TABLE OF CONTENTS Notice to the Permittee … OF CONTENTS Notice to the Permittee Permit Shield ......

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Table A: Limits and Other Requirements Table B: Submittals Table C: Compliance Schedule Appendices: Attached and Referenced in Table A

[Contact] NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area (612) 296-6300 Outside Metro Area 1-800-657-3864 TTY (612) 282-5332 The rule governing these programs are contained in Minn. Rules ch. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. Rules pt. 70007.1800, 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. Requirements which have been determined not to apply are listed in Table A of this permit, at the beginning of total facility requirements. The permit shield, however does not apply to: Minn. Rules ch. 7030 (Noise Pollution Control).

[Contact]

AIR EMISSION PERMIT NO. 00000605-001

IS ISSUED TO

GREDE FOUNDRIES INC. Grede - St. Cloud Inc. 5200 Foundry Circle

St. Cloud, Stearns County, Minnesota 56303 The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Total Facility Operating Permit 09/28/95 This permit authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit and with all general conditions listed in Minn. R. 7007.0800, subp. 16 and all standard permit requirements listed in 40 CFR 70.6(a). 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 as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: State, Syn Min PSD/NSR Issue Date: 03/14/96 Expiration: Permit does not expire All Title I Conditions do not expire. ___________________________________ Rodney E. Massey, P.E. Acting Division Manager Air Quality Division for Charles W. Williams Commissioner Minnesota Pollution Control Agency

TABLE A: LIMITS AND OTHER REQUIREMENTS 03/14/96

Grede - St Cloud Inc

00900026 - 001

Facility Name:

Permit Number:

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column ofthe table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you musttake and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it)lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facilityrequirements.

Subject Item: Total Facility

What to do Why to do itAir Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated, unlessotherwise noted in Table A.

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

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment.

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

Shutdowns: Notify the Commissioner at least 24 hours in advance of shutdown ofany process or control equipment if the shutdown would cause an increase in theemission of air contaminants. At the time of notification, notify the Commissioner ofthe cause of the shutdown and the estimated duration. Notify the Commissioneragain when the shutdown is over.

Minn. R. 7019.1000, subp. 1

Breakdowns: Notify the Commissioner immediately of a breakdown of more thanone hour duration of any process or control equipment if the breakdown causes anincrease in the emission of air contaminants. At the time of notification or as soonthereafter as possible, the permittee shall also notify the Commissioner of thecause of the breakdown and the estimated duration. Notify the Commissioneragain when the breakdown is over.

Minn. R. 7019.1000, subp. 2

Monitoring Equipment: Install or make needed repairs to monitoring equipmentwithin 60 days of issuance of the permit if monitoring equipment is not installed andoperational on the date the permit is issued.

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

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

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

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, such as for systembreakdowns, repairs, calibration checks, and zero and span adjustments (asapplicable). Monitoring records should reflect any such periods of processshutdown.

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

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

Minn. R. 7011.0020

Performance Testing: Conduct all performance tests in accordance with Minn. R.ch. 7017 unless otherwise noted in Tables A, B, and/or C.

Minn. R. ch. 7017

Oral Notification of Deviations Endangering Human Health or the Environment:Within 24 hours of discovery, orally notify the Commissioner of any deviation frompermit conditions which could endanger human health or the environment.

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

Discovery of Deviations Endangering Human Health or the Environment Report(written): due two working days after discovery of deviation, submit a writtendescription of any deviation endangering human health or the environment to theCommissioner. Include the following information in this written description: causeof the deviation; exact dates of the period of the deviation; if the deviation has notbeen corrected, the anticipated time it is expected to continue; and steps taken orplanned to reduce, eliminate, and prevent reoccurrence of the deviation.

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

Application for Permit Amendment: If you need a permit amendment, submitapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

Minn. R. 7007.1150 through Minn. R. 7007.1500

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 through Minn. R. 7002.0095

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

Minn. R. 7011.0150

Inspections: Upon presentation of credentials and other documents as may berequired by law, allow the Agency, or its representative, to enter the Permittee'spremises, to have access to and copy any records required by this permit, toinspect at reasonable times (which include any time the source is operating) anyfacilities, equipment, practices or operations, and to sample or monitor anysubstances or parameters at any location.

Minn. R. 7007.0800, subp. 9(A)

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Permit Number:

Record keeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (asrequired by Minn. R. 7007.1350, subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007.0800, subp. 5(B)

Record keeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal strip-chart recordings for continuous monitoring instrumentation, and copiesof all reports required by the permit. Records must conform to the requirementslisted in Minn. R. 7007.0800, subp. 5(A).

Minn. R. 7007.0800, subp. 5(C)

Extension Requests: The permittee may apply for an Administrative Amendment toextend a deadline in a permit by no more than 120 days, provided the proposeddeadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

Minn. R. 7007.1400, subp. 1(H)

The Permittee shall recalculate the potential to emit of the stationary source if thePermittee becomes aware of any information indicating that the original calculationwould change because thye listed control equipment is not as efficient as originallyassumed under Minn. R. 7011.0070 or changes have been made to decrease thelisted control equipment's efficiency. The permittee shall submit this recalculationto the commissioner within 30 days of becoming aware of the information.

Minn. R. 7011.0075 subp. 7

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Facility Name:

Permit Number:

Subject Item: GP 001 Grinding and Cleaning Operations Stacks

Associated Items: SV 011

SV 012

SV 013

SV 031

What to do Why to do itPerformance Test: due 180 days after Permit Issuance . The Permittee shall testone of the four stacks on or before the due date for total particulate matter. Anyfuture performance tests should be conducted on previously untested stacks withinGroup 001.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,subp. 4; Minn. R. 7017.2020, subp. 1

Performance Test Pre-test Meeting: due 7 days before Performance Test Minn. R. 7017.2030, subp. 4

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Facility Name:

Permit Number:

Subject Item: GP 002 Grinding and Cleaning Operations

Associated Items: CE 011 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 012 Fabric Filter - Low Temperature, i.e., T<180 Degrees F



EU 014 Shot Blast

EU 015 Grinding & Cleaning Booth (Not in regular use in late 1995)

EU 034 Tumble Blast Cabinet

EU 039 Tumble Blast Cabinet (To be installed in the future)

EU 040 4 Cleaning Booths (To be installed in th future)

EU 041 Grinding Stands inside 4 Cleaning Booths

SV 011

SV 012

SV 013

SV 031

What to do Why to do itThe Permittee may move the listed emission units in group 002 such that they arestill controlled by the listed control equipment in group 002. The exhaust from anyof the listed control equipment in group 002 may be rerouted through any of thestack/vents listed in group 002. The Permittee shall maintain, on site, a processflow diagram of all of the items in group 002 which shall be updated within 15 daysof any item in group 002 being moved.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,subp. 5

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Facility Name:

Permit Number:

Subject Item: GP 003 Sand Handling Systems Stacks


SV 009

SV 010

What to do Why to do itPerformance Test: due 180 days after Permit Issuance . The Permittee shall testone of the three stacks on or before the due date for total particulate matter. Anyfuture performance tests should be conducted on previously untested stacks withinGroup 003.



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Facility Name:

Permit Number:

Subject Item: GP 004 Sand System Fabric Filters




What to do Why to do itIf necessary, the permittee shall apply for an amendment to update the pressuredrop range given for this control device once vendor data is available or after actualnormal operating data has been obtained. If necessary, the permittee shall applyfor the amendment no later than 60 days after permit issuance.

Minn. R. 7007.1500, subp. 1

Pressure Drop: greater than or equal to 4 inches of water column and less than orequal to 6 inches of water column , recorded once every 24 hours when inoperation.

Title I Condition: Monitoring of control equipment usedto avoid classification as major source andmodification under 40 CFR Section 52.21; and to avoidmajor source classification under 40 CFR Section70.2; Minn. R. 7007.0800, subp.14; Minn. R. 7

Operate and maintain control equipment to achieve a control efficiency ( = 100%collection efficiency X control equipment removal efficiency) for Particulate Matter <10 micron: greater than or equal to 99 percent control efficiency

Title I condition; limit to avoid classification as majorsource and modification under 40 CFR Section 52.21;Limit to avoid major source classification under 40CFRSection 70.2; Minn. R. 7011.0065, subp. 1(A)

Operate and maintain control equipment to achieve a control efficiency ( = 100%collection efficiency X control equipment removal efficiency) for Total ParticulateMatter: greater than or equal to 99 percent control efficiency

Title I condition; limit to avoid classification as majorsource and modification under 40 CFR Section 52.21;Limit to avoid major source classification under 40CFR Section 70.2; Minn. R. 7011.0065, subp. 1(A)

F. Check daily, or as required by the manufacturing specification, monitoringequipment for example; pressure gauges, chart recorders, temperature indicators,and recorders;G. Calibrate annually, or as required by manufacturing specification, all monitoringequipment;H. Maintain a record of activities conducted in items A to G consisting of the activitycompleted, the date the activity was completed, and any corrective action taken; andI. Maintain a record of parts replaced, repaired, or modified for the previous fiveyears.


A. Maintain an inventory of spare parts that are subject to frequent replacement asrequired by the manufacturing specification or documented in records under itemsH and I;B. Train staff on the operation and monitoring of control equipment andtroubleshooting, and train and require staff to respond to indications ofmalfunctioning equipment, including alarms, and other indicators of abnormaloperation;C. Thoroughly inspect all control equipment at least annually, or as required by themanufacturing specification (this often requires shutting down temporarily);D. Inspect monthly, or as required by the manufacturing specification, componentsthat are subject to wear or plugging, for example: bearings, belts hoses, fansnozzles, orifices and ducts;E. Inspect quarterly, or as required by the manufacturing specification, componentsthat are not subject to wear including structural components, housings, ducts, andhoods;


The Permittee shall operate the control equipment monitoring equipment at alltimes the control equipment is required to operate in compliance with Minn. R.7011.0075.


The Permittee shall submit a monitoring report to the Commissioner if there aredeviations from the specified pressure drop range for more than five percent of thepressure drop measurements taken in a calendar quarter. For example, if 90measurements are taken, 5 would have to deviate in order for a report to berequired. This report shall be submitted on the included Deviation OccuranceReporting Form and shall be due within 30 days after the end of each calendarquarter that it is required.

Minn. R. 7011.0075, subp. 5(B); Minn. R. 7007.0800,subp. 4(6)(B)(1)

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Facility Name:

Permit Number:

Subject Item: SV 001

Associated Items: EU 001 Electric Induction Furnace

EU 002 Scrap & Charge Handling (Scrap Charge Conveyor installed 1/15/96)

EU 003 3 Ladle Preheaters - Exhaust to room and ultimately through SV 001

EU 004 Mold Pouring & Cooling

EU 033 Inoculation

What to do Why to do itOpacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1 (B)

Performance Test: due 180 days after Permit Issuance . The permittee shallconduct the Particulate Matter performance test on or before the due date.

Minn. R. 7017.2020, subp. 1


Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot andalso less than or equal to either the amount allowed by Minn. R. 7011.0730 or theconcentration allowed by Minn. R. 7011.0735.

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

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Facility Name:

Permit Number:


Associated Items: EU 005 Core Sand Mixing

What to do Why to do itOpacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp.1(B)


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

Volatile Organic Compounds: less than or equal to 2.05 lbs/hour expressed ascarbon

Title I condition; limit to avoid classification as majorsource and modification under 40 CFR Section 52.2l;Limit to avoid major source classification under 40CFR Section 70.2

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Facility Name:

Permit Number:


Associated Items: EU 006 Core Making Machines (6)

What to do Why to do itOpacity: less than or equal to 20 percent opacity Minn. R. 7011.0715 subp.1(B)

Volatile Organic Compounds: less than or equal to 1.295 lbs/hour expressed ascarbon.

Title I condition; limit to avoid classification as majorsource and modification under 40 CFR Section 52.2l;Limit to avoid major source classification under 40CFR Section 70.2

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Facility Name:

Permit Number:


Associated Items: EU 009 North Sand Reclaimer

EU 010 South Sand Reclaimer

GP 003 Sand Handling Systems Stacks



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

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Facility Name:

Permit Number:


Associated Items: EU 011 Casting Shakeout (Emissions from EU 011- 013 combined before going to CE 006 - 008)

EU 012 Sand Cooler (Emissions from EU 011- 013 combined before going to CE 006 - 008)

EU 013 Muller & Sand Handling (Emissions from EU 011- 013 combined before going to CE 006 - 008)




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

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Facility Name:

Permit Number:


Associated Items: EU 011 Casting Shakeout (Emissions from EU 011- 013 combined before going to CE 006 - 008)

EU 012 Sand Cooler (Emissions from EU 011- 013 combined before going to CE 006 - 008)

EU 013 Muller & Sand Handling (Emissions from EU 011- 013 combined before going to CE 006 - 008)




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

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00900026 - 001

Facility Name:

Permit Number:


Associated Items: EU 014 Shot Blast

GP 001 Grinding and Cleaning Operations Stacks

GP 002 Grinding and Cleaning Operations



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

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Facility Name:

Permit Number:


Associated Items: EU 015 Grinding & Cleaning Booth (Not in regular use in late 1995)





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

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Facility Name:

Permit Number:


Associated Items: EU 034 Tumble Blast Cabinet






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

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00900026 - 001

Facility Name:

Permit Number:


Associated Items: EU 037 Sand Heater/Cooler

What to do Why to do itOpacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1 (B)


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

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00900026 - 001

Facility Name:

Permit Number:


Associated Items: EU 039 Tumble Blast Cabinet (To be installed in the future)






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

The construction authorization expires 365 days after permit issuance. ThePermittee must keep a record of the dates of installation and start up on site. ThePermittee may apply for an extension of the construction authorization deadline byfollowing the Administrative Amendment Provisions in Minn. R. 7007.1400.

Minn. R. 7007.0800, subp. 2

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Facility Name:

Permit Number:

Subject Item: EU 001 Electric Induction Furnace


SV 001

What to do Why to do itProcess Throughput: less than or equal to 92,000 tons/year using 12 Month RollingSum . This metal melted limit of 92,000 tons per year creates a bottleneck for therest of the equipment at the facility which causes the total facility potential to emit ofParticulate Matter and Particulate Matter Smaller Than 10 Microns to be less thanthe 100 ton per year major source threshold. The potentials to emit of theremaining pollutants are less than major source thresholds before taking intoaccount the metal melting bottleneck. The metal melting bottleneck on EU 001maynot be relaxed in the future such that the facility potential to emit exceeds majorsource thresholds without the facility becoming subject to the New Source Reviewrequirements found in 40 CFR 52.21 paragraphs (j) through (s.)

Title I Condition; limit to avoid classification as majorsource and modification under 40 CFR Section 52.21;limit to avoid major source classification under 40 CFRSection 70.2; Minn. R. 7007.0800, subp. 2

Calculate and record the 12 month rolling sum of tons of metal melted by the 15thof each month by adding together the tons of metal melted each of the previous 12calendar months. For example, by August 15, 1996, the tons of metal melted fromAugust 1, 1995 to July 31, 1996 must be added together to get the 12 month rollingsum.

Title I Condition; recordkeeping to show compliancewith Title I process throughput limit; Minn. R.7007.0800, subp. 5

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Facility Name:

Permit Number:

Subject Item: EU 003 3 Ladle Preheaters - Exhaust to room and ultimately through SV 001


What to do Why to do itFuel Usage: less than or equal to 7 million BTU's/hour of only natural gas or liquidpropane gas, combined between all three ladle pre-heaters.

Title 1 Condition: limit to avoid classification as majorsource and modification under 40 CFR Section 52.21;Limit to avoid major source classification under 40CFR Section 70.2

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00900026 - 001

Facility Name:

Permit Number:

Subject Item: EU 037 Sand Heater/Cooler


SV 030

What to do Why to do itProcess Throughput: less than or equal to 78,840 tons/year using 12 Month RollingSum . This core sand processed limit of 78,840 tons per year is based on themaximum capacity of the machine which is 9 tons per hour. This limit is the basisfor the PM and PM10 potential to emit calculation for core sand handling and is thebasis for the VOC potential to emit calculation for the core sand mixer.

Title I Condition; limit to avoid classification as majorsource and modification under 40 CFR Section 52.21;limit to avoid major source classification under 40 CFRSection 70.2; Minn. R. 7007.0800, subp. 2

Calculate and record the 12 month rolling sum of tons of core sand processed bythe 15th of each month by adding together the tons of core sand processed each ofthe previous 12 calendar months. For example, by August 15, 1996, the tons ofcore sand processed from August 1, 1995 to July 31, 1996 must be added togetherto get the 12 month rolling sum.

Title I Condition; recordkeeping to show compliancewith the Title I process throughput limit; Minn. R.7007.0800, subp. 5

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00900026 - 001

Facility Name:

Permit Number:

Subject Item: EU 039 Tumble Blast Cabinet (To be installed in the future)



SV 031

What to do Why to do itThe construction authorization expires 365 days after permit issuance. ThePermittee must keep a record of the dates of installation and start up on site. ThePermittee may apply for an extension of the construction authorization deadline byfollowing the Administrative Amendment Provisions in Minn. R. 7007.1400.

Minn. R. 7007.0800, subp. 2

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00900026 - 001

Facility Name:

Permit Number:

Subject Item: EU 040 4 Cleaning Booths (To be installed in th future)



SV 031


Minn. R. 7007.0800, subp. 2

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Facility Name:

Permit Number:

Subject Item: CE 001 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

Associated Items: EU 001 Electric Induction Furnace

EU 002 Scrap & Charge Handling (Scrap Charge Conveyor installed 1/15/96)

EU 004 Mold Pouring & Cooling

EU 033 Inoculation


Minn. R. 7007.1500, subp. 1



Operate and maintain the baghouse such that it removes the following percentageof PM10 exhausted to it. Particulate Matter < 10 micron: greater than or equal to 99percent destruction efficiency


Operate and maintain the baghouse such that it removes the following percentageof PM exhausted to it. Total Particulate Matter: greater than or equal to 99 percentdestruction efficiency








The Permittee shall maintain a record of the fan rotation speed and fan power drawof the furnace hoods (EU 001) and the pouring and cooling line (EU 004) hoodtaken once each calendar month during operation. The Permittee shall alsomaintain at the stationary source the engineer's evaluations of the furnace hoods(includes the furnace hood/cover and the furnace fugitive emissions hood) and thepouring and cooling line hood.


Operate and maintain control equipment, furnace hoods and the pouring andcooling line hood to limit Particulate Matter < 10 micron: greater than or equal to 80percent capture efficiency


Operate and maintain control equipment, furnace hoods and the pouring andcooling line hood to limit Total Particulate Matter: greater than or equal to 80percent capture efficiency


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Permit Number:



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Facility Name:

Permit Number:


Associated Items: EU 037 Sand Heater/Cooler


Minn. R. 7007.1500, subp. 1



Operate and maintain control equipment such that it achieves a control efficiency (= 100 %collection efficiency x removal efficiency of the fabric filter) for TotalParticulate Matter: greater than or equal to 99 percent control efficiency


Operate and maintain control equipment such that it achieves a control efficiency (= 100 %collection efficiency x removal efficiency of the fabric filter) for TotalParticulate Matter: greater than or equal to 99 percent control efficiency


F. Check daily, or as required by the manufacturing specification, monitoringequipment for example; pressure guages, chart recorders, temperature indicators,and recorders;G. Calibrate annually, or as required by manufacturing specification, all monitoringequipment;H. Maintain a record of activities conducted in items A to G consisting of the activitycompleted, the date the activity was completed, and any corrective action taken; andI. Maintain a record of parts replaced, repaired, or modified for the previous fiveyears.








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Permit Number:





Minn. R. 7007.1500, subp. 1















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Permit Number:





Minn. R. 7007.1500, subp. 1













The Permittee shall submit a monitoring report to the Commissioner if there aredeviations from the specified pressure drop range for more than five percent of thepressure drop measurements taken in a calendar quarter. For example, if 90measurements are taken, 5 have to deviate in order for a report to be required.This report shall be submitted on the included Deviation Occurance Reporting Formand shall be due within 30 days after the end of each calendar quarter that it isrequired.


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Facility Name:

Permit Number:


Associated Items: EU 014 Shot Blast



Minn. R. 7007.1500, subp. 1















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Facility Name:

Permit Number:


Associated Items: EU 015 Grinding & Cleaning Booth (Not in regular use in late 1995)



Minn. R. 7007.1500, subp. 1















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Facility Name:

Permit Number:


Associated Items: EU 034 Tumble Blast Cabinet




Minn. R. 7007.1500, subp. 1















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00900026 - 001

Facility Name:

Permit Number:

Subject Item: CE 020 Catalytic Afterburner w/Heat Exchanger


What to do Why to do itIf necessary, the permittee shall apply for an amendment to update the minimuminlet temperature given for this control device once vendor data is available or afteractual normal operating data has been obtained. If necessary, the permittee shallapply for the amendment no later than 60 days after permit issuance.

Minn. R. 7007.1500, subp. 1

Temperature: greater than or equal to 400 degrees F using 1 Minute Average .During normal production, the core sand mixer shall be electrically interlocked withthe Inlet temperature thermal couple (located after the burner and before thecatalyst) such that the core sand mixer cannot be operated unless the Inlettemperature is at or above 400 degrees F.

Title I Condition: limit to avoid classification as majorsource and modification under 40 CFR Section 52.21;and to avoid major source classification per 40 CFRSection 70.2; Minn. R. 7007.0800, subp.14; Minn. R.7011.0075, subp. 1

Operate and maintain control equipment to achieve a control efficiency ( = 100%collection efficiency X control equipment destruction efficiency) for Volatile OrganicCompounds: greater than or equal to 95 percent control efficiency



Title I Condition: Monitoring of control equipment usedto avoid classification as major source andmodification under 40 CFR Section 52.21and 40 CFRSection 70.2; Minn. R. 7007.0800, subp. 2; Minn. R.7007.0800, subp. 14; Minn. R. 7011.0075, subp.





The Permittee shall submit a monitoring report to the Commissioner if there aredeviations from the specified minimum inlet temperature while core sand is beingmixed for more than five percent of the operating time of EU 005 in a calendarquarter. For example, if EU 005 operated 1000 hours, 50 hours worth of inlettemperature readings would have to be below 400 degrees in order for a report tobe required. This report shall be submitted on the included Deviation OccuranceReporting Form and shall be due within 30 days after the end of each calendarquarter that it is required.


The Permittee shall keep a continuous hard copy readout of the inlet (after theburner, but prior to the catalyst) and outlet (after the catalyst) temperatures duringoperation.

Title I Condition: recordkeeping used to verifycompliance with a Title I condition; Minn. R.7011.0080; Minn. R. 7007.0800, subp.5

The permittee shall mount six 1 inch diameter catalyst samples to the catalyst bedprior to the start-up of CE 020. These catalyst samples shall be used inperformance tests to determine the reactivity of the catalyst bed.

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

2nd catalyst bed reactivity Performance Test: due before 01/31/00 Title I Condition: Monitoring of control equipment usedto avoid classification as major source andmodification under 40 CFR Section 52.21and 40 CFRSection 70.2; Minn. R. 7011.0080; Minn. R.7007.0800, subp. 2; Minn. R. 7007.0800, subp. 14

3rd catalyst bed reactivity Performance Test: due before 01/31/01 Title I Condition: Monitoring of control equipment usedto avoid classification as major source andmodification under 40 CFR Section 52.21and 40 CFRSection 70.2; Minn. R. 7011.0080; Minn. R.7007.0800, subp.2; Minn. R. 7007.0800, subp. 14

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00900026 - 001

Facility Name:

Permit Number:

4th catalyst bed reactivity Performance Test: due before 01/31/02 Title I Condition: Monitoring of control equipment usedto avoid classification as major source andmodification under 40 CFR Section 52.21and 40 CFRSection 70.2; Minn. R. 7011.0080; Minn. R.7007.0800, subp.2; Minn. R. 7007.0800, subp. 14

5th catalyst bed reactivity Performance Test: due before 01/31/03 Title I Condition: Monitoring of control equipment usedto avoid classification as major source andmodification under 40 CFR Section 52.21and 40 CFRSection 70.2; Minn. R. 7011.0080; Minn. R.7007.0800, subp.2; Minn. R. 7007.0800, subp. 14

Records of the catalyst bed reactivity tests shall be kept on site. The records shallinclude the dates each test was conducted, the results of each test and anycorrective actions taken as the result of each test.

Title I Condition: Monitoring of control equipment usedto avoid classification as major source andmodification under 40 CFR Section 52.21and 40 CFRSection 70.2; Minn. R. 7011.0080; Minn. R.7007.0800, subp.5; Minn. R. 7007.0800, subp. 4

1st catalyst bed reactivity Performance Test: due before 01/31/98 Title I Condition: Monitoring of control equipment usedto avoid classification as major source andmodification under 40 CFR Section 52.21and 40 CFRSection 70.2; Minn. R. 7011.0080; Minn. R.7007.0800, subp. 2; Minn. R. 7007.0800, subp. 14

The Permittee shall replace the catalyst bed when a reactivity performance testresult indicates that it is necessary or by January 31, 2004, which ever comes first.All replacement catalyst beds shall be mounted with six catalyst samples and shallbe tested for reactivity and replaced at the same frequency as the original catalystbed.

Title I Condition: Monitoring of control equipment usedto avoid classification as major source andmodification under 40 CFR Section 52.21and 40 CFRSection 70.2; Minn. R. 7011.0080; Minn. R.7007.0800, subp.2; Minn. R. 7007.0800, subp. 14

A-32



00900026 - 001

Facility Name:

Permit Number:

Subject Item: CE 021 Gas Scrubber (General, Not Classified)

Associated Items: EU 006 Core Making Machines (6)

What to do Why to do itPressure Drop: greater than or equal to 4 inches of water column and less than orequal to 6 inches of water column , recorded once every 24 hours when inoperation.

Title 1 Condition: Monitoring of control equipmentused to avoid classification as major source andmodification under 40 CFR Section 52.21; and to avoidmajor source classification under 40 CFR Section70.2; Minn. R. 7007.0800 subp.14; Minn. R. 70

pH: greater than or equal to 2.5 and less than or equal to 5.0, recorded once every24 hours when in operation.

Title 1 Condition: Monitoring of control equipmentused to avoid classification as major source andmodification under 40 CFR Section 52.21; and to avoidmajor source classification under 40 CFR Section70.2; Minn. R. 7007.0800 subp.14; Minn. R. 70

Operate and maintain control equipment to achieve a control efficiency ( = 100%collection efficiency X control equipment destruction efficiency) for Volatile OrganicCompounds: greater than or equal to 95 percent control efficiency

Title 1 Condition: limit to avoid classification as majorsource and modification unde r40 CFR Section 52.21;Limit to avoid major source classification under 40CFR Section 70.2; Minn. R. 7007.0800 subp. 2; Minn.R. 7007.0800 subp. 14

If necessary, the permittee shall apply for an amendment to update the pressuredrop or pH range given for this control device once vendor data is available or afteractual normal operating data has been obtained. If necessary, the permittee shallapply for the amendment no later than 60 days after permit issuance.

Minn. R. 7007.1500 subp. 1







The Permittee shall submit a monitoring report to the Commissioner if there aredeviations from the specified pressure drop and pH range for more than fivepercent of the measurements of each taken in a calendar quarter. For example, if90 measurements are taken, 5 would have to deviate in order for a report to berequired. This report shall be submitted on the included Deviation OccuranceReporting Form and shall be due within 30 days after the end of each calendarquarter that it is required.


A-33



00900026 - 001

Facility Name:

Permit Number:




Minn. R. 7007.1500, subp. 1















A-34



00900026 - 001

Facility Name:

Permit Number:


Associated Items: EU 039 Tumble Blast Cabinet (To be installed in the future)




Minn. R. 7007.0800, subp. 2

If necessary, the permittee shall apply for an amendment to update the pressuredrop range given for this control device once vendor data is available or after actualnormal operating data has been obtained. If necessary, the permittee shall applyfor the amendment no later than 60 days after permit issuance.

Minn. R. 7007.1500, subp. 1















A-35

TABLE B: SUBMITTALSFacility Name: Grede - St Cloud Inc

Permit Number: 00900026 - 001

03/14/96

Table B lists the submittals you must send to the Commissioner. Table B is divided into two sections, for source-specific submittalrequirements and for submittals required of all permittees. Source-specific submittals are further organized as either one-time onlyor recurrent requirements. You may also be subject to additional reporting requirements contained in the compliance schedulelocated in Table C of this permit. All submittals must be postmarked or received by the date specified in the table, and certified by aresponsible official, defined in Minn. R. 7007.0100, subp. 21. Submittals which must be provided on standardized forms approvedby the Commissioner are noted in Tables B and C.

Send any application for a permit or permit amendment to: Permit Information Coordinator, Permit Section, Air Quality Division,Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4914. Also send the Permit InformationCoordinator notices of: accumulated insignificant activities, installation of control equipment, replacement of an emissions unit,and changes that contravene a permit term.

Send all other submittals to: Compliance Tracking Coordinator, Compliance Determination Unit, Air Quality Division, MinnesotaPollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194.

B-1

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Grede - St Cloud Inc


03/14/96

What to send When to send Portion of Facility AffectedPerformance Test Notification (written) due 30 days before Performance Test GP001, GP003, SV001

Performance Test Plan due 30 days before Performance Test GP001, GP003, SV001

Performance Test Report - Microfiche Copy due 105 days after Performance Test GP001, GP003, SV001

Performance Test Report due 45 days after Performance Test GP001, GP003, SV001

The Permittee shall report what catalyst bedreactivity level necessitates changing the bedwith the first Notification

due before 01/30/97 CE020

B-2

TABLE B: RECURRENT SUBMITTALSFacility Name: Grede - St Cloud Inc


03/14/96

What to send When to send Portion of Facility AffectedSemiannual Deviations Report due 30 days after end of each calendar

half-year following Permit Issuance . Amid-year report, covering deviations whichocurred during the period from January 1through June 30, is due by July 30 of eachyear. An end-of-year report, coveringdeviations which occurred during the periodfrom July 1 through December 31, is due byJanuary 30 of each year. The report must besubmitted even if there were no deviations forthe reporting period. To be submitted on aform approved by the Commissioner.

Total Facility

Compliance Certification due 30 days after end of each calendar yearfollowing Permit Issuance (for the previouscalendar year) (January 30). To be submittedon a form approved by the Commissioner.

Total Facility

Emissions Inventory Report due 91 days after end of each calendar yearfollowing Permit Issuance (April 1). To besubmitted on a form approved by theCommissioner.

Total Facility

B-3

TECHNICAL SUPPORT DOCUMENT For

DRAFT AIR EMISSION PERMIT NO. 00000605-001 This technical support document is for all the interested parties of the draft permit and to meet the requirements that have been set forth by the federal regulations and Minnesota Rules (40 CFR, Section 70.7(a)(5) and Minn. R. 7007.0850, subp. 1.) The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft permit. 1. General Information 1.1. Applicant and Stationary Source Location:

Applicant/Address Stationary Source/Address (SIC Code: 3321)

Grede Foundries, Inc. Grede - St. Cloud, Inc. P.O. Box 26499 5200 Foundry Circle 9898 Bluemound Road St. Cloud, Minnesota 56303 Milwaukee, Wisconsin 53226

1.2. Description Of The Permit Action

The Permittee has requested to switch from it’s current Option D Registration Permit to a State Permit which will allow the Facility to increase it’s actual emissions, but still limits the Facility’s emissions to less than 100 tons per year for each criteria pollutant. This limitation will keep the Facility from being a Major source under 40 CFR 52.21, New Source Review, Prevention of Significant Deterioration. The Permittee submitted this request in a complete permit application received on September 28, 1995. Neither an Environmental Assessment Worksheet (EAW) nor an Environmental Impact Statement (EIS) have been conducted, but neither is required.

1.3. Emissions of the Facility and Proposed Modification The Permittee purchased the Facility on September 15, 1995. The Facility has been operating under a Registration Permit Option D since then. The Permittee started producing ductile iron instead of steel when the ownership changed. This change in process necessitated several modifications at the facility which will all be completed under the auspices of the Registration Permit. The Facility has been operating in a start-up/testing/semi-construction mode since September 15, with very low actual emissions. The Facility will soon be capable of full-scale production, thus the Permittee has requested this new permit which allows higher actual emissions. The Facility is one of

[Contact] Page 2

the 28 source categories named in 40 CFR 52.21 which has a Major Source Threshold of 100 tons per year. Therefore, in requesting a permit with emission limits below 100 tons per year, the Facility will not only be considered a non-major source per 40 CFR 52.21, it will also be considered a non-major source per 40 CFR 70, the Federal Operating Permit Program. The major pollutants of concern from this facility are PM, PM10 and VOC’s. PM and PM 10 have been limited to 83 tons per year and VOC’s have been limited to 51 tons per year by limiting the melt rate on the induction furnace at the Facility, and by using the Minnesota Control Equipment Rule in Minn. R. 7011.0070 - .0080. The melt rate limitation on the induction furnace will not be able to be relaxed in the future in such a way that the Facility becomes a major source per 40 CFR 52.21 without first going through Prevention of Significant Deterioration Review, which would include establishing the Best Available Control Technology for the facility. Relaxing the melt rate limitation such that the Facility becomes a major source without Prevention of Significant Deterioration Review would constitute Sham Permitting.

Table 1. Total Facility Potential to Emit Summary and Attainment Status:

Pollutant Potential to Emit after Permit No.

00000605-001 Issued (Tons/year =TPY)

Attainment or Unclassified? (Yes or No)

Particulate Matter (PM) 82.99 Not Applied Particulate Matter less than 10 micron (PM10) 82.99 Attainment Sulfur Dioxide (SO2) 0.32 Attainment Nitrogen Oxides (NOx) 5.56 Attainment Volatile Organic Compounds (VOCs)/Ozone 50.97 Attainment Carbon Monoxide (CO) 1.07 Attainment Lead/Lead Compounds 0.97 Attainment Hazardous Air Pollutants:

Acrolein 0.0578 Not Applied Benzene 4.0683 Not Applied Formaldehyde 0.0715 Not Applied Manganese Compounds 0.2220 Not Applied Naphthalene 0.0475 Not Applied Phenol 0.2201 Not Applied Toluene 0.9754 Not Applied Xylenes (mixed isomers) 4.0591 Not Applied Total Hazardous Air Pollutants 9.7217 NA

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Table 2. Facility Classification

Classification (put x in appropriate box)

Major Synthetic Minor

Minor N/A

Prevention of Significant Deterioration X Non Attainment Area (list pollutant) X Operating Permit Program X

Table 3. Potential to Emit Allowed in the Proposed Modification

Pollutant

Potential to Emit under the Registration Permit (permit held prior to AQD Permit # 00000605-001)

Potential to Emit from the modification (TPY)

PSD* Significant Threshold Level (TPY)

PSD*Review Required (Yes or No)

PM 50 82.99 100 No PM10 50 82.99 100 No SO2 50 0.32 100 No NOx 50 5.56 100 No VOC 50 50.97 100 No CO 50 1.07 100 No

Lead .5 0.97 100 No Single Hazardous

Air Pollutant 5 Varies, see Table

1 NA NA

Total Hazardous Air Pollutants

12.5 9.7217 NA NA

*Federal Prevention of Significant Deterioration Regulation, 40 CFR Part 52.21 2. Regulatory and/or Statutory Basis of Emission Limits Control Equipment: CE 001, Fabric Filter with hood collection for the Furnace, Scrap & Charge Handling, Mold Pouring & Cooling, and Inoculation Emission Limit and/or Special Conditions: 1. Required to collect 80 percent of the emissions from these sources. 2. Required to remove 99 percent of the particulates in the exhaust stream that reaches the baghouse. 3. Required to monitor, keep records, and report deviations of the baghouse operating parameters and the hood system. Factual and legal basis for above: The Permittee is limiting the total facility PM and PM10

emissions to less than 100 tons per year in order to be classified as non-major under PSD and Part 70. The Permittee is invoking the Minnesota Control Equipment rules in Minn. R. ch. 7011 in order to limit particulates. The limits on CE 001 come straight from 7011 - see the specific rule citations in the permit.

[Contact] Page 4 Control Equipment: CE 002, 004, 005, 006, 007, 008, 011, 012, 013, 024 and 025, Fabric Filters

with total enclosure that collect dust from the rest of the facility Emission Limit and/or Special Conditions: 1. Required to remove 99 percent of the particulates in the exhaust stream that reaches the baghouse. 3. Required to monitor, keep records, and report deviations of the baghouse operating parameters. Factual and legal basis for above: The Permittee is limiting the total facility PM and PM10

emissions to less than 100 tons per year in order to be classified as non-major under PSD and Part 70. The Permittee is invoking the Minnesota Control Equipment rules in Minn. R.. ch.. 7011 in order to limit particulates. The limits on the above listed baghouses come straight from 7011 - see the specific rule citations in the permit.

Control Equipment: CE020 - Catalytic Afterburner for Core Sand Mixing with total enclosure. Emission Limit and/or Special Conditions: 1. Required to control 95% of the VOC’s emitted

from core sand mixing. 2. Required to monitor, keep records, and report deviations of the baghouse operating parameters. 3. Required to do catalyst bed reactivity tests at a minimum frequency of once every two years.

Factual and legal basis for above: The Permittee is limiting the total facility VOC emissions to less than 100 tons per year in order to be classified as non-major under PSD and Part 70. The Permittee is invoking the Minnesota Control Equipment rules in Minn. R. ch.. 7011 in order to limit VOC’s. The limits on the afterburner come straight from Minn. R. ch. 7011 - see the specific rule citations in the permit. Minn. R. ch. 7011 recommends testing the catalyst bed once every 3 months, but the manufacturer recommended once every two years because the estimated life of the bed is 8 years, and it will be difficult to test for reactivity because this system uses a platinum honeycomb matrix as the catalyst as opposed to a bed of loose catalyst material.

Control Equipment: CE021 - Gas Scrubber with total enclosure for the core making machines. Emission Limit and/or Special Conditions: 1. Required to control 95 percent of the VOC’s emitted from core making. 2. Required to monitor, keep records, and report deviations of the baghouse operating parameters Factual and legal basis for above: The Permittee is limiting the total facility VOC emissions to

less than 100 tons per year in order to be classified as non-major under PSD and Part 70. The Permittee is invoking the Minnesota Control Equipment rules in Minn. R. ch. 7011 in order to limit VOC’s. The limits on the scrubber come straight from Minn. R. ch. 7011 - see the specific rule citations in the permit. Other foundries generally don’t have VOC control on this type of source. This scrubber is mainly in place for odor control.

Emission Unit: EU 001 - Induction Furnace Emission Limit and/or Special Conditions: 1. Limited to 92,000 tons per year metal melted based on a 12 month rolling sum. 2. Required to calculate and record the rolling sum each month.

[Contact] Page 5 Factual and legal basis for above: The Permittee is limiting the total facility PM and PM10

emissions to less than 100 tons per year in order to be classified as non-major under PSD and Part 70. As well as invoking the Minnesota Control Equipment rules, the Permittee is limiting the amount of metal allowed to be melted in order to limit particulate emissions below 100 tons per year. Most of the emission factors for foundries found in AP-42 are based on the amount of metal melted, so this limitation also limits the emissions from EU 002, 004, 011, 014, 015, 033, 034, 039, 040, 041. The induction furnace is physically capable of 133152 tons of metal melted per year (15.2 tons/hour.)

Emission Unit: EU 003 - Ladle Preheaters Emission Limit and/or Special Conditions: 1. Limited to 7 MMBTU/Hr. natural gas or liquid

propane gas. Factual and legal basis for above: 7 MMBTU/Hr. is the maximum the ladle preheaters are

designed for, and they are designed to only burn natural gas or lpg, but this limit was placed in the permit as part of the limitation on the whole facility to keep PM and VOC emissions at non-major levels.

Emission Unit: EU 037 - Sand Heater/Cooler Emission Limit and/or Special Conditions: 1. Limited to 78,000 tons per year core sand

processed based on a 12 month rolling sum. 2. Required to calculate and record the rolling sum each month.

Factual and legal basis for above: The Permittee is limiting the total facility PM and PM10 emissions to less than 100 tons per year in order to be classified as non-major under PSD and Part 70. As well as invoking the Minnesota Control Equipment rules, the Permittee is limiting the amount of core sand allowed to be processed in order to limit particulate emissions below 100 tons per year. The AP-42 emission factor for sand handling is based on the tons of sand handled, and sand handling in this case includes (for emission calculation purposes) EU 037 and EU 005. VOC emissions from EU 006 are also being limited by limiting the amount of core sand that can be processed. The core sand heater/cooler and the core sand mixer are only physically capable of handling 9 tons of sand/hour (78840 tons/year.)

Emission Source Items: EU 039, 040, CE 025, and SV 031 - Future Grinding and Cleaning Line Emission Limit and/or Special Conditions: 1. Construction authorization expires one year from

permit issuance date. Factual and legal basis for above: Customary limitation on planned emission sources. This

limitation can be placed on the facility by virtue of Minn. R. 7007.0800, subp. 2. The source could probably still install a new grinding and cleaning line with less than a Major Permit Amendment after the construction authorization expires because of the way emissions have been calculated for this permit.

Emission Source Items: Total Facility Emission Limit and/or Special Conditions: 1. Various Factual and legal basis for above: See individual rule citations in the permit. All of these

requirements are standard for most facilities.

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Emission Group: GP 001 - Grinding and Cleaning Operations Stacks Emission Limit and/or Special Conditions: 1. One stack within the group must be tested within

180 days of permit issuance for Total Particulate Matter. 2. General requirements for performance tests found in Minn. R. ch.. 7017. Factual and legal basis for above: Any performance test can be required by virtue of Minn. R. ch. 7017. Only one of the four stacks in this group is required to be tested for the following reasons: 1. The baghouses serving these stacks are similar, 2. The estimated emissions based on AP-42 factors are much lower than the Minnesota Industrial Process Equipment Rule found in Minn. R. ch. 7011, 3. It would be cost prohibitive for the facility to test all of the baghouse stacks, 4. The MPCA has the authority to require more performance tests at any time in the future, which it would do if the first performance test showed that the emissions were much higher than expected based on AP-42 emission factors. The Minnesota Industrial Process Equipment Rule found in Minn. R. ch. 7011 was not used to limit PM10 on any of the stacks at this facility based on a recent decision by the Permit Leads Team. Subsequently, the facility is not required to test for PM10.

Emission Group: GP 002 - Grinding and Cleaning Operations Emission Limit and/or Special Conditions: 1. Recordkeeping of equipment moves within

Group 002. Factual and legal basis for above: This requirement is based on a request for operational

flexibility by the Permittee in the application. Emission Group: GP 003 - Sand Handling System Stacks Emission Limit and/or Special Conditions: 1. One stack within the group must be tested within

180 days of permit issuance for Total Particulate Matter. 2. General requirements for performance tests found in Minn. R. ch. 7017. Factual and legal basis for above: Any performance test can be required by virtue of Minn. R. ch. 7017. Only one of the three stacks in this group is required to be tested for the following reasons: 1. The baghouses serving these stacks are similar, 2. The estimated emissions based on AP-42 factors are much lower than the Minnesota Industrial Process Equipment Rule found in Minn. R. ch. 7011, 3. It would be cost prohibitive for the facility to test all of the baghouse stacks, 4. The MPCA has the authority to require more performance tests at any time in the future, which it would do if the first performance test showed that the emissions were much higher than expected based on AP-42 emission factors. The Minnesota Industrial Process Equipment Rule found in Minn. R. ch. 7011 was not used to limit PM10 on any of the stacks at this facility based on a recent decision by the Permit Leads Team. Subsequently, the facility is not required to test for PM10.

[Contact] Page 7 Stack/Vent: SV 001 - Induction Furnace, Scrap & Charge Handling, Mold Pouring & Cooling,

and Inoculation Stack Emission Limit and/or Special Conditions: 1. This stack must be tested within 180 days of

permit issuance for Total Particulate Matter. 2. General requirements for performance tests found in Minn. R. ch. 7017. 3. Opacity less than or equal to 20 percent. 4. Total Particulate Matter less than or equal to that allowed by Minn. R. 7011.0730 and 7011.0735.

Factual and legal basis for above: Any performance test can be required by virtue of Minn. R. ch. 7017, and the sources this stack serves are generally expected to have some of the higher emissions at a foundry. The Opacity and Total Particulate Matter limits are not the basis of the potential to emit calculations for the emission units associated with SV 001 but were placed in the permit, because they are found in the Minnesota Industrial Process Equipment Rule found in Minn. R. ch. 7011 which is an applicable requirement for the emission units associated with SV 001. The Minnesota Industrial Process Equipment Rule found in Minn. R. ch. 7011 was not used to limit PM10 on any of the stacks at this facility based on a recent decision by the Permit Leads Team. Subsequently, the facility is not required to test for PM10.

Stack/Vent: SV 004 - Core Sand Mixing Stack Emission Limit and/or Special Conditions: 1. VOC’s less than or equal to 2.05 lbs/hour.

2. Opacity less than or equal to 20 percent. 3. Total Particulate Matter less than or equal to that allowed by Minn. R. 7011.0730 and 7011.0735.

Factual and legal basis for above: The VOC limit is in place to limit VOC’s from the whole facility to less than major levels. 2.05 lbs/hour is the expected emission rate if the core sand mixer is operating at 78840 tons of sand /year. The Opacity and Total Particulate Matter limits are not the basis of the potential to emit calculations for Core Sand Mixing, but were placed in the permit, because they are found in the Minnesota Industrial Process Equipment Rule found in Minn. R. ch.. 7011 which is an applicable requirement for the Cores Sand Mixer.

Stack/Vent: SV 005 - Core Making Machine Stack Emission Limit and/or Special Conditions: 1. VOC’s less than or equal to 1.295 lbs/hour.

2. Opacity less than or equal to 20 percent. Factual and legal basis for above: The VOC limit is in place to limit VOC’s from the whole

facility to less than major levels. 1.295 lbs/hour is the expected emission rate if the core machine is operating at 78840 tons of sand /year. No Particulate Matter limit was placed on this stack, because the Core Making Machine does not emit particulates. The Opacity limit was placed in the permit in case condensed VOC’s in the form of aerosols are emitted from the stack. The opacity limit is based on Minn. R. ch. 7011.0715, subp. 1 (B).

Stack/Vent: SV 008, 009, 010, 011, 012, 013, 030 and 031 Emission Limit and/or Special Conditions: 1. Opacity less than or equal to 20 percent. 2. Total

Particulate Matter less than or equal to that allowed by Minn. R. 7011.0730 and 7011.0735.

[Contact] Page 8 Factual and legal basis for above: The Opacity and Total Particulate Matter limits are not the

basis of the potential to emit calculations for Core Sand Mixing, but were placed in the permit, because they are found in the Minnesota Industrial Process Equipment Rule found in Minn. R. ch. 7011 which is an applicable requirement for the Cores Sand Mixer.

3. Conclusion Based on the information provided by Grede Foundries, Inc., the MPCA has reasonable assurance that the proposed modification and operation of the emission facility, as described in the Air Emission Permit No. 00000605-001 and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Attachments: 1. Grede - St. Cloud Emissions Calculations Review

Need further information? Permit Engineer: Julie Hendricks Telephone No.: (218)828-6075

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Grede - St. Cloud Emissions Calculations Review AQD No. 654A (00000605-001) December 29, 1995 By: Julie Hendricks All of the Lbs/hr emissions rates listed on GI-07 Facility Emission Summary were changed because the instructions for the forms indicated that these rates should include the effect of pollution control equipment and self-imposed limits on the facility. The numbers as received with the application didn’t reflect these things. Lbs/hr for the purposes of GI-07 was calculated by multiplying the controlled & limited tons per year figures by 2000 lbs/ton and dividing by 8760 hr/yr. EU 001 - Electric Induction Furnace See Calculations for PM and PM10 on form EC-01 - they are correct There were calculation errors in the Lead and Manganese calculations in Appendix C, the calculations have been corrected as follows: .1**** lb lead X 15.2 ton X 8760 hr X 1 ton = 6.65 tons per year Pb ton metal hr yr 2000 lb (uncontrolled & unlimited) 92000 ton X .1 lb Pb X 1 ton X (1 - .79*) = .966 tons per year Pb yr ton 2000 lb (controlled and limited) .023**** lb man. X 15.2 ton X 8760 hr X 1 ton = 1.53 tons per year Manganese ton metal hr yr 2000 lb (uncontrolled & unlimited) 92000 ton X .023 lb man. X 1 ton X (1 - .79*) = .22 tons per year Manganese yr ton 2000 lb (controlled and limited) *control efficiency allowed by MN R 7011.0070 for the baghouse/hood - CE 001 ****emission factors from the Fire Database under SCC 30400303 EU 002 - Scrap and Charge Handling Calculations changed from the application because the emissions from the entire scrap and charge handling area are not collected by a hood and controlled by a baghouse. .2** lb. PM & PM10 X 15.2 tons melted X 1 ton X 8760 hr. = 13.32 tons/year ton metal melted hour 2000 lbs. yr. PM and PM10 (unlimited and uncontrolled) .2** lb. PM & PM10 X 92,000*** tons melted X 1 ton. = 9.20 tpy PM and PM10 ton metal melted year 2000 lbs (limited but uncontrolled) **From AP-42 Table 12.10-7 ***Permit limit on tons of metal melted EU 003 - Ladle Preheaters See Calculations on Form EC-08 - they are correct Even though the Process Flow Diagram - GI-02 shows that the emissions from EU 003 go through the Furnace Fugitive Emissions Hood and ultimately through CE 001

[Contact] Page 10 and SV 001, no hood collection efficiency/baghouse control efficiency was applied here because the emissions are quite small.

[Contact] Page 11 EU 004 - Mold Pouring and Cooling See the calculations for PM and PM10 on Form EC-01, they are correct. The calculations for the rest of the criteria pollutants and the HAPs from the core portion of the Mold Pouring and Cooling found in Appendix C are incorrect because they were based on a usage of 1540 tons of core sand a year, which Jim White informed me was incorrect. 9 tons of core sand per hour is the amount which should have been used, and is used below. The limited PTE calculations are based on the facility melting 92,000 tons of metal per year, which is a limit that will be applied to EU 001 which bottlenecks EU 004. The following table calculates the PTE from the core sand portion of the Mold Pouring and Cooling. These values must be added to the Green Sand portion of the Mold Pouring and cooling values in Appendix C of the application to get total PTE.

Pollutant

Theoretical Max. Usage of Isocure I & II in lb/yr

Limited Max.

Usage of Isocure I & II

in lb/yr**

Pollutant Content

in lb pollutant/ lb

Isocures

Unlimited,

Uncontrolled PTE in

tons/year

Limited but

Uncontrolled PTE in

tons/year NOx 2680560 1261458 0.000355 .4757 0.2239 SO2 2680560 1261458 0.000040 .0534 0.0252 VOC 2680560 1261458 0.035567 47.67 22.43

Acrolein 2680560 1261458 0.000088 1.1782 0.0555 Benzene 2680560 1261458 0.005336 7.1517 3.3656

Formaldehyde 2680560 1261458 0.000106 .1419 0.0669 Napthalene 2680560 1261458 0.000037 .0495 0.0233

Phenol 2680560 1261458 0.000110 .1476 0.0694 Toluene 2680560 1261458 0.001535 .0573 0.9682

m Xylene 2680560 1261458 0.002522 .3800 1.5907 o Xylene 2680560 1261458 0.003838 5.1439 2.4200

* (162 lb/hr Isocure I + 144 lb/hr Isocure II) X 8760 hr/yr = 2680560 ** (18 lb Isocure I/ton sand + 16 lb Isocure II/ton sand)X 9 tons sand/hr X 8760 hr/yr = 1261458

[Contact] Page 12 EU 005 - Core Sand Mixer EU 037 - Core Sand Heater and Cooler The Calculations were changed as follows for several reasons. 1. The PM emission factor used was wrong because of a misprint in AP-42, 2. The emissions from the combustion in the catalytic oxidizer (on EU005) are insignificant, and were therefore deleted, 3. The VOC emission calculations didn’t take into account the bottleneck due to the facility only being able to melt 92,000 tons of metal per year. and 4. The core mixing sand handling operations EU 005 and 037 were all lumped together so as not to double count emissions. 3.6* lb. PM & PM10 X 9 tons sand X 1 ton X 8760 hrs/yr. = 141.91 tons/year ton sand mixed hour** 2000 lbs. PM and PM10 (limited and unlimited and uncontrolled) 141.91 tons PM & PM10 X (1 - .99***) = 1.42 tons PM and PM10/year year (limited and controlled) 1.42 tons/year was divided in half and half was allocated to each EU 005 & EU 037. EU 005 only - For maximum VOC emission rate in lb/hr and maximum VOC uncontrolled and unlimited emissions in tons/yr, see EC-07 and Appendix C for correct calculations. 78840 tons sand X 18 lb Isocure I X .31(% VOC) X .5(%VOC retained) X (1-.95****)= year***** ton of sand 2000 lb/ton 5.49 tons VOC from Isocure I per year 78840 tons sand X 16 lb Isocure II X .22(% VOC) X .5(%VOC retained) X (1-.95****)= year***** ton of sand 2000 lb/ton 3.47 tons VOC from Isocure II per year 5.49 tons + 3.47 tons = 8.96 tons VOC/year (limited and controlled) Phenol emission calculations were deleted because additional information Jim White sent Julie Hendricks from the American Foundrymen’s Society indicated that ) 0% Phenol is evaporated during core making. *from AP-42 table 12.10-7 Sand Handling **Maximum capacity of EU 005 and EU 037, as well as the permit limit on EU 037 which bottlenecks EU 005 ***control efficiency allowed by Minn. R. 7011.0070 for the baghouse - CE 024 ****control efficiency allowed by Minn. R. 7011.0070 for the catalytic oxidizer - CE 020 *****9 tons/hr X 8760 hrs/yr = 78840 tons of core sand per year.

[Contact] Page 13 EU 006 - Core Machines There were PM10 emissions entered on GI-07 for EU 006 which were deleted, because they were put there in error. The VOC calculations on GI-07 and in Appendix are correct, except that the Limited Controlled tons per year number does not take into account the bottleneck of only being able to melt 92,000 tons of metal per year. There is not enough information in the rest of the application to do a more refined calculation though. EU 009 & 010- North and South Sand Reclaimers EU 012 - Sand Coolers EU 013 - Muller and Sand Handling All four of these sources were treated as a group when calculating PTE, because there is a single emission factor in AP-42 for Sand Handling in table 12.10.7. The Muller is only capable of handling 80 tons of sand per hour, which turns out to be very slightly less capacity than melting 92,000 tons of metal per year will require (92,000 tons per year requires 80.79 tons per hour muller capacity.) 3.6 lb PM & PM10 X 80 tons sand X 8760 hr X 1 ton = 1261.44 tons PM & PM10 ton sand hr yr 2000 lb year (unlimited & uncontrolled) 1261.44 tons PM & PM10 X (1-.99*) = 12.61 tons PM & PM10/year year (limited and controlled) * control efficiency allowed by Minn. R. 7011.0070 for the baghouses that control EU 009, 010, 012 & 013 - CE 004, 005, 006, 007, & 008 Note: The emissions estimates above were divided by four and a fourth was allocated to each of the emission units on GI-07. EU 011 - Casting Shakeout See Calculations on form EC-01 - they are correct EU 014, 015, 034, 039, 040, 041 - Blasting, Grinding and Cleaning Equipment All six of these sources were treated as a group when calculating PTE, because there is a single emission factor in AP-42 for Cleaning and Finishing in table 12.10.7. Industry Standards indicate that only 50 percent of the metal melted gets to the finishing area, but the 50 percent factor is not reflected in the calculations below, because the emission factor is based on tons of metal produced, not metal cleaned. 17 lb PM & PM10 X 15.2** tons X 8760 hr X 1 ton = 1131.79 tons ton metal melted hr yr 2000 lb PM & PM10/year (uncontrolled and unlimited) 17 lb PM & PM10 X 92,000 tons X 1 ton X (1-.99***) = 7.82 tons ton metal melted yr 2000 lb PM and PM10 (controlled and limited****) **Maximum Melt capacity of EU 001 (unlimited) ***control efficiency allowed by Minn. R. 7011.0070 for the baghouses that control EU 014 015, 034, 039, 040, & 041 - CE 011, 012, 013, & 025

[Contact] Page 14 ****limited by bottleneck of EU 001 only being able to melt 92,000 tons of metal per year

[Contact] Page 15 EU 014, 015, 034, 039, 040, 041 - (continued) 7.82 tons PM & PM10 X 2000 lbs X 1 year = 1.79 lbs per hour year ton 8760 hr EU 039 & 040 and CE 025 have been included in the above calculations even though they are only planned, and don’t exist on site yet. The above emission estimates were divided among the emission units as follows: EU 014 was allocated half of the total, and the remaining EU’s were allocated one tenth of the total. A PTE calculation based on Minn. R. 7011.0700-.0735 “Industrial Process Equipment Rule” is included for comparison below, but is not used to arrive at PTE. Table 1 - Process Weight Rate 15.2 tons/hr X .5 cleaned = 15,200 lb/hr. corresponds to a limit of: 12.62 lb/hr which is much higher than the AP-42 based calculation Table 2 - Air Flow PM Limit Corresponding Stack/Vent Air Flow Rate from Table 2 lb/hr limit 011 8,000 acfm .096 gr/dscf 6.58 lb/hr 012 35,000 acfm .059 gr/dscf 17.70 lb/hr 013 16,000 acfm .077 gr/dscf 10.56 lb/hr 031 16,000 acfm .077 gr/dscf 10.56 lb/hr Total = 45.40 lb/hr EU 033 - Inoculation See Calculations on Form EC-01 - they are correct EU 007, 022, 023, 024, 025, 026, 027, 028, 030, 031, 032, 035, 036, 038 - Were all determined to be insignificant activities, therefore the associated emissions were not included in GI-07 Facility Emissions Summary. EU 028 - Maintenance Shop Parts Cleaner had a high enough PTE to be included as a significant source the way Braun Intertec did the calculation, but after a phone call to Mike Flannery, Julie Hendricks determined that the PTE could be calculated as follows, which in turn causes the parts cleaner to become insignificant. 3 X 40 gal/yr X 7.2 lb VOC/gal = 864 lbs VOC/year Historical Mineral Spirits use in the parts cleaner is approximately 40 gal./yr. The facility will increase production, but will be using essentially the same amount equipment as in past years. If one applies a safety factor of three to the current parts cleaner usage to account for the future increase in production, the PTE of the parts cleaner is still below the 2000 lbs which qualifies it as insignificant.

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