage 1 issuance date – Authorization to Construct and Operate: August 3, 2016 Stage 2 issuance date – Major Amendment: August 23, 2016 Permit characteristics: Federal; Part 70/ Major for NSR; Limits to avoid NSR; Limits to avoid NESHAP The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the Permit Applications Table. The conditions included in Stage 1 of this permit action are effective on the Stage 1 Issuance Date shown above. Stage 1 conditions authorize construction and modification of the facility and the operation of the modified emissions units at the address listed above until final action is taken on Stage 2. Air Emission Permit No. 14700012- 004 remains effective until the Stage 2 Issue Date. Beginning on the Stage 2 Issue date Air Emission Permit No. 14700012-101 supersedes Air Emission Permit No. 14700012- 004 and authorizes the Permittee to operate, construct, and modify 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 as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Stage 1 Issuance Approval:

Signature: Steven S. Pak This document has been electronically signed. for the Minnesota Pollution Control Agency

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

Stage 2 Issuance Approval:

Signature: Toni Volkmeier 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 ............................................................................................................................................. 4 2. Where to send submittals ............................................................................................................................................ 5 3. Facility description ....................................................................................................................................................... 6 4. Amendment description .............................................................................................................................................. 6 5. Summary of subject items ........................................................................................................................................... 7 6. Limits and other requirements .................................................................................................................................... 9 7. Submittal/action requirements ................................................................................................................................. 34 8. Appendices ................................................................................................................................................................. 40

Appendix A. Insignificant Activities and General Applicable Requirements ............................................................ 40 Appendix B. Maximum Content of Materials and Capacity Information ................................................................ 41

Permit issued: August 23, 2016 14700012-101 Permit expires: September 10, 2019 of 41

1. Permit applications table Subsequent permit applications: Title description Application receipt date Action number Part 70 Reissuance 08/13/2010 14700012- 004 Part 70 Reissuance (Supplemental Information)

01/21/2011 14700012- 004

Major Amendment 10/08/2015 14700012-101


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


3. Facility description

The Crown Cork & Seal Co Inc - Owatonna (Facility) is located at 2929 W Bridge St in Owatonna, MN, Steele County, Minnesota. Crown Cork and Seal Co Inc - Owatonna (Crown) is a metal can manufacturer which consists of two identical lines for the production of two-piece steel food cans. The two manufacturing lines have an individual maximum production capacity of 1725 cans per minute each. Primarily Volatile Organic Compound (VOC) emissions are generated from the protective coatings applied to the inside (spray line) and outside (washcoat) of the cans. Coatings also contain hazardous air pollutant (HAP) emissions for which the facility has accepted limits to avoid triggering major source status under 40 CFR Section 63.2. Particulate matter (PM), particulate matter less than 10 microns (PM10), and particulate matter less than 2.5 microns (PM2.5) are also emitted from both inside spray lines and are controlled by lacquer spray machine (LSM) control boxes. The LSM control boxes work by using a series of panels that act as a baffling system and are capable of achieving an overall control efficiency of 95%. This facility is an existing major source under New Source Review (NSR) regulations.

4. Amendment description Crown is installing a regenerative thermal oxidizer (RTO) to control VOC and HAP emissions from coating lines EQUI 8 and EQUI 9 for the production of two-piece steel food cans. The RTO will also control emissions from EQUI 4 (oven) and EQUI 5 (oven). Oven emissions are included to ensure the RTO receives gases and emissions at the appropriate temperature for operation. The RTO shall achieve a capture efficiency of 75% and a control efficiency of 95% for VOC and HAP emissions. Crown will conduct performance tests to show compliance with both efficiencies. Crown is also adding a new coating to their operations. A change in coating is a change in operation and emission increases from the coating change were evaluated. Crown accepted a VOC limit of 100 tons per year for EQUIs 8 and 9 coating lines to avoid major modification status under 40 CFR 52.21. This limit is found in COMG 8 of the permit. In addition, Crown accepted a limit of 240 hour per year of uncontrolled hours of operation for EQUIs 4, 5, 8, and 9. Crown expects time is needed for repair and maintenance of the RTO, but Crown wants the ability to continue coating operations during downtime for RTO repair and maintenance. A limit on uncontrolled hours of operation allows Crown operational flexibility and to take credit for RTO operation when calculating future emission increases for EQUIs 4, 5, 8, and 9. Moreover, Crown is installing a fabric filter (baghouse). EQUIs 8 and 9 will vent emissions from the LSM control boxes to the baghouse before emissions are vented to the RTO. Crown is installing this baghouse for fire prevention reasons only and is not taking credit for this unit as a control device. Therefore, the baghouse is not included in the permit.


5. Summary of subject items

SI ID: Description

Relationship Type

Related SI ID: Description

ACTV3: All IAs COMG2: HAP Limits has

members EQUI6, EQUI7, EQUI8, EQUI9

COMG8: EQUIs 8 and 9

has members

EQUI8, EQUI9

COMG9: EQUIs controlled by TREA 5

has members

EQUI4, EQUI5, EQUI8, EQUI9

EQUI10: Inside Spray

EQUI11: Inside Spray

EQUI12: Wash Coat EQUI13: Inside Spray

EQUI1: Boiler sends to STRU16 EQUI2: Dryer, unknown firing method - Line 1

sends to STRU3

EQUI2: Dryer, unknown firing method - Line 1

sends to STRU4


sends to STRU6


sends to STRU7

EQUI4: Oven, unknown firing method - Line 1

sends to STRU10


sends to STRU17: RTO Stack


sends to STRU8


sends to STRU9


is controlled by

TREA5: Regenerative Thermal Oxidizer


sends to STRU12

EQUI5: Oven, sends to STRU13

SI ID: Description

Relationship Type


unknown firing method - Line 2 EQUI5: Oven, unknown firing method - Line 2

sends to STRU14




is controlled by


EQUI6: Wash coat 1 sends to STRU2 EQUI7: Wash coat 2 sends to STRU5 EQUI8: Spray Booth - Line 1

sends to STRU11

EQUI8: Spray Booth - Line 1



is controlled by

TREA1: LSM Collection Box


is controlled by



sends to STRU15




is controlled by



is controlled by


STRU10: STRU11: STRU12: STRU13: STRU14: STRU15: STRU16: STRU17: RTO Stack STRU1: Warehouse STRU2: STRU3: STRU4: STRU5: STRU6:


SI ID: Description

Relationship Type


STRU7: STRU8: STRU9: TFAC1: Crown Cork & Seal Co Inc - Owatonna


is controlled in series by


SI ID: Description

Relationship Type



is controlled in series by




6. Limits and other requirements Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation TFAC 1 14700012 Crown Cork &

Seal Co Inc - Owatonna

5.1.1 Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendices [Appendix A. Insignificant Activities and General Applicable Requirements; Appendix B. Maximum Content of Materials and Capacity Information]. [Minn. R. 7007.0800, subp. 2]

5.1.2 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)]

5.1.3 These requirements apply if a reasonable possibility (RP) as defined in 40 CFR Section 52.21(r)(6)(vi) exists that a proposed project, analyzed using the actual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no RP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of Section 52.21(r)(6)(vi)(b). Even though a particular modification is not subject to New Source Review (NSR), or where there isn't a RP that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R. 7007.1150 - 7007.1500. [Minn. R. 7007.0800, subp. 2, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

5.1.4 Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following: 1. Project description 2. Identification of any emission unit whose emissions of an NSR pollutant could be affected


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 3. Pre-change potential emissions of any affected existing emission unit, and the projected post-change potential emissions of any affected existing or new emission unit. 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the emission unit could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination. The Permittee shall maintain records of this documentation. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7007.1200, subp. 4, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

5.1.5 The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the ATPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

5.1.6 The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain: a. The name and ID number of the Facility, and the name and telephone number of the Facility contact person. b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

5.1.7 The Permittee shall comply with National Primary and


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 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. R. 7009.0010-7009.0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

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

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

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

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

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

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

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

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


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation subp. 16]

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

5.1.17 Performance Test Notifications and Submittals: Performance Tests are due as outlined in this permit. Performance Test Notification (written): due 30 days before each Performance Test Performance Test 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 Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R. 7017.2018. [Minn. R. 7017.2018, Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2035, subps. 1-2]

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

5.1.19 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)]

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


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 4(D)]

5.1.21 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)]

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

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

5.1.24 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]

5.1.25 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.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 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]

5.1.26 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]

5.1.27 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; 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]

5.1.28 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]

5.1.29 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)]

5.1.30 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]

5.1.31 Emission Fees: due 30 days after receipt of an MPCA bill.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation [Minn. R. 7002.0005-7002.0095]

COMG 2 GP007 HAP Limits 5.2.1 The Permittee shall limit emissions of HAPs - Total <= 22.0

tons per year 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period. HAP contents for each HAP-containing material (i.e. coatings, gun cleaner, etc.) shall be determined as described under the Material Content requirement in COMG 2. [Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2]

5.2.2 The Permittee shall limit emissions of HAPs - Single <= 9.0 tons per year 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period. HAP contents for each HAP-containing material (i.e. coatings, gun cleaner, etc.) shall be determined as described under the Material Content requirement in COMG 2. [Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2]

5.2.3 Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the total quantity of all coatings and other HAP-containing materials used at the facility. This shall be based on delivery records. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2]

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

5.2.5 HAPs: Monthly Calculation -- HAP Emissions. The Permittee shall calculate each individual HAP and total HAP emissions using equations specified in this permit for EQUIs 6, 7, 8, and 9. Each individual HAP and total HAP emissions from EQUIs 6, 7, 8, and 9 shall be summed to determine the previous month and 12-month rolling sum HAP emissions for the previous 12-month period for COMG 2 emissions.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation HAP Emissions (tons/month) = Sum of [H] Where: H = the amount of each pollutant (total HAP or each individual HAP), used, in tons/month, as calculated for EQUIs 6, 7, 8, and 9 in this permit. [Minn. R. 7007.0800, subps. 4-5]

5.2.6 Material Content. HAPs contents in coating materials shall be determined by the 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 information is provided in the Regulatory Section of the SDS, the highest number in the range of that section may be used. Other alternative methods approved by the MPCA may be used to determine the HAPs contents. The Commissioner reserves the right to require the Permittee to determine the HAP 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]

5.2.7 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 2. 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 8 EQUIs 8 and 9 5.3.1 The Permittee shall limit emissions of Volatile Organic

Compounds <= 100 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. VOC contents for each VOC-containing material shall be determined as described under the Material Content requirement in COMG 8. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.3.2 Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the following: -total quantity (tons) of all coatings and other VOC, solids, and HAP-containing materials used when COMG 8 EQUIs vented to TREA 5 and TREA 5 was in operation. This shall be based on written usage logs. -total quantity (tons) of all coatings and other VOC, solids, and HAP-containing materials used when COMG 8 EQUIs did not vent to TREA 5 or during periods of non-operation of


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation TREA 5. This shall be based on written usage logs. [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]

5.3.3 Material Content. VOC, HAPs, and Solids (PM, PM<10 microns, and PM<2.5 microns) contents in coating materials shall be determined by the 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 information is 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, HAPs, and solids contents. The Commissioner reserves the right to require the Permittee to determine the VOC, HAP, 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]

5.3.4 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 8. 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]

5.3.5 Volatile Organic Compounds: Monthly Recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following: 1a) The total usage of VOC-containing materials used in EQUI 8 when EQUI 8 vented to TREA 5 and TREA 5 was in operation 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; 1b) The total usage of VOC-containing materials used in EQUI 9 when EQUI 9 vented to TREA 5 and TREA 5 was in operation 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; 2a) The total usage of VOC-containing materials used in EQUI 8 when EQUI 8 did not vent to TREA 5 or during periods of


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation non-operation of TREA 5 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; 2b) The total usage of VOC-containing materials used in EQUI 9 when EQUI 9 did not vent to TREA 5 or during periods of non-operation of TREA 5 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 12-month rolling sum VOC emissions for the previous 12-month period by summing the monthly VOC emissions data for the previous 12 months. [Minn. R. 7007.0800, subps. 4-5]

5.3.6 Volatile Organic Compounds: Monthly Calculation -- VOC Emissions. The Permittee shall calculate VOC emissions using the following equations: 1) VOC Emissions (tons/month) = V = V1 + V2 2) Use the following equations to calculate VOC emissions when EQUI 8 or EQUI 9 vents to TREA 5, TREA 5 is in operation, and credit for capture and control can be taken. V1 = UE + CE UE = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] * (1 - CAE) CE = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] * CAE * (1 - COE) Where: V1 = the amount of VOC, in tons/month when EQUI 8 or EQUI 9 operated controlled. UE = uncaptured emissions CE = captured and controlled emissions A# = amount of each VOC-containing coating used in the previous month, in tons/month. B# = weight percent of VOC in A#, as a fraction (e.g., 50% is 0.50). CAE = capture efficiency as determined under TREA 5, as a fraction (e.g., 50% is 0.50). COE = control efficiency as determined under TREA 5, as a fraction (e.g., 50% is 0.50). 2) Use the following equation to calculate VOC emissions when EQUI 8 or EQUI 9 is not vented to TREA 5, TREA 5 is not in operation, or when credit for capture and control cannot be taken.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation V2 = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] Where: V2 = the amount of VOC, in tons/month when EQUI 8 or EQUI 9 operated uncontrolled. A# = amount of each VOC-containing coating used in the previous month, in tons/month. B# = weight percent of VOC in A#, as a fraction (e.g., 50% is 0.50). [Minn. R. 7007.0800, subps. 4-5]

COMG 9 EQUIs

controlled by TREA 5

5.4.1 The Permittee may operate EQUIs 4, 5, 8, and 9 without venting to TREA 5 for a period of uncontrolled Hours <= 240 hours 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. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.4.2 Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain a record of the total hours of controlled and uncontrolled operation for EQUI 8 and EQUI 9. The Permittee shall document periods of operation and non-operation of TREA 5 when EQUI 8 and EQUI 9 are in operation. This shall be based on written logs. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.4.3 Monthly Recordkeeping. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total hours of uncontrolled operation for the previous calendar month using the daily records; and 2) The 12-month rolling sum hours of uncontrolled operation for the previous 12-month period by summing the monthly hours of uncontrolled operation for the previous 12 months. [Minn. R. 7007.0800, subps. 4-5]

EQUI 1 EU010 Boiler 5.5.1 Fuel type: Natural gas and propane only by design. [Minn. R.

7005.0100, subp. 35a] 5.5.2 The Permittee shall submit a notification of any physical or

operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. [40 CFR 60.7(a)(4), Minn. R. 7019.0100, subp. 1]

5.5.3 Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b), Minn. R. 7019.0100, subp. 1]

5.5.4 Recordkeeping: The Permittee shall maintain a file of all


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation measurements, maintenance, reports and records for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two years. [40 CFR 60.7(f), Minn. R. 7007.0800, subp. 5(C), Minn. R. 7019.0100, subp. 1]

5.5.5 No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. [40 CFR 60.12, Minn. R. 7011.0050]

5.5.6 Recordkeeping: By the last day of each calendar month, the Permittee shall record the amount of natural gas and propane combusted in the boiler during the previous calendar month. These records shall consist of purchase records, receipts, or fuel meter readings. [40 CFR 60.48c(g), Minn. R. 7011.0570]

EQUI 2 EU002 Dryer, unknown

firing method - Line 1

5.6.1 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)]

5.6.2 Total 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)]

5.6.3 Fuel type: Natural gas and propane only by design. [Minn. R. 7005.0100, subp. 35a]

EQUI 3 EU004 Dryer, unknown





EQUI 4 EU006 Oven, unknown



5.8.2 Total 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


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0610, subp. 1(A)(1)]


EQUI 5 EU008 Oven, unknown





EQUI 6 EU001 Wash coat 1 5.10.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp.

1(B)] 5.10.2 Total 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)]

5.10.3 Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the total quantity of all coatings and other HAP-containing materials used in EQUI 6. This shall be based on delivery records. [Minn. R. 7007.0800, subp. 4-5, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2]

5.10.4 Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following information: 1) Tons of each type of coating used in EQUI 6 for the previous month and previous 12 months. This record shall also include the individual and total HAP contents of each HAP-containing material used in the previous month, as determined by the Material Content requirement of this permit; 3) The total and individual HAP emissions for the previous month using the formulas specified in this permit; and 4) The 12-month rolling sum total and individual HAP emissions for the previous 12-month period by summing the monthly emissions data for the previous 12 months. [Minn. R. 7007.0800, subp. 4-5]

5.10.5 HAPs: Monthly Calculation -- HAP Emissions. The Permittee shall calculate each individual HAP and total HAP emissions


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation using the following equation: HAP Emissions (tons/month) = H H = (A1 x B1) + (A2 x B2) + (A3 x B3) + .... Where: H = the amount of each pollutant (total HAP or each individual HAP), used in EQUI 6, in tons/month. A# = amount of each HAP-containing material used in the previous month, in tons/month. B# = weight percent of each individual or total HAP in A#, as a fraction (e.g., 50% is 0.50). [Minn. R. 7007.0800, subp. 4-5]

EQUI 7 EU003 Wash coat 2 5.11.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp.

1(B)] 5.11.2 Total 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)]

5.11.3 Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the total quantity of all coatings and other HAP-containing materials used in EQUI 7. This shall be based on delivery records. [Minn. R. 7007.0800, subp. 4-5, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2]

5.11.4 Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following information: 1) Tons of each type of coating used in EQUI 7 for the previous month and previous 12 months. This record shall also include the individual and total HAP contents of each HAP-containing material used in the previous month, as determined by the Material Content requirement of this permit; 3) The total and individual HAP emissions for the previous month using the formulas specified in this permit; and 4) The 12-month rolling sum total and individual HAP emissions for the previous 12-month period by summing the monthly emissions data for the previous 12 months. [Minn. R. 7007.0800, subp. 4-5]

5.11.5 HAPs: Monthly Calculation -- HAP Emissions. The Permittee shall calculate each individual HAP and total HAP emissions using the following equation: HAP Emissions (tons/month) = H H = (A1 x B1) + (A2 x B2) + (A3 x B3) + .... Where:


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation H = the amount of each pollutant (total HAP or each individual HAP), used in EQUI 7, in tons/month. A# = amount of each HAP-containing material used in the previous month, in tons/month. B# = weight percent of each individual or total HAP in A#, as a fraction (e.g., 50% is 0.50). [Minn. R. 7007.0800, subp. 4-5]

EQUI 8 EU005 Spray Booth -

Line 1

5.12.1 The Permittee shall limit emissions of Total Particulate Matter <= 1.30 pounds per hour 3-hour average from EQUI 8 and associated pollution control equipment (TREA 1). The emission rate is equal to the 3-Hour average of solids applied and that are not collected on the can surfaces and the LSM Collection Box. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.12.2 The Permittee shall limit emissions of PM < 10 micron <= 1.30 pounds per hour 3-hour average from EQUI 8 and associated pollution control equipment (TREA 1). The emission rate is equal to the 3-Hour average of solids applied and that are not collected on the can surfaces and the LSM Collection Box. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.12.3 The Permittee shall limit emissions of PM < 2.5 micron <= 1.30 pounds per hour 3-hour average from EQUI 8 and associated pollution control equipment (TREA 1). The emission rate is equal to the 3-Hour average of solids applied and that are not collected on the can surfaces and the LSM Collection Box. [Minn. R. 7007.0800, subp. 2]

5.12.4 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)]

5.12.5 Total 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)]

5.12.6 Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the following: -tons of each type of coating used in EQUI 8 when EQUI 8 vented to TREA 5 and TREA 5 was in operation. This shall be based on delivery records. -tons of each type of coating used in EQUI 8 when EQUI 8 did not vent to TREA 5 or during periods of non-operation of TREA 5. This shall be based on delivery records. [Minn. R. 7007.0800, subp. 4-5, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2]

5.12.7 Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation information: 1) Tons of each type of coating used in EQUI 8 when EQUI 8 vented to TREA 5 and TREA 5 was in operation for the previous month. This record shall also include the individual and total HAP contents of each HAP-containing material used in the previous month, as determined by the Material Content requirement of this permit; 2) Tons of each type of coating used in EQUI 8 when EQUI 8 did not vent to TREA 5 or during periods of non-operation of TREA 5 for the previous month. This record shall also include the individual and total HAP contents of each HAP-containing material used in the previous month, as determined by the Material Content requirement of this permit; 3) The total and individual HAP emissions for the previous month using the formulas specified in this permit; and 4) The 12-month rolling sum total and individual HAP emissions for the previous 12-month period by summing the monthly emissions data for the previous 12 months. [Minn. R. 7007.0800, subp. 4-5]

5.12.8 HAPs: Monthly Calculation -- HAP Emissions. The Permittee shall calculate each individual HAP and total HAP emissions using the following equations: 1) HAP Emissions (tons/month) = H = H1 + H2 2) Use the following equations to calculate total and individual HAPs when EQUI 8 vents to TREA 5, TREA 5 is in operation, and credit for capture and control can be taken. H1 = UE + CE UE = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] * (1 - CAE) CE = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] * CAE * (1 - COE) Where: H1 = the amount of each pollutant (total HAP or each individual HAP), used, in tons/month when EQUI 8 operated controlled. UE = uncaptured emissions CE = captured and controlled emissions A# = amount of each coating used in the previous month, in tons/month. B# = weight percent of each individual or total HAP in A#, as a fraction (e.g., 50% is 0.50). CAE = capture efficiency as determined under TREA 5, as a fraction (e.g., 50% is 0.50). COE = control efficiency as determined under TREA 5, as a fraction (e.g., 50% is 0.50).


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 2) Use the following equation to calculate total and individual HAPs when EQUI 8 is not vented to TREA 5, TREA 5 is not in operation, or when credit for capture and control cannot be taken. H2 = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] Where: H2 = the amount of each pollutant (total HAP or each individual HAP), used, in tons/month when EQUI 8 operated uncontrolled. A# = amount of each coating used in the previous month, in tons/month. B# = weight percent of each individual or total HAP in A#, as a fraction (e.g., 50% is 0.50). [Minn. R. 7007.0800, subp. 4-5]


Line 2

5.13.1 The Permittee shall limit emissions of Total Particulate Matter <= 1.30 pounds per hour 3-hour average from each inside spray machine (EQUI 9) and associated pollution control equipment (TREA 2). The emission rate is equal to the 3-Hour average of solids applied and that are not collected on the can surfaces and the LSM Collection Box. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.13.2 The Permittee shall limit emissions of PM < 10 micron <= 1.30 pounds per hour 3-hour average from each inside spray machine (EQUI 9) and associated pollution control equipment (TREA 2). The emission rate is equal to the 3-Hour average of solids applied and that are not collected on the can surfaces and the LSM Collection Boxes. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.13.3 The Permittee shall limit emissions of PM < 2.5 micron <= 1.30 pounds per hour 3-hour average from each inside spray machine (EQUI 9) and associated pollution control equipment (TREA 2). The emission rate is equal to the 3-Hour average of solids applied and that are not collected on the can surfaces and the LSM Collection Boxes. [Minn. R. 7007.0800, subp. 2]

5.13.4 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)]

5.13.5 Total 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)]

5.13.6 Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the following:


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation -tons of each type of coating used in EQUI 9 when EQUI 9 vented to TREA 5 and TREA 5 was in operation. This shall be based on delivery records. -tons of each type of coating used in EQUI 9 when EQUI 9 did not vent to TREA 5 or during periods of non-operation of TREA 5. This shall be based on delivery records. [Minn. R. 7007.0800, subp. 4-5, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2]

5.13.7 Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following information: 1) Tons of each type of coating used in EQUI 9 when EQUI 9 vented to TREA 5 and TREA 5 was in operation for the previous month. This record shall also include the individual and total HAP contents of each HAP-containing material used in the previous month, as determined by the Material Content requirement of this permit; 2) Tons of each type of coating used in EQUI 9 when EQUI 9 did not vent to TREA 5 or during periods of non-operation of TREA 5 for the previous month. This record shall also include the individual and total HAP contents of each HAP-containing material used in the previous month, as determined by the Material Content requirement of this permit; 3) The total and individual HAP emissions for the previous month using the formulas specified in this permit; and 4) The 12-month rolling sum total and individual HAP emissions for the previous 12-month period by summing the monthly emissions data for the previous 12 months. [Minn. R. 7007.0800, subp. 4-5]

5.13.8 HAPs: Monthly Calculation -- HAP Emissions. The Permittee shall calculate each individual HAP and total HAP emissions using the following equations: 1) HAP Emissions (tons/month) = H = H1 + H2 2) Use the following equations to calculate total and individual HAPs when EQUI 9 vents to TREA 5, TREA 5 is in operation, and credit for capture and control can be taken. H1 = UE + CE UE = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] * (1 - CAE) CE = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] * CAE * (1 - COE) Where: H1 = the amount of each pollutant (either total HAP or each individual HAP), used, in tons/month when EQUI 9 operated


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation controlled. UE = uncaptured emissions CE = captured and controlled emissions A# = amount of each coating used in the previous month, in tons/month. B# = weight percent of each individual or total HAP in A#, as a fraction (e.g., 50% is 0.50). CAE = capture efficiency as determined under TREA 5, as a fraction (e.g., 50% is 0.50). COE = control efficiency as determined under TREA 5, as a fraction (e.g., 50% is 0.50). 2) Use the following equation to calculate total and individual HAPs when EQUI 9 is not vented to TREA 5, TREA 5 is not in operation, or when credit for capture and control cannot be taken. H2 = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] Where: H2 = the amount of each pollutant (either total HAP or each individual HAP), used, in tons/month when EQUI 9 operated uncontrolled. A# = amount of each coating used in the previous month, in tons/month. B# = weight percent of each individual or total HAP in A#, as a fraction (e.g., 50% is 0.50). [Minn. R. 7007.0800, subp. 4-5]

EQUI 10 TK001 Inside Spray 5.14.1 The tank shall be equipped with a submerged fill pipe; or be

equipped with a floating roof, vapor recovery system or its equivalent. The tank has been equipped with a permanent submerged fill pipe. [Minn. R. 7011.1505, subp. 3(B)]



EQUI 12 TK003 Wash Coat 5.16.1 The tank shall be equipped with a submerged fill pipe; or be




TREA 1 CE002 LSM Collection


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation Box

5.18.1 The Permittee shall vent emissions from EQUI 8 to TREA 1 whenever EQUI 8 operates, and operate and maintain TREA 1 at all times that any emissions are vented to TREA 1. The Permittee shall document periods of non-operation of the control equipment. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.18.2 The Permittee shall operate and maintain the LSM Collection Box (TREA 1) such that it achieves an overall control efficiency, for Total Particulate Matter >= 95 percent. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.18.3 The Permittee shall operate and maintain the LSM Collection Box (TREA 1) such that it achieves an overall control efficiency, for PM < 10 micron >= 95 percent. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.18.4 The Permittee shall operate and maintain the LSM Collection Box (TREA 1) such that it achieves an overall control efficiency, for PM < 2.5 micron >= 95 percent. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.18.5 Daily Inspections: Once each operating day, the Permittee shall visually inspect the condition of TREA 1 with respect to alignment, saturation and any other condition that may affect the performance of the LSM Collection box. The Permittee shall maintain a daily written record of TREA 1 inspections. [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]

5.18.6 Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturer's 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, subps. 4-5]

5.18.7 Corrective Actions: If the LSM Collection box or any components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the LSM Collection box. The Permittee shall keep a record of the type and date of any corrective action taken for TREA 1. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

5.18.8 Operation and Maintenance of LSM Control Box: The Permittee shall operate and maintain TREA 1 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]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation TREA 2 CE004 LSM Collection

Box

5.19.1 The Permittee shall vent emissions from EQUI 9 to TREA 2 whenever EQUI 9 operates, and operate and maintain TREA 2 at all times that any emissions are vented to TREA 2. The Permittee shall document periods of non-operation of the control equipment. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.19.2 The Permittee shall operate and maintain the LSM Collection Box (TREA 2) such that it achieves an overall control efficiency, for Total Particulate Matter >= 95 percent. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.19.3 The Permittee shall operate and maintain the LSM Collection Box (TREA 2) such that it achieves an overall control efficiency, for PM < 10 micron >= 95 percent. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.19.4 The Permittee shall operate and maintain the LSM Collection Box (TREA 2) such that it achieves an overall control efficiency, for PM < 2.5 micron >= 95 percent. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.19.5 Daily Inspections: Once each operating day, the Permittee shall visually inspect the condition of TREA 2 with respect to alignment, saturation and any other condition that may affect the performance of the LSM Collection box. The Permittee shall maintain a daily written record of inspections. [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]

5.19.6 Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturer's 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, subps. 4-5]

5.19.7 Corrective Actions: If the LSM Collection box or any components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the LSM Collection box. The Permittee shall keep a record of the type and date of any corrective action taken for TREA 2. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

5.19.8 Operation and Maintenance of LSM Control Box: The Permittee shall operate and maintain each LSM Collection Box 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]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation TREA 5 Regenerative

Thermal Oxidizer

5.20.1 The Permittee is authorized to construct and operate TREA 5 meeting the following design requirements; 1400 degrees Fahrenheit inlet temperature, 250 degree Fahrenheit outlet temperature, 1.5 second residence time, and 4.00 MMBtu/hr burner capacity, within 18 months after permit issuance of Permit No. 14700012-101. The units shall meet all the requirements of this permit. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.20.2 The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds >= 95 percent control efficiency. [Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.20.3 The Permittee shall operate and maintain control equipment such that it achieves an overall capture efficiency for Volatile Organic Compounds >= 75 percent capture efficiency. [Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.20.4 The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for HAPs - Total >= 95 percent control efficiency. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2]

5.20.5 The Permittee shall operate and maintain control equipment such that it achieves an overall capture efficiency for HAPs - Total >= 75 percent capture efficiency. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2]

5.20.6 Temperature >= 1400 degrees Fahrenheit 3-hour rolling average at the combustion chamber outlet, unless a new limit is required to be set pursuant to Minn. R. 7017.2025, subp. 3. If a new minimum is required to be set it will be based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3-hour rolling average temperature is below the minimum temperature limit, the VOC emitted during that time shall be considered uncontrolled until the average temperature is above the minimum temperature limit. This shall be reported as a deviation. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, 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 63.2]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.20.7 The Permittee shall vent emissions from EQUIs 4, 5, 8, and 9

to TREA 5 whenever EQUIs 4, 5, 8, and 9 operate, and operate and maintain TREA 5 at all times that any emissions are vented to TREA 5, except for a period of less than or equal to 240 hours per year the Permittee may operate EQUIs 4, 5, 8, and 9 without venting to TREA 5. The Permittee shall document periods of non-operation of the control equipment, TREA 5, whenever EQUIs 4, 5, 8, and 9 are operating. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, 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 63.2]

5.20.8 The Permittee shall operate and maintain the thermal oxidizer 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]

5.20.9 Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/- 0.75 percent of the temperature being measured or +/- [2.5 degrees Celsius][4.5 degrees Fahrenheit]. The recording device shall also calculate the three-hour rolling average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7011.7000, 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 63.2]

5.20.10 Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7011.7000, 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 63.2]

5.20.11 Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [Minn. R. 7007.0800, subps. 4-5]

5.20.12 The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three hour rolling average temperatures for the combustion chamber. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7011.7000, 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 63.2]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.20.13 Annual Calibration: The Permittee shall calibrate the

temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4-5]

5.20.14 Quarterly Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer's specifications, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4-5]

5.20.15 Annual Inspection: At least once per calendar year, the Permittee shall conduct an inspection that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4-5]

5.20.16 For periods when the thermal oxidizer is operated above the minimum combustion chamber temperature, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit: 1a. The overall control efficiency limit specified in this permit for this equipment (x%); or 1b. The overall control efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test. 2a. The overall capture efficiency limit specified in this permit for this equipment (x%); or 2b. The overall capture efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7011.7000, 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 63.2]

5.20.17 For periods when the thermal oxidizer is operated below the minimum combustion chamber temperature, the Permittee shall use a 0% control efficiency and 0% capture efficiency when completing calculations as required elsewhere in this permit. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, 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 63.2]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.20.18 For periods when the thermal oxidizer is not operated, the

Permittee shall use a 0% control efficiency and 0% capture efficiency when completing calculations as required elsewhere in this permit. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, 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 63.2]

5.20.19 Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4-5]

5.20.20 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]

5.20.21 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]

5.20.22 Daily Recordkeeping: On each day of operation, the Permittee shall calculate, record and maintain the following for TREA 5: - hours of operation - hours of non-operation [Minn. R. 7007.0800, subp. 4-5, Minn. R. 7011.7000, 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 63.2]

5.20.23 Fuel type: Natural gas only. [Minn. R. 7005.0100, subp. 35a]


7. 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 1 14700012 Crown Cork &

Seal Co Inc - Owatonna

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)]

COMG 8 EQUIs 8 and 9 6.2.1 The Permittee shall submit an annual report : Due annually, by

the 31st of January The report shall document the VOC 12-month rolling sum calculations for the previous calendar year. The report shall be submitted with the annual Compliance Certification required by this permit. [Minn. R. 7007.0800, subp. 2]


Line 1

6.3.1 PM < 10 micron : The Permittee shall conduct a performance test : Due before 04/01/2018 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit;


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Each performance test shall consist of at least three separate test runs. The sampling time per run is one hour. Each run will measure the amount of solids applied (S), the amount of solids deposited on the cans (C) and the amount of solids captured by control box, TREA 1 (B). The emission rate for each run = S - C - B. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

6.3.2 PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 04/01/2018 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Each performance test shall consist of at least three separate test runs. The sampling time per run is one hour. Each run will measure the amount of solids applied (S), the amount of solids deposited on the cans (C) and the amount of solids captured by control box, TREA 1 (B). The emission rate for each run = S - C - B. [Minn. R. 7017.2020, subp. 1]

6.3.3 Total Particulate Matter : The Permittee shall conduct a performance test : Due before 04/01/2018 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required:


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Each performance test shall consist of at least three separate test runs. The sampling time per run is one hour. Each run will measure the amount of solids applied (S), the amount of solids deposited on the cans (C) and the amount of solids captured by control box, TREA 1 (B). The emission rate for each run = S - C - B. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]


Line 2

6.4.1 PM < 10 micron : The Permittee shall conduct a performance test : Due before 04/01/2018 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Each performance test shall consist of at least three separate test runs. The sampling time per run is one hour. Each run will measure the amount of solids applied (S), the amount of solids deposited on the cans (C) and the amount of solids captured by control box, TREA 2 (B). The emission rate for each run = S - C - B. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

6.4.2 PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 04/01/2018 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Each performance test shall consist of at least three separate test runs. The sampling time per run is one hour. Each run will measure the amount of solids applied (S), the amount of solids deposited on the cans (C) and the amount of solids captured by control box, TREA 2 (B). The emission rate for each run = S - C - B. [Minn. R. 7017.2020, subp. 1]

6.4.3 Total Particulate Matter : The Permittee shall conduct a performance test : Due before 04/01/2018 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Each performance test shall consist of at least three separate test runs. The sampling time per run is one hour. Each run will measure the amount of solids applied (S), the amount of solids deposited on the cans (C) and the amount of solids captured by control box, TREA 2 (B). The emission rate for each run = S - C - B. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

TREA 5 Regenerative

Thermal Oxidizer

6.5.1 The Permittee shall submit a notification of the date construction began : Due 30 calendar days after Date of Construction Start. Submit the name and number of the Subject Item and the date construction began. [Minn. R. 7007.0800,


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation subp. 16(L)]

6.5.2 The Permittee shall submit a notification of the actual date of initial startup : Due 15 calendar days after Initial Startup Date. Submit the name and number of the Subject Item and the date of startup. Startup is as defined in Minn. R. 7007.0500, subp. 42a. [Minn. R. 7007.0800, subp. 16(L)]

6.5.3 Volatile Organic Compounds : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date to measure control efficiency. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

6.5.4 Volatile Organic Compounds : The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date to measure capture efficiency. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 1, 2, 3, 4, or 25A, or other method approved by MPCA in the performance test plan approval. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

6.5.5 HAPs - Total : The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date to measure control efficiency. The performance test shall include the HAP species of Methyl isobutyl ketone. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 18 or 320, or other method approved by MPCA in the performance test plan approval. [Minn. R. 7011.7000, Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2]

6.5.6 HAPs - Total : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date to measure capture efficiency. The performance test shall include the HAP species of Methyl Isobutyl Ketone. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 18 or 320, or other method approved by MPCA in the performance test plan approval. [Minn. R. 7011.7000, Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2]

6.5.7 Volatile Organic Compounds : The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for control efficiency of VOC emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

6.5.8 Volatile Organic Compounds : The Permittee shall submit a test


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation frequency plan : Due 60 calendar days after Initial Performance Test Date for capture efficiency of VOC emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

6.5.9 HAPs - Total : The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for control efficiency of HAPs - Total emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7011.7000, Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2]

6.5.10 HAPs - Total : The Permitee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for capture efficiency of HAPs - Total emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7011.7000, Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2]


8. 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. 7011.0110) Minn. R. 7007.1300, subp. 3(H)(2) Equipment used for hydraulic or

hydrostatic testing PM, variable depending on airflow Opacity <= 20% (Minn. R. 7011.0715)

Minn. R. 7007.1300, subp. 3(H)(3) Brazing, soldering or welding equipment; 2, Migmaster 250 s wirefeed 1, Lincoln SP-125 wirefeed 110V unit 1, Lincoln electric arc welder and TIG 1, Lincoln 409 arc welder 2, Oxy/Acetylene, (one is portable)

PM, variable depending on airflow Opacity <= 20% (Minn. R. 7011.0715)

Minn. R. 7007.1300, subp. 3(H)(4) Blueprint copiers and photographic processes

Opacity <= 20% (Minn. R. 7011.0110)

Minn. R. 7007.1300, subp. 3(H)(5) Equipment used exclusively for melting or application of wax


Minn. R. 7007.1300, subp. 3(H)(7) Cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners

PM, variable depending on airflow Opacity <= 20% (Minn. R. 7011.0610 & Minn. R. 7011.0715)

Minn. R. 7007.1300, subp. 3(I) Individual units with potential emissions less than 2000 lb/year of certain pollutants; •26 Sterling Manufacturing space heaters (0.25 MMBtu/hr individual capacity) •17 Sterling Manufacturing space heaters (0.125 MMBtu/hr individual capacity) •1 Sterling Manufacturing space heaters (0.1 MMBtu/hr individual capacity) •4 Sterling Manufacturing space heaters (0.075 MMBtu/hr individual capacity) •1 Sterling Manufacturing space heaters (0.045 MMBtu/hr individual capacity) •1 Sterling Manufacturing space heaters (0.03 MMBtu/hr individual capacity)

(Minn. R. 7011.0515)

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)

Minn. R. 7007.1300, subp. 3(K) Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source



Appendix B. Maximum Content of Materials and Capacity Information The maximum spray capacity of each spray booth is given in the table below for the specified unit – if the unit can use more than one gun at the same time, the number below reflects the combined spray rate.

Emission

Unit (EQUI)

Maximum Production

(cans/minute)

Maximum Usage

(gallons/hr)

Maximum Solids Content

(lb/gallon)

Maximum VOC Content

(lb/gallon)

Maximum Single-HAP

Content (lb/gallon)

Maximum Total-HAP Content

(lb/gallon) 6 1725 5.2 3.0 0.7 0.001 0.001 7 1725 5.2 3.0 0.7 0.001 0.001 8 1725 27.9 3.1 1.4 0.13 0.14 9 1725 27.9 3.1 1.4 0.13 0.14

Technical Support Document, Permit Number: 14700012-101 Page 1 of 9

Technical Support Document For

Air Emission Permit No. 14700012-101 This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit. 1. General information

1.1 Applicant and stationary source location:

Table 1. Applicant and source address

Applicant/Address Stationary source/Address (SIC Code: 3411 - Metal Cans)

Crown Cork & Seal USA Inc 1 Crown Way Philadelphia, Pennsylvania 19154-4599

Crown Cork and Seal Co Inc - Owatonna 2929 West Bridge Street Owatonna, Steele County, MN 55060

Contact: Michael Herron Phone: 215-698-5151

1.2 Facility description

Crown Cork and Seal Co Inc – Owatonna (Crown) is a metal can manufacturer which consists of two identical lines for the production of two-piece steel food cans. The two manufacturing lines have an individual maximum production capacity of 1725 cans per minute each. Primarily Volatile Organic Compound (VOC) emissions are generated from the protective coatings applied to the inside (spray line) and outside (washcoat) of the cans. Coatings also contain hazardous air pollutant (HAP) emissions for which the facility has accepted limits to avoid triggering major source status under 40 CFR Section 63.2. Particulate matter (PM), particulate matter less than 10 microns (PM10), and particulate matter less than 2.5 microns (PM2.5) are also emitted from both inside spray lines and are controlled by lacquer spray machine (LSM) control boxes. The LSM control boxes work by using a series of panels that act as a baffling system and are capable of achieving an overall control efficiency of 95%. This facility is an existing major source under New Source Review (NSR) regulations.

1.3 Description of the activities allowed by this permit action This permit action is Major Amendment. Crown is installing a regenerative thermal oxidizer (RTO) to control VOC and HAP emissions from coating lines EQUI 8 and EQUI 9 for the production of two-piece steel food cans. The RTO will also control emissions from EQUI 4 (oven) and EQUI 5 (oven). Oven emissions are included to ensure the RTO receives gases and emissions at the appropriate temperature for operation. The RTO shall achieve a capture efficiency of 75% and a control efficiency of 95% for VOC and HAP emissions. Crown will conduct performance tests to show compliance with both efficiencies. Crown is also adding a new coating to their operations. A change in coating is a change in operation and emission increases from the coating change were evaluated. Crown accepted a VOC limit of 100 tons per year for EQUIs 8 and 9 coating lines to avoid major modification status under 40 CFR 52.21. This limit is found in COMG 8 of the permit. In addition, Crown accepted a limit of 240 hour per year of uncontrolled hours of operation for EQUIs 4, 5, 8, and 9. Crown expects time is needed for repair and maintenance of the RTO, but Crown wants the ability to continue coating operations during downtime for RTO repair and maintenance. A limit on uncontrolled


hours of operation allows Crown operational flexibility and to take credit for RTO operation when calculating future emission increases for EQUIs 4, 5, 8, and 9. Moreover, Crown is installing a fabric filter (baghouse). EQUIs 8 and 9 will vent emissions from the LSM control boxes to the baghouse before emissions are vented to the RTO. Crown is installing this baghouse for fire prevention reasons only and is not taking credit for this unit as a control device. Therefore, the baghouse is not included in the permit. The MPCA has a combined operating and construction permitting program under Minn. R. ch. 7007, and under Minn. R. 7007.0800. Under that authority, this permit action authorizes construction.

1.4 Facility emissions: Table 2. Title I emissions summary

Pollutant

Future potential emissions (tpy)

Baseline actual emissions (tpy)

Increases from existing units (tpy)

PTE from new units (tpy)

Total emission increases from the modification (tpy)

Limited emissions increase from the modification (tpy)

NSR/112(g) Significant thresholds for major sources (tpy)

NSR/ 112(g) review required? (yes/no)

PM 9.47 0.40 9.1 0.13 9.23 9.23 25 No PM10 9.47 0.40 9.1 0.13 9.23 9.23 15 No PM2.5 9.47 0.40 9.1 0.13 9.23 9.23 10 No NOx 1.72 1.72 1.72 40 No SO2 0.01 0.01 0.01 40 No CO 1.44 1.44 1.44 100 No Ozone (VOC) 339 293 47 0.095 47.1 0.095*** 40 No Lead 8.59*10-6 8.59*10-6 8.59*10-6 0.6 No CO2e* 2,047 2,047 2,047 75,000 No Single HAP 9.00** 0.031 0.031 9.031 10 No Total HAP 22.00** 0.032 0.032 22.032 25 No

*Carbon dioxide equivalents as defined in Minn. R. 7007.0100. **Limits to avoid major source for 40 CFR pt. 63. ***100 tpy VOC limit and 240 uncontrolled hours of operation limit taken to avoid major modification for 40 CFR 52.21 results in no VOC emission increase from EQUIs 8 and 9.

Table 3. Total facility potential to emit summary

PM tpy

PM10 tpy

PM2.5 tpy

SO2 tpy

NOx tpy

CO Tpy

CO2e tpy

VOC tpy

Single HAP tpy

All HAPs tpy

Total Facility Limited Potential Emissions 45.2 45.2 45.2 0.106 25.1 14.9

24,622 136 9.21 22.2

Total Facility Actual Emissions (2014) 4.47 4.68 4.64 0.034 5.68 4.773 * 303 *

* Not reported in MN emission inventory.


Table 4. Facility classification

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

1.5 Changes to permit The MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R. 7007.0800, the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action:

· Updated permit to reflect current MPCA templates and standard citation formatting. · GP 002 of permit 14700012-004 requirements are listed under the individual unit · GP 003 of permit 14700012-004 requirements are listed under the individual unit · STRU 11 (SV 010) requirements are listed under the emission unit, EQUI 8 (EU 005) · STRU 15 (SV 015) requirements are listed under the emission unit, EQUI 9 (EU 007) · EQUI 8 (EU 005) requirement in permit 14700012-004 is listed under TREA 1 (CE 002) · EQUI 9 (EU 007) requirement in permit 14700012-004 is listed under TREA 2 (CE 004)

2. Regulatory and/or statutory basis

2.1 New source review (NSR)

The facility is an existing major source under New Source Review regulations. Changes authorized by this permit do not require NSR review.

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

2.3 New source performance standards (NSPS) The New Source Performance Standard, 40 CFR pt. 60 Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units applies to boilers constructed after June 9, 1989. EQUI 1 at Crown was installed in 1994, has a rated heat input of 10.5 MMBtu/hr and is designed to burn only natural gas and propane. The boiler is subject only to fuel record keeping requirements of this standard. The following New Source Performance Standards were evaluated for applicability but do not apply to operations at this facility;

40 CFR pt. 60, Subpart Kb: EQUI 11 (aboveground storage tank) has a capacity larger than 40 cubic meters (10,567 gallons) and is used to store volatile organic liquids. However, because the capacity is less than 75 cubic meters (19,813 gallons), EQUI 11 is not subject to subpart Kb.

40 CFR pt. 60, Subpart WW: Subpart WW only applies to can coating processes applied to beverage cans. Crown only produces steel cans for food; therefore this subpart does not apply as long as beverage cans are not produced.

2.4 National emission standards for hazardous air pollutants (NESHAP)

Crown has accepted limits on HAP emissions such that it is an area source under 40 CFR pt. 63. Thus, no major source NESHAPs apply. In addition, the Permittee has stated that no area source NESHAPs apply to the facility.


2.5 Compliance assurance monitoring (CAM) EQUIs 4 (dryer/oven), 5 (dryer/oven), 8 (spray booth), and 9 (spray booth) will vent emissions to TREA 5 (RTO). TREA 5 will control VOC and HAP emissions. The Crown Cork application determined that EQUIs 8 and 9 are applicable to CAM requirements for VOC and HAP emissions. When evaluating CAM applicability for multiple emission units that vent to a common control device, the combined uncontrolled PTE from all units venting to that control would be considered. EQUIs 4 and 5 are subject to PM and Opacity limits under Minn. R. 7011.0610; TREA 5 will not affect compliance with these limits and therefore these units would not affect CAM applicability. EQUIs 8 and 9 are subject to hourly Title I limits to avoid major modification under 40 CFR 52.21 for PM and PM10 (PM2.5 hourly limits are cited under Minn. R. 7007.0800, subp. 2 because PM2.5 was not a regulated pollutant under 40 CFR 52.21 when the modification was made and the limits were incorporated into the permit), PM and Opacity limits under Minn. R. 7011.0715, and annual Title I limits to avoid major source classification for single and total HAPs. TREA 5 will control HAP emissions, however the Title I limits to avoid major source classification for single and total HAPs are annual limits and the permit specifies a continuous compliance determination method so these limits are exempt from CAM (40 CFR 64.2(b)(1)(vi)). Additionally, the VOC annual limit taken to avoid a major modification for EQUIs 8 and 9 or the 240 hour per year of uncontrolled hours of operation for EQUIs 4, 5, 8, and 9 would not affect CAM applicability because continuous compliance determinations were also included for these limits. Therefore CAM does not apply to the emission units venting to TREA 5. Moreover, CAM does not apply to EQUIs 8 and 9 for control of PM emissions from the LSM control boxes. The controls are needed to comply with the hourly particulate emission limits established in the permit however the uncontrolled and controlled PM PTE for EQUI 8 and EQUI 9 are less than 100 tons per year.

2.6 Minnesota state rules Portions of the facility are subject to the following Minnesota Standards of Performance:

· Minn. R. 7011.0610 Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment · Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment · Minn. R. 7011.1505 Standards of Performance for Storage Vessels

Table 5. Regulatory overview of units affected by the modification/permit amendment

Subject item* Applicable regulations Rationale COMG 2 (HAP Limits) Title I limit to avoid NESHAPs

National Emission Standards for Hazardous Air Pollutants. Limit set on HAPs emissions from coating operations to avoid major source classification under 40 CFR Part 63.

COMG 8 (EQUIs 8 and 9)

Title I limit to avoid major modification under 40 CFR 52.21

100 tons per year 12-month rolling sum limit on VOCs to avoid major modification status under 40 CFR 52.21

COMG 9 (EQUIs controlled by TREA 5)

Title I limit to avoid major modification under 40 CFR 52.21

240 hours per year 12-month rolling sum of uncontrolled operation for EQUIs 4, 5, 8, and 9.

TREA 5 (Thermal Title I limit to avoid NESHAPs

Crown has accepted limits of 75% capture efficiency and 95% control efficiency for the RTO.


Subject item* Applicable regulations Rationale Oxidizer) Title I limit to avoid major

modification under 40 CFR 52.21 Minn. R. 7007.0800, subp. 2

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

3. Technical information

3.1 Calculations of potential to emit Attachment 1 to this TSD contains a summary of the PTE of the Facility and emission increase calculations on detailed spreadsheets prepared by the MPCA and the Permittee. Coating calculations are based on densities, VOC, PM, and HAP information from material safety data sheets (MSDS), and application rates listed in permit 14700012 - 004. Material content and assumptions used when calculating coating emissions are listed in Appendix B of the permit. Coating MSDS are included as Attachment 5 to this TSD. Coatings used at Crown are water based. VOC content as provided on the MSDS includes water. To accurately calculate VOC emissions, water in the coatings should not be included in calculations. VOC emissions were calculated by multiplying the maximum usage rate in gallons per hour, solids volume percent, and weight of VOC per volume solids in pounds per gallon. PM emissions from coatings were calculated by multiplying the maximum usage rate in gallons per hour, coating density in pounds per gallon, and the solids weight percent. HAP emissions from coatings were calculated by multiplying the total weight percent, coating density in pounds per gallon, and the maximum usage rate in gallons per hour. The MSDS provides volatile weight percent and total weight percent for HAPs. The total weight percent is used to calculate HAP emissions as discussed because the total weight percent represents the weight percent from the entire coating. Combustion emissions were determined using AP-42 emission factors for natural gas and propane emissions from external combustions sources. The RTO has emissions from fuel combustion to heat the incoming gas flow to be treated. RTO fuel combustion emissions are included in the emission calculations. The RTO at Crown is required to maintain an incoming gas flow temperature of 1400 degrees Fahrenheit or higher. To potentially reduce gas combustion usage and ensure appropriate gas flow temperatures, oven emissions from EQUIs 4 and 5 are included in the incoming gas flow to the RTO. VOC and HAP capture efficiencies of 75% and control efficiencies of 95% for coating lines EQUIs 8 and 9, and ovens EQUIs 4 and 5 are included under the respective emission calculations. Crown will conduct performance tests to show compliance with both efficiencies. Based on the HAP PTE emissions from coating lines, Methyl Isobutyl Ketone has a PTE greater than 10 tons per year. TREA 5 (thermal oxidizer) capture and control efficiency performance testing must include testing for this HAP to ensure that Crown takes credit for the appropriate HAP capture and control efficiencies when calculating HAPs emissions to avoid major source status for NESHAPs. Crown accepted a VOC limit of 100 tons per year for EQUIs 8 and 9 coating lines to avoid major modification status under 40 CFR 52.21. This limit is found in COMG 8 of the permit and is incorporated into the limited emission calculations for EQUIs 8 and 9. The uncontrolled hours of operation limit of 240 hour per year for EQUIs 4, 5, 8, and 9 is also incorporated into the limited emission calculations. Crown expects longer periods of time are needed for repair and


maintenance of the RTO, but Crown wants the ability to continue coating operations during downtime for RTO repair and maintenance. A limit on uncontrolled hours of operation allows Crown operational flexibility and to take credit for RTO operation when calculating future emission increases for EQUIs 4, 5, 8, and 9. Moreover, Crown is installing a fabric filter (baghouse). EQUIs 8 and 9 will vent emissions from the LSM control boxes to the baghouse before emissions are vented to the RTO. Crown is installing this baghouse for fire prevention reasons only and is not taking credit for this unit as a control device. Therefore, the baghouse is not included in the permit.

3.2 Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considered the following:

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

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

The table below summarizes the monitoring requirements associated with this amendment. Table 6. Monitoring

Subject item* Requirement (rule basis) Monitoring Discussion

COMG 2 (HAP Limits)

HAPs - Total ≤ 22.0 tons per year, on a 12 month rolling sum basis (limit to avoid major source status for NESHAPs)

Recordkeeping: Daily records of coating usage; On-going MSDS records of coating contents; Monthly calculations of emissions.

Records can be generated on a daily basis based on delivery records and monthly emissions can be calculated from daily records. For these reasons, 12 month rolling sum limits are reasonable for this Facility.

HAPs - Single ≤ 9.0 tons per year, on a 12 month rolling sum basis (limit to avoid major source status for NESHAPs)

COMG 8 (EQUIs 8 and 9)

VOC < 100 tons per year, on a 12-month rolling sum (limit to avoid major modification under 40 CFR 52.21; Minn. R. 7007.3000)

Recordkeeping: Daily records of coating usage; On-going MSDS records of coating contents; Monthly calculations of emissions.

Records can be generated on a daily basis based on written usage logs and monthly emissions can be calculated from daily records. For these reasons, 12 month rolling sum limits are reasonable for this Facility.


Subject item* Requirement (rule basis) Monitoring Discussion

COMG 9 (EQUIs controlled by TREA 5)

Uncontrolled hours of operation < 240 hours per year, on a 12-month rolling sum (limit to avoid major modification under 40 CFR 52.21; Minn. R. 7007.3000)

Recordkeeping: Daily records of operation; Monthly calculations of emissions.

Records can be generated on a daily basis based on written logs and monthly emissions can be calculated from daily records. For these reasons, 12 month rolling sum limits are reasonable for this Facility.

TREA 5 (Thermal Oxidizer)

HAPs: Capture Efficiency of 75% (limit to avoid major source status for NESHAPs; Minn. R. 7007.0800, subp. 2)

Performance Testing

Performance testing is required for HAPs and VOC capture and control efficiencies. HAP capture and control efficiency performance testing is required to include the specific HAP of Methyl Isobutyl Ketone because Methyl Isobutyl Ketone PTE is over the major source single HAP threshold of 10 tons per year. Crown must use either the capture and control efficiencies in the permit or capture and control efficiencies as determined by the performance test(s) if the performance test(s) result in a capture or control efficiency lower than what is permitted. Crown may choose to perform subsequent performance tests.

HAPs: Control Efficiency of 95% (limit to avoid major source status for NESHAPs; Minn. R. 7007.0800, subp. 2) VOC: Capture Efficiency of 75% (limit to avoid major modification under 40 CFR 52.21; Minn. R. 7007.0800, subp. 2) VOC: Control Efficiency of 95% (limit to avoid major modification under 40 CFR 52.21; Minn. R. 7007.0800, subp. 2)


Subject item* Requirement (rule basis) Monitoring Discussion Temperature Limit ≥ 1400 °F based on 3 hour rolling average at the combustion chamber (limit to avoid major source status for NESHAPs; limit to avoid major modification under 40 CFR 52.21; Minn. R. 7007.0800, subp. 2)

Continuous temperature monitoring, O & M, inspections, calibration,

Continuous temperature monitoring equipment and recordkeeping of temperature readings allows the Permittee to demonstrate compliance with the temperature limit listed in the permit.

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

3.3 Insignificant activities Crown Cork and Seal Co Inc - Owatonna has several operations which are classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix A to the permit. No insignificant activities are included in this modification.

3.4 Permit organization

In general, the permit meets the MPCA Tempo Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Tempo guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be electronically tracked (e.g., limits, submittals, etc.), should be in the Requirements table in Tempo. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these. This permit uses an appendix for maximum contents of materials. Maximum contents are used to determine PTE from coating operations. Crown may choose to use a different coating but before using that coating Crown must evaluate whether or not the contents of the coating are above maximum contents listed in Appendix B and if use of the coating triggers the need for a permit amendment. Therefore the maximum contents of materials are not necessary to enter into Tempo.

3.5 Comments received Public Notice Period: July 2nd, 2016 – August 1st, 2016 EPA Review Period: August 2nd, 2016 – August 17th, 2016 No comments were received during the public notice or EPA 45-day review period.

4. Permit fee assessment Attachment 4 to this TSD contains the MPCA’s assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R. 7002.0019. The permit action includes one permit application received after the effective date of the rule (July 1, 2009). The action includes limits taken to avoid major modification status under 40 CFR 52.21 and limits to avoid major source status under 40 CFR 63.2 (NESHAPs). Additional fees apply for each program that is avoided.


5. Conclusion Based on the information provided by Crown Cork and Seal Co Inc - Owatonna the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 14700012-101 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Andrea Walkush (permit engineer)

Tarik Hanafy (peer reviewer) Jenna Ness (enforcement) Lad Strzok (compliance) Beckie Olson (permit writing assistant) Laurie O’Brien (administrative support)

TEMPO360 Activities: Permit Change – Major (IND20150001) AQ File No. 2007; DQ 5397

Attachments: 1. PTE Summary and Emissions Increase Calculation Spreadsheets

2. Requirements development report 3. Subject item inventory/details 4. Points calculator 5. MSDS

Attachment 1 – PTE Summary and Emissions Increase Calculation Spreadsheets

PTE SUMMARY

HOURLY POTENTIAL

UNRESTRICTED POTENTIAL

LIMITED POTENTIAL

2012 ACTUAL EMISSIONS

LBS/HR TONS/YEAR TONS/YEAR TONS/YEAR

EQUI 6 (EU 001)WASHCOAT 1 FORMALDEHYDE 0.00317 0.0139 9.00 0.01

STRU 2 PM 3.92 17.2 17.2

PM10 3.92 17.2 17.2

PM2.5 3.92 17.2 17.2

VOC 3.49 15.3 15.3 8.71

SINGLE HAP 0.00317 0.0139 COMG 2TOTAL HAP 0.00317 0.0139 COMG 2

EQUI 2 (EU 002)DRYER 1 CO 0.298 1.31 1.31 0.42

STRU 3 NOX 0.517 2.27 2.27 0.50

STRU 4 PM 0.0278 0.122 0.122 0.06

PM10 0.0278 0.122 0.122 0.06

PM2.5 0.0278 0.122 0.122

SO2 0.00212 0.00928 0.00928 0.00

VOC 0.0398 0.174 0.174 0.03

CO2e 499 2,185 2,185 ARSENIC 7.06E‐07 3.09E‐06 3.09E‐06BENZENE 7.41E‐06 3.25E‐05 3.25E‐05BERYLLIUM 4.24E‐08 1.86E‐07 1.86E‐07CADMIUM 3.88E‐06 1.70E‐05 1.70E‐05CHROMIUM 4.94E‐06 2.16E‐05 2.16E‐05COBALT 2.96E‐07 1.30E‐06 1.30E‐06DICHLOROBENZENE 4.24E‐06 1.86E‐05 1.86E‐05FORMALDEHYDE 2.65E‐04 1.16E‐03 1.16E‐03LEAD 1.76E‐06 7.73E‐06 7.73E‐06MANGANESE 1.34E‐06 5.87E‐06 5.87E‐06MERCURY 9.18E‐07 4.02E‐06 4.02E‐06NAPTHALENE 2.15E‐06 9.43E‐06 9.43E‐06NICKEL 7.41E‐06 3.25E‐05 3.25E‐05HEXANE 6.35E‐03 2.78E‐02 2.78E‐02TOLUENE 1.20E‐05 5.26E‐05 5.26E‐05POM 3.11E‐07 1.36E‐06 1.36E‐06SINGLE HAP 6.35E‐03 2.78E‐02 2.78E‐02TOTAL HAP 6.67E‐03 2.92E‐02 2.92E‐02

EQUI 7 (EU 003)WASHCOAT 2 FORMALDEHYDE 0.00317 0.0139 9.00 0.01

STRU 5 PM 3.92 17.2 17.2

PM10 3.92 17.2 17.2

PM2.5 3.92 17.2 17.2

VOC 3.49 15.3 15.3 8.54

SINGLE HAP 0.00317 0.0139 COMG 2

TOTAL HAP 0.00317 0.0139 COMG 2

EQUI 3 (EU 004)DRYER 2 CO 0.298 1.31 1.31 0.42

STRU 6 NOX 0.517 2.27 2.27 0.49

STRU 7 PM 0.0278 0.122 0.122 0.06

PM10 0.0278 0.122 0.122 0.06

PM2.5 0.0278 0.122 0.122

SO2 0.00212 0.00928 0.00928 0.00

VOC 0.0398 0.174 0.174 0.03

CO2e 499 2,185 2,185 ARSENIC 7.06E‐07 3.09E‐06 3.09E‐06BENZENE 7.41E‐06 3.25E‐05 3.25E‐05BERYLLIUM 4.24E‐08 1.86E‐07 1.86E‐07CADMIUM 3.88E‐06 1.70E‐05 1.70E‐05CHROMIUM 4.94E‐06 2.16E‐05 2.16E‐05COBALT 2.96E‐07 1.30E‐06 1.30E‐06DICHLOROBENZENE 4.24E‐06 1.86E‐05 1.86E‐05FORMALDEHYDE 2.65E‐04 1.16E‐03 1.16E‐03LEAD 1.76E‐06 7.73E‐06 7.73E‐06MANGANESE 1.34E‐06 5.87E‐06 5.87E‐06MERCURY 9.18E‐07 4.02E‐06 4.02E‐06NAPTHALENE 2.15E‐06 9.43E‐06 9.43E‐06NICKEL 7.41E‐06 3.25E‐05 3.25E‐05HEXANE 6.35E‐03 2.78E‐02 2.78E‐02TOLUENE 1.20E‐05 5.26E‐05 5.26E‐05POM 3.11E‐07 1.36E‐06 1.36E‐06SINGLE HAP 6.35E‐03 2.78E‐02 2.78E‐02TOTAL HAP 6.67E‐03 2.92E‐02 2.92E‐02

EQUI 8 (EU 005)LSM 1 FORMALDEHYDE 0.219 0.96 9.00 0.67

TREA 1 PM 21.6 94.7 4.74 0.20

TREA 5 PM10 21.6 94.7 4.74 0.20

STRU 11 PM2.5 21.6 94.7 4.74

STRU 17 VOC 38.7 170 52.1 142.13

TRIETHYLAMINE 0.95 4.18 9.00

MIBK 3.60 15.8 9.00


EQUI 4 (EU 006)IBO 1 CO 0.808 3.54 3.54 1.27

TREA 5 NOX 1.40 6.13 6.13 1.51

STRU 8 PM 0.0754 0.330 0.330 0.18

STRU 17 PM10 0.0754 0.330 0.330 0.18

PM2.5 0.0754 0.330 0.330

SO2 0.00574 0.0251 0.0251 0.01

VOC 0.108 0.472 0.136 0.08

CO2e 1,351 5,917 5,917 ARSENIC 1.91E‐06 8.37E‐06 2.41E‐06BENZENE 2.01E‐05 8.79E‐05 2.53E‐05BERYLLIUM 1.15E‐07 5.02E‐07 1.44E‐07CADMIUM 1.05E‐05 4.61E‐05 1.32E‐05CHROMIUM 1.34E‐05 5.86E‐05 1.69E‐05COBALT 8.03E‐07 3.52E‐06 1.01E‐06DICHLOROBENZENE 1.15E‐05 5.02E‐05 1.44E‐05FORMALDEHYDE 7.17E‐04 3.14E‐03 9.03E‐04LEAD 4.78E‐06 2.09E‐05 6.02E‐06MANGANESE 3.63E‐06 1.59E‐05 4.57E‐06MERCURY 2.49E‐06 1.09E‐05 3.13E‐06NAPTHALENE 5.83E‐06 2.55E‐05 7.34E‐06NICKEL 2.01E‐05 8.79E‐05 2.53E‐05HEXANE 1.72E‐02 7.54E‐02 2.17E‐02TOLUENE 3.25E‐05 1.42E‐04 4.09E‐05POM 8.43E‐07 3.69E‐06 1.06E‐06SINGLE HAP 1.72E‐02 7.54E‐02 2.17E‐02TOTAL HAP 1.81E‐02 7.91E‐02 2.27E‐02

EQUI 9 (EU 007)LSM 2 FORMALDEHYDE 0.219 0.96 9.00 0.64

TREA 2 PM 21.6 94.7 4.74 0.19

TREA 5 PM10 21.6 94.7 4.74 0.19

STRU 15 PM2.5 21.6 94.7 4.74

STRU 17 VOC 38.7 170 52.1 143.42

TRIETHYLAMINE 0.95 4.18 9.00

MIBK 3.60 15.8 9.00


EQUI 5 (EU 008)IBO 2 CO 0.808 3.539 3.54 1.25

TREA 5 NOX 1.40 6.13 6.13 1.48

STRU 12 PM 0.0754 0.3303 0.330 0.18

STRU 17 PM10 0.0754 0.3303 0.330 0.18

PM2.5 0.0754 0.3303 0.330

SO2 0.0057 0.0251 0.0251 0.01

VOC 0.108 0.472 0.136 0.08

CO2e 1,351 5,917 5,917 ARSENIC 1.43E‐06 6.28E‐06 1.81E‐06BENZENE 1.51E‐05 6.59E‐05 1.90E‐05BERYLLIUM 8.60E‐08 3.77E‐07 1.08E‐07CADMIUM 7.89E‐06 3.45E‐05 9.93E‐06CHROMIUM 1.00E‐05 4.40E‐05 1.26E‐05

COBALT 6.02E‐07 2.64E‐06 7.58E‐07DICHLOROBENZENE 8.60E‐06 3.77E‐05 1.08E‐05FORMALDEHYDE 5.38E‐04 2.36E‐03 6.77E‐04LEAD 3.58E‐06 1.57E‐05 4.51E‐06MANGANESE 2.72E‐06 1.19E‐05 3.43E‐06MERCURY 1.86E‐06 8.16E‐06 2.35E‐06NAPTHALENE 4.37E‐06 1.92E‐05 5.51E‐06NICKEL 1.51E‐05 6.59E‐05 1.90E‐05HEXANE 1.29E‐02 5.65E‐02 1.62E‐02TOLUENE 2.44E‐05 1.07E‐04 3.07E‐05POM 6.32E‐07 2.77E‐06 7.96E‐07SINGLE HAP 1.72E‐02 7.54E‐02 2.17E‐02TOTAL HAP 1.81E‐02 7.91E‐02 2.27E‐02

EQUI 1 (EU 001)BOILER CO 0.870 3.81 3.81 0.84

STRU 16 NOX 1.51 6.61 6.61 1.00

PM 0.0812 0.356 0.356 0.12

PM10 0.0812 0.356 0.356 0.12

PM2.5 0.0812 0.356 0.356

SO2 0.00618 0.0271 0.0271 0.01

VOC 0.116 0.508 0.508 0.05


EQUI 10 (TK 001)INSIDE SPRAY VOC 0.001 0.003 0.003


EQUI 12 (TK 003)VARNISH VOC 0.001 0.003 0.003


INSIGNIFICANT CO 0.754 3.30 3.30 0.10

TOTAL NOX 1.31 5.73 5.73 0.17

PM 0.0704 0.308 0.308 0.01

PM10 0.0704 0.308 0.308 0.01

PM2.5 0.0704 0.308 0.308

SO2 0.00535 0.0234 0.0234 0.00

VOC 0.101 0.440 0.440 0.01


TREA 5 CO 0.329 1.44 1.44

RTO NOX 0.392 1.72 1.72

PM 0.0298 0.131 0.131

PM10 0.0298 0.131 0.131

PM2.5 0.0298 0.131 0.131

SO2 0.00235 0.0103 0.0103

VOC 0.0216 0.0945 0.0945

CO2e 467 2,047 2,047 ARSENIC 0.000000784 0.00000344 0.00000344

BENZENE 0.00000824 0.0000361 0.0000361

BERYLLIUM 0.0000000471 0.000000206 0.000000206

CADMIUM 0.00000431 0.0000189 0.0000189

CHROMIUM 0.00000549 0.0000240 0.0000240

COBALT 0.000000329 0.00000144 0.00000144

DICHLOROBENZENE 0.00000471 0.0000206 0.0000206

FORMALDEHYDE 0.000294 0.00129 0.00129

LEAD 0.00000196 0.00000859 0.00000859

MANGANESE 0.00000149 0.00000653 0.00000653

MERCURY 0.00000102 0.00000447 0.00000447

NAPTHALENE 0.00000239 0.0000105 0.0000105

NICKEL 0.00000824 0.0000361 0.0000361

HEXANE 0.00706 0.0309 0.0309

TOLUENE 0.0000133 0.0000584 0.0000584

POM 0.000000346 0.00000151 0.00000151

SINGLE HAP 0.00706 0.0309 0.0309

TOTAL HAP 0.00741 0.0324 0.0324

FACILITY TOTALSHOURLY

POTENTIAL


LIMITED POTENTIAL

ACTUAL EMISSIONS


CO 4.17 18.2 18.2 4.29

NOX 7.04 30.8 30.8 5.17

PM 51.5 225 45.5 1.00

PM10 51.5 225 45.5 1.00

PM2.5 51.5 225 45.5

SO2 0.03 0.13 0.13 0.03

VOC 85.0 372 136 303

CO2e 6,882 30,143 30,143 HAP SINGLE 7.30 32.0 9.28

HAP TOTAL 7.79 34.1 22.30

HOURLY POTENTIAL


LIMITED POTENTIAL

ACTUAL EMISSIONS


CO 3.41 14.9 14.9 4.19

NOX 5.74 25.1 25.1 4.99

PM 51.4 225 45.2 0.99

PM10 51.4 225 45.2 0.99

PM2.5 51.4 225 45.2

SO2 0.02 0.11 0.11 0.03

VOC 84.9 372 136 303

CO2e 5,621 24,621 24,621 HAP SINGLE 7.29 32.0 9.21

HAP TOTAL 7.77 34.1 22.2

FACILITY TOTALS W/O INSIGNIFICANT ACTIVITIES

Coating Density Max Production Application Rate Volume % Solids Wt VOC /Vol solids VOC Content WT % Solid Solids Content Max Total HAPs(lb/gal) (cans/min) (gal/mcans) (gal/hr) (gal/yr) lb/gal lb/gal lb/gal % lb/gal % lb/gal % lb/gal lb/gal

652‐C‐676 8.75 0.05 5.2 45,333 30.4% 2.2 0.7 34.6% 3.0 0.01% 0.001 0% 0 0% 0 0.001

642‐L‐523 8.55 0.240 24.8 217,598 22.4% 6.2 1.4 27.5% 2.4 0.10% 0.009 0% 0 0% 0 0.009

642‐W502 9.22 0.310 32.1 281,065 19.2% 5.2 1.0 28.9% 2.7 0.01% 0.0005 0% 0 0% 0 0.0005

PPG3923605 8.90 0.259 26.8 234,825 23.2% 5.3 1.2 30.4% 2.7 0% 0 0.40% 0.036 0% 0 0.04

36Q38AC 8.60 0.270 27.9 244,798 30.8% 4.5 1.4 36.0% 3.1 0.10% 0.009 0% 0 1.50% 0.129 0.14

VOC TOTAL HAP TOTAL HAPlb/hr tons/year Limited tpy lb/hr tons/year Limited tpy lb/hr ton/yr lb/hr ton/yr lb/hr ton/yr lb/hr ton/yr Controlled lb/hr Controlled tpy

EQUI 6 652‐C‐676 3.92 17.2 17.2 3.49 15.3 15.3 0.00 0.01 0 0 0 0 0.00 0.01 0.00 0.01

EQUI 7 652‐C‐676 3.92 17.2 17.2 3.49 15.3 15.3 0.00 0.01 0 0 0 0 0.00 0.01 0.00 0.01

642‐L‐523 11.0 48.0 2.40 25.9 113 5.51 0.16 0.70 0 0 0 0 0.16 0.70 0.01 0.03

642‐W502 16.0 70.2 3.51 24.0 105 5.12 0.01 0.05 0 0 0 0 0.01 0.05 0.00 0.00

PPG3923605 13.6 59.6 2.98 24.7 108 5.27 0 0 0.72 3.13 0 0 0.72 3.13 0.04 0.16

36Q38AC 16.2 71.1 3.55 29.0 127 6.19 0.18 0.79 0 0 2.70 11.8 2.88 12.63 0.14 0.63EQUI 8

Uncaptured 5.41 23.7 1.18 9.68 42.4 45.9 0.06 0.26 0.24 1.04 0.90 3.95 0.96 4.21 0.96 4.21EQUI 8 Total 21.6 94.7 4.74 38.7 170 52.1 0.22 0.96 0.95 4.18 3.60 15.8 3.85 16.8 1.11 4.84

642‐L‐523 11.0 48.0 2.40 25.9 113 5.51 0.16 0.70 0 0 0 0 0.16 0.70 0.01 0.03

642‐W502 16.0 70.2 3.51 24.0 105 5.12 0.01 0.05 0 0 0 0 0.01 0.05 0.00 0.00

PPG3923605 13.6 59.6 2.98 24.7 108 5.27 0 0 0.72 3.13 0 0 0.72 3.13 0.04 0.16

36Q38AC 16.2 71.1 3.55 29.0 127 6.19 0.18 0.79 0 0 2.70 11.84 2.88 12.63 0.14 0.63EQUI 9

Uncaptured 5.41 23.7 1.18 9.68 42.4 45.9 0.06 0.26 0.24 1.04 0.90 3.95 0.96 4.21 0.96 4.21EQUI 9 Total 21.6 94.7 4.74 38.7 170 52.1 0.22 0.96 0.95 4.18 3.60 15.8 3.85 16.8 1.11 4.84

Totals 51.1 224 43.8 84.4 370 131 *

Coating HAP Totals 0.45 1.95 1.91 8.4 7.21 31.6 7.70 33.7 2.22 9.71

8520.0 Controlled Coating HAP Totals 0.14 0.62 0.55 2.40 2.07 9.08

*COMG 9 limit of 240 hours/year uncontrolled operation of EQUIs 4, 5, 8, and 9, and COMG 8 limit of 100 tpy VOC for EQUIs 8 and 9Maximum Emissions in boldPARTICULATE EMISSION CALCULATION (INSIDE SPRAY)BASED ON 95% CONTROL ‐ ACTUAL EMISSIONS BASED ON MOST RECENT TEST REPORTINSIDE SPRAY LINES ARE CONTROLLED BY A BAFFLE FILTER DESIGNED WITH WITH A 95%+ REMOVAL EFFICIENCYCalculation:

EU USAGE = USAGE x PRODUCTION LSM CONTROL TRANSFER EFF. MIN CONTROLPM = EU USAGE x DENSITY x WT% SOLID x (1‐TRANSFER EFFICIENCY) 75% 95.0% LINE 1 ‐ RE% LINE 2 ‐ RE%PM EMISSIONS = PM x (1‐ CONTROL EFF) 99.62% 96.74%

RTO Capture Eff. Control Eff. 75% 95.0%

Formaldehyde Triethylamine MIBK

Unit Coating

Maximum Usage Rates

1725

EQUI 8 Captured

EQUI 9 Captured

RECENT PERFORMANCE TEST

Formaldehyde TriethylaminePM/PM10/PM2.5 MIBK

Coating Density Max Production Application Rate Volume % Solids Wt VOC /Vol solids VOC Content WT % Solid Solids Content Max Total HAPs(lb/gal) (cans/min) (gal/mcans) (gal/hr) (gal/yr) lb/gal lb/gal lb/gal % lb/gal % lb/gal % lb/gal lb/gal

652‐C‐676 8.75 0.05 5.2 45,333 30.4% 2.2 0.7 34.6% 3.0 0.01% 0.001 0% 0 0% 0 0.00061

642‐L‐523 8.55 0.240 24.8 217,598 22.4% 6.2 1.4 27.5% 2.4 0.10% 0.009 0% 0 0% 0 0.0086

642‐W502 9.22 0.310 32.1 281,065 19.2% 5.2 1.0 28.9% 2.7 0.01% 0.0005 0% 0 0% 0 0.00046

PPG3923605 8.90 0.259 26.8 234,825 23.2% 5.3 1.2 30.4% 2.7 0% 0 0.40% 0.036 0% 0 0.036

36Q38AC 8.60 0.270 27.9 244,798 30.8% 4.5 1.4 36.0% 3.1 0.10% 0.009 0% 0 1.50% 0.129 0.14

VOC lb/hr tons/year Limited tpy lb/hr tons/year Limited tpy

642‐L‐523 14.6 64.0 3.20 34.5 151 46.4

642‐W502 21.4 93.6 4.68 32.0 140 43.1

PPG3923605 18.1 79.4 3.97 33.0 144 44.3

36Q38AC 21.6 94.7 4.74 38.7 170 52.1

642‐L‐523 14.6 64.0 3.20 34.5 151 46.4

642‐W502 21.4 93.6 4.68 32.0 140 43.1

PPG3923605 18.1 79.4 3.97 33.0 144 44.3

36Q38AC 21.6 94.7 4.74 38.7 170 52.1Totals 43.3 189 9.47 77.5 339 104.2

Before Change 42.7 187.2 69.0 302

After Change 43.3 189.5 77.5 339

Net Change 0.51 8.47 Net change in hourly emission increases for VOC are within minor amendment thresholds Annual 2.24 37.1

Title I CalculationsFuture Potential 189 9.47 339

Baseline 0.40 (2011‐2012) 293 (2011‐2012)Increase 9.1 47 Title I NSR emission increases using future potentials for VOC require a major amendment

Limit of 100 tpy for VOCs for EQUI 8 and 9, and to have an alternating operating scenario of 240 hours per year uncontrolled emissions

Maximum Emissions in boldPARTICULATE EMISSION CALCULATION (INSIDE SPRAY)BASED ON 95% CONTROL ‐ ACTUAL EMISSIONS BASED ON MOST RECENT TEST REPORTINSIDE SPRAY LINES ARE CONTROLLED BY A BAFFLE FILTER DESIGNED WITH WITH A 95%+ REMOVAL EFFICIENCYCalculation:

EU USAGE = USAGE x PRODUCTION LSM CONTROL TRANSFER EFF. MIN CONTROLPM = EU USAGE x DENSITY x WT% SOLID x (1‐TRANSFER EFFICIENCY) 75% 95.0% LINE 1 ‐ RE% LINE 2 ‐ RE%PM EMISSIONS = PM x (1‐ CONTROL EFF) 99.62% 96.74%

RTO Capture Eff. Control Eff. 75% 95.0%

PM/PM10/PM2.5CoatingUnit

EQUI 8

EQUI 9

RECENT PERFORMANCE TEST

Maximum Usage Rates Formaldehyde Triethylamine MIBK

1725

Natural Gas Emissions: Emission factors (EF) are referenced from AP‐42 Section 1.4EF

(lbs/MMcf)

MMBtu/hr lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy

EQUI 2 ‐ Dryer 1 3.6 0.296 1.299 0.353 1.546 0.027 0.117 0.027 0.117 0.027 0.117 0.002 0.009 0.019 0.085 420 1841 0.008 0.035 0.001 0.003 421 1,843 1.76E‐06 7.73E‐06EQUI 3 ‐ Dryer 2 3.6 0.296 1.299 0.353 1.546 0.027 0.117 0.027 0.117 0.027 0.117 0.002 0.009 0.019 0.085 420 1841 0.008 0.035 0.001 0.003 421 1,843 1.76E‐06 7.73E‐06EQUI 4 ‐ Oven 9.8 0.602 2.638 0.717 3.140 0.054 0.239 0.054 0.239 0.054 0.239 0.004 0.019 0.039 0.173 854 3739 0.016 0.070 0.002 0.007 854 3,743 3.58E‐06 1.57E‐05EQUI 5 ‐ Oven 9.8 0.602 2.638 0.717 3.140 0.054 0.239 0.054 0.239 0.054 0.239 0.004 0.019 0.039 0.173 854 3739 0.016 0.070 0.002 0.007 854 3,743 3.58E‐06 1.57E‐05EQUI 1 ‐ Boiler 10.5 0.865 3.787 1.029 4.509 0.078 0.343 0.078 0.343 0.078 0.343 0.006 0.027 0.057 0.248 1226 5369 0.023 0.101 0.002 0.010 1,227 5,374 5.15E‐06 2.25E‐05Space Heaters 9.1 0.749 3.282 0.892 3.908 0.068 0.297 0.068 0.297 0.068 0.297 0.005 0.023 0.049 0.215 1062 4653 0.020 0.088 0.002 0.009 1,063 4,658 4.46E‐06 1.95E‐05TREA 3 ‐ RTO 4.0 0.329 1.443 0.392 1.718 0.030 0.131 0.030 0.131 0.030 0.131 0.002 0.010 0.022 0.094 467 2045 0.009 0.039 0.001 0.004 467 2,047 1.96E‐06 8.59E‐06

Natural Gas HAPsEF (lb/MMcf)

lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy

EQUI 2 ‐ Dryer 1 7.06E‐07 3.09E‐06 7.41E‐06 3.25E‐05 4.24E‐08 1.86E‐07 3.88E‐06 1.70E‐05 4.94E‐06 2.16E‐05 2.96E‐07 1.30E‐06 4.24E‐06 1.86E‐05 2.65E‐04 1.16E‐03 1.34E‐06 5.87E‐06 9.18E‐07 4.02E‐06 2.15E‐06 9.43E‐06 7.41E‐06 3.25E‐05 6.35E‐03 2.78E‐02 1.20E‐05 5.26E‐05 3.11E‐07 1.36E‐06EQUI 3 ‐ Dryer 2 7.06E‐07 3.09E‐06 7.41E‐06 3.25E‐05 4.24E‐08 1.86E‐07 3.88E‐06 1.70E‐05 4.94E‐06 2.16E‐05 2.96E‐07 1.30E‐06 4.24E‐06 1.86E‐05 2.65E‐04 1.16E‐03 1.34E‐06 5.87E‐06 9.18E‐07 4.02E‐06 2.15E‐06 9.43E‐06 7.41E‐06 3.25E‐05 6.35E‐03 2.78E‐02 1.20E‐05 5.26E‐05 3.11E‐07 1.36E‐06EQUI 4 ‐ Oven 1.43E‐06 6.28E‐06 1.51E‐05 6.59E‐05 8.60E‐08 3.77E‐07 7.89E‐06 3.45E‐05 1.00E‐05 4.40E‐05 6.02E‐07 2.64E‐06 8.60E‐06 3.77E‐05 5.38E‐04 2.36E‐03 2.72E‐06 1.19E‐05 1.86E‐06 8.16E‐06 4.37E‐06 1.92E‐05 1.51E‐05 6.59E‐05 1.29E‐02 5.65E‐02 2.44E‐05 1.07E‐04 6.32E‐07 2.77E‐06EQUI 5 ‐ Oven 1.43E‐06 6.28E‐06 1.51E‐05 6.59E‐05 8.60E‐08 3.77E‐07 7.89E‐06 3.45E‐05 1.00E‐05 4.40E‐05 6.02E‐07 2.64E‐06 8.60E‐06 3.77E‐05 5.38E‐04 2.36E‐03 2.72E‐06 1.19E‐05 1.86E‐06 8.16E‐06 4.37E‐06 1.92E‐05 1.51E‐05 6.59E‐05 1.29E‐02 5.65E‐02 2.44E‐05 1.07E‐04 6.32E‐07 2.77E‐06EQUI 1 ‐ Boiler 2.06E‐06 9.02E‐06 2.16E‐05 9.47E‐05 1.24E‐07 5.41E‐07 1.13E‐05 4.96E‐05 1.44E‐05 6.31E‐05 8.65E‐07 3.79E‐06 1.24E‐05 5.41E‐05 7.72E‐04 3.38E‐03 3.91E‐06 1.71E‐05 2.68E‐06 1.17E‐05 6.28E‐06 2.75E‐05 2.16E‐05 9.47E‐05 1.85E‐02 8.12E‐02 3.50E‐05 1.53E‐04 9.08E‐07 3.98E‐06Space Heaters 1.78E‐06 7.82E‐06 1.87E‐05 8.21E‐05 1.07E‐07 4.69E‐07 9.81E‐06 4.30E‐05 1.25E‐05 5.47E‐05 7.49E‐07 3.28E‐06 1.07E‐05 4.69E‐05 6.69E‐04 2.93E‐03 3.39E‐06 1.48E‐05 2.32E‐06 1.02E‐05 5.44E‐06 2.38E‐05 1.87E‐05 8.21E‐05 1.61E‐02 7.03E‐02 3.03E‐05 1.33E‐04 7.87E‐07 3.45E‐06TREA 3 ‐ RTO 7.84E‐07 3.44E‐06 8.24E‐06 3.61E‐05 4.71E‐08 2.06E‐07 4.31E‐06 1.89E‐05 5.49E‐06 2.40E‐05 3.29E‐07 1.44E‐06 4.71E‐06 2.06E‐05 2.94E‐04 1.29E‐03 1.49E‐06 6.53E‐06 1.02E‐06 4.47E‐06 2.39E‐06 1.05E‐05 8.24E‐06 3.61E‐05 7.06E‐03 3.09E‐02 1.33E‐05 5.84E‐05 3.46E‐07 1.51E‐06

Natural Gas HAPsEF (lb/MMcf)

lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy

EQUI 2 ‐ Dryer 1 6.35E‐03 2.78E‐02 6.35E‐03 2.78E‐02 6.67E‐03 2.92E‐02 6.67E‐03 2.92E‐02EQUI 3 ‐ Dryer 2 6.35E‐03 2.78E‐02 6.35E‐03 2.78E‐02 6.67E‐03 2.92E‐02 6.67E‐03 2.92E‐02EQUI 4 ‐ Oven 1.29E‐02 5.65E‐02 6.45E‐04 2.83E‐03 1.35E‐02 5.93E‐02 6.77E‐04 2.96E‐03

EQUI 4 ‐ Uncaptured 4.30E‐03 1.88E‐02 4.30E‐03 1.88E‐02 4.51E‐03 1.98E‐02 4.51E‐03 1.98E‐02EQUI 4 Total 1.72E‐02 7.54E‐02 4.95E‐03 2.17E‐02 1.81E‐02 7.91E‐02 5.19E‐03 2.27E‐02EQUI 5 ‐ Oven 1.29E‐02 5.65E‐02 6.45E‐04 2.83E‐03 1.35E‐02 5.93E‐02 6.77E‐04 2.96E‐03

EQUI 5 ‐ Uncaptured 4.30E‐03 1.88E‐02 4.30E‐03 1.88E‐02 4.51E‐03 1.98E‐02 4.51E‐03 1.98E‐02EQUI 5 Total 1.72E‐02 7.54E‐02 4.95E‐03 2.17E‐02 1.81E‐02 7.91E‐02 5.19E‐03 2.27E‐02EQUI 1 ‐ Boiler 1.85E‐02 8.12E‐02 1.85E‐02 8.12E‐02 1.94E‐02 8.51E‐02 1.94E‐02 8.51E‐02Space Heaters 1.61E‐02 7.03E‐02 1.61E‐02 7.03E‐02 1.68E‐02 7.38E‐02 1.68E‐02 7.38E‐02TREA 3 ‐ RTO 7.06E‐03 3.09E‐02 7.06E‐03 3.09E‐02 7.41E‐03 3.24E‐02 7.41E‐03 3.24E‐02

Total 0.12 0.54 0.07 0.32 0.13 0.57 0.08 0.34

Propane Emissions: Emission factors (EF) are referenced from AP‐42 Section 1.4EF

(lbs/Mgal)

MMBtu/hr lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy

EQUI 2 ‐ Dryer 1 3.6 0.298 1.307 0.517 2.265 0.028 0.122 0.028 0.122 0.028 0.122 0.001 0.003 0.040 0.174 498 2181 0.024 0.104 0.001 0.003 499 2,185 EQUI 3 ‐ Dryer 2 3.6 0.298 1.307 0.517 2.265 0.028 0.122 0.028 0.122 0.028 0.122 0.001 0.003 0.040 0.174 498 2181 0.024 0.104 0.001 0.003 499 2,185 EQUI 4 ‐ Oven 9.8 0.606 2.654 1.050 4.601 0.057 0.248 0.057 0.248 0.057 0.248 0.002 0.007 0.081 0.354 1,011 4430 0.048 0.211 0.002 0.007 1,013 4,437 EQUI 5 ‐ Oven 9.8 0.606 2.654 1.050 4.601 0.057 0.248 0.057 0.248 0.057 0.248 0.002 0.007 0.081 0.354 1,011 4430 0.048 0.211 0.002 0.007 1,013 4,437 EQUI 1 ‐ Boiler 10.5 0.870 3.811 1.508 6.606 0.081 0.356 0.081 0.356 0.081 0.356 0.002 0.010 0.116 0.508 1,452 6361 0.069 0.304 0.002 0.010 1,455 6,372 Space Heaters 9.1 0.754 3.303 1.307 5.725 0.070 0.308 0.070 0.308 0.070 0.308 0.002 0.009 0.101 0.440 1,259 5513 0.060 0.263 0.002 0.009 1,261 5,522 TREA 3 ‐ RTO NA ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐

Maximum Combustion Emissions

lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy

EQUI 2 ‐ Dryer 1 0.298 1.307 0.517 2.265 0.028 0.122 0.028 0.122 0.028 0.122 0.002 0.009 0.040 0.174 0.040 0.174 498 2,181 0.024 0.104 0.001 0.003 499 2,185 EQUI 3 ‐ Dryer 2 0.298 1.307 0.517 2.265 0.028 0.122 0.028 0.122 0.028 0.122 0.002 0.009 0.040 0.174 0.040 0.174 498 2,181 0.024 0.104 0.001 0.003 499 2,185 EQUI 4 ‐ Oven 0.606 2.654 1.050 4.601 0.057 0.248 0.057 0.248 0.057 0.248 0.004 0.019 0.081 0.354 0.004 0.018 1,011 4,430 0.048 0.211 0.002 0.007 1,013 4,437

EQUI 4 ‐ Uncaptured 0.202 0.885 0.350 1.534 0.019 0.083 0.019 0.083 0.019 0.083 0.001 0.006 0.027 0.118 0.027 0.118 337 1,477 0.016 0.070 0.001 0.002 338 1,479 EQUI 4 Total 0.808 3.539 1.401 6.134 0.075 0.330 0.075 0.330 0.075 0.330 0.006 0.025 0.108 0.472 0.031 0.136 1,349 5,907 0.064 0.282 0.002 0.009 1,351 5,917 EQUI 5 ‐ Oven 0.606 2.654 1.050 4.601 0.057 0.248 0.057 0.248 0.057 0.248 0.004 0.019 0.081 0.354 0.004 0.018 1,011 4,430 0.048 0.211 0.002 0.007 1,013 4,437

EQUI 5 ‐ Uncaptured 0.202 0.885 0.350 1.534 0.019 0.083 0.019 0.083 0.019 0.083 0.001 0.006 0.027 0.118 0.027 0.118 337 1,477 0.016 0.070 0.001 0.002 338 1,479 EQUI 5 Total 0.808 3.539 1.401 6.134 0.075 0.330 0.075 0.330 0.075 0.330 0.006 0.025 0.108 0.472 0.031 0.136 1,349 5,907 0.064 0.282 0.002 0.009 1,351 5,917 EQUI 1 ‐ Boiler 0.870 3.811 1.508 6.606 0.081 0.356 0.081 0.356 0.081 0.356 0.006 0.027 0.116 0.508 0.116 0.508 1,452 6,361 0.069 0.304 0.002 0.010 1,455 6,372 Space Heaters 0.754 3.303 1.307 5.725 0.070 0.308 0.070 0.308 0.070 0.308 0.005 0.023 0.101 0.440 0.101 0.440 1,259 5,513 0.060 0.263 0.002 0.009 1,261 5,522 TREA 3 ‐ RTO 0.329 1.443 0.392 1.718 0.030 0.131 0.030 0.131 0.030 0.131 0.002 0.010 0.022 0.094 0.022 0.094 467 2,045 0.009 0.039 0.001 0.004 467 2,047

75% 95%

6.6E‐03 2.2E‐04

SOx CO2 CH4 N2O CO2eCO NOx PM PM10 PM2.5 VOC VOC Limited

Manganese Napthalene

Single HAP

Nickel

Total HAP

2.00E‐04 2.10E‐03 1.20E‐05 1.10E‐03 1.40E‐03 8.40E‐05 1.20E‐03 7.50E‐02 3.80E‐04 2.60E‐04

Single Limited

Hexane Toluene POMMercury

3.40E‐03 8.82E‐056.10E‐04 2.10E‐03 1.80E+00

CH4 (lb/MMBtu) N2O (lb/MMBtu) CO2e

Cobalt

CO NOx PM PM10 PM2.5

Arsenic Benzene Beryllium Cadmium Chromium Dichlorobenzene Formaldehyde

Lead 0.0005

CO2 (lb/MMBtu)

116.7

CH4 (lb/MMBtu)

2.2E‐03N2O (lb/MMBtu)

2.2E‐04CO2ePM10

7.684

NOx

100

PM

7.6

CO PM2.5

7.6

SOx

0.6

VOC

5.5

Total Limited

0.7 0.0 1.08 13 0.7 0.7

SOx VOC

Capture Eff.

Control Eff. RTO

CO2 (lb/MMBtu)

1.89E+00

138.3

SEE "Crown Cork Actual Emissions, EI 2012" for editable spreadsheetPARTICULATE EMISSION CALCULATION (INSIDE SPRAY)

MATERIAL USAGE DENSITY WT % SOLID TRANSFER EFF. TOTAL PM (TONS)GALLON LBS/GALLON LINE 1 0.198314173 EU 005

G 642‐L‐523 300308 8.55 0.275 0.75 LINE 2 0.194700497 EU 007W 642‐W‐502 78752 9.22 0.289 0.75

gr 3923605 59545 8.9 0.31 0.75

wa 652‐C‐676 51180 8.75 0.346 NA

Unit Unit Description Crown ID Production EU USAGE PM PM CONTROL PM EMISSIONS

GALLONS LBS TONS (FILTER) TONS

EU 005 LINE 1 GOLD +ADD 0.499795613 150092.6208 88226.31868 44.11315934 0.997 0.132339478

EU 005 LINE 1 WHITE 0.950135889 74825.1015 43983.12998 21.99156499 0.997 0.065974695

EU 005 LINE 1 GREY 0 0 0 0 0.997 0

EU 007 LINE 2 GOLD 0.500204387 157347.3792 92490.75632 46.24537816 0.997 0.138736134

EU 007 LINE 2 WHITE 0.049864111 3926.898498 2308.280023 1.154140012 0.997 0.00346242

EU 007 LINE 2 GREY 1 59545 35001.29531 17.50064766 0.997 0.052501943

INSIDE SPRAY LINES ARE CONTROLLED BY A BAFFLE FILTER WITH A 99.70% REMOVAL EFFICIENCY

Calculation:

EU USAGE = USAGE x PRODUCTIONPM = EU USAGE x DENSITY x WT% SOLID x (1‐TRANSFER EFFICIENCY)PM EMISSIONS = PM x (1‐ CONTROL EFF)

VOC DATA SUMMARY BY EMISSION UNIT

VOC ‐ CAN PRODUCTION Unit Crown ID Production THROUGH PUT THROUGH PUT VOC EMISSIONS FORMALDEHYDE TRIETHYLAMINE CELLOSOLVE

Unit Description GALLONS TONS TONS TONS TONS TONS

WASHCOAT 1 EU 001 0.504931861 25842.41264 113.0605553 8.705533546 0.007348936 0 0

WASHCOAT 2 EU 003 0.495068139 25337.58736 110.8519447 8.535473054 0.007205376 0 0

INSIDE SPRAY 1 EU 005 0.504931861 221465.6388 965.3482573 142.1322829 0.665792014 0.0898632 1.1382672

INSIDE SPRAY 2 EU 007 0.495068139 217139.3612 946.4904127 143.4244847 0.643437956 0.79492575 0

303.0723487 1.323784283 0.88478895 1.1382672

VOC ‐ TANKS Unit Crown ID SIZE THROUGH PUT THROUGH PUT VOC EMISSIONS

Unit Description GALLONS TONS TONS ADD COATING INCLUDED WITH EU 005INSIDE SPRAY TK 001 GOLD 8000 300308 1283.8167 0 224271.3612 GALLONS

INSIDE SPRAY TK002 WHITE 8000 78752 363.04672 0 995.3026573 TONS

WASHCOAT TK003 WASH 8000 51180 223.9125 0 VOC 147.9519949 TONS

INSIDE SPRAY TK004 GREY 8000 59545 264.97525 0

308.8920607

SEE "Crown Cork Actual Emissions, EI 2012" for editable spreadsheetFUEL BURNING EMISSION CALCULATIONSNATURAL GAS

OWATONNA 2012

YEARLY USAGE 1032526 THERM

YEARLY USAGE 99.8452642 MMCF

DAILY USAGE 0.293662542 MMCF

Natural Gas Usage POLLUTANT EMISSION RATEEMISSION BREAKDOWN MMCF PM‐10 NOx CO VOC SOx AMMONIA

Annual Emission (tons/yr) 99.8452642 0.599071585 4.99226321 4.193501096 0.274574477 0.029953579 0.159752423

Daily Emission (lbs/day) 0.293662542 3.523950501 29.36625418 24.66765351 1.61514398 0.176197525 0.939720134

Emission Factors (AP‐42): Natural Gas CONVERSION FACTORNOx 100 lbs/million Ft3 96.7 cu ft/thermPM‐10 12 lbs/million Ft3 340 OPERATION DAYSSOx 0.6 lbs/million Ft3CO 84 lbs/million Ft3VOC 5.5 lbs/million Ft3Ammonia 3.2 lbs/million Ft3

Annual Emissions = YEARLY USAGE(MM CUFT) X EMISSION FACTOR / 2000 (LBS/TON)= TON/YRDaily Emissions = YEARLY EMISSIONS (TON/YR) X 2000 (LBS/TON) / 260 (OP DAYS/YR) = LB/DAY

BY EMISSION UNIT ‐ TONS PER YEARNatural Gas Usage POLLUTANT EMISSION RATEEMISSION BREAKDOWN MMCF PM‐10 NOx CO VOC SOx AMMONIA

DRYER 1 EU 2 10.08301101 0.060498066 0.504150551 0.423486462 0.02772828 0.003024903 0.016132818

DRYER 2 EU 4 9.88604183 0.059316251 0.494302091 0.415213757 0.027186615 0.002965813 0.015817667

IBO1 EU 6 30.24903303 0.181494198 1.512451652 1.270459387 0.083184841 0.00907471 0.048398453

IBO2 EU 8 29.65812549 0.177948753 1.482906274 1.245641271 0.081559845 0.008897438 0.047453001

BOILER EU 10 19.96905284 0.119814317 0.998452642 0.838700219 0.054914895 0.005990716 0.031950485

TOTAL 99.8452642 0.599071585 4.99226321 4.193501096 0.274574477 0.029953579 0.159752423

PROPANE

TOTAL EU 9 26.872 0.0094052 0.174668 0.10077 0.013436 0.000241848 0

Attachment 2 – Requirements development report

Subject Item Sequence # Type Parameter CAS # Usage Description Description Source Regulatory Program Citation Status Inspectable Flag Requirement ID Profile Inactive Flag

COMG0000000002 GP007 3860 Limitation HAPs ‐ Total 0

These requirements are entered at the unit or group level. The template assumes that it is listedat a group. HAP limit taken to avoid major under Part 63; add citations as needed (e.g., 70.2). The optional text includes language for credit for recovery/recycling of materials.

[Stage 1] The Permittee shall limit emissions of HAPs ‐ Total <= 22.0 tons per year 12‐month rolling sum to be calculated by the 15th day of each month for the previous 12‐month period. HAP contents for each HAP‐containing material (i.e. coatings, gun cleaner, etc.) shall be determined as described under the Material Content requirement in COMG 2. [Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] IND20150001 Air

[Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] Agency Modified Standard Requirement TRUE 1077986

COMG0000000002 GP007 3870 Limitation HAPs ‐ Single 0

These requirements are entered at the unit or group level. The template assumes that it is listedat a group. HAP limit taken to avoid major under Part 63; add citations as needed (e.g., 70.2). The optional text includes language for credit for recovery/recycling of materials.

[Stage 1] The Permittee shall limit emissions of HAPs ‐ Single <= 9.0 tons per year 12‐month rolling sum to be calculated by the 15th day of each month for the previous 12‐month period. HAP contents for each HAP‐containing material (i.e. coatings, gun cleaner, etc.) shall be determined as described under the Material Content requirement in COMG 2. [Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] IND20150001 Air

[Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] Agency Modified Standard Requirement TRUE 1077985

COMG0000000002 GP007 3890 Text

This Profile is for facility‐wide limits with no flexibility provisions. See the PreCap Profile for flexible limits. Use when can do records on a daily basis. If not able to do daily records, specify frequency as close to daily as possible (e.g., weekly). Edit citations as needed ‐ should be the same citation as the limit. Default citation is to avoid major source for NSR.

[Stage 1] Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the total quantity of all coatings and other HAP‐containing materials used at the facility. This shall be based on delivery records. [Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] IND20150001 Air

[Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] Agency Modified Standard Requirement TRUE 1077988

COMG0000000002 GP007 3900 Text HAPs 0

Basic formula. If control or emissions factors are used, need to add this option.

HAPs: Monthly Recordkeeping. By the 15th of the month, the Permittee shall calculate and record the following using the formulas specified in this permit: 1) The total HAP‐containing materials used in the previous calendar month using the daily usage records. This record shall also include the individual and total HAP contents of each HAP‐containing material used in the previous month, as determined by the Material Content requirement of this permit; 2) The total and individual HAP emissions for the previous month using the formulas specified in this permit; and 3) The 12‐month rolling sum total and individual HAP emissions for the previous 12‐month period by summing the monthly emissions data for the previous 12 months. [Minn. R. 7007.0800, subps. 4‐5] IND20150001 Air [Minn. R. 7007.0800, subps. 4‐5] Agency Modified Standard Requirement TRUE 1091314

COMG0000000002 GP007 3910 Text HAPs 0

Basic formula. If control or emissions factors are used, need to add this option.

HAPs: Monthly Calculation ‐‐ HAP Emissions. The Permittee shall calculate each individual HAP and total HAP emissions using equations specified in this permit for EQUIs 6, 7, 8, and 9. Each individual HAP and total HAP emissions from EQUIs 6, 7, 8, and 9 shall be summed to determine the previous month and 12‐month rolling sum HAP emissions for the previous 12‐month period for COMG 2 emissions. HAP Emissions (tons/month) = Sum of [H] Where: H = the amount of each pollutant (total HAP or each individual HAP), used, in tons/month, as calculated for EQUIs 6, 7, 8, and 9 in this permit. [Minn. R. 7007.0800, subps. 4‐5] IND20150001 Air [Minn. R. 7007.0800, subps. 4‐5] Agency Modified Standard Requirement TRUE 1077990

COMG0000000002 GP007 3920 Text

Defines method used to determine the material content of materials used. Edit [ ] text.

Material Content. HAPs contents in coating materials shall be determined by the 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 givenon the SDS or the MSDS, the highest number in the range shall be used in all compliance calculations. If information is provided in the Regulatory Section of the SDS, the highest number in the range of that section may be used. Other alternative methods approved by the MPCA may be used to determine the HAPs contents. The Commissioner reserves the right to require the Permittee to determine the HAP 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 supersedethe SDS or the MSDS. [Minn. R. 7007.0800, subps. 4‐5] IND20150001 Air [Minn. R. 7007.0800, subps. 4‐5] Agency Modified Standard Requirement TRUE 1077991

COMG0000000002 GP007 3930 Text

You need to create an Appendix that documents the material contents (and perhaps other assumptions) that were used to determine the hourly PTE. An example of "other assumptions" is spray gun transfer efficiency, line speed, spray or equipment capacity, etc.. Edit the locational data to reflect where the units appear in the permit (can list the Subject Items if not in a GP).

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 2. 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] IND20150001 Air [Minn. R. 7005.0100, subp. 35a] Agency Modified Standard Requirement TRUE 1091352

COMG0000000008 1 Limitation Volatile Organic Compounds 0

These requirements are entered at the unit or group level. The template assumes that it is listedat a group. Default citation is a limit taken to avoid major source under New Source Review (Section 52.21). Edit citation as needed. The optional text includes language for credit for recovery/recycling of materials.

[Stage 1] The Permittee shall limit emissions of Volatile Organic Compounds <= 100 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. VOC contents for each VOC‐containing material shall be determined as described under the Material Content requirement in COMG 8. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air

[Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] Agency Modified Standard Requirement TRUE 1119642

COMG0000000008 3860 Text

This Profile is for facility‐wide limits with no flexibility provisions. See the PreCap Profile for flexible limits. Use when can do records on a daily basis. If not able to do daily records, specify frequency as close to daily as possible (e.g., weekly). Edit citations as needed ‐ should be the same citation as the limit. Default citation is to avoid major source for NSR.

[Stage 1] Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the following: ‐total quantity (tons) of all coatings and other VOC, solids, and HAP‐containing materials used when COMG 8 EQUIs vented to TREA 5 and TREA 5 was in operation. This shall be based on written usage logs. ‐total quantity (tons) of all coatings and other VOC, solids, and HAP‐containing materials used when COMG 8 EQUIs did not vent to TREA 5 or during periods of non‐operation of TREA 5. This shall be based on written usage logs. [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] IND20150001 Air

[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] Agency Modified Standard Requirement TRUE 1119638

COMG0000000008 3870 Text

Defines method used to determine the material content of materials used. Edit [ ] text.

Material Content. VOC, HAPs, and Solids (PM, PM IND20150001 Air [Minn. R. 7007.0800, subps. 4‐5] Agency Modified Standard Requirement TRUE 1119639

COMG0000000008 3890 Text

You need to create an Appendix that documents the material contents (and perhaps other assumptions) that were used to determine the hourly PTE. An example of "other assumptions" is spray gun transfer efficiency, line speed, spray or equipment capacity, etc.. Edit the locational data to reflect where the units appear in the permit (can list the Subject Items if not in a GP).

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 8. 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] IND20150001 Air [Minn. R. 7005.0100, subp. 35a] Agency Modified Standard Requirement TRUE 1119641

COMG0000000008 4040 Text Volatile Organic Compounds 0

Basic VOC formula. If control or emissions factors are used, need to add this option.

g p y

Recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following: 1a) The total usage of VOC‐containing materials used in EQUI 8 when EQUI 8 vented to TREA 5 and TREA 5 was in operation 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; 1b) The total usage of VOC‐containing materials used in EQUI 9 when EQUI 9 vented to TREA 5 and TREA 5 was in operation 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; 2a) The total usage of VOC‐containing materials used in EQUI 8 when EQUI 8 did not vent to TREA 5 or during periods of non‐operation of TREA 5 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; 2b) The total usage of VOC‐containing materials used in EQUI 9 when EQUI 9 did not vent to TREA 5 or during periods of non‐operation of TREA 5 for the previous calendar month using the daily usage records. This record shall also include the VOC and solids contents of each material as IND20150001 Air [Minn. R. 7007.0800, subps. 4‐5] Agency Modified Standard Requirement TRUE 1119645

COMG0000000008 4050 Text Volatile Organic Compounds 0

Basic VOC formula. If control or emissions factors are used, need to add this option.

g p y

Calculation ‐‐ VOC Emissions. The Permittee shall calculate VOC emissions using the following equations: 1) VOC Emissions (tons/month) = V = V1 + V2 2) Use the following equations to calculate VOC emissions when EQUI 8 or EQUI 9 vents to TREA 5, TREA 5 is in operation, and credit for capture and control can be taken. V1 = UE + CE UE = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] * (1 ‐ CAE) CE = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] * CAE * (1 ‐ COE) Where: V1 = the amount of VOC, in tons/month when EQUI 8 or EQUI 9 operated controlled. UE = uncaptured emissions CE = captured and controlled emissions A# = amount of each VOC‐containing coating used in the previous month, in tons/month. B# = weight percent of VOC in A#, as a fraction (e.g., 50% is 0.50). CAE = capture efficiency as determined under TREA 5, as a fraction (e.g., 50% is 0.50). COE = control efficiency as determined under TREA 5, as a fraction (e.g., 50% is 0.50). 2) Use the following equation to calculate VOC emissions when EQUI 8 or EQUI 9 is not vented to TREA 5, TREA 5 is not in operation, or when credit for capture and control cannot be taken. V2 = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] Where: V2 = the amount of VOC, in tons/month when EQUI 8 or EQUI 9 operated uncontrolled. A# = amount of each VOCcontaining coating used in the previous month, in tons/month. B# = weight percent of VOC in A#, IND20150001 Air [Minn. R. 7007.0800, subps. 4‐5] Agency Modified Standard Requirement TRUE 1119646

COMG0000000008 4060 Submittal/Action

The default language is for a VOC 12‐month rolling sum to avoid NSR. Edit the language as needed for other pollutants, limit format (e.g., production, 30‐day limit, etc.), or program requirements (e.g., Part 70).

The Permittee shall submit an annual report : Due annually, by the 31st of January The report shall document the VOC 12‐month rolling sum calculations for the previous calendar year. The report shall be submitted with the annual Compliance Certification required by this permit. [Minn. R. 7007.0800, subp. 2] IND20150001 Air [Minn. R. 7007.0800, subp. 2] Agency Modified Standard Requirement TRUE 1119633

COMG0000000009 1 Limitation Hours

Use this requirement if you will be limiting the hours of operation of the subject item to avoid an applicable requirement. Default citation is a limit taken to avoid major source under New Source Review (Section 52.21). Edit citation as needed.

[Stage 1] The Permittee may operate EQUIs 4, 5, 8, and 9 without venting to TREA 5 for a period of uncontrolled Hours <= 240 hours 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. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


COMG0000000009 2 Text

Daily recordkeeping for limiting the hours of operation of the subject item to avoid an applicable requirement. Default citation is a limit taken to avoid major source under New Source Review (Section 52.21). Edit citation as needed.

[Stage 1] Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain a record of the total hours of controlled and uncontrolled operation for EQUI 8 and EQUI 9. The Permittee shall document periods of operation and non‐operation of TREA 5 when EQUI 8 and EQUI 9 are in operation. This shall be based on written logs. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


COMG0000000009 3 Text

Monthly Recordkeeping for limiting the hours of operation of the subject item to avoid an applicable requirement.

Monthly Recordkeeping. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total hours of uncontrolled operation for the previous calendar month using the daily records; and 2) The 12‐month rolling sum hours of uncontrolled operation for the previous 12‐month period by summing the monthly hours of uncontrolled operation for the previous 12 months. [Minn. R. 7007.0800, subps. 4‐5] IND20150001 Air [Minn. R. 7007.0800, subps. 4‐5] Agency Modified Standard Requirement TRUE 1120320

EQUI0000000001 EU010 2 Text

Fuel type: Natural gas and propane only by design. [Minn. R. 7005.0100, subp. 35a] Air [Minn. R. 7005.0100, subp. 35a] Agency Custom Requirement TRUE 664148

EQUI0000000001 EU010 4570 Text

The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. [40 CFR 60.7(a)(4), Minn. R. 7019.0100, subp. 1] IND20150001 Air [40 CFR 60.7(a)(4), Minn. R. 7019.0100, subp. 1] Standard Library Requirement TRUE 1030936

Air, Permitting, Individual Permits, Federal Requirements, NSPS, Dc, Natural Gas. N

EQUI0000000001 EU010 4600 Text

Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b), Minn. R. 7019.0100, subp. 1] IND20150001 Air [40 CFR 60.7(b), Minn. R. 7019.0100, subp. 1] Standard Library Requirement TRUE 1030939


EQUI0000000001 EU010 4610 Text

Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two years. [40 CFR 60.7(f), Minn. R. 7007.0800, subp. 5(C), Minn. R. 7019.0100, subp. 1] IND20150001 Air

[40 CFR 60.7(f), Minn. R. 7007.0800, subp. 5(C), Minn. R. 7019.0100, subp. 1] Standard Library Requirement TRUE 1030940


EQUI0000000001 EU010 4630 Text

No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. [40 CFR 60.12, Minn. R. 7011.0050] IND20150001 Air [40 CFR 60.12, Minn. R. 7011.0050] Standard Library Requirement TRUE 1030942


EQUI0000000001 EU010 4830 Text

Updated August 2009. If the unit burns natural gas, the Permittee may do monthly records.

Recordkeeping: By the last day of each calendar month, the Permittee shall record the amount of natural gas and propane combusted in the boiler during the previous calendar month. These records shall consist of purchase records, receipts, or fuel meter readings. [40 CFR 60.48c(g), Minn. R. 7011.0570] IND20150001 Air [40 CFR 60.48c(g), Minn. R. 7011.0570] Agency Modified Standard Requirement TRUE 1086181

EQUI0000000002 EU002 1 Limitation Opacity 0

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)] IND20150001 Air [Minn. R. 7011.0610, subp. 1(A)(2)] Standard Library Requirement TRUE 1030824

Air, Permitting, Individual Permits, Minnesota Performance Stds, Direct Heating Equipment, On or after July 9, 1969, PM Limit. N

EQUI0000000002 EU002 3450 Limitation Total Particulate Matter 0

DHE requirements go into all permits with direct heating equipment for which a standard of performance has not been promulgated in a specific rule. Select the appropriate particulate matter limit profile. Pre‐1969 equipment is defined as equipment which was in operation before July 9, 1969 (7011.0710), otherwise it is Post 1969 (7011.0715). Select this limit, when 7011.0715, subp 2 or 3 does not apply. See Minn. R. 7011.0610, subp. 1(B) for an existing gray iron cupola with a melting capacity of less than 1‐1/2 tons per hour

Total 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)] IND20150001 Air [Minn. R. 7011.0610, subp. 1(A)(1)] Standard Library Requirement TRUE 1075273


EQUI0000000002 EU002 3460 Text









EQUI0000000003 EU004 3460 Text









EQUI0000000004 EU006 3460 Text









EQUI0000000005 EU008 3460 Text



Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] IND20150001 Air [Minn. R. 7011.0715, subp. 1(B)] Standard Library Requirement TRUE 1030847

Air, Permitting, Individual Permits, Minnesota Performance Stds, Industrial Process Equipment, On or after July 9, 1969, PM Limit. N


IPER requirements go into all permits with industrial process equipment for which a standard of performance has not been promulgated in a specific rule. Select the appropriate IPER particulate matter profile. Pre‐1969 equipment is defined as equipment which was in operation before July 9, 1969 (7011.0710), otherwise it is Post 1969 (7011.0715). Select this profile when subp. 2 or 3 does not apply.

Total 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)] IND20150001 Air [Minn. R. 7011.0715, subp. 1(A)] Standard Library Requirement TRUE 1075283


EQUI0000000006 EU001 3 Text

Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the total quantity of all coatings and other HAP‐containing materials used in EQUI 6. This shall be based on delivery records. [Minn. R. 7007.0800, subp. 4‐5, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] IND20150001 Air

[Minn. R. 7007.0800, subp. 4‐5, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] Agency Custom Requirement FALSE 1098911

EQUI0000000006 EU001 4 Text

Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following information: 1) Tons of each type of coating used in EQUI 6 for the previous month and previous 12 months. This record shall also include the individual and total HAP contents of each HAP‐containing material used in the previous month, as determined by the Material Content requirement of this permit; 3) The total and individual HAP emissions for the previous month using the formulas specified in this permit; and 4) The 12‐month rolling sum total and individual HAP emissions for the previous 12‐month period by summing the monthly emissions data for the previous 12 months. [Minn. R. 7007.0800, subp. 4‐5] IND20150001 Air [Minn. R. 7007.0800, subp. 4‐5] Agency Custom Requirement FALSE 1098910

EQUI0000000006 EU001 5 Text

HAPs: Monthly Calculation ‐‐ HAP Emissions. The Permittee shall calculate each individual HAP and total HAP emissions using the following equation: HAP Emissions (tons/month) = H H = (A1 x B1) + (A2 x B2) + (A3 x B3) + .... Where: H = the amount of each pollutant (total HAP or each individual HAP), used in EQUI 6, in tons/month. A# = amount of each HAP‐containing material used in the previous month, in tons/month. B# = weight percent of each individual or total HAP in A#, as a fraction (e.g., 50% is 0.50). [Minn. R. 7007.0800, subp. 4‐5] IND20150001 Air [Minn. R. 7007.0800, subp. 4‐5] Agency Custom Requirement FALSE 1098909








EQUI0000000007 EU003 3 Text

Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the total quantity of all coatings and other HAP‐containing materials used in EQUI 7. This shall be based on delivery records. [Minn. R. 7007.0800, subp. 4‐5, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] IND20150001 Air


EQUI0000000007 EU003 4 Text

Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following information: 1) Tons of each type of coating used in EQUI 7 for the previous month and previous 12 months. This record shall also include the individual and total HAP contents of each HAP‐containing material used in the previous month, as determined by the Material Content requirement of this permit; 3) The total and individual HAP emissions for the previous month using the formulas specified in this permit; and 4) The 12‐month rolling sum total and individual HAP emissions for the previous 12‐month period by summing the monthly emissions data for the previous 12 months. [Minn. R. 7007.0800, subp. 4‐5] IND20150001 Air [Minn. R. 7007.0800, subp. 4‐5] Agency Custom Requirement FALSE 1098907

EQUI0000000007 EU003 5 Text

HAPs: Monthly Calculation ‐‐ HAP Emissions. The Permittee shall calculate each individual HAP and total HAP emissions using the following equation: HAP Emissions (tons/month) = H H = (A1 x B1) + (A2 x B2) + (A3 x B3) + .... Where: H = the amount of each pollutant (total HAP or each individual HAP), used in EQUI 7, in tons/month. A# = amount of each HAP‐containing material used in the previous month, in tons/month. B# = weight percent of each individual or total HAP in A#, as a fraction (e.g., 50% is 0.50). [Minn. R. 7007.0800, subp. 4‐5] IND20150001 Air [Minn. R. 7007.0800, subp. 4‐5] Agency Custom Requirement FALSE 1098906


The Permittee shall limit emissions of Total Particulate Matter <= 1.30 pounds per hour 3‐hour average from EQUI 8 and associated pollution control equipment (TREA 1). The emission rate is equal to the 3‐Hour average of solids applied and that are not collected on the can surfaces and the LSM Collection Box. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air

[Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] Agency Custom Requirement TRUE 1086161

EQUI0000000008 EU005 3 Limitation PM < 10 micron 0

The Permittee shall limit emissions of PM < 10 micron <= 1.30 pounds per hour 3‐hour average from EQUI 8 and associated pollution control equipment (TREA 1). The emission rate is equal to the 3‐Hour average of solids applied and that are not collected on the can surfaces and the LSM Collection Box. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


EQUI0000000008 EU005 4 Limitation PM < 2.5 micron 0

The Permittee shall limit emissions of PM < 2.5 micron <= 1.30 pounds per hour 3‐hour average from EQUI 8 and associated pollution control equipment (TREA 1). The emission rate is equal to the 3‐Hour average of solids applied and that are not collected on the can surfaces and the LSM Collection Box. [Minn. R. 7007.0800, subp. 2] IND20150001 Air [Minn. R. 7007.0800, subp. 2] Agency Custom Requirement TRUE 1086163








EQUI0000000008 EU005 20230 Submittal/Action PM < 10 micron 0

g g

where initial testing has been completed so that the first due date is known. Delete if not needed. Edit test method as needed. Default is to test to measure emissions. Edit or add as needed, "verify PM10 control efficiency". You must edit the "Date" field to be the due date of the next test. If the due date of the next test is not known, you can revise the condition to have a Custom Schedule is used with trigger Task, or when possible, permit staff may choose to switch from Custom schedule to Schedule based off Permit Issuance. Default frequency is for 60‐month frequency. Edit as needed. Testing may be required at different frequencies according to AQ guidance. Tempo language for recurring test must be worded very carefully in order to ensure that all related requirements are trackable. See guidance under VOC limit if maximum achievable operating rate is undefined and you need to set a short‐term process throughput limit. Default citation is to avoid PSD. Edit citations as needed to reflect reason for test (Title I Conditions, etc.). If the performance testing is required under NESHAP, include citation for 40 CFR 63.7 and any citation specific to the standard. If the testing is required under NSPS, include citation for 40 CFR 60.8(a) and any citation specific to the standard. Always include the Minn. R. 7017 citation. Test extension amendments or re‐tests do not extend the original schedule for the recurring tests. Early

PM < 10 micron : The Permittee shall conduct a performance test : Due before 04/01/2018 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Each performance test shall consist of at least three separate test runs. The sampling time per run is one hour. Each run will measure the amount of solids applied (S), the amount of solids deposited on the cans (C) and the amount of solids captured by control box, TREA 1 (B). The emission rate for each run = S ‐ C ‐ B. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air

[Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] Agency Modified Standard Requirement TRUE 1086435

EQUI0000000008 EU005 20240 Submittal/Action PM < 2.5 micron 0

g g

where initial testing has been completed so that the first due date is known. Delete if not needed. Edit test method as needed. Default is to test to measure emissions. Edit or add as needed, "verify PM2.5 control efficiency". You must edit the "Date" field to be the due date of the next test. If the due date of the next test is not known, you can revise the condition to have a Custom Schedule is used with trigger Task, or when possible, permit staff may choose to switch from Custom schedule to Schedule based off Permit Issuance. Default frequency is for 60‐month frequency. Edit as needed. Testing may be required at different frequencies according to AQ guidance. Tempo language for recurring test must be worded very carefully in order to ensure that all related requirements are trackable. See guidance under VOC limit if maximum achievable operating rate is undefined and you need to set a short‐term process throughput limit. Default citation is to avoid PSD. Edit citations as needed to reflect reason for test (Title I Conditions, etc.). If the performance testing is required under NESHAP, include citation for 40 CFR 63.7 and any citation specific to the standard. If the testing is required under NSPS, include citation for 40 CFR 60.8(a) and any citation specific to the standard. Always include the Minn. R. 7017 citation. Test extension amendments or re‐tests do not extend the original schedule for the recurring tests. Early

PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 04/01/2018 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Each performance test shall consist of at least three separate test runs. The sampling time per run is one hour. Each run will measure the amount of solids applied (S), the amount of solids deposited on the cans (C) and the amount of solids captured by control box, TREA 1 (B). The emission rate for each run = S ‐ C ‐ B. [Minn. R. 7017.2020, subp. 1] IND20150001 Air [Minn. R. 7017.2020, subp. 1] Agency Modified Standard Requirement TRUE 1086436

EQUI0000000008 EU005 20250 Submittal/Action Total Particulate Matter 0

g g

initial testing has been completed so that the first due date is known. Delete if not needed. Edit test method as needed. Default is to test to measure emissions. Edit or add as needed, "verify PM control efficiency". You must edit the "Date" field to be the due date of the next test. If the due date of the next test is not known, you can revise the condition to have a Custom Schedule is used with trigger Task, or when possible, permit staff may choose to switch from Custom schedule to Schedule based off Permit Issuance. Default frequency is for 60‐month frequency. Edit as needed. Testing may be required at different frequencies according to AQ guidance. Tempo language for recurring test must be worded very carefully in order to ensure that all related requirements are trackable. See guidance under VOC limit if maximum achievable operating rate is undefined and you need to set a short‐term process throughput limit. Default citation is to avoid PSD. Edit citations as needed to reflect reason for test (Title I Conditions, etc.). If the performance testing is required under NESHAP, include citation for 40 CFR 63.7 and any citation specific to the standard. If the testing is required under NSPS, include citation for 40 CFR 60.8(a) and any citation specific to the standard. Always include the Minn. R. 7017 citation. Test extension amendments or re‐tests do not extend the original schedule for the recurring tests. Early

conduct a performance test : Due before 04/01/2018 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date.The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Each performance test shall consist of at least three separate test runs. The sampling time per run is one hour. Each run will measure the amount of solids applied (S), the amount of solids deposited on the cans (C) and the amount of solids captured by control box, TREA 1 (B). The emission rate for each run = S ‐ C ‐ B. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


EQUI0000000008 EU005 20251 Text

Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the following: ‐tons of each type of coating used in EQUI 8 when EQUI 8 vented to TREA 5 and TREA 5 was in operation. This shall be based on delivery records. ‐tons of each type of coating used in EQUI 8 when EQUI 8 did not vent to TREA 5 or during periods of non‐operation of TREA 5. This shall be based on delivery records. [Minn. R. 7007.0800, subp. 4‐5, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] IND20150001 Air


EQUI0000000008 EU005 20252 Text

Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following information: 1) Tons of each type of coating used in EQUI 8 when EQUI 8 vented to TREA 5 and TREA 5 was in operation for the previous month. This record shall also include the individual and total HAP contents of each HAP‐containing material used in the previous month, as determined by the Material Content requirement of this permit; 2) Tons of each type of coating used in EQUI 8 when EQUI 8 did not vent to TREA 5 or during periods of non‐operation of TREA 5 for the previous month. This record shall also include the individual and total HAP contents of each HAP‐containing material used in the previous month, as determined by the Material Content requirement of this permit; 3) The total and individual HAP emissions for the previous month using the formulas specified in this permit; and 4) The 12‐month rolling sum total and individual HAP emissions for the previous 12‐month period by summing the monthly emissions data for the previous 12 months. [Minn. R. 7007.0800, subp. 4‐5] IND20150001 Air [Minn. R. 7007.0800, subp. 4‐5] Agency Custom Requirement FALSE 1098593

EQUI0000000008 EU005 20253 Text

y

Permittee shall calculate each individual HAP and total HAP emissions using the following equations: 1) HAP Emissions (tons/month) = H = H1 + H2 2) Use the following equations to calculate total and individual HAPs when EQUI 8 vents to TREA 5, TREA 5 is in operation, and credit for capture and control can be taken. H1 = UE + CE UE = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] * (1 ‐ CAE) CE = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] * CAE * (1 ‐ COE) Where: H1 = the amount of each pollutant (total HAP or each individual HAP), used, in tons/month when EQUI 8 operated controlled. UE = uncaptured emissions CE = captured and controlled emissions A# = amount of each coating used in the previous month, in tons/month. B# = weight percent of each individual or total HAP in A#, as a fraction (e.g., 50% is 0.50). CAE = capture efficiency as determined under TREA 5, as a fraction (e.g., 50% is 0.50). COE = control efficiency as determined under TREA 5, as a fraction (e.g., 50% is 0.50). 2) Use the following equation to calculate total and individual HAPs when EQUI 8 is not vented to TREA 5, TREA 5 is not in operation, or when credit for capture and control cannot be taken. H2 = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] Where: H2 = the amount of each pollutant (total HAP or each individual HAP), used, in tons/month when EQUI 8 operated uncontrolled. A# = amount of each IND20150001 Air [Minn. R. 7007.0800, subp. 4‐5] Agency Custom Requirement FALSE 1098630


The Permittee shall limit emissions of Total Particulate Matter <= 1.30 pounds per hour 3‐hour average from each inside spray machine (EQUI 9) and associated pollution control equipment (TREA 2). The emission rate is equal to the 3‐Hour average of solids applied and that are not collected on the can surfaces and the LSM Collection Box. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


EQUI0000000009 EU007 2 Limitation PM < 10 micron 0

The Permittee shall limit emissions of PM < 10 micron <= 1.30 pounds per hour 3‐hour average from each inside spray machine (EQUI 9) and associated pollution control equipment (TREA 2). The emission rate is equal to the 3‐Hour average of solids applied and that are not collected on the can surfaces and the LSM Collection Boxes. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


EQUI0000000009 EU007 3 Limitation PM < 2.5 micron 0

The Permittee shall limit emissions of PM < 2.5 micron <= 1.30 pounds per hour 3‐hour average from each inside spray machine (EQUI 9) and associated pollution control equipment (TREA 2). The emission rate is equal to the 3‐Hour average of solids applied and that are not collected on the can surfaces and the LSM Collection Boxes. [Minn. R. 7007.0800, subp. 2] IND20150001 Air [Minn. R. 7007.0800, subp. 2] Agency Custom Requirement TRUE 1086171








EQUI0000000009 EU007 6 Submittal/Action PM < 10 micron 0

g g

where initial testing has been completed so that the first due date is known. Delete if not needed. Edit test method as needed. Default is to test to measure emissions. Edit or add as needed, "verify PM10 control efficiency". You must edit the "Date" field to be the due date of the next test. If the due date of the next test is not known, you can revise the condition to have a Custom Schedule is used with trigger Task, or when possible, permit staff may choose to switch from Custom schedule to Schedule based off Permit Issuance. Default frequency is for 60‐month frequency. Edit as needed. Testing may be required at different frequencies according to AQ guidance. Tempo language for recurring test must be worded very carefully in order to ensure that all related requirements are trackable. See guidance under VOC limit if maximum achievable operating rate is undefined and you need to set a short‐term process throughput limit. Default citation is to avoid PSD. Edit citations as needed to reflect reason for test (Title I Conditions, etc.). If the performance testing is required under NESHAP, include citation for 40 CFR 63.7 and any citation specific to the standard. If the testing is required under NSPS, include citation for 40 CFR 60.8(a) and any citation specific to the standard. Always include the Minn. R. 7017 citation. Test extension amendments or re‐tests do not extend the original schedule for the recurring tests. Early

PM < 10 micron : The Permittee shall conduct a performance test : Due before 04/01/2018 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Each performance test shall consist of at least three separate test runs. The sampling time per run is one hour. Each run will measure the amount of solids applied (S), the amount of solids deposited on the cans (C) and the amount of solids captured by control box, TREA 2 (B). The emission rate for each run = S ‐ C ‐ B. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


EQUI0000000009 EU007 7 Submittal/Action PM < 2.5 micron 0

g g

where initial testing has been completed so that the first due date is known. Delete if not needed. Edit test method as needed. Default is to test to measure emissions. Edit or add as needed, "verify PM2.5 control efficiency". You must edit the "Date" field to be the due date of the next test. If the due date of the next test is not known, you can revise the condition to have a Custom Schedule is used with trigger Task, or when possible, permit staff may choose to switch from Custom schedule to Schedule based off Permit Issuance. Default frequency is for 60‐month frequency. Edit as needed. Testing may be required at different frequencies according to AQ guidance. Tempo language for recurring test must be worded very carefully in order to ensure that all related requirements are trackable. See guidance under VOC limit if maximum achievable operating rate is undefined and you need to set a short‐term process throughput limit. Default citation is to avoid PSD. Edit citations as needed to reflect reason for test (Title I Conditions, etc.). If the performance testing is required under NESHAP, include citation for 40 CFR 63.7 and any citation specific to the standard. If the testing is required under NSPS, include citation for 40 CFR 60.8(a) and any citation specific to the standard. Always include the Minn. R. 7017 citation. Test extension amendments or re‐tests do not extend the original schedule for the recurring tests. Early

PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 04/01/2018 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Each performance test shall consist of at least three separate test runs. The sampling time per run is one hour. Each run will measure the amount of solids applied (S), the amount of solids deposited on the cans (C) and the amount of solids captured by control box, TREA 2 (B). The emission rate for each run = S ‐ C ‐ B. [Minn. R. 7017.2020, subp. 1] IND20150001 Air [Minn. R. 7017.2020, subp. 1] Agency Modified Standard Requirement TRUE 1086439

EQUI0000000009 EU007 8 Submittal/Action Total Particulate Matter 0

g g

initial testing has been completed so that the first due date is known. Delete if not needed. Edit test method as needed. Default is to test to measure emissions. Edit or add as needed, "verify PM control efficiency". You must edit the "Date" field to be the due date of the next test. If the due date of the next test is not known, you can revise the condition to have a Custom Schedule is used with trigger Task, or when possible, permit staff may choose to switch from Custom schedule to Schedule based off Permit Issuance. Default frequency is for 60‐month frequency. Edit as needed. Testing may be required at different frequencies according to AQ guidance. Tempo language for recurring test must be worded very carefully in order to ensure that all related requirements are trackable. See guidance under VOC limit if maximum achievable operating rate is undefined and you need to set a short‐term process throughput limit. Default citation is to avoid PSD. Edit citations as needed to reflect reason for test (Title I Conditions, etc.). If the performance testing is required under NESHAP, include citation for 40 CFR 63.7 and any citation specific to the standard. If the testing is required under NSPS, include citation for 40 CFR 60.8(a) and any citation specific to the standard. Always include the Minn. R. 7017 citation. Test extension amendments or re‐tests do not extend the original schedule for the recurring tests. Early

conduct a performance test : Due before 04/01/2018 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date.The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Each performance test shall consist of at least three separate test runs. The sampling time per run is one hour. Each run will measure the amount of solids applied (S), the amount of solids deposited on the cans (C) and the amount of solids captured by control box, TREA 2 (B). The emission rate for each run = S ‐ C ‐ B. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


EQUI0000000009 EU007 9 Text

Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the following: ‐tons of each type of coating used in EQUI 9 when EQUI 9 vented to TREA 5 and TREA 5 was in operation. This shall be based on delivery records. ‐tons of each type of coating used in EQUI 9 when EQUI 9 did not vent to TREA 5 or during periods of non‐operation of TREA 5. This shall be based on delivery records. [Minn. R. 7007.0800, subp. 4‐5, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] IND20150001 Air


EQUI0000000009 EU007 10 Text

Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following information: 1) Tons of each type of coating used in EQUI 9 when EQUI 9 vented to TREA 5 and TREA 5 was in operation for the previous month. This record shall also include the individual and total HAP contents of each HAP‐containing material used in the previous month, as determined by the Material Content requirement of this permit; 2) Tons of each type of coating used in EQUI 9 when EQUI 9 did not vent to TREA 5 or during periods of non‐operation of TREA 5 for the previous month. This record shall also include the individual and total HAP contents of each HAP‐containing material used in the previous month, as determined by the Material Content requirement of this permit; 3) The total and individual HAP emissions for the previous month using the formulas specified in this permit; and 4) The 12‐month rolling sum total and individual HAP emissions for the previous 12‐month period by summing the monthly emissions data for the previous 12 months. [Minn. R. 7007.0800, subp. 4‐5] IND20150001 Air [Minn. R. 7007.0800, subp. 4‐5] Agency Custom Requirement FALSE 1098637

EQUI0000000009 EU007 11 Text

y

Permittee shall calculate each individual HAP and total HAP emissions using the following equations: 1) HAP Emissions (tons/month) = H = H1 + H2 2) Use the following equations to calculate total and individual HAPs when EQUI 9 vents to TREA 5, TREA 5 is in operation, and credit for capture and control can be taken. H1 = UE + CE UE = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] * (1 ‐ CAE) CE = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] * CAE * (1 ‐ COE) Where: H1 = the amount of each pollutant (either total HAP or each individual HAP), used, in tons/month when EQUI 9 operated controlled. UE = uncaptured emissions CE = captured and controlled emissions A# = amount of each coating used in the previous month, in tons/month. B# = weight percent of each individual or total HAP in A#, as a fraction (e.g., 50% is 0.50). CAE = capture efficiency as determined under TREA 5, as a fraction (e.g., 50% is 0.50). COE = control efficiency as determined under TREA 5, as a fraction (e.g., 50% is 0.50). 2) Use the following equation to calculate total and individual HAPs when EQUI 9 is not vented to TREA 5, TREA 5 is not in operation, or when credit for capture and control cannot be taken. H2 = [(A1 x B1) + (A2 x B2) + (A3 x B3) + ....] Where: H2 = the amount of each pollutant (either total HAP or each individual HAP), used, in tons/month when EQUI 9 operated uncontrolled. A# = amount of each IND20150001 Air [Minn. R. 7007.0800, subp. 4‐5] Agency Custom Requirement FALSE 1098638

EQUI0000000010 TK001 2 Text

The tank shall be equipped with a submerged fill pipe; or be equipped with a floating roof, vapor recovery system or its equivalent. The tank has been equipped with a permanent submerged fill pipe. [Minn. R. 7011.1505, subp. 3(B)] Air [Minn. R. 7011.1505, subp. 3(B)] Agency Custom Requirement TRUE 718163

EQUI0000000011 TK002 2 Text


EQUI0000000012 TK003 2 Text


EQUI0000000013 TK004 2 Text


TREA0000000001 CE002 1 Text

Load this profile on the emitting Subject Item. Default citation is a limit to avoid major NSR source. Edit as needed. Fill in subject item # references. This requirement is standard for controls that are required by a permit (i.e., not CAM‐specific). For those controls subject to the control equipment rule, DELETE this requirement.

The Permittee shall vent emissions from EQUI 8 to TREA 1 whenever EQUI 8 operates, and operate and maintain TREA 1 at all times that anyemissions are vented to TREA 1. The Permittee shall document periods of non‐operation of the control equipment. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


TREA0000000001 CE002 2 Limitation Total Particulate Matter 0

The Permittee shall operate and maintain the LSM Collection Box (TREA 1) such that it achieves an overall control efficiency, for Total Particulate Matter >= 95 percent. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air

[Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] Agency Custom Requirement TRUE 1086131

TREA0000000001 CE002 3 Limitation PM < 10 micron 0

The Permittee shall operate and maintain the LSM Collection Box (TREA 1) such that it achieves an overall control efficiency, for PM < 10 micron >= 95 percent. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


TREA0000000001 CE002 7 Limitation PM < 2.5 micron 0

The Permittee shall operate and maintain the LSM Collection Box (TREA 1) such that it achieves an overall control efficiency, for PM < 2.5 micron >= 95 percent. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2] IND20150001 Air

[Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2] Agency Custom Requirement TRUE 1086133

TREA0000000001 CE002 8 Text

Daily Inspections: Once each operating day, the Permittee shall visually inspect the condition of TREA 1 with respect to alignment, saturation and any other condition that may affect the performance of the LSM Collection box. The Permittee shall maintain a daily written record of TREA 1 inspections. [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] IND20150001 Air

[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] Agency Custom Requirement TRUE 1086269

TREA0000000001 CE002 9 Text

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturer's 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, subps. 4‐5] Air

[Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5] Agency Custom Requirement TRUE 1086138

TREA0000000001 CE002 10 Text

Corrective Actions: If the LSM Collection box or any components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the LSM Collection box. The Permittee shall keep a record of the type and date of any corrective action taken for TREA 1. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5] IND20150001 Air


TREA0000000001 CE002 19650 Text

Operation and Maintenance of LSM Control Box: The Permittee shall operate and maintain TREA 1 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] IND20150001 Air [Minn. R. 7007.0800, subp. 14] Agency Custom Requirement TRUE 1086272

TREA0000000002 CE004 4 Text

Load this profile on the emitting Subject Item. Default citation is a limit to avoid major NSR source. Edit as needed. Fill in subject item # references. This requirement is standard for controls that are required by a permit (i.e., not CAM‐specific). For those controls subject to the control equipment rule, DELETE this requirement.

The Permittee shall vent emissions from EQUI 9 to TREA 2 whenever EQUI 9 operates, and operate and maintain TREA 2 at all times that anyemissions are vented to TREA 2. The Permittee shall document periods of non‐operation of the control equipment. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


TREA0000000002 CE004 5 Limitation Total Particulate Matter 0

The Permittee shall operate and maintain the LSM Collection Box (TREA 2) such that it achieves an overall control efficiency, for Total Particulate Matter >= 95 percent. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


TREA0000000002 CE004 6 Limitation PM < 10 micron 0

The Permittee shall operate and maintain the LSM Collection Box (TREA 2) such that it achieves an overall control efficiency, for PM < 10 micron >= 95 percent. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


TREA0000000002 CE004 7 Limitation PM < 2.5 micron 0

The Permittee shall operate and maintain the LSM Collection Box (TREA 2) such that it achieves an overall control efficiency, for PM < 2.5 micron >= 95 percent. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2] IND20150001 Air

[Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2] Agency Custom Requirement TRUE 1086126

TREA0000000002 CE004 8 Text

Daily Inspections: Once each operating day, the Permittee shall visually inspect the condition of TREA 2 with respect to alignment, saturation and any other condition that may affect the performance of the LSM Collection box. The Permittee shall maintain a daily written record of inspections. [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] IND20150001 Air

[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] Agency Custom Requirement TRUE 1086273

TREA0000000002 CE004 9 Text

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturer's 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, subps. 4‐5] Air


TREA0000000002 CE004 10 Text

Corrective Actions: If the LSM Collection box or any components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the LSM Collection box. The Permittee shall keep a record of the type and date of any corrective action taken for TREA 2. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5] IND20150001 Air


TREA0000000002 CE004 19650 Text

Operation and Maintenance of LSM Control Box: The Permittee shall operate and maintain each LSM Collection Box 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] Air [Minn. R. 7007.0800, subp. 14] Agency Custom Requirement TRUE 1086130

TREA0000000005 1 Text

It is important to have an actual permit condition that tells the facility what they are allowed to do. Can use an appendix to document the equipment design/size requirements (those that are relevant in determining PTE) or directly list them as a permit requirement whichever is clearer. Construction authorization should generally be written to expire (don't get to "reserve" air quality indefinitely). The default should be 18 months, unless the permit team decides otherwise. No longer than 5 years. If they are netting and the netting credits involve removing/shutdown as well as starting up new stuff, or if the authorization expires, also include notification of equipment installation and startup and dismantlement (see last item in this Profile for dismantlement example). Default citation of limits to avoid major source under NSR; edit as needed. If not to avoid a requirement, use Minn. R. 7007.0800, subp. 2 as the basis (general authority).

[Stage 1] The Permittee is authorized to construct and operate TREA 5 meeting the following design requirements; 1400 degrees Fahrenheit inlet temperature, 250 degree Fahrenheit outlet temperature, 1.5 second residence time, and 4.00 MMBtu/hr burner capacity, within 18 months after permit issuance of Permit No. 14700012‐101. The units shall meet all the requirements of this permit. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


TREA0000000005 2 Limitation Volatile Organic Compounds 0

Include for thermal oxidizers where the control equipment is used to determine potential to emit

(e.g., Title I) but the control equipment rule is not the basis for the limits. This requirement is standard for controls that are required by a permit. Default citation is for a limit to avoid major source for NSR. This Profile only includes requirements for the control device itself. The Profile includes periodic monitoring, not CAM, and does not include any performance testing (same as all of the control equipment profiles). You may need to add testing to the equipment SI or treatment SI on a case‐by‐case basis.

[Stage 1] The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds >= 95 percent control efficiency. [Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air


TREA0000000005 3 Limitation Volatile Organic Compounds 0

[Stage 1] The Permittee shall operate and maintain control equipment such that it achieves an overall capture efficiency for Volatile Organic Compounds >= 75 percent capture efficiency. [Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air

[Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] Agency Custom Requirement TRUE 1096627

TREA0000000005 4 Limitation HAPs ‐ Total 0

[Stage 1] The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for HAPs ‐ Total >= 95 percent control efficiency. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] IND20150001 Air

[Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] Agency Custom Requirement TRUE 1096629

TREA0000000005 5 Limitation HAPs ‐ Total 0

[Stage 1] The Permittee shall operate and maintain control equipment such that it achieves an overall capture efficiency for HAPs ‐ Total >= 75 percent capture efficiency. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] IND20150001 Air

[Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, Title I Condition: Avoid major source under 40 CFR 63.2] Agency Custom Requirement TRUE 1096635

TREA0000000005 6 Limitation Temperature T‐121

Default citation is to avoid being major source under NSR; edit as needed. A temperature limit is standard for controls that are required by a permit (i.e., not CAM‐specific), and violation of the limit is a deviation, not just an excursion.

[Stage 1] Temperature >= 1400 degrees Fahrenheit 3‐hour rolling average at the combustion chamber outlet, unless a new limit is required to be set pursuant to Minn. R. 7017.2025, subp. 3. If a new minimum is required to be set it will be based on the values recorded during the most recent MPCA‐approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3‐hour rolling average temperature is below the minimum temperature limit, the VOC emitted during that time shall be considered uncontrolleduntil the average temperature is above the minimum temperature limit. This shall be reported as a deviation. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, 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 63.2] IND20150001 Air

[Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, 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 63.2] Agency Modified Standard Requirement TRUE 1096617

TREA0000000005 7 Text

Default citation is a limit to avoid major NSR source. Edit as needed. Fill in subject item # references. This requirement is standard for controls that are required by a permit. The default language means the requirements apply to like‐kind replacements of the control equipment. Edit the language if your permit allows different control operating scenarios (different controls for different operating conditions). For those controls subject to the control equipment rule, DELETE this requirement (each CE rule Profile has a rule‐specific condition that will be included instead).

from EQUIs 4, 5, 8, and 9 to TREA 5 whenever EQUIs 4, 5, 8, and 9 operate, and operate and maintain TREA 5 at all times that any emissions are vented to TREA 5, except for a period of less than or equal to 240 hours per year the Permittee may operate EQUIs 4, 5, 8, and 9 without venting to TREA 5. The Permittee shall document periods of non‐operation of the control equipment, TREA 5, whenever EQUIs 4, 5, 8, and 9 are operating. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, 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 63.2] IND20150001 Air

[Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, 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 63.2] Agency Modified Standard Requirement TRUE 1096607

TREA0000000005 8 Text

This requirement is standard for controls that are required by a permit.

The Permittee shall operate and maintain the thermal oxidizer 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] IND20150001 Air [Minn. R. 7007.0800, subp. 14] Standard Library Requirement TRUE 1032353

Air, Permitting, Individual Permits, Control Equipment, No CAM, Oxidizer, Thermal ‐ w/o CE rule, No ARM for Temperature. N

TREA0000000005 9 Text

Edit citation as needed. Pick temperature scale in [ ] text.

[Stage 1] Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/‐0.75 percent of the temperature being measured or +/‐ [2.5 degrees Celsius][4.5 degrees Fahrenheit]. The recording device shall also calculate the three‐hour rolling average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. [Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7011.7000, 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 63.2] IND20150001 Air

[Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7011.7000, 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 63.2] Agency Modified Standard Requirement TRUE 1096610

TREA0000000005 10 Text Edit the citation as needed.

[Stage 1] Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7011.7000, 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 63.2] IND20150001 Air



Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [Minn. R. 7007.0800, subps. 4‐5] IND20150001 Air [Minn. R. 7007.0800, subps. 4‐5] Agency Modified Standard Requirement TRUE 1096612


[Stage 1] The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three hour rolling average temperatures for the combustion chamber. [Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7011.7000, 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 63.2] IND20150001 Air


TREA0000000005 13 Text

Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4‐5] IND20150001 Air

[Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4‐5] Agency Modified Standard Requirement TRUE 1121401

TREA0000000005 14 Text

Quarterly Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer's specifications, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4‐5] IND20150001 Air


TREA0000000005 15 Text

Annual Inspection: At least once per calendar year, the Permittee shall conduct an inspection that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4‐5] IND20150001 Air


TREA0000000005 16 Text

If the control efficiency is used in permit calculations (e.g., to show compliance with a VOC cap), the permit has to allow for the use of tested control efficiencies when the minimum temperature is maintained. A separate requirement states that the efficiency is "zero" if the minimum temperature is not maintained.

[Stage 1] For periods when the thermal oxidizer is operated above the minimum combustion chamber temperature, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit: 1a. The overall control efficiency limit specified inthis permit for this equipment (x%); or 1b. The overall control efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test. 2a. The overall capture efficiency limit specified in this permit for this equipment (x%); or 2b. The overall capture efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test. [Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7011.7000, 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 63.2] IND20150001 Air


TREA0000000005 17 Text

[Stage 1] For periods when the thermal oxidizer is operated below the minimum combustion chamber temperature, the Permittee shall use a 0% control efficiency and 0% capture efficiency when completing calculations as required elsewhere in this permit. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, 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 63.2] IND20150001 Air

[Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, 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 63.2] Agency Custom Requirement FALSE 1096665

TREA0000000005 18 Text

[Stage 1] For periods when the thermal oxidizer is not operated, the Permittee shall use a 0% control efficiency and 0% capture efficiency when completing calculations as required elsewhere in this permit. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, 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 63.2] IND20150001 Air

[Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7000, 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 63.2] Agency Custom Requirement FALSE 1096667

TREA0000000005 19 Text

Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4‐5] IND20150001 Air


TREA0000000005 20 Text

Include when the emission unit is not totally enclosed. May also be required due to other applicable requirements (e.g., modeling, to avoid PSD or Pt. 70). Edit citation as needed. A copy of the most recent hood evaluation and certification must be submitted and reviewed for a hood that is relied upon to avoid an applicable requirement. If the hood does not exist at permit issuance or is inadequately certified, add a submittal item for the hood certification and evaluation within 30 days after start up or permit issuance. Include a notification of start‐up to trigger the submittal if needed. Sample S/A: The Permittee shall submit a report: Due 30 calendar days after permit issuance that certifies that the hood conforms to the requirements identified in the Hood Certification and Evaluation requirement in this permit. The Permittee shall submit the results of the evaluation and certification on forms HE‐01 and CR‐02, along with any other information required by the forms for MPCA review.

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] IND20150001 Air [Minn. R. 7007.0800, subp. 2] Agency Modified Standard Requirement TRUE 1096615

TREA0000000005 21 Text

Include when the emission unit is not totally enclosed. May also be required due to other applicable requirements (e.g., modeling, to avoid PSD or Pt. 70). Edit citation as needed. The permit engineer should consider including a specific parameter and range for the parameter(s) to be monitored (e.g., fan power draw ≥ 156 amps) based on the most recent evaluation.

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] IND20150001 Air [Minn. R. 7007.0800, subp. 2] Agency Modified Standard Requirement TRUE 1096616

TREA0000000005 22 Text

[Stage 1] Daily Recordkeeping: On each day of operation, the Permittee shall calculate, record and maintain the following for TREA 5: ‐ hours of operation ‐ hours of non‐operation. [Minn. R. 7007.0800, subp. 4‐5, Minn. R. 7011.7000, 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 63.2] IND20150001 Air

[Minn. R. 7007.0800, subp. 4‐5, Minn. R. 7011.7000, 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 63.2] Agency Custom Requirement FALSE 1096645

TREA0000000005 23 Text

Fuel type: Natural gas only. [Minn. R. 7005.0100, subp. 35a] IND20150001 Air [Minn. R. 7005.0100, subp. 35a] Agency Custom Requirement FALSE 1096651

TREA0000000005 24 Submittal/Action

Include in all permits. Authorizations expire and we won't know if they complied unless they notify us of construction. Include at each Subject Item that is authorized.

The Permittee shall submit a notification of the date construction began : Due 30 calendar days after Date of Construction Start. Submit the name and number of the Subject Item and the date construction began. [Minn. R. 7007.0800, subp. 16(L)] IND20150001 Air [Minn. R. 7007.0800, subp. 16(L)] Agency Modified Standard Requirement TRUE 1120430

TREA0000000005 25 Submittal/Action

Include in all permits where other S/A requirements are triggered off of startup. Include at each Subject Item that is authorized.

The Permittee shall submit a notification of the actual date of initial startup : Due 15 calendar days after Initial Startup Date. Submit the name and number of the Subject Item and the date of startup. Startup is as defined in Minn. R. 7007.0500, subp. 42a. [Minn. R. 7007.0800, subp. 16(L)] IND20150001 Air [Minn. R. 7007.0800, subp. 16(L)] Standard Library Requirement TRUE 1030790

Air, Permitting, Individual Permits, Construction Conditions, Non‐NSR. N

TREA0000000005 26 Submittal/Action Volatile Organic Compounds 0

Initial Performance Test for VOC. Delete if not needed. Edit test method as needed. Default is to test to measure emissions. Edit or add as needed, "verify VOC control efficiency" or "VOC as mass" (requires additional text method to speciate, always required for ethanol). Tacilities with undefined max operating rates: INSERT after “subp. 2”: “and as identified in Appendix [] of this permit using EPA Reference Method 25A [in addition to Method 18 or Method 320], or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C).” Default citation is to avoid PSD. Edit citations as needed to reflect reason for test (Title I Conditions, etc.). If the performance testing is required under NESHAP, include citation for 40 CFR 63.7 and any citation specific to the standard. If the testing is required under NSPS, include citation for 40 CFR 60.8(a) and any citation specific to the standard. Always include the Minn. R. citation.

Volatile Organic Compounds : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date to measure control efficiency. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. [Stage 1]. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air



Volatile Organic Compounds : The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date to measure capture efficiency. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 1, 2, 3, 4, or 25A, or other method approved by MPCA in the performance test plan approval. [Stage 1]. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air

[Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] Agency Custom Requirement FALSE 1096668

TREA0000000005 28 Submittal/Action HAPs ‐ Total 0

HAPs ‐ Total : The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date to measure control efficiency. The performance test shall include the HAP species of Methyl isobutyl ketone. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 18 or 320, or other method approved by MPCA in the performance test plan approval. [Stage 1]. [Minn. R. 7011.7000, Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] IND20150001 Air

[Minn. R. 7011.7000, Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] Agency Custom Requirement FALSE 1096671


HAPs ‐ Total : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date to measure capture efficiency. The performance test shall include the HAP species of Methyl Isobutyl Ketone. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 18 or 320, or other method approved by MPCA in the performance test plan approval. [Stage 1]. [Minn. R. 7011.7000, Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] IND20150001 Air



Volatile Organic Compounds : The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for control efficiency of VOC emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval of the MPCA. [Stage 1]. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air



Volatile Organic Compounds : The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for capture efficiency of VOC emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval of the MPCA. [Stage 1]. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000] IND20150001 Air



HAPs ‐ Total : The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for control efficiency of HAPs ‐ Total emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval of the MPCA. [Stage 1]. [Minn. R. 7011.7000, Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] IND20150001 Air



HAPs ‐ Total : The Permitee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for capture efficiency of HAPs ‐ Total emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval of the MPCA. [Stage 1]. [Minn. R. 7011.7000, Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] IND20150001 Air


TFAC0000000001 14700012 1 Text

Include for any source‐specific requirements that are contained within an Appendix. This includes insignificant activities, modeling parameters among other possibilities. The reference "as described elsewhere" could be tailored to your permit requirements ‐ e.g., refer to the specific Tier I/II/III/IV text regarding the parameter appendices. Edit or delete [ ] sentence as needed.

Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendices [AppendixA. Insignificant Activities and General Applicable Requirements; Appendix B. Maximum Content of Materials and Capacity Information]. [Minn. R. 7007.0800, subp. 2] IND20150001 Air [Minn. R. 7007.0800, subp. 2] Agency Modified Standard Requirement TRUE 1086011

TFAC0000000001 14700012 2 Text

Include in all permits; if you receive a request to modify this language, research current MPCA policy on when we do/don't modify it and act accordingly. Need to discuss modified language in TSD.

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)] IND20150001 Air [Minn. R. 7007.1800, (A)(2)] Standard Library Requirement TRUE 1030605

Air, Permitting, Individual Permits, General Total Facility Requirements, Major NSR Facilities. N

TFAC0000000001 14700012 3 Text

Include in all permits for major sources under NSR. If the facility has a PAL for one or more pollutants, you may have to modify the language to apply only to the non‐PAL pollutants. Section 52.21(r)(6) also applies to the hybrid test. Section 52.21(r)(6) does not apply to greenhouse gases, so if GHGs are the only pollutant for which the source is (or will be) major, do not include any of these Section 52.21(r)(6) requirements.

These requirements apply if a reasonable possibility (RP) as defined in 40 CFR Section 52.21(r)(6)(vi) exists that a proposed project, analyzed using the actual‐to‐projected‐actual (ATPA) test (either by itself or as part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no RP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of Section 52.21(r)(6)(vi)(b). Even though a particular modification is not subject to New Source Review (NSR), or where there isn't a RP that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R. 7007.1150 ‐ 7007.1500. [Minn. R. 7007.0800, subp. 2, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000] IND20150001 Air

[Minn. R. 7007.0800, subp. 2, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000] Standard Library Requirement TRUE 1030609


TFAC0000000001 14700012 4 Text

Include in all permits for major sources under NSR. If the facility has a PAL for one or more pollutants, you may have to modify the language to apply only to the non‐PAL pollutants. The extra documentation of pre and post‐change PTE is a state requirement. For existing units it is to verify if PTE increases because of the role it plays in determining if recordkeeping must occur for 5 or 10 years. Documentation of post‐change new unit PTE is required because emission changes from a new unit are always determined with the actual‐to‐potential method. Minn. R. 7007.0800, subps. 4 and 5 added to the citation to reflect state requirements. Section 52.21(r)(6) does not apply to greenhouse gases, so if GHGs are the only pollutant for which the source is (or will be) major, do not include any of these Section 52.21(r)(6) requirements.

Preconstruction Documentation ‐‐ Before beginning actual construction on a project, the Permittee shall document the following: 1. Project description 2. Identification of any emission unit whose emissions of an NSR pollutant could be affected 3. Pre‐change potential emissions of any affected existing emission unit, and the projected post‐change potential emissions of any affected existing or new emission unit. 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the emission unit could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination. The Permittee shall maintain records of this documentation. [Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7007.1200, subp. 4, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000] IND20150001 Air

[Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7007.1200, subp. 4, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000] Standard Library Requirement TRUE 1069562


TFAC0000000001 14700012 5 Text

Include in all permits for major sources under NSR. If the facility has a PAL for one or more pollutants, you may have to modify the language to apply only to the non‐PAL pollutants. Section 52.21(r)(6) does not apply to greenhouse gases, so if GHGs are the only pollutant for which the source is (or will be) major, do not include any of these Section 52.21(r)(6) requirements.

The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the ATPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. [Minn. R. 7007.0800, subps. 4‐5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000] IND20150001 Air

[Minn. R. 7007.0800, subps. 4‐5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000] Standard Library Requirement TRUE 1030611


TFAC0000000001 14700012 6 Text

Include in all permits for major sources under NSR when the facility does not include any electric utility steam generating units. If the facility has a PAL for one or more pollutants, you may have to modify the language to apply only to the non‐PAL pollutants. Section 52.21(r)(6) does not apply to greenhouse gases, so if GHGs are the only pollutant for which the source is (or will be) major, do not include any of these Section 52.21(r)(6) requirements.

The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain: a. The name and ID number of the Facility, and the name and telephone number of the Facility contact person. b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. [Minn. R. 7007.0800, subps. 4‐5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000] IND20150001 Air

[Minn. R. 7007.0800, subps. 4‐5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000] Agency Modified Standard Requirement TRUE 1096367

TFAC0000000001 14700012 7 Text

Put this requirement in all permits for sources that are major for PSD and/or Part 70 regardless of whether or not modeling has already been completed.

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. R. 7009.0010‐7009.0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9] IND20150001 Air

[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. R. 7009.0010‐7009.0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9] Standard Library Requirement TRUE 1030616


TFAC0000000001 14700012 8 Text Include in all permits

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] IND20150001 Air [Minn. R. 7011.0020] Standard Library Requirement TRUE 1030618


TFAC0000000001 14700012 9 Text

Include in all permits even if the facility does not have existing pollution control equipment. The Permittee may add pollution control equipment in the future. If there are situations where the Permittee may not be required to operate the pollution control equipment, exceptions should be specified in the permit. If there are exceptions, you will need to edit this requirement to indicate the location of the additional language (i.e. except as specified within xxx).

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] IND20150001 Air

[Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 2] Standard Library Requirement TRUE 1030619


TFAC0000000001 14700012 10 Text

Include in all permits. This requirement applies to any current or future air pollution control equipment.

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)] IND20150001 Air

[Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J)] Standard Library Requirement TRUE 1059092


TFAC0000000001 14700012 11 Text Include in all permits.

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 theoperation 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] IND20150001 Air [Minn. R. 7019.1000, subp. 4] Standard Library Requirement TRUE 1030621



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] IND20150001 Air [Minn. R. 7011.0150] Standard Library Requirement TRUE 1030622


TFAC0000000001 14700012 13 Text

Include in all permits. This is a state‐only requirement because it is not contained within our SIP.

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] IND20150001 Air [Minn. R. 7030.0010‐7030.0080] Standard Library Requirement TRUE 1030623



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)] IND20150001 Air [Minn. R. 7007.0800, subp. 9(A)] Standard Library Requirement TRUE 1030624



The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. [Minn. R. 7007.0800, subp. 16] IND20150001 Air [Minn. R. 7007.0800, subp. 16] Standard Library Requirement TRUE 1030625


TFAC0000000001 14700012 16 Text

Include in all permits that have performance test requirements.

Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in this permit. [Minn. R. ch. 7017] IND20150001 Air [Minn. R. ch. 7017] Agency Modified Standard Requirement TRUE 1096374

TFAC0000000001 14700012 17 Text

This summarizes notification and submittal requirements related to performance test requirements. Place at AI SI with other performance test general requirements. In cases where only one or two units in the permit are to be tested, the language could be added at the unit SI instead. If performance testing due to a NESHAP is required, determine if Section 63.9(e), (f) are relevant.

Performance Test Notifications and Submittals: Performance Tests are due as outlined in this permit. Performance Test Notification (written): due 30 days before each Performance Test Performance Test 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 Performance Test Report ‐Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R. 7017.2018. [Minn. R. 7017.2018, Minn. R. 7017.2030, subps. 1‐4, Minn. R. 7017.2035, subps. 1‐2] IND20150001 Air

[Minn. R. 7017.2018, Minn. R. 7017.2030, subps. 1‐4, Minn. R. 7017.2035, subps. 1‐2] Standard Library Requirement TRUE 1030627


TFAC0000000001 14700012 18 Text

Include in all permits that have performance test requirements.

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] IND20150001 Air [Minn. R. 7017.2025, subp. 3] Standard Library Requirement TRUE 1030628



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)] IND20150001 Air [Minn. R. 7007.0800, subp. 4(D)] Standard Library Requirement TRUE 1030629



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)] IND20150001 Air [Minn. R. 7007.0800, subp. 4(D)] Standard Library Requirement TRUE 1030630


TFAC0000000001 14700012 21 Submittal/Action Include in all expiring permits

The Permittee shall submit an application for permit reissuance : Due 180 calendar days before Permit Expiration Date. [Minn. R. 7007.0400, subp. 2] IND20150001 Air [Minn. R. 7007.0400, subp. 2] Standard Library Requirement TRUE 1030634


TFAC0000000001 14700012 22 Text

Include in all permits. You may edit the text to authorize the Permittee to retain records at a location other than the stationary source or if the Permittee must retain the records for longer for 5 years, per agreement with enforcement staff. Include discussion of authorization for alternative location or increated record retention in the TSD.

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)] IND20150001 Air [Minn. R. 7007.0800, subp. 5(C)] Standard Library Requirement TRUE 1069578



Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. [Minn. R. 7007.0800, subp. 5(B)] IND20150001 Air [Minn. R. 7007.0800, subp. 5(B)] Standard Library Requirement TRUE 1030642


TFAC0000000001 14700012 24 Text

Include in all permits. Select text based on if the permit is expiring or nonexpiring

If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. These records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. [Minn. R. 7007.1200, subp. 4] IND20150001 Air [Minn. R. 7007.1200, subp. 4] Agency Modified Standard Requirement TRUE 1086015


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] IND20150001 Air [Minn. R. 7019.1000, subp. 3] Standard Library Requirement TRUE 1030644



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] IND20150001 Air [Minn. R. 7019.1000, subp. 2] Standard Library Requirement TRUE 1030645



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] IND20150001 Air [Minn. R. 7019.1000, subp. 1] Standard Library Requirement TRUE 1030646



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; 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] IND20150001 Air [Minn. R. 7019.1000, subp. 1] Standard Library Requirement TRUE 1030647


TFAC0000000001 14700012 29 Submittal/Action

This requirement must go into every permit. Use the template language for total facility permits (including reissuances). For permit amendments the date of the most recent total facility permit issuance should be used. Every permittee should receive a copy of the MPCA's deviation reporting forms (i.e. DRF‐1 & DRF‐2). The forms are used to report all noncompliance during the reporting period. Reporting is required semiannually regardless of whether or not a deviation occurred.

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)] IND20150001 Air [Minn. R. 7007.0800, subp. 6(A)(2)] Standard Library Requirement TRUE 1030648

Air, Permitting, Individual Permits, General Total Facility Requirements, Major NSR Facilities. Y


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] IND20150001 Air

[Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 ‐ 7007.1500] Standard Library Requirement TRUE 1030650



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)] IND20150001 Air [Minn. R. 7007.1400, subp. 1(H)] Standard Library Requirement TRUE 1030651


TFAC0000000001 14700012 32 Submittal/Action

This requirement must go into every permit. The report forms are used to report all noncompliance during the entire year. As of March 13, 2014, for Part 70 permits, this certification does not need to be submitted to EPA per March 13, 2014, C&E agreement with EPA.

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)] IND20150001 Air [Minn. R. 7007.0800, subp. 6(C)] Standard Library Requirement TRUE 1030653



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] IND20150001 Air [Minn. R. 7019.3000‐7019.3100] Standard Library Requirement TRUE 1030654



Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005‐7002.0095] IND20150001 Air [Minn. R. 7002.0005‐7002.0095] Standard Library Requirement TRUE 1030655


Attachment 3 – Subject item inventory/details

Category Type ID Designation Description Sort OrderAI Conventional site AISI0000002007 1.00

Category Type ID Designation Description GroupsInclude In Permit

Sort Order End Date

Activity

Insignificant Air Emissions Activity ACTV0000000003 All IAs None Yes

Equipment Aboveground Storage Tank EQUI0000000010 TK001 Inside Spray None Yes


Equipment Aboveground Storage Tank EQUI0000000012 TK003 Wash Coat None Yes


Equipment Boiler EQUI0000000001 EU010 Boiler None Yes

Equipment

Dryer/Oven, unknown firing method EQUI0000000002 EU002 Dryer, unknown firing method ‐ Line 1 None Yes

Equipment

Dryer/Oven, unknown firing method EQUI0000000003 EU004 Dryer, unknown firing method ‐ Line 2 None Yes

Equipment

Dryer/Oven, unknown firing method EQUI0000000004 EU006 Oven, unknown firing method ‐ Line 1 COMG0000000009 Yes

Equipment

Dryer/Oven, unknown firing method EQUI0000000005 EU008 Oven, unknown firing method ‐ Line 2 COMG0000000009 Yes

Equipment Spray Booth/Coating Line EQUI0000000006 EU001 Wash coat 1 COMG0000000002 Yes

Equipment Spray Booth/Coating Line EQUI0000000007 EU003 Wash coat 2 COMG0000000002 Yes

Equipment Spray Booth/Coating Line EQUI0000000008 EU005 Spray Booth ‐ Line 1COMG0000000002, COMG0000000008, COMG0000000009 Yes

Equipment Spray Booth/Coating Line EQUI0000000009 EU007 Spray Booth ‐ Line 2COMG0000000002, COMG0000000008, COMG0000000009 Yes

Structure Building STRU0000000001 BG001 Warehouse None Yes

Structure Stack/Vent STRU0000000002 SV001 None Yes















Structure Stack/Vent STRU0000000017 RTO Stack None Yes

Total Facility Air Quality Total Facility TFAC0000000001 14700012 Crown Cork & Seal Co Inc ‐ Owatonna None Yes 1.00

Treatment 099‐Other TREA0000000001 CE002 LSM Collection Box None Yes

Treatment 099‐Other TREA0000000002 CE004 LSM Collection Box None Yes

Treatment 131‐Thermal Oxidizer TREA0000000005 Regenerative Thermal Oxidizer None Yes

Category Type ID Designation Description Components Include In Permit Sort Order

Component Group Air Component Group COMG0000000002 GP007 HAP Limits

EQUI0000000006, EQUI0000000007, EQUI0000000008, EQUI0000000009 Yes

Component Group Air Component Group COMG0000000008 EQUIs 8 and 9 EQUI0000000008, EQUI0000000009 Yes

Component Group Air Component Group COMG0000000009 EQUIs controlled by TREA 5EQUI0000000004, EQUI0000000005, EQUI0000000008, EQUI0000000009 Yes

Attachment 4 – Points calculator

Points Calculator

1) AI ID No.: 2007 Total Points 452) Facility Name: Crown Cork and Seal Co Inc - Owatonna3) Small business? y/n? n 4) Air Project Tracking Numbers (including 5397 5) Date of each Application Received: 11/16/20156) Final Permit No. 14700012-1017) Permit Staff Andrea Walkush

Total TotalApplication Type Air Project Tracking No. Tempo Activity ID Qty. Points Points Additionl Cost DetailsAdministrative Amendment 1 0 -$ Minor Amendment 4 0 -$ Applicability Request 10 0 -$ Moderate Amendment 15 0 -$ Major Amendment 5397 IND20150001 1 25 25 7,125.00$ Individual State Permit (not reissuance) 50 0 -$ Individual Part 70 Permit (not reissuance) 75 0 -$

Additional PointsModeling Review 15 0 -$

BACT Review 15 0 -$ LAER Review 15 0 -$ CAIR/Part 75 CEM analysis 10 0 -$ NSPS Review 10 0 -$ NESHAP Review 10 0 -$ Case-by-case MACT Review 20 0 -$ Netting 10 0 -$ Limits to remain below threshold 5397 IND20150001 2 10 20 5,700.00$ Plantwide Applicability Limit (PAL) 20 0 -$ AERA review 15 0 -$ Variance request under 7000.7000 35 0 -$ Confidentiality request under 7000.1300 2 0 -$ EAW reviewPart 4410.4300, subparts 18, item A; and 29 15 0 -$ Part 4410.4300, subparts 8, items A & B; 10, items A to C; 16, items A & D; 17, items A to C & E to G; and 18, items B & C

35 0 -$

Part 4410.4300, subparts 4; 5 items A & B; 13; 15; 16, items B & C; and 17 item D

70 0 -$

Add'l Points 20

NOTES:

(DQ Points)

Attachment 5 ‐ MSDS

CCS EMCS - ICI - 642-W-502 - Coating Report Page 1of3

CROWN Technology Electronic Materials Control System CROWN

Environmental Health & Safety Report - Coatings and Side Seams

Select Application

Supplier Name: !CI Supplier Date Prepared:

(Material)

Supplier Date Prepared:

(Application)

03-Jun-2002

10-Jul-2001

Material Description-------------------------------------.

Supplier Code:

Old Supplier Code:

Old CCS/CMB Code:

Material Type:

Material Status:

Comments:

Primary Use:

Secondary Use:

642-W-502

92-G-4W

1.5.6

Water Based

Standard

Interior Food Can Coating

DWI Coating

Application Method: Airless Spray

Major Resin Type: Modified epoxy

Dry Film Color: White

Where Used: Americas Division

Purchasing Code: COT01553

CCS Code: 20.01.879

Function Codes-------------------------------------........ CS1028 = BUSINESS AREA: Food; PACKAGE TECHNOLOGY: DWI; COATING USE: Single coat; SURFACE: Interior; SUBSTRATE: Tinplate; DESCRIPTOR: Spray, White;

Acceptable Usage and Limitations------------------------------.. Based on continuing acceptable performance, the status of this version of 642-W-502 is revised to "Standard" as of 13 November 2001.

EX-01-218 & EX-01-218-1 run at Plant #84, Owatonna.

This version of 642-W-502 has the original solvent blend and 0.15% Defoaming Agent.

PROTECT FROM FREEZING. This is a water base coating.

voe= 3.o lb./gal.

Optimum spray gun pressures and placements will vary slightly from machine to ,machine.

Film Weight Distribution: Upper Side Wall - 24 mg/4 sq.in. minimum Lower Side Wall - 20 mg/4 sq.in. minimum Dome - 18 mg/4 sq.in. minimum

Cure temperatures are metal temperatures measured on the dome.

,.. Internal Lubricants ------------. r Resin Modifiers r Pigments

Name Level .. LM_e_1_am_in_e_F_orm_a_1d_e_h_yd_e _________ ...1l 1.tn_r_ta_n_iu_m_D_i_ox_i_de ____ __.j

Carnauba 0.5%

[

Additives Used at Point of Application.

r"''·~~ lwater

',,

1 I Amount Units CCSCode

Hazardous Ingredients (Non-Volatile)---------------------------------.

C.A.S.# Ingredient Name

68002-20-0 Melamine Resin

r Volatile Ingredients I Ingredient Name

Weight% (Total) C.A.S. # Ingredient Name

2.1 13463-67-7 Titanium Dioxide

Wt 0/o Wt 0/o Vol 0/o Specific Volatile

http:// emcseur/v _ Coating.asp?MaterialID= 1002301&ApplicationID=1002301 &CallSource ...

Weight% (Total)

8.9

8/3/2010

CCS EMCS - ICI - 642-W-502 - Coating Report Page 2 of3

Water 84.8 60.3 82.6 1.000 8.33 lb/US gal

n-Butanol 7.7 5.5 9.2 0.812 6.76 lb/US gal

Ethylene Glycol Monobutyl Ether 4.6 3.3 5 0.902 7.51 lb/US gal

Dimethyl Ethanolamine (DMEA) "' '2'.4"' 1.7 2.6 0.887 7.39 lb/US gal

Isopropanol 'b.5 0.3 0.6 0.788 6.56 lb/US gal

Formaldehyde 0.01 0.005 0.01 1.100 9.16 lb/US gal

voe Data

lb/gal kg/I Weight% Volume%

Liquid Density: 9.22 1.1 Coating Solids (Non-Volatiles): 28.9 19.2

ASTM Dl475 ASTM D2369

VOC Content: 3 0.36 Coating Water Content: 60.3 66.7

Method 24 ASTM 03960 Check Method: ASTM 3792

Density (Wt. VOC/vol. Solids): 5.2 0.62 Total Volatiles: 71.1 80.8

Method 24 ASTM 03960 ASTM 02369 (H20 Included):

Physical Properties Flash Point: 124 ° F -- O.Sg -- -- 1.0g --

pH: 8.5 +/- 0.5 Percent Solids: 27 +/- 0.6 +/- (Weight%) (water based materials) (per recommended Cure Schedule)

Received Viscosity • Specific Gravity

Method: #4 Ford Cup :J, •i' ..

24 +/- 5 sec.@ 70° F 1.11 +/- 0.005 70° F

22 +/- 5 sec.@ 80° F 1.107 +/- 0.005 80° F

20 +/- 5 sec.@ 90° F 1.104 +/- 0.005 90° F

19 +/- 5 sec.@ 100° F 1.101 +/- 0.005 100° F

Storage and Handling-----------------------------------..

Minimum Storage Temp: 40 ° F

Optimum Storage Temp: 70 ° F

Maximum Storage Temp: 100 ° F

Shelf Life: 6 months @ optimum storage temperature

Comment: PROTECT FROM FREEZING. Mix with agitation before use.

Application Data-------------------------------------.

Cure Schedule @ Peak Substrate Temperature Temperature Curve

Minimum Cure: 400 ° F 2 Minutes

Maximum Cure: 415 ° F 3 Minutes

Coating Application Temp: 100 ° F

Clean-Up Solvents-----------------

80:20 Water:Ethylene Glycol Monobutyl Ether

Water

Film Weight p_er Can Mileage Calculations per Component •

(Enter all film weights/components and appropriate sizes) ASTM (EPA): Per lg Sample: Per O.Sg Sample:

Film wt: Size: 'I':.'.. ' gal IM kg I K gal IM kg I K gal IM kg I K

1) 365 +/- 45 mg/Can 300 x 407 in. - Stl 0.3020 1.2630 0.0000 0.0000 0.3232 1.3519

2) 355 +/- 45 mg/Can 300 x 404 in. - Stl 0.2937 1.2284 0.0000 0.0000 0.3144 1.3148

3) 349 +/- 45 mg/Can 300 x 402 in. - Stl 0.2888 1.2076 0.0000 0.0000 0.3091 1.2926

4) 343 +/- 45 mg/Can 300 x 400 in. - Stl 0.2838 1.1869 0.0000 0.0000 0.3038 1.2704

http://emcseur/v _ Coating.asp?MaterialID= 1002301&ApplicationID=1002301 &CallSource. .. 8/3/2010

CCS EMCS - ICI - 642-W-502 - Coating Report Page 3 of3

5) 340 +/- 45 mg/Can 300 x 315 in. - Stl 0.2813 1.1765 0.0000 0.0000 0.3011 1.2593

r Mixing Instructions Mix coating thoroughly prior to use.

~Supporting Documentation (Material)-------------------------------.

Safety Data Sheets

USA Version: Verification Date: 05-May-2006

~ Supporting Documentation (Application

EX Records

Initially Prepared By:

(Material)


(Application)

01-218-1

03-413-0

Lewandowski, Phil

Lewandowski, Phil

84-0watonna · ... i '

245-Weston

Plant will

schedule.

8-0ct-2003

CCS Date Prepared:

CCS Date Prepared:

Copyright © Crown Cork and Seal Company, Inc. 1998

.r.·,

Passed

Passed

10-Jul-2001

10-Jul-2001

View EX

http://emcseur/v_Coating.asp?MaterialID=1002301&ApplicationID=1002301&CallSource... 8/3/2010

,~CS EMCS - Akzo Nobel - 642-L-523 .: Coating Report

CROWN Technology Electronic Materials Control System

Environmental Health & Safety Report - Coatings and Side Seams

Supplier Name: Akzo Nobel Supplier Date Prepared:

(Material)


(Application)

26-Jun-2002

26-Jun-2002

Page 1of3

CROWN

Material Description-------------------------------------.

Supplier Code:

Old Supplier Code:

Old CCS/CMB Code:

Material Type:

Material Status:

Comments:

Primary Use:

Secondary Use:

642-L-523

1.5.9

Water Based

Standard


DWI Coating

. Application Method: Airless Spray

Ma.)or Resin Type: Modified epoxy

· Dry Film Color: Gold

Where Used: Americas Division

Purchasing Code: COT02071

CCSCode: 20.02.093

Function Codes---------------------------------------. CS1026 = BUSINESS AREA: Food; PACKAGE TECHNOLOGY: DWI; COATING USE: Single coat; SURFACE: Interior; SUBSTRATE: Tinplate; DESCRIPTOR: Spray, Transparent;

Acceptable Usage and Limitations-------------------------------. This cured film is identical to that of Akzo 642-L-501 (20.01.364).

Apply without reduction.

Optimum spray gun pressures and placements will vary slightly from machine to machine.

MINIMUM dry coating weight: Upper Side Wall - 4.5 msi Lower Side Wall - 4.0 msi Dome -4.0 msi

PROTECT FROM FREEZING. This is a water base coatin!;J.

VOC Content = 3.3 Lb./Gal.


I d" ts ngre 1en - Internal Lubricants - Resin Modifiers

Name Level Phenolic

Carnauba 0.5% Melamine Formaldehyde

- Pigments No Pigment information to

display

Additives Used at Point of Application----------------------------...... rThinners

I None Allowed

Amount Units CCS Code

Hazardous Ingredients (Non-Volatile)---------------------------------.

C.A.S.# Ingredient Name

25085-75-0 Phenolic Resin

r

Volatile Ingredients

Ingredient Name

Water

Weight% C.A.S.# (Total)

6.6 68002-20-0

Wt% Wt% (Volatiles) (Total)

77.5 56.2

Ingredient Name

Melamine Resin

Vol 0/o Specific Volatile (Volatiles) Gravity Density

74.4 1.000 8.33

http://emcseur/v_Coating.asp?MaterialID=1003016&ApplicationID=l003016&Ca11Source ...

Weight% (Total)

1.9

lb/US gal

8/3/2010

CCS EMCS - Akzo Nobel - 642-L-523 - Coating Report Page 2of3

n-Butanol 12.4 9 14.6 0.812 6.76 lb/US gal

Ethylene Glycol Monobutyl Ether 6.3 4.6 6.7 0.902 7.51 lb/US gal

Dimethyl Ethanolamine (DMEA) 2.1 1.5 2.3 0.887 7.39 lb/US gal

Isopropanol 1.7 1.2 2 0.788 6.56 lb/US gal

Formaldehyde 0.14 0.1 0.12 1.100 9.16 lb/US gal

voe Data lb/gal kg/I Weight% Volume%

Liquid Density: 8.55 1.03 Coating Solids {Non-Volatiles): 27.5 22.4

ASTM 01475 ASTM 02369

VOC Content: 3.3 0.4 Coating Water Content: 56.2 57.7

Method 24 ASTM 03960 Check Method: ASTM 3792

Density {Wt. VOC/vol. Solids): 6.2 0.74 Total Volatiles: 72.5 77.6

Method 24 ASTM 03960 ASTM 02369 (H20 Included):

h .. P ys1ca I p rope rt" 1es Flash Point: 122 ° F -- O.Sg -- -- 1.0g --

pH: 8.5 +/- 0.5 Percent Solids: 25 +/- 1 +/- (Weight%) (water based materials)

(per recommended Cure Schedule)

- Received Viscosity .. Specific Gravity

Method: #4 Ford Cup

26 +/- 3 sec.@ 70° F 1.029 +/- 0.012 70° F

24 +/- 3 sec.@ 80° F 1.026 +/- 0.012 80° F

21 +/· 3 sec.@ 90° F I

"" ',, 1.023 +/- 0.012 90° F

19 +/- 3 sec.@ 100° F 1.02 +/- 0.012 100° F

Storage and Handling------------------------------------.



Comment:

- Application Data Cure Schedule @ Peak Substrate Temperature

Minimum Cure: 400 ° F 2.5 Minutes


,.. Clean-Up Solvents



Temperature Curve

Coating Application Temp: 100 ° F

80:20 Water:Ethylene Glycol Monobutyl Ether

Water

Film Weight per Can Mileage Calculations per Component

(Enter all film weights/components and appropriate sizes) ASTM (EPA): Per lg Sample: Per O.Sg Sample:

Film wt: Size: gal/ M kg I K gal IM kg I K gal/ M kg I K

1) 250 +/- 35 mg/Can 300 x 407 in. - Stl 0.2344 0.9091 0.0000 0.0000 0.2578 1.0000

2) 240 +/- 35 mg/Can 300 x 404 in. - Stl '' 0.2250 0.8727 0.0000 0.0000 0.2475 0.9600

3) 234 +/- 35 mg/Can 300 x 402 in. - Stl 0.2194 0.8509 0.0000 0.0000 0.2413 0.9360

4) 228 +/- 35 mg/Can 300 x 400 in. - Stl 0.2138 0.8291 0.0000 0.0000 0.2352 0.9120

5) 225 +/- 35 mg/Can 300 x 315 in. - Stl 0.2110 0.8182 0.0000 0.0000 0.2321 0.9000

6) 202 +/- 20 mg/Can 211 x 315 in. - Stl 0.1894 0.7345 0.0000 0.0000 0.2083 0.8080

http://emcseur/v_Coating.asp?MaterialID=1003016&ApplicationID=1003016&Ca11Source... 8/3/2010

CCS EMCS - Akzo Nobel - 642-L-523 - Coating Report Page 3of3

Mixing Instructions--------------------------------------Mix coating thoroughly prior to use.

- Supporting Documentation (Material)------------------------------

USA

Safety Data Sheets

Version: Verification Date: 25-Apr-2006

- Supporting Documentation (Application)-------------------------------.


(Material)


(Application)

02-164-0

Lewandowski, Phil

Lewandowski, Phil

EX Records

84-0watonna July lO - ll, Passed

2002

CCS Date Prepared: 05-Jul-2002

CCS Date Prepared: 05-Jul-2002

Copyright © Crown Cork and Seal Company, Inc. 1998

http://emcseur/v _ Coating.asp?MateriallD= 1003016&ApplicationID= 10030 l 6&Ca11Source... 8/3/2010

r::cs EMCS - PPG- PPG3923605 - Coating Report

CROWN Technology Electronic Materials Control System

Environmental Health &. Safety Report - Coatings and Side Seams

Supplier Name: PPG Supplier Date Prepared:

(Material)


(Application)

17-Sep-2009

17-Sep-2009

Page 1 of 3

CROWN

Material Description--------------------------------------

Supplier Code:

Old Supplier Code:

Old CCS/CMB Code:

Material Type:

Material Status:

Comments:

Primary Use:

Secondary Use:

PPG3923605

Water Based

EX


DWI Coating

Application Method:

Major Resin Type:

Dry Film Color:

Where Used:

Purchasing Code:

CCSCode:

Airless Spray

Epoxy-phenolic

Gray

Americas Division

20.01.BUV

Function Codes----------------------------------------. CX1030 = BUSINESS AREA: Food; PACKAGE TECHNOLOGY: DWI; COATING USE: Single coat; SURFACE: Interior; SUBSTRATE: Tinplate; DESCRIPTOR: Spray, Grey, Meat Release;

Acceptable Usage and Limitations------------------------------.. Interior Gray water base spray enamel with meat release agent.

voe= 3.o

FIILM WEIGHT DISTRIBUTION Upper Side Wall = 18 mg/4 sq.in. MINIMUM Lower Side Wall = 18 mg/4 sq.in. MINIMUM Dome= 20 mg/4 sq.in. MINIMUM

PROTECT FROM FREEZING. This is a water base coating.


'"Ingredients ,. Internal Lubricants ~ Resin Modifiers

Name Level Acrylic

Hydrocarbon 2.85%

[

Additives Used at Point of Application

[

Thinners

_water

Amount

,. Pigments I Titanium Dioxide

Black

Units CCS Code

1 I Hazardous Ingredients (Non-Volatile)---......,-----------------------------.

C.A.S. # Ingredient Name Weight% CA. S # (Total) • • •

No Hazardous Ingredients to display

Volatile Ingredients

Ingredient Name Wt% Wt% (Volatiles) (Total)

Water 80 55.2

n-Butanol 8.7 6

Not Listed 4.9 3.4

Ethylene Glycol Monobutyl Ether 3 2.1

Ingredient Name

Vol% Specific (Volatiles) Gravity

76.9 1.000

10.3 0.809

5.8 0.816

3.2 0.902

Volatile Density

8.33

6.74

6.8

7.51

Weight% (Total)

lb/US gal

lb/US gal

lb/US gal

lb/US gal

http://emcseur/v _ Coating.asp?MaterialID=l 004482&ApplicationID=l 004695&Cal1Source... 8/3/2010

CCS EMCS - PPG- PPG3923605 - Coating Report Page 2 of3

Dimethyl Ethanolamine (DMEA) 2 1.4 2.2 0.887 7.39 lb/US gal

Methyl Ethyl Ketone (MEK) 0.5 0.4 0.6 0.809 6.74 lb/US gal

Triethylamine 0.5 0.4 0.7 0.727 6.06 lb/US gal

Propylene Glycol '0.4' ''1 ": .~ I 0.4 0.3 1.036 6.74 lb/US gal '·'~ '11 : •

voe Data

lb/gal kg/I Weight% Volume 010

Liquid Density: 8.9 1.068 Coating Solids (Non-Volatiles): 31 23.2

ASTM D1475 ASTM D2369

VOC Content: 3 0.36 Coating Water Content: 55.2 59

Method 24 ASTM D3960 Check Method: ASTM 4017

Density {Wt. VOC/vol. Solids): 5.3 0.63 Total Volatiles: 69 76.8

Method 24 ASTM D3960 ASTM D2369 (H20 Included):

h - P ys1ca Properties

Flash Point: 116 ° F -- O.Sg -- -- 1.0g --

pH: 7.64 +/- 0.15 Percent Solids: 27.8 +/- 1.5 27.2 +/- 1.5 (Weight%) (water based materials) (per recommended Cure Schedule)

• Received Viscosity Specific Gravity

Method: #4 Ford Cup

24 +/- 2 sec.@ 70° F 9.06 +/- 0.024 70° F

22 +/- 2 sec.@ 80° F 9.041 +/- 0.024 80° F 'f;.

20 +/- 2 sec.@ 90° F 9.02 +/- 0.024 90° F

18 +/- 2 sec.@ 100° F 9.011 +/- 0.024 100° F

Storage and Handling-----------------------------------



Comment: Do not freeze



-Application Data--------------------------------------.

Cure Schedule @ Peak Substrate Temperature Temperature Curve

Minimum Cure: 400 ° F 2 Minutes


Coating Application Temp: ° F

[ Clean-Up Solvents

Water

Film Weight per Can Mileage Calculations per Component

(Enter all film weights/components and appropriate sizes)

1}

2)

Film wt:

275 +/- 25 mg/Can

310 +/- 25 mg/Can

r Mixing Instructions Mix coating thoroughly prior to use.

Size:

300 x 400 in. - Stl

300 x 404 in. - Stl

ASTM (EPA}:

gal/ M kg I K

0.2197 0.8871

0.2477 1.0000

Per lg Sample: Per O.Sg Sample:

gal IM kg I K gal IM kg I K

0.2504 1.0110 0.2450 0.9892

0.2823 1.1397 0.2762 1.1151

,... Supporting Documentation (Material)--------------------------------.

Safety Data Sheets

USA Version: 00294885 Verification Date: 14-Jul-2004

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CCS EMCS - PPG - PPG3923605 - Coating Report Page 3 of3

- Supporting Documentation (Application)----------------------------


(Material)


(Application)

04-368-0

04-368-1

Lewandowski, Phil

Lewandowski, Phil

EX Records

84-0watonna 22 September Passed

84-0watonna

2004

06 February

2009

CCS Date Prepared:

CCS Date Prepared:

Passed

16-Jul-2004

16-Jul-2004

Copyright ©.Crown ·~ork. ~hd :Se.al .Company, Inc. 1998 ,.'1' .' ..

View!;)<

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